ML20248G595

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Responds to Weaknesses Identified in SALP Insp Repts 50-338/89-16 & 50-339/89-16.Security Administratively Separated from Station Mgt to Ensure Security Remains Independent & Not Subj to Operational Pressures
ML20248G595
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 09/22/1989
From: Stewart W
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: Ebneter S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
89-615, NUDOCS 8910100309
Download: ML20248G595 (2)


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VIRGINIA ELECTRIC AND POWER COMPANY RICIIMOND, VIRGINIA 23261

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33 ba 6 September 22, 1989 Mr. Stewart D. Ebneter Serial No 89-615 Regional Administrator NOS:jm]

U. S. Nuclear Regulatory Commission Docket No. 50-338 Region ll 50-339 101 Marietta Street, N.W.

License No. NPF-4 Suite 2900 NPF-7 Atlanta, Georgia 30323

Dear Mr. Ebneter:

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 RESPONSE TO INSPECTION REPORT 50-338&339/89-16 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Virginia Electric and Power Company has reviewed the interim report on the Systematic Assessment of Licensee Performance (SALP) for the period of May 1, 1988 through May 31,1989 for North Anna Power Station. On August 24,1989, we met with members of your staff to discuss the assessment. As we stated at that time, we consider the SALP process to be a useful and important tool for both NRC and Virginia Electric and Power Company in assessing and improving the performance and safety at our nuclear stations.

The recognition of the strengths noted in the report in operations and the other functional areas was appreciated and we will continue to build upon those strengths.

We will make every effort to strengthen our performance in those areas wnere weaknesses were identified.

We have one comment regarding your assessment in the functional area of Security.

The NRC expressed concern that the security force, which is proprietary and does not rely on contract personnel beyond routine administrative duties, does not report directly to the Station Manager. NRC observed that this arrangement appears to cause problems in the areas of long-term commitment of financial and engineering support.

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,,; A Security is administratively separated from station management to ensure that Security. remains independent and not subject to operational pressures which could compromise the integrity of Security's effectiveness. To ensure that security problems -

and long term needs are properly addressed by the station maintenance and

' engineering staffs, there is a direct communication and functional linkage to station management.

Our security force is integrated with and respected by the station operating staff. The security organization at North Anna has a veteran staff characterized by a high level of employee retention and a staffing level better than 99% of that authorized. This low turnover rate allows the security training and requalification programs to be more aggressive and advanced with realistic and thorough contingency drills.

By having a proprietary security force instead of a contracted one, we are able to give more attention to security problems. Unlike contract operations, our security officers are an integral part of the organization and can directly communicate concerns and suggestions to management.

During the inspection period, almost 50% of the suggestions received from security officers to improve security or job performance were implemented.

During the inspection period there were no significant breeches of security and no violations or reportable events. The aspects of our security force described above are, in large part, responsible for this excellent performance.

.Therefore, your consideration of these additional comments in determining the final assessment in this functional area would be appreciated. It is felt that upon review and -

consideration of these factors, a Category 1, rather than a "high Category 2" rating, would be warranted.

We have no additional comments on the other functional areas discussed in the report.

If you have any questions, please contact us immediately.

Very truly yours, 1

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W. L. Stewart Senior Vice President - Power cc: U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.

20555 Mr. J. L. Caldwell NRC Senior Resident inspector North Anna Power Station l

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