ML040210789
| ML040210789 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna, 07200002  |
| Issue date: | 01/09/2004 |
| From: | Grecheck E Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| -RFPFR, 03-574 | |
| Download: ML040210789 (7) | |
Text
S-VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINA 23261 January 9, 2004 United States Nuclear Regulatory Commission Serial No.03-574 Attention: Document Control Desk NL&OS/SLW RO Washington, D. C. 20555-0001 Docket Nos.
50-280,281 50-338, 339 72-2,16 License Nos. DPR-32, 37 NPF-4, 7 SNM-2501, 2507 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY AND NORTH ANNA POWER STATIONS UNITS i AND 2 OPERATIONAL QUALITY ASSURANCE PROGRAM INSPECTION PROGRAM CHANGES AND CLARIFICATIONS RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)
On February 27, 2003, Virginia Electric and Power Company (Dominion) submitted a revision to the Operational Quality Assurance Program (Topical Report) for NRC review and approval. The requested program changes and clarifications involve the Inspection Program. Subsequently, the NRC requested additional information regarding the submittal. In a telephone call on October 28, 2003, to discuss the RAI and to develop a better understanding of the information requested, Dominion agreed to document the response to the RAI on the docket. A response to the requested information is provided in Attachment 1.
Please contact us if you have any questions or require additional information.
Very truly yours, E. S. Grecheck Vice President-Nuclear Support Services poA4
Commitments made in this letter:
- 1.
There are no commitments made in this letter.
Attachments: Response to Request for Additional Information cc:
US Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, S.W., Suite 23T85 Atlanta, GA 30303 Mr. G. J. McCoy NRC Senior Resident Inspector Surry Power Station NRC Senior Resident Inspector North Anna Power Station Mr. S. R. Monarque U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8-H12 Rockville, MD 20852 Mr. C. Gratton U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 8-G9 Rockville, MD 20852 Commissioner Bureau of Radiological Health 1500 East Main Street Suite 240 Richmond, VA 23218
Serial No.03-574 Page 1 of 5 Virginia Electric and Power Company (Dominion)
Operational Quality Assurance Program Inspection Program Changes and Clarifications Response to Request for Additional Information (RAI)
On February 27, 2003, Dominion submitted a revision to the Quality Assurance Topical Report (QATR) for NRC review and approval. The requested program changes and clarifications involve the Inspection Program. Subsequently, the NRC requested additional information regarding the submittal. In a telephone conversation on October 28, 2003 Dominion discussed the RAI and agreed to document responses to the RAI.
The RAI covered two general areas of concern with the submittal: the definition and scope of non-routine and routine maintenance and the peer review process.
As discussed in the phone call, the following are clarifications to our submittal.
NRC Concern:
The first concern was that for routine maintenance the requirements of the Reg.
Guides and standards are not applied and therefore the definition of non-routine maintenance is critical. The proposed definition of non-routine maintenance does not address such factors as special processes, task complexity, qualifications of personnel performing the activity, or the adequacy of procedural guidance.
Dominion Response:
In order to address the concern of the routine maintenance activities not being inspected in accordance with the regulatory guides and standards the process for establishing hold points for routine maintenance will be described.
Each maintenance procedure is developed and reviewed to ensure compliance with the inspection program. The inspection program incorporates the requirements of the governing Engineering documents (installation specifications, etc.), as well as the requirements to meet the regulatory guides and standards (as committed to in Topical Report Table 17.2-0). The Engineering documents have as their basis the regulatory guides and standards but may not include all of the same inspection requirements.
When the proposed QATR change is approved, the inspection program will be revised to clearly indicate which hold points are required by regulatory guides and standards and which are requirements from the Engineering documents. Where specific hold points are not required by either documents, the Quality Inspection Coordinator (QIC) may add hold points as deemed necessary to ensure quality.
Dominion experienced difficulty in developing specific proposed definitions for distinguishing routine and non-routine maintenance. The industry was surveyed and associated guidance documents were reviewed to determine if any available
Serial No.03-574 Page 2 of 5 standard definition might exist. There appeared to be no clear or specific definition existing in the industry.
Because our internal attempts to develop a precise definition were met with so many exceptions, we decided to allow flexibility in what is considered non-routine by allowing that determination to be made by Engineering and the QIC. A general definition was also deemed acceptable based on the similarities between the inspections required for routine and non-routine maintenance. The inspections in most cases would be the same with exceptions requiring Engineering concurrence.
The definitions provided in the submittal were: "Routine maintenance is defined as maintenance activities required to preserve or restore plant systems, structures, and components to their approved design configuration," and " Non-routine maintenance is defined as maintenance, which is both infrequently performed (once in the life of the plant) and requires special procedures."
(Note that the qualifying statement "once in the life of the plant" is based on and intended to represent the anticipated frequency of occurrence per design. The actual occurrence of non-routine maintenance may be more than once in the life of the plant for any specific component.) Special processes were segregated by the statement: "For safety related welding and civil activities (concrete, grout, soils, coatings & structural steel) inspections will be conducted as required by the applicable codes and standards."
The proposed QATR states "The QIC will determine if a procedure for infrequently performed maintenance is to be considered non-routine for establishing hold points."
The intent of the wording was to limit excess detail in the QATR and include the details in our inspection program.
With this approach the QIC has the ultimate responsibility to ensure that "Inspection hold points for routine maintenance will be placed in technical procedures where necessary to assure quality."
The inspection program addresses the following factors that were identified in the NRC concern as not addressed.
Special processes - Our submittal states in section 3 on page 6, "For safety related welding and civil activities (concrete, grout, soils, coatings & structural steel) inspections will be conducted as required by the applicable codes and standards." Safety related special processes will be handled in the same manner as non-routine maintenance (in accordance with the governing regulatory guides and standards).
It was not our intent to include these items with routine maintenance activities.
Task complexity - All maintenance work activities will be dispositioned as a design change or maintenance.
Many items worked by maintenance are controlled under the Design Change Process and therefore, inspections are implemented in accordance with applicable regulatory guides and standards.
Non-routine maintenance would also require the implementation of the regulatory guides and standards. For routine maintenance, as noted in the submittal
a Serial No.03-574 Page 3 of 5 section 3 page 6, "The determination of these inspection hold points and the type of inspection to be performed will be based on Engineering Specifications or other Engineering documents (Installation Specifications, Corporate Weld Manual, Engineering Transmittal etc.)". Engineering considers the requirements of the regulatory guides and standards in developing Engineering documents and incorporates what they deem appropriate.
Therefore, all inspections of maintenance work are determined considering the requirements of the regulatory guides and standards, but for routine maintenance, we are able to use some discretion in the mechanical, electrical and l&C disciplines. Safety-related civil, welding, coatings, and other Special Processes would require inspection per the regulatory guides and standards.
Some complex maintenance activities are routinely performed (refueling) and have experience-based hold points as well as those required by the Engineering documents (e.g. reactor coolant pump seal replacement). It would be very rare for there to be a new maintenance item that is infrequent and complex and it not be part of the DCP process. Therefore, any examples of non-routine maintenance that we can envision (reactor head replacement, SG replacement, etc.) have actually been performed by the DCP process in practice. If there is a complex task which is not covered by the DCP process and is not clearly routine, then the QIC can make the determination whether it should be handled as a non-routine maintenance item for establishing hold points.
The following is a list of examples of work activities and the level of hold points established for the activity:
Routine Maintenance with no QC hold points - Adjustment of valve packing on low risk significant, safety related valve.
Routine Maintenance with some QC hold points - Repair of leaking mechanical seal on High Head Safety Injection Pumps (hold points are based on task complexity, risk significance and human performance data).
Special Processes with all required (consistent with regulatory guides and standards) QC hold points - Repair of damaged coatings on reactor containment liner; Welding and mechanical work to cutout and replace Safety Injection check valve; Soils, concrete and structural steel work for constructing a safety related structure.
Any safety related Design Change would require regulatory guides and standards QC hold points for all craft disciplines. In addition, Engineering may require hold points to meet the regulatory guides and standards even for non-safety related special requirements (NSQ) design change implementation. As an example, Engineering required establishing regulatory guides and standards hold points for the ISFSI even though it was classified as NSQ.
I Serial No.03-574 Page 4 of 5 Qualifications of personnel performing the activity -
Routine maintenance is performed by trained and qualified maintenance personnel.
Dominion's Maintenance and Radiological Protection training programs have been developed and maintained using the systematic approach to training in accordance with INPO's ACAD-02-001, The Objectives and Criteria for Accreditation of Training in the Nuclear Power Industry and have consistently received renewal of accreditation by the INPO National Nuclear Accrediting Board. The Step Development Program and completion of Job Performance Measures (JPM) ensure individual qualification for the task.
The Step Development Program qualifies maintenance personnel in a series of steps, which vary from simple in Step I to more complex in each subsequent step.
Step 1 may involve tasks such as print reading and tool knowledge and use.
Step 2 is more complex and for mechanics may involve such tasks as replacing filters and strainers and some rigging.
Each continuing step represents an increase in the level of complexity in the tasks performed. The training may become component specific at the higher level steps. The worker is tested in both knowledge and skill on a specific task such as re-packing gate valves. JPMs are used to assure adequate capabilities. Maintenance workers are assigned to tasks based on their completed training, qualifications and experience.
In addition to the training and qualifications of a worker, if the task is complex or infrequently performed there will be more supervisory involvement, briefings, and training. Mock-ups are also utilized on infrequently performed complex tasks such as Charging Pump seal replacement and RCP seal work.
Adequacy of procedural guidance - All routine and non-routine maintenance procedures are reviewed by the QIC to ensure they contain the necessary QC Holds required by our Inspection Program. Maintenance procedures are utilized for routine maintenance, non-routine maintenance and DCPs as appropriate. As noted above, all inspections of maintenance work have been determined considering the requirements of the regulatory guides and standards but for routine maintenance, Engineering discretion is permitted.
Because our program functions as described above, it provides a conservative approach to establishing QC hold points which allows most of our routine maintenance activities to be inspected the same as, or similar to, our non-routine maintenance activities.
NRC Concem:
Because Dominion proposes to utilize peer inspectors for routine maintenance, the RAI requested a description of the general requirements of the peer review process and peer inspector qualifications. In addition, the RAI requested a description of the process for ensuring the peer reviewer is not engaged in the work activity.
C 4
a Serial No.03-574 Page 5 of 5 Dominion response:
ANSI N45.2.6 certified inspectors are required for all steps designated as a QC hold point in the work document for that activity as required by our Inspection Program.
An ANSI N45.2.6 qualified inspector may be a member of the Quality Maintenance Team (QMT) (peer inspection).
QMT inspectors are also required to have completed Step Development training. Special Processes are inspected in accordance with the applicable regulatory guides and standards by independent inspectors.
However, for welds, visual inspections may be performed by peer inspectors. All NDE type inspections for welding are performed by independent inspectors under engineering direction. Simultaneous Verification/Independent Verification (SV/IV) inspections are above and beyond inspections required by either the regulatory guides and standards or engineering documents. SV/IV inspectors are qualified in the task they are inspecting, but are not required to be ANSI N45.2.6 certified inspectors.
Independence of peer inspection from work activities is assured at the work level by the supervisor requesting the inspection, program requirements, initial and periodic training and work procedures.
Independence is verified through monitoring/assessments of field activities and Nuclear Oversight audit activities.