ML18153D309
| ML18153D309 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 04/19/1993 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 93-148, NUDOCS 9304260080 | |
| Download: ML18153D309 (4) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 April 19, 1993 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NORTH ANNA POWER STATION UNITS 1 AND 2 SYSTEM DESIGN BASIS DOCUMENTS Serial No.
NL&P/MAE:
Docket Nos.
License Nos.93-148 R22 50-280 50-281 50-338 50-339 DPR-32 DPR-37 NPF-4 NPF-7 On February 1 O, 1993, the NRC issued Inspection Report Nos. 50-338/92-32 and 50-339/92-32 for North Anna Power Station. The report expressed concerns regarding Virginia Electric and Power Company's (Virginia Power's) review of items for reportability or unreviewed safety questions that have been identified during the implementation of the System Design Basis Document (DBD) program. Specifically, your report indicated that no evaluation had been performed for several items cited in the report. We do not agree with that observation. These open items were evaluated at the time they were identified. These evaluations were discussed with the North Anna NRC Resident Inspector and with Mr. G. A. Belisle during his March 12, 1993 visit to Virginia Power. Additional information regarding our evaluation process for determining whether items are reportable or unreviewed safety questions is provided below.
Participants in the DBD program, as in any other engineering activity, are required to initiate an _immediate review of any item which is potentially reportable or could present an unreviewed safety question. If the issue is considered to be significant, further review is initiated through the Engineering Potential Problem Report (PPR) process. PPRs are reviewed by a Management Problem Review Team which consists of the Engineering Managers.
The Management Problem Review Team either resolves the PPR or a Deviation Report (DR) is initiated. DRs are the normal station process for identifying items of potential non-compliance.
Significant open issues identified during the preparation of a DBD are presented to
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Virginia Power in an information assessment meeting held following completion of each draft DBD review. Participants in this meeting include applicable representatives from the engineering disciplines, licensing, nuclear safety analysis, system engineering and engineering consultants involved in the preparation of the package.
The purpose of the meeting is to ensure that priority issues have been properly resolved and that any open items being deferred do not represent a potential failure to meet the design basis of the system.
The information assessment meeting minutes completed to date document the issues presented, but do not always provide a detailed discussion of why various open items were judged to be deferrable. We agree that this represents a weakness in our documentation. As we have previously discussed with Mr. M. S. Lesser and Mr. G. A.
Belisle, in the future we will provide a more thorough documentation of information assessment meeting discussions of deferred items.
Virginia Power has met with the NRC to review the scope and process for the Configuration Management Project on August 15, 1990 and again on March 15, 1991.
During both of these meetings, we discussed our process for addressing open items.
A summary of this process is provided in Attachment 1 for your information.
The DBD program was voluntarily initiated by Virginia Power to integrate existing plant documentation and to provide a more complete design basis.
This program has benefited Virginia Power by providing a process for the review and identification of significant design weaknesses.
Although the DBD program is not a regulatory requirement, Virginia Power is still dedicated to ensuring that the program is appropriately maintained.
We would like to meet with you to further discuss the Virginia Power DBD program and the Unresolved Items raised in Inspection Report Nos. 50-338/92-32 and 50-339/92-32 for North Anna Power Station, and Inspection Report Nos. 50-280/93-07 and 50-281/93-07 for Surry Power Station, which was exited on April 5, 1993. This meeting is currently scheduled for May 3, 1993, in the NRC Region II office in Atlanta.
Very truly yours, Q9~~
C::-v-- W. L. Stewart
\\ -
Senior Vice President - Nuclear Attachment
cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station Mr. M. S. Lesser NRC Senior Resident Inspector North Anna Power Station
f ATTACHMENT 1 The DBD program creates the draft DBDs based on available design and licensing documentation.
The documentation reviewed includes design and licensing documentation that dates back to the original plant designs. If at any time during the preparation or review of the DBDs an error or omission is identified that would represent a safety or operability concern, timely action is taken to resolve the issue.
Other missing information or inconsistencies in the large volume of documentation are identified as open items.
Several hundred open items may be identified during the preparation and review of each DBD. Chapter 24 of the DBDs lists all of the remaining open items. Many of the open items are cross-references to other DBDs that are scheduled to be completed later in the DBD program and are not technically significant. The open items will be categorized into one of three groups: 1) Immediate - which are potentially reportable or safety concerns that are required to be resolved promptly. Critical calculations that are determined to be missing or found to contain errors are created or corrected within 30 days. To date, the reportability or safety concerns of these open items have been addressed. 2) Intermediate - which will be resolved in the interest of having a quality body of design information, but are deferrable, or 3) Resolve If Needed - which are minor in nature and have no need to be resolved unless a specific item is needed for design work or operations support. It is not the intention of the program to expend the resources to resolve the minor open items.
The DBD program is an engineering design program, and as such, is periodically assessed by the Quality Assurance Department. A Quality Assurance Audit of the program was performed in 1992. A currently open finding was issued due to the large number of unresolved open items.
In response to the finding, Engineering has committed to resolving 15% of all currently existing open items in 1993.
This represents approximately 500 open items. The resolution of the open items will be incorporated into the next revision of the DBDs. A Quality Assurance Assessment on the Configuration Management Project was also performed in March of 1993. This assessment is currently being evaluated by management.