ML20077M663

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Comments on Insp Repts 50-338/94-28 & 50-339/94-28 on 941114-18
ML20077M663
Person / Time
Site: North Anna  
Issue date: 01/06/1995
From: Ohanlon J
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
94-735, NUDOCS 9501130131
Download: ML20077M663 (2)


Text

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VIHOINIA Er.ECTRIC AND POWER COMPANY Hicnxown,VruorwrA 2026

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January 6, 1995 U. S. Nuclear Regulatory Commission Serial No.94-735 Attention: Document Control Desk NAPS /MAE R7 Washington, D.C. 20555 Docket Nos.

50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT NOS.1 AND 2 INSPECTION REPORT NOS. 50-338/94-28 AND 50-339/94-28 NRC Inspection Report Nos. 50-338, 339/94-28, dated December 16, 1994, documented the results of a routine announced inspection at North Anna Power Station in the area of engineering and technical support. The inspection was conducted November 14-18,1994. We have reviewed the inspection report and have several comments.

The inspection report summary stated that the use of Engineering Transmittals in lieu of a design change package to perform physical changes to the plant was questionable for some examples. It was noted that this issue had been identified in a previous NRC Inspection report. However, as was discussed during the inspectors' exit meeting, only one example of a misapplied Engineering Transmittal had been identified. This example, involving a casing cooling pump recirculation flow switch, was the one identified in the previous inspection report. No other examples of misapplication of Engineering Transmittals have been identified.

It should be noted that several months prior to the transmittal in question, Virginia Power Engineering had identified the need for concise and consistent guidance for the appropriate use of Engineering Transmittals.

This led to the development of Engineering Standard STD-GN-0041, which contains provisions that preclude the use of transmittals for making changes to the plant. This standard was issued on February 25,1994, less than two weeks after the transmittal in question.

4 Even though this was an isolated case, an Engineering Review Team, consisting of engineering personnel from both stations and corporate, was tasked on March 28, 1994 to review the issue and make appropriate recommendations. Those recommendations included further enhancements to engineering standard STD-GN-0041 and other design control standards. Thus, the cuidance currently in place is adequate to ensure that Engineering Transmittals are used only as intended.

In a second area, the inspection report identified a weakness for not requiring periodic verification to ensure that the rate of water in-leakage into the North Anna Unit 2 steam driven auxiliary feedwater pump's lubricating oil remained below the value assumed 12G03; 95o113o131 95o106 h

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in a Justification for Continued Operation (JCO). Following preparation of the JCO, actions were taken to further reduce water intrusion below that originally identified.

Measurements taken at that time verified that the water intrusion rate was well below that assumed in the JCO. We agree that the JCO should have provided for continuing verification that the JCO assumptions remained valid. Action has now been taken to periodically verify the rate of water in leakage. In-leakage measurements taken in November verified that the JCO assumptions remain conservative. Programmatic enhancements are being evaluated for incorporation into the JCO process.

Finally, the inspection report concluded that engineering was, overall, effective in addressing Deviation Reports (DR), with operability issues addressed properly and promptly. In some cases, the inspectors noted that the DR packages did not always completely document all of the engineering actions taken in response to a DR. In these cases, substantial engineering involvement in the issue was not immediately apparent from the available documentation. For example, in the case of DR N-94-807 regarding power range instrument N 42, the reactor engineer was notified when the problem occurred as required by the procedure. The reactor engineer worked closely with the operating and instrument staff to troubleshoot the instrumentation and assure a valid surveillance. Following a recurrence of the meter problem on November 16, 1994, Engineering recommended replacement, which occurred on November 18, 1994.

i in conclusion, we believe that the inspection report, in conjunction with the above comments, demonstrates that engineering's response to the resolution of problems in support of the safe and reliable operation of North Anna Power Station has been effective, that engineering support to operations and maintenance for day-to-day activities and emergent issues has been effective and-timely, and that a strong program exists which provides for the review, prioritization and scheduling of plant modifications with an emphasis on nuclear and personnel safety.

t if you have any questions, please contact us.

Very truly yours, rn James P. O'Hanlon Senior Vice President - Nuclear 1

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U. S. Nuclear Regulatory Commission Region il 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 i

Mr. R. D. McWhorter NRC Senior Resident inspector North Anna Power Station i

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