ML20137Z062
| ML20137Z062 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/02/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Butcher E, Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 85-494A, GL-83-28, NUDOCS 8510080153 | |
| Download: ML20137Z062 (5) | |
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i YINUINEA I$I.ECTMIC AMI) I'OWiiH COMI'ANY Hic slMa> Min.VIHillNIA 2352 61 I
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I October 2, 1985 j
Mr. Harold R. Denton, Director Serial No.
85-494A Office of Nuclear Reactor Regulation NAPS /JHL l
Attn: Mr. Edward J. Butcher, Acting Chief Docket Nos. 50-3.18 l
Operating Reactors Branch No. 3 50-339 Division of Licensing License Nos. NPF-4 U. S. Nuclear Regulatory Commission NPF-7 Washington, D, c. 20555 I
Gentlemen
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i VIRGINTA ELECTRIC AND POWER COMPANY
(
NORTil_ ANNA POWER STATION UNIT NOS. 1 AND 2 GENERIC !.ETTER 83 28 L
ADDITIONAI. INFORMATION I
I i
In your letter of June 24, 1985, you requested that we provide addi-tional information rer,arding Items 3.1.1, 3.1.2, 3.2.1, and 3.2.2 of l
Generic Letter 83 28 or our schedule for submitting this information.
In our response of August 16, 1985, we indicated we would provide the roquested information by October 2,1985. The pur-l pose of this letter is to provide the requested information. If you j
l have any questions reg.Irding this matter, please contact us.
l i
l Very truly yours, l
WC W. L. Stewart cc Dr. J. Nelson Orace I
Regional Administrator F
NRC Region !!
i Hr. Morris W. Branch NRC Resident Inspector North Anna Power Station i
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s ENCLOSURE Item 3.1.1 The licensen needs to confirm that test and maintenance procedures and Technical Specifications have been reviewed for all safety-related components in the reactor trip system (RTS). This review is to assure that post-maintenance testing is specified in the working level procedures and that the testing will verify component capability to perform safety functions prior to being returned to service. Your response to Item 3.1.1 states that the Administrative Procedures, Quality Assurance (QA) procedures and Technical Specifi-cations require demonstration of equipment operability before returning equipment to service, liowever, your response does not con-firm that individual maintenance and test procedures have been reviewed to ensure they contain post maintenance testing require-monts specified by Administrative Procedures, QA Procedures and Technical Specifications. The confirmation statement should indi-cate whether such testing adequately verifies component capability to perform its intended safety functions, y_i ginia power Rosponse l
A sample of maintenance and testing procedures have been reviewed and the requirements for post maintenance testing were found adequate. The determination for post-maintenance oper-ability tests are delineated by maintenance procedures. The maintenance procedures either specify the appropriate testing directly or require the Shift Supervisor to make a determi-nation of the necessity of an operability test to ensure that component safety functions are met.
In order to state that test and maintenance procedures require post-maintenance testing, where applicable, a procedures review will have to be performed. This procedure review will determine if post maintenance testing is required and if the post maintenance testing verifies component capability to per-form its intended safety function prior to returning the component to service. The procedure review and necessary pro-cedure revisions will be completed by September 1,1987.
To ensure that post maintenance testing will be included in test and maintenance procedures, where applicable, we will revise our administrative procedure, for processing new and revised procedures.
This administrative procedure revision will have a step to acknowledge that a review has been performed to determine if post maintenance testing la required. This procedure revision will be implemented by November 1,198$.
Item 3.1.2 The licensee does not state whether a review was made of test and maintenance procedures for other safety-related components in the RTS to verify that appropriate vendor and engineering information was included in the procedures.
It is concluded from the response and from discussion with plant personnel that only new and revised vendor information will be reviewed and evaluated for incorporation into plant procedures. The Generic Letter is quite specific in this area in that it states in part that, " licensees shall submit the results of their check of vendor and engineering recommendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications." However, the response does not address the adequacy of current (in use) proce-dures which are developed from older vendor and engineering recommendations. The licensee needs to provido additional informa-tion on:
- 1) How VEPCO's administrative procedures ensure that all previous vandor and engineering recommendations were appropriately incorporated into test and maintenance procedures or Technical Specifications.
- 2) The results of VEPCO's check to determine if vendor and engineering recommendations have been included in current test and maintenance procedures.
Virginia power Response We have determined that approximately 800 North Anna working level procedures will require additional review to assure that vendor and engineering recommendations have been included into current plant procedures. This number of procedures is significantly less than the total number of test and maintenance procedures because procedures that have been implemented since June,1984 have incorporated vendor and engineering recommendations in accordance with station adminis-trative procedures.
In addition, the Instrument Department has reviewed the vendor and engineering recommendations portaining to components in the reactor trip system and the appropriate recommen-dations have been incorporated into procedures.
A review will be performed to ensure that previous vendor and engi-neering recommendations are included in test and maintenance proce-l
- dures, where applicable.
The procedure review and necessary procedure revisions will be completed by September 1,1987.
l To ensure that previous vendor and engineering recommnndations will l
be included in test and maintenance procedures, we will revise our administrative procedure, for processing of new and revised proco-dures. This procedure revision will have a step to acknowledge that a review of vendor and engineering recommendations has been per-formed. This administrative procedure revision will be implemented by November 1,1985.
l
F l _
Item 3.2.1 The licensee needs to confirm that test and maintenance procedures and Technical Specifications were reviewed for all other safety-related components to assure that post-maintenance testing is l
required and that the testing verifies component capability to per-form safety functions prior to being returned to service.
Virginia Power Response A sample of maintenance and testing procedures have been l
reviewed and the requirements for post maintenance testing were found adequate. The determination for post maintenance oper-ability tests were delineated by maintenance procedures. The maintenance procedures either specify the appropriate testing directly or require the Shif t Supervisor to make a determi-nation of the necessity of an operability te t to ensure that component safety functions are met.
In order to state that test and maintenance procedures require post-maintenance testing, where applicabic, a procedures review will have to be performed. This procedure review will determine if post-maintenance testing is required and if the post-maintenance testing verifies component capability to per-form its intended safety function prior to returning the component to service. The procedure review and necessary pro-cedure revisions will be completed by September 1,1987.
To ensure that post-maintenance testing will be included in test and maintenance procedures, where applicable, we will revise our administrative procedure, for processing new and revised procedures. This procedure revision will have a step to acknowledge that a review has been performed to determine if post-maintenance testing is required. This procedure revision sill be implemented by November 1,1985.
Item 3.2.2 The licensee does not state whether a review was made of test and maintenance procedures for other safety-related components to verify that appropriate vendor and engineering information was included in the procedures.
It is concluded from the response and from dis-cussion with plant personnel that only new and revised vendor infor-mation will be reviewed and evaluated for incorporation into plant procedures.
The Generic Letter is quite specific in this area in that it states in part that, " licensees shall submit the results of their check of vendor and engineering recommendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications." However, the response does not address the adequacy of current (in use) procedures which are developed from older vendor and engineering recommendations.
The licensee needs to provide additional information on:
....g.-
- 1) How VEPCO's administrative procedures ensure that all previous vendor and engineering recommendations were appropriately incorporated into test and maintenance procedures or Technical Specifications.
Virginia Power Response We have determined that approximately 800 North Anna working level procedures will require additional review to assure that vendor and engineering recommendations have been included into current plant procedures. This number of procedures is signif-icantly less than the total number of test and maintenance pro-cedures because procedures that have been implemented since June, 1984 have incorporated vendor and engineering recommen-dations in accordance with station administrative procedures.
In addition, the Instrument Department has reviewed the vendor and engineering recommendations for other safety-related compo-nents and the appropriate recommendations have been incorporated into procedures.
A review will be performed to ensure that previous vendor and engineering recommendations are included in test and mainte-nance procedures, where applicable. The procedure review and necessary procedure re/isions will be completed by September 1, 1987.
To ensure that previous vendor and engineering recommendations will be included in test and maintenance procedures, we will revise our administrative procedure, for' processing of new and revised procedures. This procedure revision will have a step to acknowledge that a review of vendor and engineering recommen-dations has been performed. This procedure revision will be implemented by November 1,1985.
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