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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217K4391999-10-18018 October 1999 Provides Response to RAI to Support USI A-46 Program Submittal for North Anna Power Station,Units 1 & 2.Rev 10 to BNL Rept 52361,encl ML20217H3301999-10-14014 October 1999 Forwards Rev 0 to COLR for North Anna 2 Cycle 14 Pattern Su. No New Commitments Intended by Ltr ML18152B3541999-10-12012 October 1999 Requests Use of Code Case N-532 & N-619,per Provisions of 10CFR50.55a(a)(3).Detailed Info Supporting Request,Encl. Attachment 2 Includes Technical White Paper That Provides Further Technical Info ML20216K1681999-10-0101 October 1999 Forwards Vols I-VIII of Rev 35 to UFSAR for Naps.Rev Also Includes Update to Chapter 17 of Ufsar,Which Contains Operational QA Program.Changes to Program Description Do Not Reduce Commitments Contained Therein ML20212J9101999-10-0101 October 1999 Forwards SE Accepting Licensee 990916 & 27 Relief Requests IWE-3 for Plant.Se Addresses Only IWE-3 Due to Util Urgent Need for Relief.Requests IWE-7 & IWE-8 Will Be Addressed at Later Date ML18152B3391999-09-27027 September 1999 Forwards Revised Relief Request IWE-3,which Now Includes Addl Visual Exam Requirement After post-repair or Mod Pressure Testing Is Completed,Per Telcon with NRC ML20212G5091999-09-22022 September 1999 Forwards in Triplicate,Applications for Renewal of Licenses for Listed Individuals.Encls Withheld,Per 10CFR2.790(a)(6) ML18152B6671999-09-17017 September 1999 Forwards Two NRC Forms 536,containing Info on Proposed Site Specific Operator Licensing Exam Schedules & Estimated Number of Applicants Planning to Take Exams And/Or Gfes,In Response to NRC Administrative Ltr 99-03 ML18152B3331999-09-17017 September 1999 Forwards Revised 180-day Response to NRC GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML18152B3341999-09-16016 September 1999 Requests Relief from Specific Requirements of Subsection IWE of 1992 Edition with 1992 Addenda of ASME Section XI Re Containment Liner Examination Requirements,For North Anna & Surry Power Stations ML20211N2531999-09-0808 September 1999 Responds to Request to Exceed 60,000 Mwd/Mtu Lead Rod Burnup in Small Number of Fuel Rods in North Anna Unit 2.Informs That NRC Offers No Objection to Requested Use of Rods in Reconstituted Fuel Assembly.Se Supporting Request Encl ML18152B4471999-09-0101 September 1999 Requests That NRC Remove Listed Labels from Distribution ML20211L9151999-09-0101 September 1999 Forwards Response to NRC Request for Comments Re Closure of Review of Response to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML20211J2211999-08-31031 August 1999 Approves Request to Remove Augmented ISI (Aii) Program for RCS Bypass Lines from North Anna Licensing Basis.Se Re Request to Apply LBB to Eliminate Augmented Insp Program on RCS Bypass Lines Encl ML20211H4131999-08-27027 August 1999 Informs That Util Revised Encl Bases for TS 2.2.1, Reactor Trip Sys Instrumentation Setpoints, Discussing Steam Flow/ Feed Flow Mismatch Portion of Steam Flow/Feed Flow Mismatch & Low SG Water Level Reactor Trip Setpoint ML20138B3241999-08-23023 August 1999 Forwards Draft Response to Question 1 Re NAPS USI A-46 ML20211D9041999-08-20020 August 1999 Forwards Revised Pages to Third Ten Year ISI Program & Relief Requests, Replacing Pages in 990408 Submittal ML20211B3871999-08-17017 August 1999 Requests Permission to Routinely Discharge from SW Reservior to Waste Heat Treatment Facility Under Existing Vpdes Permit Through Outfalls 108 & 103.Discharges Are Scheduled to Commence on 990907,due to High Priority Placed on Project ML20210T0671999-08-13013 August 1999 Informs of Completion of Review of Proposed Revs of Schedule for Withdrawal of Rv Surveillance Capsules Submitted by VEPCO on 981217.Approves Proposed Revs.Forwards Safety Evaluation ML20210Q9841999-08-12012 August 1999 Forwards Rev 1 to Vepc COLR for North Anna Unit 2,Cycle 13 Pattern Ud, Per TS 6.9.1.7.d.COLR Was Revised to Include Temp Coastdown Operation at End of Cycle 13 ML18152B4081999-08-0606 August 1999 Forwards Response to NRC 990520 & 0525 RAIs Re North Anna & Surry Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves. ML20210Q7661999-08-0606 August 1999 Requests Exception to 10CFR50.4 Requirement to Provide Total of Twelve Paper Copies When Submitting Surry & North Anna UFSAR Updates.Seek Approval to Submit Only Signed Original & One CD-ROM Version,Per Conversation with J Skoczlas ML18152B4091999-08-0505 August 1999 Forwards Vepc semi-annual fitness-for-duty Program Performance Data Rept for 990101-990630,IAW 10CFR26.71(d) ML20210N2921999-08-0505 August 1999 Discusses Which Submitted Proposed TSs Bases Change for Containment Leakage. Licensee Changes to Bases May Be Subj to Future Insps or Audits ML20210J8861999-08-0202 August 1999 Provides Clarification to Commitment Made in Identifying Extent by Which Existing Plant Design Complied with RG 1.97,specifically Re Variable, Radiation Exposure Rate ML20210F6121999-07-28028 July 1999 Forwards Supplemental Info on Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit,Documenting Info Provided During 990624 Meeting & Suppl Original Submittal ML18152B3971999-07-26026 July 1999 Provides Estimates of Licensing Actions Expected to Be Submitted in Fys 2000 & 2001,in Response to NRC AL 99-02 ML20209E7621999-07-0909 July 1999 Provides Addl Info to Justify Use of Less than One Gpm Detectable Leakage Rate to Establish Required Margin for Crack Stability in LBB Analysis,Per 980623 Application on Reactor Coolant Loop Bypass Lines 05000338/LER-1999-005, Forwards LER 99-005-00,IAW 10CFR50.73.Commitment Made by Util Encl1999-07-0808 July 1999 Forwards LER 99-005-00,IAW 10CFR50.73.Commitment Made by Util Encl ML20209E3711999-07-0202 July 1999 Forwards Insp Repts 50-338/99-03 & 50-339/99-03 on 990425-0605.Violations Being Treated as Noncited Violations ML18152B4401999-07-0101 July 1999 Informs NRC That on 990511,Dominion Resources,Inc,Executed Amended & Restated Agreement & Plan of Merger with Consolidated Natural Gas Co ML18152B4371999-06-24024 June 1999 Forwards Response to NRC Request for Clarification of Relief Requests Submitted on 990212,requesting Relief from Performing Hydrostatic Testing for Certain Small Diameter Class 1,RCS Pressure Boundary Connections ML20196G2581999-06-23023 June 1999 Discusses Closure of GL 92-01,rev 1,suppl 1,reactor Vessel Structural Integrity ML20212J2951999-06-22022 June 1999 Forwards Corrected Markup & Typed Version of Affected Pages. Requests That Attached Pages for Those Previously Provided in 990506 Submittal Be Replaced & Incorporated Into NRC Review of Proposed TS ML18152B4361999-06-22022 June 1999 Forwards Response to RAI Re Surry & North Anna Power Stations,Units 1 & 2,per GL 96-06 ML20196F1151999-06-22022 June 1999 Forwards Relief Requests NDE-047 & NDE-048 for North Anna Power Station,Unit 1 Re ASME Section XI ISI Program ML20196G2211999-06-21021 June 1999 Forwards Licensee Sampling & Testing Obligations Re Vpdes Permit VA0052451 Reissuance Application.Details of Requests for Sampling & Testing Waivers,Included ML20195J7011999-06-15015 June 1999 Forwards Revised EPIP 2.01 Which Corrects Typo That Was Found in Step 10 of Procedure.Rev Does Not Implement Actions That Decrease Effectiveness of EP ML20195J1391999-06-11011 June 1999 Submits Addl Info as Addendum to Original Application Which Proposed Use of Three Chemicals in Bearing Cooling Tower at North Anna Power Station,Per Reissuance of Vpdes Permit ML18152B4301999-06-0303 June 1999 Informs of Util Intention to Revise Schedule for Submittal of License Renewal Applications for Surry & North Anna Power Stations to March 2002 ML20195C6601999-06-0101 June 1999 Forwards Response to NRC 990216 RAI Re Summary Rept of USI A-46 Program ML20207C9851999-05-28028 May 1999 Requests Regrading of Rt Robinson 990408 Written Exam,Based on Listed Reasons.Answer C for Question 18 Is Requested to Be Reconsidered as Correct or Question Be Deleted ML18152B4261999-05-28028 May 1999 Provides Formal Notification of Effect of Recent Organizational Restructuring on OLs of North Anna & Surry Power Stations,Per NRC 990513 Telcon Request ML18152B4221999-05-27027 May 1999 Forwards Info Concerning Changes to ECCS Evaluation Models & Application in Existing Licensing Analyses for Surry & North Anna Power Stations,Units 1 & 2 ML18152B4231999-05-26026 May 1999 Informs That Vepc Will Revise 180 Day Response to NRC GL 96-05,within 120 Days of Date of Ltr to Incorporate Commitment to Participate in Joint Owners Group Program as Applicable ML20206U7441999-05-20020 May 1999 Informs That NRC Unable to Conclude That NAPS Has Met Intent of Supplement 4 to GL 88-20.RAI Re Fire Area of IPEEE Encl. Response Requested within 90 Days of Submittal Date ML20207A8541999-05-20020 May 1999 Forwards RAI Re Licensee Listed Responses to GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves. Response Requested within 90 Days of Submittal Date ML20195B5381999-05-14014 May 1999 Forwards Rev 8,Change 2 to North Anna Units 1 & 2 IST Programs for Pumps & Valves. Summaries of Program Changes Provided for Each Unit IST Program.Relief Requests Have Been Removed from IST Programs ML18152A3701999-05-13013 May 1999 Submits Proposal to Use Provisions of ASME Section XI Code Case N-597 for Analytical Evaluation of Class 1,2 & 3 Carbon & Low Alloy Steel Piping Components Subjected to Wall Thinning as Result of Flow Accelerated or Other Corrosion ML20206L4661999-05-10010 May 1999 Forwards SE Accepting Request to Delay Submitting Plant, Unit 1 Class Piping ISI Program for Third Insp Interval Until 010430,to Permit Development of Risk Informed ISI Program for Class 1 Piping 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217K4391999-10-18018 October 1999 Provides Response to RAI to Support USI A-46 Program Submittal for North Anna Power Station,Units 1 & 2.Rev 10 to BNL Rept 52361,encl ML20217H3301999-10-14014 October 1999 Forwards Rev 0 to COLR for North Anna 2 Cycle 14 Pattern Su. No New Commitments Intended by Ltr ML18152B3541999-10-12012 October 1999 Requests Use of Code Case N-532 & N-619,per Provisions of 10CFR50.55a(a)(3).Detailed Info Supporting Request,Encl. Attachment 2 Includes Technical White Paper That Provides Further Technical Info ML20216K1681999-10-0101 October 1999 Forwards Vols I-VIII of Rev 35 to UFSAR for Naps.Rev Also Includes Update to Chapter 17 of Ufsar,Which Contains Operational QA Program.Changes to Program Description Do Not Reduce Commitments Contained Therein ML18152B3391999-09-27027 September 1999 Forwards Revised Relief Request IWE-3,which Now Includes Addl Visual Exam Requirement After post-repair or Mod Pressure Testing Is Completed,Per Telcon with NRC ML20212G5091999-09-22022 September 1999 Forwards in Triplicate,Applications for Renewal of Licenses for Listed Individuals.Encls Withheld,Per 10CFR2.790(a)(6) ML18152B3331999-09-17017 September 1999 Forwards Revised 180-day Response to NRC GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves. ML18152B6671999-09-17017 September 1999 Forwards Two NRC Forms 536,containing Info on Proposed Site Specific Operator Licensing Exam Schedules & Estimated Number of Applicants Planning to Take Exams And/Or Gfes,In Response to NRC Administrative Ltr 99-03 ML18152B3341999-09-16016 September 1999 Requests Relief from Specific Requirements of Subsection IWE of 1992 Edition with 1992 Addenda of ASME Section XI Re Containment Liner Examination Requirements,For North Anna & Surry Power Stations ML18152B4471999-09-0101 September 1999 Requests That NRC Remove Listed Labels from Distribution ML20211L9151999-09-0101 September 1999 Forwards Response to NRC Request for Comments Re Closure of Review of Response to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML20211H4131999-08-27027 August 1999 Informs That Util Revised Encl Bases for TS 2.2.1, Reactor Trip Sys Instrumentation Setpoints, Discussing Steam Flow/ Feed Flow Mismatch Portion of Steam Flow/Feed Flow Mismatch & Low SG Water Level Reactor Trip Setpoint ML20138B3241999-08-23023 August 1999 Forwards Draft Response to Question 1 Re NAPS USI A-46 ML20211D9041999-08-20020 August 1999 Forwards Revised Pages to Third Ten Year ISI Program & Relief Requests, Replacing Pages in 990408 Submittal ML20210Q9841999-08-12012 August 1999 Forwards Rev 1 to Vepc COLR for North Anna Unit 2,Cycle 13 Pattern Ud, Per TS 6.9.1.7.d.COLR Was Revised to Include Temp Coastdown Operation at End of Cycle 13 ML20210Q7661999-08-0606 August 1999 Requests Exception to 10CFR50.4 Requirement to Provide Total of Twelve Paper Copies When Submitting Surry & North Anna UFSAR Updates.Seek Approval to Submit Only Signed Original & One CD-ROM Version,Per Conversation with J Skoczlas ML18152B4081999-08-0606 August 1999 Forwards Response to NRC 990520 & 0525 RAIs Re North Anna & Surry Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves. ML18152B4091999-08-0505 August 1999 Forwards Vepc semi-annual fitness-for-duty Program Performance Data Rept for 990101-990630,IAW 10CFR26.71(d) ML20210J8861999-08-0202 August 1999 Provides Clarification to Commitment Made in Identifying Extent by Which Existing Plant Design Complied with RG 1.97,specifically Re Variable, Radiation Exposure Rate ML20210F6121999-07-28028 July 1999 Forwards Supplemental Info on Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit,Documenting Info Provided During 990624 Meeting & Suppl Original Submittal ML18152B3971999-07-26026 July 1999 Provides Estimates of Licensing Actions Expected to Be Submitted in Fys 2000 & 2001,in Response to NRC AL 99-02 ML20209E7621999-07-0909 July 1999 Provides Addl Info to Justify Use of Less than One Gpm Detectable Leakage Rate to Establish Required Margin for Crack Stability in LBB Analysis,Per 980623 Application on Reactor Coolant Loop Bypass Lines 05000338/LER-1999-005, Forwards LER 99-005-00,IAW 10CFR50.73.Commitment Made by Util Encl1999-07-0808 July 1999 Forwards LER 99-005-00,IAW 10CFR50.73.Commitment Made by Util Encl ML18152B4401999-07-0101 July 1999 Informs NRC That on 990511,Dominion Resources,Inc,Executed Amended & Restated Agreement & Plan of Merger with Consolidated Natural Gas Co ML18152B4371999-06-24024 June 1999 Forwards Response to NRC Request for Clarification of Relief Requests Submitted on 990212,requesting Relief from Performing Hydrostatic Testing for Certain Small Diameter Class 1,RCS Pressure Boundary Connections ML18152B4361999-06-22022 June 1999 Forwards Response to RAI Re Surry & North Anna Power Stations,Units 1 & 2,per GL 96-06 ML20196F1151999-06-22022 June 1999 Forwards Relief Requests NDE-047 & NDE-048 for North Anna Power Station,Unit 1 Re ASME Section XI ISI Program ML20212J2951999-06-22022 June 1999 Forwards Corrected Markup & Typed Version of Affected Pages. Requests That Attached Pages for Those Previously Provided in 990506 Submittal Be Replaced & Incorporated Into NRC Review of Proposed TS ML20195J7011999-06-15015 June 1999 Forwards Revised EPIP 2.01 Which Corrects Typo That Was Found in Step 10 of Procedure.Rev Does Not Implement Actions That Decrease Effectiveness of EP ML18152B4301999-06-0303 June 1999 Informs of Util Intention to Revise Schedule for Submittal of License Renewal Applications for Surry & North Anna Power Stations to March 2002 ML20195C6601999-06-0101 June 1999 Forwards Response to NRC 990216 RAI Re Summary Rept of USI A-46 Program ML18152B4261999-05-28028 May 1999 Provides Formal Notification of Effect of Recent Organizational Restructuring on OLs of North Anna & Surry Power Stations,Per NRC 990513 Telcon Request ML20207C9851999-05-28028 May 1999 Requests Regrading of Rt Robinson 990408 Written Exam,Based on Listed Reasons.Answer C for Question 18 Is Requested to Be Reconsidered as Correct or Question Be Deleted ML18152B4221999-05-27027 May 1999 Forwards Info Concerning Changes to ECCS Evaluation Models & Application in Existing Licensing Analyses for Surry & North Anna Power Stations,Units 1 & 2 ML18152B4231999-05-26026 May 1999 Informs That Vepc Will Revise 180 Day Response to NRC GL 96-05,within 120 Days of Date of Ltr to Incorporate Commitment to Participate in Joint Owners Group Program as Applicable ML20195B5381999-05-14014 May 1999 Forwards Rev 8,Change 2 to North Anna Units 1 & 2 IST Programs for Pumps & Valves. Summaries of Program Changes Provided for Each Unit IST Program.Relief Requests Have Been Removed from IST Programs ML18152A3701999-05-13013 May 1999 Submits Proposal to Use Provisions of ASME Section XI Code Case N-597 for Analytical Evaluation of Class 1,2 & 3 Carbon & Low Alloy Steel Piping Components Subjected to Wall Thinning as Result of Flow Accelerated or Other Corrosion ML20206H0221999-05-0303 May 1999 Informs That Licensee Changes Bases for TS 3/4.6.1.2, Containment Leakage. Changes Allow Use of Other NRC Staff Approved/Endorsed Integrated Leak Test Methodologies to Perform Containment Leakage Rate Testing.Ts Bases Page,Encl ML20206G9481999-05-0303 May 1999 Informs NRC That Insp of 58 Accessible safety-related Pipe Supports Completed in Response to NOV from Insp Rept 50-338/98-05 & 50-339/98-05.Commitments Made Include Plans to Perform Assessment of Welding & Welding Insp ML20205T1181999-04-16016 April 1999 Requests NRC Approval Prior to Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit.Nrc Concurrence with Irradiation Program Requested by End of June 1999 ML20205P1891999-04-0808 April 1999 Forwards ISI Program for Third ten-yr ISI Interval for North Anna Unit 1 for Class 1,2 & 3 Components & Component Support.Third ten-yr Insp Interval for North Anna Unit 1 Begins on 990501.Page 2-26 of Encl Not Included ML20205K3631999-04-0505 April 1999 Requests That Relief Request IWE-3 Be Removed from 980804 Relief Requests Submitted to Nrc.Subject Relief Request Was Inadvertently Retained in Attachment 1 for Unit 1 ML20205K2191999-04-0101 April 1999 Forwards Response to NRC 990106 RAI Re Util Summary Rept on USI A-46 Program,Submitted 970527.Calculations & Corrected Table 11.1-1,encl ML18151A5851999-03-31031 March 1999 Forwards Rept on Status of Decommissioning Funding for Each of Four Nuclear Power Reactors,Per 10CFR50.75(f)(1) ML18152A2801999-03-30030 March 1999 Forwards Summary of Structural Integrity Evaluation of Thermally Induced Over Pressurization of Containment Penetration Piping During DBA for SPS & Naps,Units 1 & 2,per GL 96-06.Draft Proposed UFSAR Revised Pages,Encl ML20204H0331999-03-17017 March 1999 Forwards Rev 5 to PSP for Surry & North Anna Power Stations & Associated Isfsis.Description & Justification for Changes Included with Plan Rev.Rev 5 to PSP Withheld Per 10CFR73.21 ML20205E2701999-02-25025 February 1999 Forwards Rept on Status of Decommissioning Funding for North Anna Power Station,Units 1 & 2.Trust Agreement Between Old Dominion & Bankers Trust Co,Effective 990301,attached ML20207A8741999-02-25025 February 1999 Draft Response to NRC Telcon Re Licensee Request for Approval of LBB Evaluation in Support of Elimination of Augmented Insp Program on RCS Loop Bypass Lines.Response Justifies Use of Less than One Gpm Detectable Leakage Rate ML18152B5401999-02-11011 February 1999 Requests Relief from Specific Requirements of Subsection Iwl of 1992 Edition with 1992 Addenda of ASME Section Xi,Per 10CFR50.55a(a)(3) ML20203C8181999-02-0505 February 1999 Forwards Response to NRC 981217 Telcon RAI Re risk-basis of Nitrogen Accumulator Action Statement to Complete NRC Review of 951025 Proposed TS Changes 1999-09-27
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l Vincisir EIECTRIC AND POWER CON 1PANY l
RioistoNo, VHMH NI A 23261 March 10, 1997 United States Nuclear Regulatory Commission Serial No.97-061 Attention: Document Control Desk SPS/GDM R2' Washington, D. C. 20555 Docket Nos. 50-338 50-339 4 License Nos. NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT 1 AND UNIT 2 SUPPLEMENTAL RESPONSE TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-338/96-10 AND 50-339/96-10 Virginia Electric and Power Company received two violations in NRC Inspection Report Nos. 50-338/96-10 and 50-339/96-10 dated December 2,1996. We responded to these two violations in our letter dated January 2,1997 (Serial No.96-622). Violation B identified three examples of noncompliance regarding implementation of the maintenance rule. In our response to Violation B, we identified that we had contracted with a consultant to perform an independent assessment of our implementation of the maintenance rule program. We further noted that upon completion of our review of the results of that assessment, we would develop an appropriate corrective action plan and advise the resident inspectors accordingly.
Following subsequent telephone conversations between Mr. D. A. Sommers of Virginia Electric and Power Company and Mr. G. A. Belisle of the NRC, we agreed to submit a supplemental response to Violation B instead of briefing the North Anna Resident inspectors on the self-assessment. This response provides a summary of the assessment findings, as well as additional details on our long term corrective actions.
This additional information is provided in Attachment 1 to this letter. It should be noted that the corrective actions detailed in Attachment 1 are also the subject of a pre-decisional enforcement conference for Surry Power Station to be held at NRC Region ll }
offices in Atlanta, Georgia on March 11, 1997. Additional information regarding the I' implementation of the maintenance rule program will be discussed at that time. I As noted in the recent SALP report for North Anna, station maintenance on systems, hO structures and components is being effectively performed. This is evidenced by the '
high availability and excellent performance of safety related systems and components.
However, we recognize the regulatory significance of not effectively implementing the 9703180007 970310 PDR G
ADOCK 05000338 lEl$((EElEEE%%
PDR >-****
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1 maintenance rule and are committed to the prompt correction of the issues identified in the independent assessment.
! 1 l We have no objection to this letter being made part of the public record. The specific l commitments made in this letter are summarized in Attachment 2. Please contact us if {
you have any questions or require additional information.
Very truly yours, j A
ames P. O'Hanlon Senior Vice President - Nuclear j Attachments cc: U.S. Nuclear Regulatory Commission Region 11 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323 -
Mr. R. D. McWhorter NRC Senior Resident inspector North Anna Power Station e
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l ATTACHMENT 1 SUPPLEMENTAL RESPONSE TO VIOLATION B NRC INSPECTION CONDUCTED SEPTEMBER 22 - NOVEMBER 2.1996 N_QRTH ANNA POWER STATION UNITS 1 AND 2 INSPESTION REPORT NOS. 50-338/96-10 AND 50-339/96-10 i
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SUPPLEMENTAL RESPONSE TO VIOLATION B NORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOJJJ-338/96-10 AND 50-339/96-10 In a letter dated January 23,1997, the NRC requested Virginia Electric and Power Company to submit a supplemental response to Violation B identified in NRC Inspection Reports Nos. 50-338/96-10 and 50-339/96-10. The supplemental response was requested to submit additional detail regarding long term corrective actions planned for North Anna Power Station in response to an independent assessment of our
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implementation of the maintenance rule. Consequently, item No. 3, " Corrective Steps Which Will Be Taken to Avoid Further Violations," and item No. 4, "The Date When Full Compliance Will Be Achieved," provided in our original response to Violation B are amended by the additional information provided below.
Ithiopendent Assessment Results The independent assessment of maintenance rule implementation concluded that l
! although significant effort had been expended in establishing the maintenance rule j program, major elements of the maintenance rule and associated industry guidelines '
were not thoroughly understood by the personnel responsible for the implementation of j
- the maintenance rule and had not been effectively implemented.
l The assessment identified that weaknesses existed in implementation of the following major elements of the maintenance rule:
determining structures, systems and components (SSCs) that are within the
- scope of the maintenance rule determining safety significant SSCs through the use of probabilistic safety assessment (PSA) and deterministic safety significance methodologies establishing appropriate performance criteria commensurate with safety 4
monitoring SSC performance to determine whether performance criteria are achieved or not achieved i
establishing cause, corrective action and goals to achieve desired performance controlling the removal of SSCs for maintenance to assure overall plant safety is
, maintained and that balance is applied between the need to improve reliability while minimizing out of service time l
Specific issues / examples were noted in each area.
i The assessment also identified those areas for which the maintenance rule program i could most significantly be improved by corrective efforts: I Additional staff training to ensure that the requirements of the maintenance rule, applicable industry guidance, and the application of probabilistic and deterministic risk assessment methodologies are thoroughly understood by the !
personnel responsible for implementing the maintenance rule {
l Improving the process for data verification, including scoping and functional !
failure screening for maintenance preventable functional failures Improving the level of detail in, and compliance with, the station administrative l procedure that establishes the maintenance rule program 1 Improving supporting / interfacing station procedures necessary for maintenance rule implementation and administratively associating them with the maintenance rule program Due to the extent of the weaknesses identified in the independent assessment, we have initiated, and continue to take, corrective actions to integrate the maintenance rule processes into day-to-day operations and decisions to promote verbatim compliance with the maintenance rule. The corrective actions are being applied programmatically.
Consequently, these actions apply to both North Anna and Surry Power Stations. Our corrective action plan is provided below.
CORRECTIVE ACTION PLAN
- 1. Establish a Maintenance Rule Recoverv Team To address the issues identified in the independent assessment, Virginia Electric and Power Company has established a maintenance rule recovery team to facilitate compliance with the maintenance rule. The recovery team will ensure proper implementation of maintenance rule requirements at all levels and ensure
] that appropriate direction and oversight are provided for each aspect of the 1
program. The recovery team reports directly to the Manager - Nuclear Engineering and consists of a multi-discipline team of personnel who have been dedicated to coordinate the following corrective actions:
Provide expanded guidance to ensure that scoping, evaluation of safety significance, performance criteria, corrective actions and goal setting for j SSCs are in accordance with approved industry guidance. This guidance will be documented in procedures.
Perform a complete verification and validation of the maintenance rule baseline by re-performing the steps used for the initial implementation of
the maintenance rule but in accordance with the expanded guidance.
This verification / validation includes the following activities:
Scoping to identify the SSC functions included in the rule l
Identifying SSC functions that are considered risk significant using PSA methods and deterministic review by an expert panel Developing performance criteria that are commensurate with safety Performing a historical review of SSC reliability and availability Dispositioning functional failures identified during the historical review Comparing the results of the historical review and performance criteria to determine SSC classification Dispositioning SSCs with unacceptable performance with appropriate initial evaluations, corrective actions and goals The validated baseline will be reviewed and approved by the appropriate system engineers and the station maintenance rule working groups.
Resolve identified issues related to maintenance rule program implementation regarding functional failure disposition and the timeliness of the dispositions.
Develop enhanced guidelines for the evaluation and ' classification of SSCs for placement into the (a)(1) category including goal setting.
Improve the current process for performing on-line maintenance to ensure that risk is appropriately addressed when SSCs are removed from service for maintenance and competing requirements of availability and reliability are reasonably considered.
Develop a method to improve the availability and use of operating experience in the required portions of the maintenance rule program.
Develop a transition plan to transfer ownership of the Maintenance Rule program from the corporate operations support group to the engineering department.
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- 2. Provide Staff Trainina on the Maintenance Rule The maintenance rule recovery team expert panel, as well as certain corporate and station management personnel, have received training on the maintenance rule from a consultant who was personally involved in the development of l NUMARC 93-01, " Industry Guidelines for Monitoring the Effectiveness of i
( - Maintenance- at Nuclear Power Plants." Training on the use of PSA in the maintenance rule program was also provided by a corporate PSA engineering representative. Additional training is currently being scheduled for other personnel who have specific responsibilities in the ongoing implementation of the l maintenance rule program (e.g., management, training, system engineering, ;
operations, planning and maintenance personnel). This training will also address the use of PSA in the implementation of the maintenance rule. Furthermore, continuing technical training for station and corporate personnel will include training on the maintenance rule in future sessions.
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- 3. Revise Anolicable Station Procedures Station administrative procedures VPAP-0815, " Maintenance Rule Program,"
and VPAP-2001, " Station Planning and Scheduling," have been revised to provide additional guidance for the control of SSCs that are out of service.
VPAP-2001 was revised to provide additional emphasis on the use of PSA information when removing SSCs from service. VPAP-0815 was revised to 1) l provide a clear definition of when an SSC is considered " unavailable" and to correct the definition for a maintenance rule functional failure,2) add criteria for I addressing the balance between SSC reliability and unavailability requirements,
- 3) require approval by the maintenance rule Working Group for maintenance preventable functional failures and (a)(1) evaluations, and 4) require generic.
failure concems to be addressed by cause determinations.
The procedures that control the implementation of design changes and revisions of Emergency Operating Procedures (EOP) at the station will be revised to :
ensure that any effects of the design change or EOP revisions on the '
maintenance rule program are appropriataly considered as part of the design change implementation and close-out process and the EOP revision process.
- 4. Perform a Follow-un Assessment of the Maintenance Rule Prcaram A follow-up assessment will be conducted of the revised maintenance rule program within approximately ninety days of declaring full compliance with the 7
maintenance rule. This assessment is meant to ensure that outstanding l implementation issues have been adequately resolved and the overall program has been effectively implemented.
- 5. Perform an Assessment of Management Oversight of the Malotenance Rule Program An assessment of the management factors that contributed to the deficiencies in the development and implementation of the maintenance rule program has been completed by an independent consultant. Management is currently reviewing the results of the assessment and will take corrective actions as considered warranted.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Completion of our corrective actions and return to full compliance with the maintenance rule will be achieved by June 30,1997. The follow-up self-assessment discussed above will be performed approximately three months later to ensure the program has been implemented appropriately and to make any process enhancements as deemed necessary.
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ATTACHMENT 2 1
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SUMMARY
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SUMMARY
OF COMMITMENTS
- 1. The recovery team reports directly to the Manager-Nuclear Engineering and consists of dedicated, cross-functional personnel who have been assigned to coordinate the following corrective actions:
Provide expanded guidance to ensure that scoping, evaluation of safety significance, performance criteria, corrective actions and goal setting for SSCs are in accordance with approved industry guidance. This guidance will be documented in procedures.
Perform a complete verification and validation of the maintenance rule baseline by re-performing the steps used for the initial implementation of the maintenance rule but in accordance with the expanded guidance.
This verification / validation includes the following activities:
Scoping to identify the SSC functions included in the rule Identifying _SSC functions that are considered risk significant using PSA methods and deterministic review by an expert panel Developing' performance criteria that are commensurate with safety.
Performing a historical review of SSC reliability and availability Dispositioning functional failures identified during the historical review Comparing the results of the historical review and performance criteria to determine SSC classification Dispositioning SSCs with unacceptable performance with appropriate initial evaluations, corrective actions and goals The validated baseline will be reviewed and approved by the appropriate system engineers and the station maintenance rule working groups.
Resolve identified issues related to maintenance rule program implementation regarding functional failure disposition and the timeliness of the dispositions.
Develop enhanced guidelines for the evaluation and classification of SSCs for placement into the (a)(1) category including goal setting.
Improve the current process for performing on-line maintenance to ensure that risk is appropriately addressed when SSCs are removed from service
0 for maintenance and competing requirements of availability and reliability are reasonably considered.
Develop a method to improve the availability and use of operating experience in the required portions of the maintenance rule program.
Develop a transition plan to transfer ownership of the Maintenance Rule ,
program from the corporate operations support group to the engineering department.
- 2. Additional training is currently being scheduled for other personnel who have specific responsibilities in the ongoing implementation of the maintenance rule program (e.g., management, training, system engineering, operations, planning and maintenance personnel). This training will also address the use of PSA in the implementation of the maintenance rule. Furthermore, continuing technical training for station and corporate personnel will include training on the maintenance rule in future sessions.
- 3. The procedures that control the implementation of design changes and revisions of Emergency Operating Procedures (EOP) at the station will be revised to ensure that any effects of the design change or EOP revisions on the maintenance rule program are appropriately considered as part of the design change implementation and close-out process and the EOP revision process.
- 4. A follow-up assessment will be conducted of the revised maintenance rule program within approximately ninety days of declaring full compliance with the maintensnce rule. This assessment is meant to ensure that outstanding implementation issues have been adequately resolved and the program has been effectively implemented.