ML20245F167
| ML20245F167 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/26/1989 |
| From: | Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 88-858A, NUDOCS 8905020283 | |
| Download: ML20245F167 (3) | |
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VruaINIA ELucruic ann Powim COMI'ANY c
RICitMON D, VIHOINIA 23 2 61 j
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April 26, 1989 Nucomas U. S. Nuclear Regulatory Commission Serial No.
88-858A Attention: Cocument Control Desk NAPS /DEQ l
Washington, D. C. 20555 Docket Nos.
50-338 j
50-339 License Nos. NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTRlNNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-338/88-31 AND 50-339/88-31 SUPPLEMENTAL REsh0NSE TO THE NOTICES Of VIOLATION Our response to your letter of December 23, 1988, which referred to the inspection conducted at North Anna on September 17, 1988 through November 4,
1988 and reported in Inspection Report Nos. 50-338/88-31 and 50-339/88-31, was provided to.you on January 23, 1989.
In our response to Violation A, Section 3, Corrective Steps Which Have Been Taken and the Results Achieved, we identified several initiatives to implement progranrnatic corrective actions in response to the violation.
These initiatives incluoed the Corhing Program, the Self Checking Program, the Self Assessment Program and Configuration Control.
Under Configuration Control we identified seven specific activities.
In Iten:
4, we stated that the j
Operations Department is systematically verifying that valve lineup procedures I
are consistent with controlled drawing i consistent with the actual lineup in the plant. Tu Operations Department is systematically verifying only that the valve lineuo procedures are consistent with the actual lineup in the plant (i.e., the valve is in the correct position (open/ closed) to achieve the desired mode of operation).
The valve lineup procedures are not beirg verified consistent with the controlled drawings (i.e., the relative position of the valve shown on the drawing).
Valve positions are routinely manipulated with the use of valve lineup procedures, tagouts, and other administrative k
controls, to achieve a desired mode of operation.
Consequently, due to our current drawing conventions, the position of 6 valve shown on a controlled drawing may not represent the current position of the valve.
However, as part of the Configuration Management Program currently being implemented at North Anna, system design basis will be established and verified, and a drawing convention will be established to alltaw the position of a valve on a controlled drawing to be shown for the desired mode of operation.
FoHowing implementation of the Configuration Management Programs, stated above, valve lineup procedures will be routinely reviewed for consistency with the new drawing convention.
8905020283 890426 L
PDR ADOCK 05000338 U; Q
PNV i 0 n
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We have had several meetings with the NRC Resident Inspcctor on the Drawing Control Program.
These discussions encompassed the issues discussed in Inspection Reports 88-31, 88-33, rnd 89-03 (NRC exit meeting for IR 89-03 was held on March 20, 1989). As requested on April 14,
- 1989, the status of corrective actions for these issues is presented below. A summary of the drawing update process is attached.
I Accuracy of Controlled Drawings The valve lineup procecures are being verified consistent with the actual
. lineup in the plant.
(Currently being implemented. The systematic verification of valve lineup procedures with the actual plant will be completed by December 31, 1989 for Safety Related systems, and by December 31, 1990 for selected Non-Safety Related systems. See responses to Ik 88-31)
The Drawing Update Process will be enhanced to include operator involvement and timely annotation (redlining) of control room drawings when a drawing error in the plant is discovered. (Scheduled to begin by S/1/89)
Changes / Updates of Controlled Drawings Engineering has been given overall responsibility for the Drawing Control Program. (Completed.
See responses to IR 88-33)
Control Room drawings have been reviewed and redline information verified. (Completed.
See responses to IP 88-33)
Open DCPs have been reviewed and Control Room drawings affected by two field changes to a DCP were re-redlined and drawing updates were initiated. (Completed.
See responses to IR 88-33)
Drawing updates for DCPs, as defined in ADM-6.10, are now required to be initiated when zany portion of a modification is made operable rather l
than waiting for the entire modification to be completed.
(Process implemented.
See responses to IR 88-33) Drawing updates for EWRs are required to be initiated in accordance with ADM-3.7.
' Red]ining for drawings affected by DCPs has been eliminated except for emergency changes required during non-routine work hours. (Completed.
See responc.es to IR 88-33)
Redlining f.or drawings affected by EWRs will be eliminated to the extent possible.
(Scheduled to begin 7/1/89.
See responses to IR 88-33)
Any redlined drawings will be updated within 15 days in accordance with our letter of 12/18/84, Serial Number 740.
(Implemented for DCPs and scheduled to begin 5/1/89 for partial technical reviewed EWRs.
See responsea to 12 88-33)
Composite drawings are now available in the Control Room and TSC (Shift Supervisor Office). Reference drawings have been remov J from the Control Room.
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Enhancements have been made to the process for reviewing procedure l
schematics against the controlled drawings any time procedures are l
revised, and during routine procedure reviews. (Process implemented) i ADM-3.12, 3.14 and 6.10 will t,e upgraded and consolidated to more l
effectively implement the abeve commitments.
(Scheduled to be completed by S/15/89)
The Resident Insoector will be kept informed of the status of the verification program and the additional enhancements being made to the Drawinn Control Program.
We have no objection to this correspondence being hiade a matter of public record.
If you have any further questions, pleau contact ust i
Very truly yours, i
I_
O h SA R. Cartwright Lcc:
U. S. Nuclear Regulatory Cormnission 101 Marietth Strett, N. W.
Suite 2900 I
Atlanta, Georgia 30323 Mr. J. L. Caldwell i
NRC Senior Resident Inspector l
North Anna Power Station i
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