ML20246K320
| ML20246K320 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/08/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20246K325 | List: |
| References | |
| 89-276, NUDOCS 8905180030 | |
| Download: ML20246K320 (3) | |
Text
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o-VIRGINIA ELECTRIC AND POWER COMPANY RICllMOND, VIRGINIA 23261 May 8, 1989 W. L. STEWART SENIOR VICE PRESIDENT POWER U. S. Nuclear Regulatory Commission Serial No.89-276 Attention:
Document Control Room NL/GLP:glp/R8 Washington, D. C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 N PF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT NOS.1 AND 2 PROPOSED REMOVAL FROM THE NORTH ANNA UFSAR OF ON-LINE TESTING OF SAFETY SYSTF,fA SLAVE RELAYS This letter provides our evaluation and proposed changes to the UFSAR for on-line safety system functional testing requirements.
The North Anna UFSAR describes on-line testing of certain safety circuit relays which has not been conducted since startup of either unit.
The Technical Specification requirements for testing have been interpreted to require only master relay actuation coupled with a slave relay coil continuity test. The Technical Specifications are not explicit when describing the extent of the functional testing required during reactor operation.
A voluntary licensee event report (LER 88-027-00) was submitted on December 15, 1988 to document the difference between the Technical Specification (T.S.) interpretation and the Updated Final Safety Analysis Report (UFSAR).
Also, a Justification for Continued Operation was developed and approved by the Station Nuclear Safety Operating Committee (SNSOC).
Attached is our technical evaluation of testing requirements as they should apply to North Anna and a justification for changing the UFSAR to reflect testing as it is currently performed.
We propose to change the UFSAR to remove the description for on-line slave relay testing and to describe the functional ESF testing that will be performed over an eighteen month interval.
Based on our current interpretation of Technical Specifications we l
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are in compliance with and meet the intent of the specifications for on-line Safety System Functional testing.
We consider that the proposed test methodology is sufficiently different from that described in the UFSAR that we believe NRC review and approval of the change is appropriate in accordance with 10CFR50.59 and 10CFR50.90.
We have also determined that no significant hazards consideration as described in 10CFR50.92 is involved.
The basis for our determination is provided in the attachments. An amendment to our license to reflect Engineered Safety Feature (ESF) testing as riescribed in this submittal is also attached.
We will submit an updated Licensee Event Report which reflects the current state of our engineering review regarding slave relay testing on-line.
If you having any questions regarding this change, please contact us at any time.
Very truly yours, h.b, W.L. Stewart Attachments:
1.
Technical Evaluation and Safety Analysis 2.
Functional Description of Test Circuitry 3.
NRC Policy issue SECY 88-304 4.
Draft Proposed Change, North Anna UFSAR 5.
Draft License Amendment cc:
U. S. Nuclear Regulatory Commission Region ll 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. J. L. Caldwell NRC Senior Resident inspector North Anna Power Station 1
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