ML20058N594

Responds to NRC Re Violations Noted in Insp Repts 50-338/90-11 & 50-339/90-11.Corrective Actions:Procedure Revised to Limit Applicablity to Small Refueling Cavity Leaks & Listed Evaluations & Revs Will Be Made to EOP

ML20058N594
Person / Time
Site:	North Anna
Issue date:	08/08/1990
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-441, NUDOCS 9008140217
Download: ML20058N594 (4)

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• VIMOINIA ELucTurc Axu Powen Cowt Axy  !

H art: Mown,Vinoix A 20201 -

August 8,1990  ;

United States NiMear Regulatory Commission Serial No.: 90 441

, Attention: Document Control Desk NAPS /JHLTAH:R1 l 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 UNITS NO.1 AND 2 CORRECTIVE ACTION PLAN ,

NRC INSPECTION REPORTS 50-338&339/90-11  ;

We have received your letter dated July 9,1990 and the NRC Inspection Reports 50-338&339/90 11 and have reviewed the findings of the inspection. Our response, the schedules and plans for resolving these findings are attached.

We concur with the overall assessment that the Emergency Operating Procedures (EOPs) adequately covered the broad range of accidents and equipment failures to support the safe ,

shutdown of the plant. Evaluations of this inspection and our internal audit of the EOPs have been performed and it was determined that no immediate revisions to the EOPs are required.

The EOPs will be revised during the next scheduled upgrade, currently scheduled for the

. third quarter of 1991.

Our Technical Procedure Upgrade Program has an upgrade of the Abnormal Procedures (APs) scheduled to be completed during the first quarter of 1991. Because no formalinternal review, nor NRC inspection, has examined the APs to the same degree recently afforded the EOPs, it is appropriate to place a higher priority on first completing our review of the APs.

- 1 AP 52, ss of Refueling Cavity Level During Refueling, was revised to limit its applicability to small refueling cavity leaks. The technical basis for this procedure will be further evaluated l as part of the AP Upgrade Program. In addition, all EOPs and APs will be revi6wed for

' deficiencies similar to those identified during the NRC Inspection and our internal audit and  ;

will be corrected as necessary.

If you have any further questions, please contact us. ,

[ Ve truly yo ,

W. L. tes, rt h ,

Senior Vi6e President - Nuclear & 1

Attachment l

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Serial No. 90 441 l . Docket Nos. 50 338&339 .i L' 1 License Nos. NPF 4&7 i oc: U. S.' Nuclear Regulatory Commission j Region ll  !

101 Marietta Street, N. W. i Suite 2900-  !

Atlanta, Georgia 30323 I

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Mr. M. S. Lesser NRC Senior Resident Inspector  ;

North Anna Power Station i

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ATTACHMENT Response to NRC Inspection Reports No. 50 338&339/9011 l

IFl Number Description, Paragraph Status l IFl 338,339/901101 Inadequate Cavity Level Procedure, 1 AP 52 was revised to imit its .

1 AP 52, Paragraph 3. applicability to small refueing cavity leaks. 1 The technical basis for 1 AP 62 will be further evaluated as part of the AP Upgrade Program.

E IFl 338,339/901102 Lack of Detailin Procedures, These comments will be evaluated and Paragraph 3 and Appendix B. appropriate revisions completed with the next scheduled annual update to the EOPs, currently scheduled for the third quarter of 1991. Evaluations have been performed and determined that no immediate actions are required. ,

q IFl 338,339/901103 EOP TechnicalInadequacies, These comments will be evaluated and Paragraph 3 and Appendix B. appropriate revisions completed with the next scheduled annual update to the 4 EOPs, currently scheduled for the third quarter of 1991. Evaluations have been  !

performed and determined that no I immediate actions are required. i IFl 338,339/901104 Improper Content in Noter, and These comments will be evaluated and Cautions, Paragraph 3. appropriate revisions completed with the next scheduled annual update to the EOPs, currently scheduled for the third

, quarter of 1991. Evaluations have been performed and determined that no immediate actions are required.

IFl 338,339/9011-05 EOP Technicaland Human Factors These comments will bo evaluated and Deficiencies, Paragraph 4 and appropriate revisions completed with the Appendix B. next scheduled annual update to the j EOPs, currently scheduled for the third 4 quarter of 1991. Evaluations have been performed and determined that no immedate actions are required. The APs are scheduled for upgrade as part of the Technical Procedure Upgrade Program.

Completion of AP upgrades is currently scheduled for the first quarter of 1991.

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Serial No. 90-4e

,. Response to IR 50-338&339/9011

- Page 2 of i IFl Number Description, Paragraph Status 1 IPl 338,339/901107 EOP Nomenclature and Labeling Labels in the plant will be corrected by l Inaccuracies, Paragraph 4 and November 1,1990, subject to Appendix D. availabilityof materials. EOP nomenclature comments will be

. - evaluated and appropriate changes to  ;

EOPs will be completed with the next i s scheduled annual upgrade of the 1 EOPs, currently scheduled for the third 7

l Quarter of 1991. Evaluations have :

been performed and determined that ,

no immediate actions are required.' i IFl 338,339/901108 EOP Use of inconsistent Wording These comments willbe evaluated and for the Same Actions, Paragraph 7. appropriate revisions completed with .

the next scheduled annual update to ,

the EOPs, currently scheduled for the ,

third quarter of 1991. Evaluations have l been performed and determined that no immediate actions are required.  ;

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