ML20136G298
| ML20136G298 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/18/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Butcher E, Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| 85-695, GL-83-28, NUDOCS 8511220309 | |
| Download: ML20136G298 (7) | |
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8 VINUINEA ELECTHIC AND POWEN COMI%NY HIcnwoNn,VIHOINIA 2332 61 November 18, 1985 W. I., Srawort V,cm Pomminant Nuctuam OrnaATIONS Mr. Harold R. Denton, Director Serial No.85-695 Office of Nuclear Reactor Regulation N0/EJL:aca Atta:
Mr. Edward J. Butcher, Acting Chief Docket Nos. 50-338 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 Gentlemen:
VIRGINIC ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 RESPONSE TO GENERIC LETTER 83-28 ITEMS 2.1, 2.2, 3.1.3 3
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.2.3, 4.4, AND 4.5 REQUEST FOR ADDITIONAL INFORMATION Your letter dated September 12, 1985 requested additional information for our response to Generic Letter 83-28.
Specifically, you asked us to provide additional information for items 2.1, 2. 2, 3.1. 3, 3. 2. 3, 4. 4, and 4.5.
Your letter also contained response guidance for items 2.1, 2.2.1, 2.2.2, 4.5.2, and 4.5.3.
.In a telephone conversation with your Staff, we were told that we should not provide additional information for items 3.1.3, 3.2.3, and 4.4 because response guidance was not provided for these items.
We were also told that we did not have to provide additional information for item 2.2.1 since item 2.2.1.6 of Generic Letter 83-28 was not intended to be a question, but rather was intended to provide guidance to the licensees. The response guidance and the additional information for items 2.1, 2.2.2, 4.5.2, and 4.5.3 are enclosed in Attachments 1 through 4, respectively.
If you have any questions about this material, please contact us.
Very truly yours, 9
.f W. L. Stewart 4
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VamoinA EtscTarc Ano Powsu COMPANY TO Mr. Ilarold R. Denton Attachments 1.
Generic Letter 83-28 Item 2.1 (part 2) 2.
Generic Letter 83-28 Item 2.2.2 3.
Generic Letter 83-28 Item 4.5.2 4.
Generic Letter 83-28 Item 4.5.3 cc:
Dr. J. Nelson Grace Regional Administrator NRC Region II Mr. M. W. Branch NRC Resident Inspector North Anna Power Station e
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KITICHMENT 1 l
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GENERIC LETTER 83-28 ITEM 2.1 (Part 2)
EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (REACTOR TRIP SYSTEM COMPONENTS) - VENDOR INTERFACE f-Response Guidance Licensee needs to submit detailed information describing his vendor interface program for reactor trip system components.
Information supplied should state how the program assures that vendor technical information is kept complete, current and controlled throughout the life of the plant and should also indicate how the program will be implemented at North Anna 1 and 2.
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Response
Our vendor interface program for reactor trip system components is a part of the overall vendor information program for safety related components.
As such, our resportse for item 2.2.2, Equipment Classification and Vendor Interface (Programs for all Safety Related Components)-Vendor Interface, which is presented in Attachment 2, is also applicable for this item.
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e ATTACHMENT 2 GENERIC LETTER 83-28 ITEM 2.2.2 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (PROGRAMS FOR ALL SAFETY RELATED COMPONENTS) - VENDOR INTERFACE Response Guidance Licensee needs to submit detailed information describing his vendor interface program for all safety-related components.
Information supplied should state how the program assures that vendor technical information is kept complete, current and controlled throughout the life of the plant and should also indicate how the program will be implemented at North Anna 1 and 2.
Response
The vendor interfsce program for safety related components for North Anna Power Station is defined by Administrative Procedure 6.18
" Control of Vendor Manuals, Vendor Files, and Interface" (10/25/84). The purpose of the program is to provide for the control of vendor information or interface that could generate a change to equipment specifications or operating methods, to identify the scope and define responsibilities for the control of vendor information, and to provide a reference to other station procedures that must be utilized to implement the program '
controls.
The scope of the program has been established to include vendor information and interface involving safety related equipment and structures, and the material or services to support safety rotated structures and equipment; vendor activities and services that may affect the vendor information currently available on site; vendor information obtained by vendor mailings, direct interface by telephone or on-site contact; and off-site vendor contacts and industry wide reports on equipment failures and vendor recommended changes.
The program identifies the staff positions that are responsible for controlling the distribution of vendor information and changes that are made to the vendor information, tracking the status of items that require review, resolving the items that have been assigned for review, and monitoring industry wide problem reports.
Vendor manuals and vendor files have been established and an index has been established that cross-references controlled vendor manuals with the safety related equipment listing for the station. In the event that the information necessary to establish a vendo; manual or file cannot be
- obtained, an evaluation is performed to document the continued acceptability of,the equipment based on exper: ence with the equipment.
The master copy of vendor manuals and files ar e placed in Station Records.
The controlled distribution of vendor manuals and vendor files including a periodic inventory and controlled change dis'ribution is made by Station
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Records in accordance with the Document Control Manual Procedure - 75,
" Procedure for Vendor Manuals and Files".
Vendor recommended changes received at the station are reviewed for action requireents by the Licensing Coordinator. Any items that require action are placed on the Commitment Tracking System (CTS) and assigned to the cognf zant maintenance or engineering group for action in accordance with Administrative Procedure 16.14, " Commitment Tracking Program". As part of this assignment the cognizant supervisor must determine if a change to the vendor manual or file is required. If a change is required Station Records is notified so that they can implement the change. Changes that are recommended by third party agencies such as the NRC, INPO, or other industry groups are regarded as vendor initiated changes. Any other recommended revision to a controlled vendor manual or file must be reviewed and approved by the cognizant department. The program also has provisions for deleting or removing information from the controlled vendor manuals and files.
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i Additionally, an industry-wide approach for a Vendor Equipment Technical Information Program was issued by INPO in March,1984 (INPO 84-010). My letter to you dated August 30, 1985 (Serial No. 85-0638) describes our j
participation and use of certain elements of that program.
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ATTACHMENT 3 GENERIC LETTER 83-28 ITEM 4.5.2 REACTOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING) - ON LINE TESTING Response Guidance Licensee needs to state if his plant is currently designed to permit on-line testing of the RTS. If not either design modifications that will permit such testing shall be described along with an implementation schedule or justification for not providing on-line testing capability shall be provided.
Response
. North Anna Power Station Units 1 and 2 are currently designed to permit on-line testing of the RTS. Section 7.2.2.2.1.6 of the North Anna Power Station Updated Final Safety Analysis Report (UFSAR) addresses the capability for testing the reactor trip system. A summary description follous.
The reactor trip system is capable of being tested during power operation.
When only parts of the system are tested at any one time, the testing sequence provides the necessary overlap between the parts to ensure complete system operation. The protection system is designed to permit periodic testing of the analog channel portion of the reactor trip system during reactor power operation. The operability of the process sensors is ascertained by comparison with redundant channels monitoring the same process variables or those with a fixed known relationship to the parameter being checked.
The reactor logic trains of the reactor trip system are designed to be capable of complete testing at power. The reactor coolant pump breakers, the turbine trip, and initiation of safety injection cannot be done at power without upsetting normal plant operation.
However, the logic for the associated trips is testable at power.
The manual trip cannot be tested at power without causing a reactor trip since operation of either manual trip switch actuates both train A and train B.
Section 7.2.2.2.1.7 of the North Anna Power Station UFSAR describes the testing of reactor trip breakers.
Table 4.3-1 of the Technical Specificationsr for North Anna Units 1 and 2 establishes the surveillance requirements for the reactor trip system instrumentation - including the operational modes in which surveillance is required.
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r; ATI'ACHMENT 4 GENERIC LETTER 83-28 ITEM 4.5.3 REACTOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING) - SURVEILLANCE INTERVALS Response Guidance Licensee needs to submit a description of the implementation of those provisions of WCAP-10271 and Supplement I which have been approved in the NRC's SER issued in March,1985. Also, the licensee needs to describe the additional provisions and implementation that may be developed by the WOG for the actuation logic and activated devices.
Response
We plan.to submit a technical specifications change request that would take advantage of those provisions of WCAP-10271 and Supplement 1 which have been approved in the NRC's SER issued in March, 1985 and in accordance with the guidance provided in the letter from Mr. H. R. Denton (NRC) to Mr. L. D. Butterfield (WOG) dated July 24, 1985. We intend to submit this technical specifications change request prior to December, i
1986.
Regarding additional provisions for the actuation logic and activated devices, based on telephone conversations with members of the WOG, it is our understanding that a letter will be sent by the end of November,1985 from the WOG to the NRC that describes the additional work that is planned for the trip breakers and the associated attachments. It is also our understanding that no additional work is planned for the actuation logic at this time, i
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