ML18038A110
| ML18038A110 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/20/1985 |
| From: | Lempges T NIAGARA MOHAWK POWER CORP. |
| To: | Adensam E Office of Nuclear Reactor Regulation |
| References | |
| CON-IIT07-447-91 (NMP2L-0566), GL-83-28, NUREG-1455, NUDOCS 8601060171 | |
| Download: ML18038A110 (58) | |
Text
ACCESSION NBR:
'ACIL:50-410 AUTH. NANE LENPQESp T. E.
REC IP. NANE ADENBANiE. Q.
REGULAT INFORNATION DISTRIBUTION YBTEN (RIDB) 8b010b0171 DOC. DATE: 85/12/20 NOTARIZED:
NO DOCKET I Nine Nile Point Nuclear Stationi Unit 2.
Niagara Noha 05000410 AUTHOR AFFILIATION Niagara Nohaek Poeer Corp.
RECIPIENT AFFILIATION BMR Prospect Directorate 3
SUBJECT:
Forwards suppl to 840410 response to Generic Ltr 83-28:
Topics addressed include post-trip reviee program descriptioni post-trip data h info capabilitgi equipment classification Cc vendor interface re reactor trip sos parts.
DISTRIBUTION CODE'055D COPIES RECEIVED: LTR ENCL SIZE!
TITLE: OR/Licensing Submittal:
Salem ATMB Events QL-83-28 NOTES:
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- K UMOHANK NIAGARAMOHAWKPOWER CORPORATION/300 ERIE BOULEVARDWEST, SYRACUSE, N.Y. 13202/TELEPHONE (315) 474-1511 December 20, 1985 (NMP2L 0566)
Ms. El inor G. Adensam, Director BWR Project Directorate No.
3 U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Washington, DC 20555
Dear Ms. Adensam:
Re:
Nine Nile Point Unit 2 Docket.No.
50-410 Attached are six additional responses (Sections 1.1, 2.1, 2.2, 2.2.2, 3.1, 3.2 and 4.5) concerning Generic Letter 83-28.
These responses are in addition to the previous responses sent to the Nuclear Regulatory Commission on April 10, 1984 (G.K. Rhode (NMPC) to A. Schwencer (NRC)).
Very truly yours,
<<pP~
T. E.
Lempges Vice President Nuclear Generation TEL/TL:rla 1156G Attachments xc:
R. A. Gramm, NRC Resident Inspector Project File (2) 8602060272 852 P20 PDR ADDCK 05000020 A
PDR'EB (LIAW)
PSB (L. HULNAN)
EICSB (SRINIVASAN)
RSB (ACTING)
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ATTACHMENT ADDITIONAL'NFORMATION'ONCERNING GENERIC LETTER'3-28 I. POST-TRIP 'REVIEW'ROGRAM'ESCRIPTION'AND'PROCEDURE'SECTION 1;1 Position Licensees and applicants shall describe their program for ensuring that unscheduled reactor shutdowns are analyzed and that a determination is made that the plant can be restarted safely.
A report describing the program for review and analysis of such unscheduled reactor shutdowns should include, as a minimum:
1.1.1.
The criteria for determining the acceptability of restart.
Response
Nine Mile Point Unit 2's criteria for determining the acceptability of restart are contained in the Interim Operating Procedure N2-IOP-101A (Plant Startup) which will be upgraded to a permanent operating procedure by startup.
This procedure requires the use of pre-startup checkoff sheets which are used to ensure all instrumentation is operating in accordance with plant specifications.
The order to start up the plant is issued by the Station Superintendent or his designated alternate.
Additionally, in the event that the cause of the scram or plant transient is not fully understood, the Site Operations Review Committee (SORC) will review the scram reports prepared per Niagara Mohawk Procedures.
In addition, Nine Mile Point Unit 2 endorses the BWR Owners'roup position with regard to Section 1.1.1.
1.1.2.
The responsibilities and authorities of personnel who will perform the review and analysis of these events.
Response
The Superintendent Operations, Station Shift Supervisor and technical department personnel will perform the post-trip review analysis.
Their duties are specifically stated in Administrative Procedures AP-1.2 and AP-1.3, Composition and Responsibility of Unit Or anization and personnel Responsibi sties and Authority.
They are assisted by the eac or na ys epar men w ic is irectly responsible for the collection of data, and to assist in the evaluation as to the cause of the reactor scram.
The responsibilities and authorities of the Reactor Analyst Supervisor and Unit Reactor Analyst Supervisor are stated in the Administrative Procedure AP-l.l, Composition and Responsibility of Site
~tl Our review of the administrative controls which regulate the responsibilities and authorities of personnel evaluating the Post-Trip Review, meet the intent of Section 1.1.2 and therefore no further action will be taken.
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1.1.3 The necessary qualifications and training for the responsible personnel.
Response
The analysis of unscheduled shutdowns at Nine Mile Point Unit 2 will be performed by a select group of trained and qualified individuals.
The
'ducation, training, and job related experience of these people provide the basis for the evaluation needed to make the post-trip review and restart recommendation.
The qualifications and training for the positions of Station Superintendent, Superintendent Operations, and Unit Reactor Analyst Supervisor comply with the requirements of ANSI/ANS 3.1-1978 and 10CFR55.
The Station Shift Supervisor and Shift Technical Advisor also meet the requirements of NTP-10 (Trainin of"Licensed Operator Candidates) and NTP-ll (Licensed Operator Retrainin In addition to all the initial training requirements for these positions per Nine Mile Training Procedure NTP-ll, retraining and periodic requalification are performed.
Retraining examines plant operations and off-normal events while requalification ensures that the recommended degree of knowledge is being maintained.
1.1.4.
Response
The sources of plant information necessary to conduct the review and analysis.
The sources of information should include the measures and equipment that provide the necessary detail and type of information to reconstruct the event accurately and in sufficient detail for proper understanding.
(See Action 1.2 )
The sources of information necessary to conduct the r eview and analysis will be provided in Reactor Analyst Procedure N2-RAP-6 (Post-Reactor Scram'Analysis and Evaluation) and Interim Operating Procedure N -I P-P an ar up The Reactor Analyst Procedure N2-RAP-6 is d
which will provide the necessary information to make an evaluation of the cause of a scram.
This procedure will be completed prior to startup.
Interim Operating Procedure N2-IOP-101A is currently available for review.
This evaluation will include the information provided by a GETARS system.
1.1.5 The methods and criteria for comparing the event information with known or expected plant behavior (e.g., that safety-related equipment operates as required by the Technical Specifications or other performance specifications related to the safety function).
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Response
The individuals responsible for the event analysis are qualified per ANSI/ANS 3.1-1978.
At their disposal will be records of previous reactor trips and the Final Safety Analysis Report Data which are used at their discretion for comparing the transient to expected responses.
Since Nine Mile Point Unit 2 will have sufficient data capability for comparing these
- events, and the operating personnel are trained and qualified to perform this evaluation, no further action will be taken at this time.
1.1e6 Criteria for Determining the Need for Independent Assessment
~Res ense:
In the event that the scram report, Post Reactor-Scram Analysis and Evaluation procedure, and/or the star up c ec o
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authorize restart.
- Instead, the appropriate staff members (representing the Site Oper ations Review Committee) will be requested to assist in the evaluation of the event.
Additionally, Administrative Procedure AP-3.4.1 (Administration of Technical and Safety Reviews) provides further gui ance or e ermining the need for independent assessment.
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II. POST-'TRIP 'EVIEW ='ATA'AND"INFORMATION CAPABILITY'1:2 Niagara Mohawk will provide a response to this section by fuel load.
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III. EQUIPMENT'CLASSIFICATION AND VENOOR'NTERFACE (Reactor Trip System. Components)
Section.2;1)
Niagara Mohawk does not currently plan to develop a specific list of components that would comprise a reactor trip system.
The reactor trip function is accomplished at Nine Mile Point Unit 2 by utilizing redundant plant process instrumentation that input to a one-out-of-two twice logic system.
These signals initiate a reactor trip (rapid control rod insertion i.e.
scram) by deenergizing solenoid operated scram pilot valves that vent air from the reactor scram valves.
Additional information is available in our current FSAR Section 7.2, "Reactor Protection (Trip) System (RPS) Instrumentation and Control."
The components that contribute to the reactor trip function are contained in several systems rather than one reactor trip system.
Those systems whose components contribute to the reactor trip function include reactor protection
- system, reactor vessel instrumentation
- system, neutron monitoring system and control rod drive system.
Therefore, a
new system identified as the reactor trip system would cause unnecessary inconsistencies with existing Nine Mile Point Unit 2 system nomenclature.
This would require extensive revision to existing documentation and a training program with no resultant enhancement of safety.
- However, Niagara Mohawk will review maintenance procedures to ensure that safety classification information is included with the appropriate maintenance documentation.
Niagara Mohawk will review General Electric Service Information letters pertaining to the reactor trip components.
Appropriate changes to equipment or procedures deemed necessary will be incorporated.
As a part of the startup of Nine Mile Point Unit 2, vendor manuals are being compiled for the appropriate NMP2 equipment.
The task will be complete prior to startup.
The permanent update program will be completed prior to commercial operation and will be onsite for your review.
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IV. EQUIPMENT'CLASSIFICATION AND'ENDOR'NTERFACE (Pro rams. For All Safety-Related-Components
" 2;2) 2.2.1.3
Response
A description of the process by which station personnel use this information handling system to determine that an activity is safety-related and what procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10CFR50, Appendix 8, apply to safety-related components.
The following is a description of the process of determining if an activity is safety related.
The supervisor of the department responsible for the activity has the responsibility to utilize the Equipment Classification List (Q-List) to determine the equiment classification.
Documents such as work requests and purchase requisitions are reviewed and approved by the Quality Assurance Department.
Activities such as surveillance or preventative maintenance are covered by procedures which are reviewed per technical specification requirements.
The final administrative control before work occurs is the requirement that the Shift Supervisor grant permission.
Based on the training, experience and knowledge of Technical Specifications required to fill the position, the Shift Supervsor can determine if the correct practices are to be used.
This control includes signoffs in the procedures, work requests and markups (tags) to be used.
It is the intent of the process at Nine Mile Point Unit 2 to have checks and balances in the system to assure that an error on the part of an individual will not result in "non-safety related practices" being applied to safety-related equipment.
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V V.
VENDOR INTERFACE PROGRAM- "RESPONSE".(Section-2;2;2 The Vendor Interface Program currently being implemented at Nine Mile Point Unit 2 consists of procedures and data collection requirements necessary to perform a complete evaluation on vendor/engineering recommendations.
The Administrative and Technical procedures which support this program are AP-3.4.2 (Operations Experience Assessment) and TDP-5 (Administration. of.O erationa n sneersn Assessmen I ems These procedures provide an engineering evaluation for tracking an item until it is incorporated into plant operations.
In addition to our administrative controls, Niagara Mohawk was an active participant in the Nuclear UtilityTask Action Committee formed to address Section 2.2.2.
Niagara Mohawk is currently in compliance with their response.
Therefore, no further action wil be taken at this time.
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VI. POST MAINTENANCE TESTING REACTOR TRIP SYSTEM. COMPONENTS)
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Niagara Mohawk is revising Administrative Procedure AP-5 (Procedure for
~on app icable safety-related equipment.
This procedure will be revised by startup.
Technical specifications will also be reviewed to ensure that post-maintenance testing be performed on applicable safety-related equipment.
Niagara Mohawk will review General Electric Service Information letters for test guidance on reactor trip system components and incorporate the appropriate changes into procedures.
The technical specifications will be reviewed to ensure that post-maintenance test procedures will not degr ade safety.
These actions will be completed prior to startup.
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V VII. POST'MAINTENANCE'TESTING ALL'OTHER'SAFETY-RELATED'COMPONENTS)';2 Niagara Mohawk is revising Administrative Procedure AP-5 (Procedure for
~app scable safety-related equipment.
Tais procedure will be revised by startup.
Technical specifications will also be reviewed to ensure that post-maintenance testing be performed on applicable safety-related equipment.
Niagara Mohawk will review General Electric Service Information letters for test guidance on safety-related systems and incorporate the appropriate changes into procedures.
Technical specifications will be reviewed to ensure that post-maintenance test procedures will not degrade safety.
These actions will be completed prior to startup.
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REACTOR 'RIP 'YSTEM'ELIABILITY'YSTEM'UNCTIONAL'ESTING) 'ECTION"4'5 Niagara Mohawk will perform testing of backup scram valves (including initiating circuitry) during refueling outages in lieu of on-line testing.
This guidance was provided in a letter dated March 19,
- 1985, from Mr. A. Schwencer to B. G. Hooten.
This response satisfies the concerns of Section 4.5.
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STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION 1.1.1 TITLE Post-Trip Review (program description and procedure)
Criteria for Determining Acceptability of Restart DECEMBER 19B5 SCHEDULE/ST/TUS Procedures to be implemented for startup.
COMMENTS
Response
in 12/20/85 letter to NRC.
-1.1-.2:--=
1.1.3 1.1.4 Responsibilities and Authorities of personnel who wi1l perform the Review and Analysis of these events Qualifications and Training-
-- for the responsible Personnel Source of plant information necessary to conduct the review ted for startup.
Procedures to be implemen Procedures to be implemente d for startup:
Procedures to be. implemented.forwtartup.
Response
in NRC.
Response
in NRC.
response in NRC.
12/20/85 letter to 12/20/85 letter to "
12/20/85 letter to 1.1.5 1.1.6 Criteria for Determining the need for Independent Assessment t
Procedures to be implemented for startup.
Methods and Criteria for comparing Complete event information with known or expected plant behavior'esponse in 12/20/85 letter to NRC.
Response
in 12/20/85 letter to NRC.
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SECTION 1.2 1.2.1 1.2.1.1 TITLE Post-Trip Review Data and Information Capability Capability of Assessing Sequence of Events (on-off indications)
Description of Equipment (e.g. plant computer, dedicated computer, strip chart)
J TABLE 1
STATUS, OF GENERIC LETTER Q3-2Q REF'ULATORY ACTION ITEMS NI)E MILE POINT UNIT 2 DECEMBER 1985 SCHEDULE/STATUS A report will be submitted to t1pe NRC prior to startup which describes the post-trip review and data and i.nformation capabi-1-ity for Nine Mile Point Unit 2 by fuel load.
(See S'ection 1.2)
(See Section 1.2)
CONNENTS SE
=- PERTURB CARB 1.2.1.2 1.-2.1.3 1.2.1.4 Parameters-Monitored Time Discrimination-Between, Events
=-. -,Format for Displaying Data and Information (See-Section=l (See Section 1
(See Section 1
I
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.2)
Also Avai1able On Aperture Card-
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STATUS OF GENERIC LETTER 83-28 RKULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION 1.2.1.5 1.2.1.6 TITLE Capability for Retention of Data and Information Power Source(s)
(e.g.,
Class IE; Non=Class-IE; Non-Interruptable)
DECEMBER 1985 SCHEDULE/STATUS (See Section 1.2)
(See Section 1.2)
COHHENTS 1.2.2 1.2.2.1 1.2.2.2 Capability for assessing the time history of ~annie variahies needed to determine the cause of unschedu1ed reactor shutdowns, and the functioning of safety related equipment (See Section 1.2) p e, S<r>p Charts)..
Parameters Monitored, Sampling (S
Rate and Basis for Selecting
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Parameters and Sampling Rate e Section 1.2)
Brief Descri ption-of Equipment
.."(See Section 1.2)
(e.g.,
Plant Computer, Dedicated-Com ut r SI
. APErnURE CARD Also Available On Aperture Card 1.2.2.3 1.2.2.4 Duration of Time History (Minutes Before Trip and Minutes After Trip)
Format for Displaying Data Including Scale (Readability of Time Histories)
(See Section 1.2)
(See Section 1.2)
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TABLE 1
STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT. UNIT 2
~SEC ION 1.2.2.5 1.2.2.6 1.2.3 1:2.4
- ~ -2 1
TITLE Capabi 1 i ty for Retention of Data, Information and Physical Evidence (Both Hardware Software)
Power Source(s)
(e.g.,
Class IE, Non-Class noninterruptable)
Other Data and Information Provided to Assess the cause of Unscheduled Reactor Shutdowns Schedule for any Planned Changes-to Existing Data and Information Capability Equipment Classification and Vendor Interface (Reactor Trip
'ystem Components)
Review Maintenance Procedures (mechanical, electrical and I&C) to ensure classification information is included with the appropriate maintenance documen-tation.
Complete investigation of SIL's pertaining to Reactor Trip Function Components and change procedures and equipment, as necessary-DECEMBER 1985 SCHEDULE/STATUS (See Section 1.2)
(See Section 1.2)
(See Section 1.2)
(See Section 1.2)
Prior -to-startup-Prior to startup COMMENTS'
- SI
'PERTggm P
cARD Also AvailaMe Oz AgCcture Cnrd'esponse
-in 12/20/85 letter to NRC
Response
in 12/20/85 letter to NRC
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SECTION TITLE Compi 1 e vendor manual s for appropriate NMP2 equipment TABLE 1
STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEM Prior to startup S
NIJ~E MILE POINT UNIT 2 DECEMBER 1985 SCHEDULE/STATUS COMMENTS
Response
in 12/20/85 letter to NRC 2.2 Permanent update program will be completed prior to commercial operation Equipment classification and vendor interface (programs for all safety-related components)
Prior to startup
Response
in 12/20/85 letter to NRC 2.2.1 2.2.1.2 Description of the information handling system used to identify safety related components Describe the program for ensuring
.'afety-related components are identified as safety-related in-
=
appropriate documentation 2.2;1.1
'riteria for identifying com-ponents as safety-related (review engineering -procedures to ensure a
method exists for identifying safety-'related components and services)
Comp 1 e te.
Procedure review to be
- completed prior to startup Complete
Response
in 4/10/83-letter to NRC
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Response
in 4/10/83 letter to NRC
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Response
in 4/10/83 letter to NRC
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SECTION 2.2.1.3 TITLE TABLE 1
STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2
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DECEMBER 1985 SCHEDULE/STATUS Complete Description of the process by which station personnel use this information handling system to determine that an activity is safety-related-and what procedures for maintenance, surveillance parts replacement and other activities defined in 10CFR50, Appendix B, apply to safety-related components COMMENTS
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Response
in 12/20/85 letter to NRC 2.2.1.4 2.2.1.5 2.2.1.6 Description of the management controls utilized to verify that the procedures for preparation, validation and routine utilization of the information handling system have been -fol lowed Demonstrate that the appropriate design verification.and qualification testing is specified for procure-ment of safety-related components Licensees and applicants need only to submit for staff review the equipment classification program for safety-related components Complete Ensure engineering procedures ensure that applicable reg-regulatory requirements design bases and quality requirements are met when obtaining material and services Complete
Response
in 4/10/83 letter to NRC
Response
in 4/10/83-letter to NRC
Response
in 4/10/84 letter to NRC
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anmh CARD Also Available Orj' per<ure Car<V 2.2.2 Vendor Interface Program Procedures rocedures to be implemented
Response
in. 12/20/85 letter.
prior to startup.
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STATUS OF GENERIC LETTER 83 28 REGULATORY ACTION ITEHS NINE HILE POINT UNIT 2 SECTION TITLE DECEHBER 1985 SCHEDULE/STATUS COHHENTS 3.1 3.1.1 3.1.2
- 3.1;3 3.2 Post Haintenance Testing (Reactor Trip System Com-ponents)
Revise administrative pro-cedures to ensure post-maintenance testing'for Reactor Trip Com-ponents prior to startup Review Tech Specs to ensure post-maintenance testing for Reactor Trip components prior to startup N
Revie~ of SIL's recommendations to ensure appropriate test guidance is included in procedures Identify any post-maintenance test requirements in technical specifi-cations which can be demonstrated to degrade rather than enhance safety
/
Post-Haintenance Testing (all other safety-related components) 4 Review to be completed prior to startup Review to be completed prior to startup Review to be completed prior to startup Review to be 'completed prior to startup P
Response
in 12/20/85 letter to NRC
Response
in 12/20/85 letter to NRC
Response
in 12/20/85 letter to NRC
Response
in 12/20/85 letter to NRC Si pyERYURE CARD Nso Available On Aperture Card
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TABLE 1
STATUS OF-GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION 3.2.1 TITLE l
Revise administrative procedures to ensure post-maintenance testing for safety-related equipment Review Technical Specifications to ensure post-maintenance testing for safety-related equipment DECEMBER 1985 SCHEDULE/STATUS Review to be complete prior to startup Review to be complete prior to startup COMMENTS
Response
in 12/20/85 letter to NRC 3.2.2 3.2.3-4.5 Review of SIL's to ensure appropriate test guidance is included in pro-cedures.
Identify any post-maintenance test requirements in technical specifi-cations which can be demonstrated to degrade rather.than enhance safety Reactor Trip System Reliability (System Functional Testing)
Functional Testing of scram pilot valves and backup scram valves.
Evaluate existing intervals for on-line functional testing required by technical specifications Review to be complete prior to startup Complete
- Response in 12/20/85 letter to NRC Si PyERTURK CARD pisd Available 8A Aperture Car4
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PEAL CORRESPONDENCE
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Z6 li 'P~8+Zf gf'I g V NIAGARA FROM T. Loomis S. Nicolas R. Randall D. LoSurdo DISTRICT DATE SUBJECT Syracuse January 2, 1986 FILE CODE Commitments in Regard to Generic Letter 83-28 Attached is a draft listing of the commitments required to complete the actions identified in Generic Letter 83-28.
Please review this listing and provide any comments or corrections by January 6, 1986. It is my intention to forward this list to the 8+2 site management for a formal assignment of responsibilities.
TL:ja Attachment xc: A. F. Zallnick, Jr Project File (2)
Ooml s Licensing Engineer
TABLE 1
STATUS OF GENERIC LETTER 83 28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION 1.1.1 1.1.2 TITLE Post-Trip Review (program description and procedure)
Criteria for Determining Acceptability of Restart Responsibilities and Authorities of personnel who will perform the Review and Analysis of these events DECEMBER 1985 SCHEDULE/STATUS Procedures=to
.be-implemented for startup.
Procedures to be implemented for startup.
COMMENTS
Response
in 12/20/85"letter to NRC.
Response
in 12/20/85 letter to NRC.
1.1.3 Qualifications and Training for the responsible Personnel Procedures to be implemented for startup.
Response
in 12/20/85 letter to NRC.
1.1.4
-. 1-. 5 Source of plant information necessary to conduct the review
- --- -=-Methods--and-Criteria "for corn arin event information with known or - "-
expected. plant behavior Procedures to be implemented for Complete
. =
startup.
Response
in 12/20/85 letter to NRC.
Response'in T2/20785 'letter to NRC.
1.1.6 nee for Independent Assessment NRC.
Criteria for Determining the Procedures to be implemented for startup..
Response
in 12/20/85 lett t
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TABLE 1
STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION 1.2 1.2.1 1.2.1.1
-- ---- 1.2;1..2 1.2.1.3 1.2.1.4 TITLE Post-Trip Review Data and Information Capability Capability of Assessing Sequence of Events (on-off indications)
Description of Equipment (e.g. plant computer, dedicated computer, strip
. chart)
Parameters Monitored Time Discrimination Between Events Format for Displaying Data and Information DECEMBER 1985 SCHEDULE/STATUS A report will be submitted to the NRC prior to startup which
'describes the post-trip review and data and information-capability for Nine Mile Point Unit 2 by
- fuel load.
(See Section 1.2) t (See Section 1.2)
{See Section 1.2)
(See Section 1.2)
I (See Section 1.2)
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STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS PINE MILE POINT UNIT 2 SECTION 1.2.1.5 1.2.1.6 1.2.2 1.2.2.1 1;2.2.2 1.2.2.3 1.2.2.4 TITLE Capability for Retention of Data and Information Power Source(s).(e.g.
Class IE, Non-Class IE, Non-Interruptable)
Capability for assessing the time history of ~analo variables needed to determine the cause of unscheduled reactor shutdowns, and =the functioning of safety related equipment Brief Description of Equipment-(e.g.,
Plant Computer, Dedicated Computer-,-Strip-Charts)
Parameters Monitored, Sampling Rate and Basis for Selecting Parameters and Sampling Rate Duration of Time History (Minutes Before Trip and Minutes After Trip)
Format for Displaying Data Including Scale (Readability of Time Hi stori es)
DECEMBER 1985 SCHEDULE/STATUS
,(See Section 1.2)
'.(See Section 1.2)
(See Section 1.2) t
- (See Section 1.2)
I'See Section 1.2) s (See Section 1.2)
Ii (See Section 1.2)
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SECTION 1.2.2.5 1.2.2.6 TITLE Capability for Retention of Data, Information and Physical Evidence (Both Hardware 8
Software)
Power Source(s)
(e.g.,
Class IE, Non-Class noninterruptable)
TABLE 1
STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2
.DECEMBER 1985 SCHEDULE/STATUS 11 (See Section 1.2)
(See Section 1.2)
COMMENTS 1.2.3 1.2.4 Other Data and Information Provided to Assess the cause of Unscheduled Reactor Shutdowns Schedule for any Planned Changes to Existing Data and Information Capability.
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Equipment. Classification and"
. Vendor Interface (Reactor Trip System Components)
Review Maintenance Procedures
. (mechanical, electrical and ILC) to ensure classification information is included with the appropriate maintenance documen-tation.
Complete investigation of SIL's pertaining to Reactor Trip Function Components and change procedures and equipment, as necessary (See Section 1.2)
Prior to startup
", Prior to startup
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Response
in 12/20/85 letter to NRC
Response
in 12/20/85 letter to NRC
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TABLE 1
STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION TITLE Compile vendor manuals for appropriate NMP2 equipment
.DECEMBER 1985 SCHEDULE/STATUS Prior to startup COMMENTS
Response
in 12/20/85 letter to NRC 2.2 Permanent update program. will be completed prior to commercial operation Equipment classification and vendor interface (programs for all safety-related components)
Prior to startup
=
-Response in 12/20/85 letter to NRC 2.2.1
,2.2..1.1 2.2.1.2 Describe the program for ensuring all safety-related components are identified as safety-related in appropriate.documentation Criteria"for identifying corn=
ponents as safety-related (review engineering procedures to ensure a
method exists for.identifying safety-'related components and services)
Description of the information handi i ng sys tern used to identi fy safety related components Complete II
.Procedure review.to be completed prior to startup I
Complete
Response
in 4/10/83 letter to NRC
-- Response in 4/10/83 letter to NRC
Response
in 4/10/83 letter to NRC
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STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION 2.2.1.3 TITLE Description of the process by which station personnel use this information handling system to determine that an activity is
= safety-related and what procedures for maintenance, surveillance parts replacement and other activities defined in 10CFR50, Appendix 8, apply to safety-related components DECEMBER 1985 SCHEDULE/STATUS Complete COMMENTS
Response
in l2/20/85 letter to NRC 2.2.1.4 2.2.1.5 Description of the management controls utilized to verify that the procedures for preparation, validation and routine utilization of the i nformation handling system have been -followed..'---
Demonstrate that the appropriate design verification and qualifi.cation testing is specified for procure-ment of safety-related components Complete Ensure engineering procedures ensure-that applicable. reg-.
regu'latory requirements design bases and quality requirements are met when obtaining material and services
Response
in 4/10/83 letter to NRC
Response
in 4/10/83 letter to NRC
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2.2.1.6 2.2.2 Licensees and applicants need only to submit for staff review the equipment classification program for safety-related components Vendor Interface Program Compl ete Procedures to be implemented prior to startup.
Response
in 4/10/&4 letter to NRC Response--sn
-12/20/85 letter.
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TABLE 1
STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION TITLE DECEMBER 1985 SCHEDULE/STATUS COMMENTS 3.1 3.1.1 3.1.2 3:1-:3 3.2 Post Maintenance Testing (Reactor Trip System Com-ponents)
Revise administrative pro-cedures to ensure post-maintenance testing for Reactor Trip Com-ponents prior to startup Review Tech Specs to ensure post-maintenance testing for Reactor Trip components prior to startup Review of..SIL's recommendations to ensure appropriate test guidance is included in procedures=-
-Identify any post-maintenance test
~ requirements in -technical specifi-
- cations which can be demonstrated to degrade rather than enhance safety Post-Maintenance Testing (all other safety-related components)
Review to be completed p'rior to startup Review to be completed prior
-to startup Review to be completed prior to startup
--Review-to-be-completed-prior-to startup
Response
in 12/20/85 letter to NRC
Response
in 12/20/85 letter to NRC
Response
in 12/20/85 letter to NRC
Response
in 12/20/85 letter to NRC SL
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TABLE 1
STAT S
OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION 3.2.1 TITLE Revise administrative procedures to ensure post-maintenance testing for safety-related equipment Review Technical Specifications to ensure post-maintenance testing for safety-related equipment DECEMBER 1985 SCHEOULE/STATUS Review to be complete prior to startup Review to be complete prior to startup COMMENTS
Response
in 12/20/85 letter to NRC 3.2.2 3.2.3
'45 Review of SIL's to ensure appropriate test guidance is included in pro-cedures.
Identify any post-.maintenance test-requirements in technical specifi-cations which can be demonstrated to degrade rather than enhance safety Reactor Tiip System Reliability (System Functional Testing)
Functional Testing of scram pilot valves.and backup scram valves.
Evaluate existing intervals for on-1 i ne f unct i ona 1 tes ting requi red by,techni cal speci ficati ons Review to be complete prior to startup Complete
Response
in 12/20/85 letter to NRC fl Q~
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