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
REGULAT INFORNATION DISTRIBUTION YBTEN (RIDB)
ACCESSION
'AC NBR: 8b010b0171 DOC. DATE: 85/12/20 Nine Nile Point Nuclear Stationi Unit 2. Niagara Noha NOTARIZED: NO DOCKET 05000410 I
IL: 50-410 AUTH. NANE AUTHOR AFFILIATION LENPQESp T. E. Niagara Nohaek Poeer Corp.
REC IP. NANE RECIPIENT AFFILIATION ADENBANi E. Q. 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 NIAGARA MOHAWK POWER CORPORATION/300 ERIE BOULEVARD WEST, 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, T. E. Lempges
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th ' ft W 0 ~ Page 2 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. 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 )
Response
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
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In the event that the scram report, Post Reactor-Scram Analysis and Evaluation procedure, and/or the star up c ec o s ee s revea a i p i d 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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Page 4 I I. POST-'TRIP 'EVIEW ='ATA'AND"INFORMATION CAPABILITY'1:2 Niagara Mohawk will provide a response to this section by fuel load.
R Page 5 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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Page 6 IV. EQUIPMENT'CLASSIFICATION AND'ENDOR'NTERFACE (Pro rams. For All Safety-Related-Components "
2;2) 2.2.1.3 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.
Response
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 . 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 Utility Task 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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Page 8 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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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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Page 10 VI I I . 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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TABLE 1 STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION TITLE DECEMBER 19B5 SCHEDULE/ST/TUS COMMENTS Post-Trip Review (program description and procedure) 1.1.1 Criteria for Determining Acceptability of Restart Procedures to be implemented for startup. Response in 12/20/85 letter to NRC.
-1.1-.2:--= Responsibilities and Authorities of personnel who wi1l perform the Procedures to be implemen ted
- for startup. Response in 12/20/85 letter to Review and Analysis of these events NRC.
1.1.3
-- Qualifications and for the responsible Training-Personnel Procedures to be. implemented.forwtartup. Response in 12/20/85 letter to "
'esponse NRC.
1.1.4 Source of plant information Procedures to be implemente d for startup: response in 12/20/85 letter to necessary to conduct the review NRC.
1.1.5 Methods and Criteria for comparing Complete event information with known or in 12/20/85 letter to expected plant behavior NRC. SK
@PPRTURE 1.1.6 Criteria for Determining the y CAR>
t need for Independent Assessment Procedures to be implemented for startup. in 12/20/85 Response letter to NRC.
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TABLE 1 STATUS, OF GENERIC LETTER Q3-2Q REF'ULATORY ACTION ITEMS NI)E MILE POINT UNIT 2 SECTION TITLE DECEMBER 1985 SCHEDULE/STATUS 1.2 CONNENTS Post-Trip Review Data and Information Capability A report will be submitted to t1pe NRC prior to startup which describes the post-trip review and data and i.nformation for Nine Mile Point Unit 2capabi-1-ity by fuel load.
1.2.1 Capability of Assessing (See S'ection 1.2)
Sequence of Events (on-off indications) 1.2.1.1 Description of Equipment (e.g. plant computer, (See Section 1.2) dedicated computer, strip chart) SE
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PERTURB 1.2.1.2 Parameters- Monitored CARB (See-Section=l 1.-2.1.3 Time Discrimination-Between, Events (See Section 1 .2) Also Avai1able On Aperture Card-1.2.1.4 =-. -,Format for Displaying Data and Information (See Section 1 .2)
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Class IE; Non=Class- IE; Non-Interruptable) 1.2.2 Capability for assessing the time history of ~annie (See Section 1.2) variahies needed to determine the cause of unschedu1ed reactor shutdowns, and the functioning of safety related equipment SI APErnURE 1.2.2.1 Bri ef Descri ption-of - - CARD
.."(See Section 1.2)
(e.g., Plant Computer,Equipment Dedicated-rS<r>p Charts)..
Com p ut e, Also Available On 1.2.2.2 Aperture Card Parameters Monitored, Sampling Rate and Basis for Selecting (S e Section 1.2)
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Parameters and Sampling Rate 1.2.2.3 Duration of Time History (Minutes Before Trip and (See Section 1.2)
Minutes After Trip) 1.2.2.4 Format for Displaying Data Including Scale (Readability (See Section 1.2) of Time Histories)
V TABLE 1 STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT. UNIT 2
~SEC ION TITLE DECEMBER 1985 SCHEDULE/STATUS COMMENTS' 1.2.2.5 Capabi 1 i ty for Retention of Data, Information and Physical (See Section 1.2)
Evidence (Both Hardware &
Software) 1.2.2.6 Power Source(s) (e.g., Class IE, (See Section 1.2)
Non-Class noninterruptable) 1.2.3 Other Data and Information -
Provided to Assess the cause (See Section 1.2) SI of Unscheduled Reactor Shutdowns 'PERTggm P cARD 1:2.4 Schedule for any Planned Changes- .
to Existing Data (See Section 1.2) and Information Also AvailaMe Capability Oz AgCcture
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1 Equipment Classification and Vendor Interface (Reactor Trip Components) 'ystem Cnrd'esponse Review Maintenance Procedures (mechanical, electrical and Prior -to-startup- -in 12/20/85 I&C) to ensure classification letter to NRC information is included with the appropriate maintenance documen-tation.
Complete investigation of SIL's pertaining to Reactor Trip Prior to startup Response in 12/20/85 letter to NRC Function Components and change procedures and equipment, as necessary-
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TABLE 1 STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NIJ~E MILE POINT UNIT 2 SECTION TITLE DECEMBER 1985 SCHEDULE/STATUS COMMENTS Compi 1 e vendor manual s for Prior to startup Response in 12/20/85 letter to NRC appropriate NMP2 equipment Permanent update program will Prior to startup Response in 12/20/85 letter to NRC be completed prior to commercial operation 2.2 Equipment classification and vendor interface (programs for all safety-related components) 2.2.1 Describe the program for ensuring Comp 1 e te.
.'afety-related Response in 4/10/83-letter to NRC
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components are identified as safety-related in- =
appropriate documentation 2.2;1.1 'riteria for identifying ponents as com-safety-related (review -
Procedure review to be completed prior to startup Response in 4/10/83 letter to NRC engineering -procedures to ensure a method exists for identifying
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safety-'related components and i APERTQQg services) CARD 2.2.1.2 Description of the information Complete ~I oAvaihbie Ov handling system used to identify Response in 4/10/83 letter to NRC safety related components APerture Ca>>
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TABLE 1 STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS
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2.2.1.3 Description of the process by Complete Response in 12/20/85 letter to NRC 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 2.2.1.4 Description of the management Complete Response in 4/10/83 letter to NRC controls utilized to verify that the procedures for preparation, validation and routine utilization of the information handling system ~pano have been -fol lowed Sf~
2.2.1.5 Demonstrate that the appropriate Ensure engineering procedures Response in 4/10/83-letter to NRC anmh design verification.and qualification ensure that applicable reg-CARD testing is specified for procure- regulatory requirements design ment of safety-related components bases and quality requirements Also Available Orj' are met when obtaining material per<ure Car<V and services 2.2.1.6 Licensees and applicants need Complete Response in 4/10/84 letter to NRC only to submit for staff review the equipment classification program for safety-related components 2.2.2 Vendor Interface Program rocedures Procedures to be implemented Response in. 12/20/85 letter.
prior to startup.
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TABI E 1 STATUS OF GENERIC LETTER 83 28 1 1 REGULATORY ACTION ITEHS NINE HILE POINT UNIT 2 SECTION TITLE DECEHBER 1985 SCHEDULE/STATUS COHHENTS 3.1 Post Haintenance Testing (Reactor Trip System Com-ponents) 4 3.1.1 Revise administrative pro- Review to be completed prior Response in 12/20/85 letter to NRC cedures to ensure post-maintenance to startup testing'for Reactor Trip Com-ponents prior to startup Review Tech Specs to ensure post- Review to be completed prior Response in 12/20/85 letter to NRC maintenance testing for Reactor . to startup Trip components prior to startup N
3.1.2 Revie~ of SIL's recommendations to Review to be completed prior Response in 12/20/85 letter to NRC ensure appropriate test guidance is to startup included in procedures 3.1;3 Identify any post-maintenance test Review to be 'completed prior Response in 12/20/85 letter to NRC requirements in technical specifi- to startup cations which can be demonstrated to degrade rather than enhance P safety Si
/ pyERYURE 3.2 Post-Haintenance Testing (all other safety-related components) 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 l
SECTION TITLE DECEMBER 1985 SCHEDULE/STATUS COMMENTS 3.2.1 Revise administrative procedures Review to be complete prior Response in 12/20/85 to ensure post-maintenance to startup letter to NRC testing for safety-related equipment Review Technical Specifications Review to be complete prior to ensure post-maintenance testing to startup for safety-related equipment 3.2.2 Review of SIL's to ensure appropriate Review to be complete prior test guidance is included in pro- to startup cedures.
3.2.3- Identify any post-maintenance test requirements in technical specifi-cations which can be demonstrated .
to degrade rather .than enhance safety 4.5 Reactor Trip System Reliability Complete -
Response in 12/20/85 letter to NRC (System Functional Testing)
Functional Testing of scram pilot valves and backup scram valves. Si PyERTURK Evaluate existing intervals for CARD on-line functional testing required by technical specifications pisd Available 8A Aperture Car4
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'P~8+Zf V NIAGARA PEAL CORRESPONDENCE
,>Aha i12.2R &40 664114113 g FROM DISTRICT T. Loomis Syracuse DATE FILE CODE S. Nicolas January 2, 1986 R. Randall SUBJECT in Regard to Generic D. LoSurdo Commitments 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.
Ooml s Licensing Engineer TL:ja Attachment xc: A. F. Zallnick, Jr Project File (2)
TABLE 1 STATUS OF GENERIC LETTER 83 28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION TITLE DECEMBER 1985 SCHEDULE/STATUS COMMENTS Post-Trip Review (program description and procedure) 1.1.1 Criteria for Determining Procedures=to .be-implemented for startup. in 12/20/85"letter to Acceptability of Restart Response NRC.
1.1.2 Responsibilities and Authorities Procedures to be implemented for startup.
of personnel who will perform the Response in 12/20/85 letter to Review and Analysis of these events NRC.
1.1.3 Qualifications and Training for the responsible Procedures to be implemented for startup. Response in 12/20/85 letter to Personnel NRC.
1.1.4 Source of plant information !
Procedures to be implemented for startup.
necessary to conduct the review Response in 12/20/85 letter to NRC.
- --- -=-Methods--and-Criteria
- . 1-. 5 "for corn arin event information with known or - "-
Complete . = - -- - - Response'in T2/20785 'letter to expected. plant behavior NRC.
1.1.6 Criteria for Determining the nee for Independent Assessment Procedures to be implemented for startup.. Response in 12/20/85 lett e er to NRC.
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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 CONNENTS 1.2 Post-Trip Review Data A report will be submitted to and Information Capability 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.
1.2.1 Capability of Assessing (See Section 1.2)
Sequence of Events (on-off indications) t 1.2.1.1 Description of Equipment (See Section 1.2)
(e.g. plant computer, dedicated computer, strip
. chart)
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{See Section 1.2) 1.2.1.3 Time Discrimination (See Section 1.2)
Between Events SI 1.2.1.4 I
RYURE Format for Displaying Data and Information (See Section 1.2) =
CARD Also Available On, Aperture Car<
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TABLE 1 STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS PINE MILE POINT UNIT 2 SECTION TITLE DECEMBER 1985 SCHEDULE/STATUS CONNENTS .
1.2.1.5 Capability for Retention of ,(See Section 1.2)
Data and Information 1.2.1.6 Power Source(s) .(e.g. '.(See Section 1.2)
Class IE, Non-Class IE, Non-Interruptable) 1.2.2 Capability for assessing (See Section 1.2) the time history of ~analo variables needed to determine the cause of unscheduled reactor shutdowns, and =the functioning of safety related equipment t
1.2.2.1 Brief Description of Equipment- -
(See Section 1.2)
(e.g., Plant Computer, Dedicated Computer-,-Strip-Charts) 1;2.2.2 Parameters Monitored, Sampling I'See gf .
Rate and Basis for Selecting Section 1.2) :
PERTURB s
Parameters and Sampling Rate CARD 1.2.2.3 Duration of Time History (See Section 1.2) Also Avnlhble On (Minutes Before Trip and Minutes After Trip) Aperture Ca<.i Ii 1.2.2.4 Format for Displaying Data (See Section 1.2)
Including Scale (Readability of Time Hi stori es)
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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 1.2.2.5 Capability for Retention of 11 (See Section 1.2)
Data, Information and Physical Evidence (Both Hardware 8 Software) ..
1.2.2.6 Power Source(s) (e.g., Class IE, (See Section 1.2)
Non-Class noninterruptable) 1.2.3 Other Data and Information (See Section 1.2)
Provided to Assess the cause of Unscheduled Reactor Shutdowns ~" ~87~
1.2.4 Schedule for any Planned Changes 'PERTURE to Existing Data and Information CARD Capability.
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Equipment. Classification and" Aiso Availablu Orr..---
Apet'ture-Qnrd
. Vendor Interface (Reactor Trip System Components)
Review Maintenance Procedures
. (mechanical, electrical and Prior to startup Response in 12/20/85 letter to NRC ILC) to ensure classification information is included with the appropriate maintenance documen-tation.
Complete investigation of SIL's ",
Prior to startup pertaining to Reactor Trip Response in 12/20/85 letter to NRC Function Components and change procedures and equipment, as necessary
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J y TABLE 1 STATUS OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION TITLE .DECEMBER 1985 SCHEDULE/STATUS COMMENTS Compile vendor manuals for Prior to startup appropriate NMP2 equipment Response in 12/20/85 letter to NRC Permanent update program. will Prior to startup - = - - -Response in 12/20/85 letter to be completed prior to commercial NRC operation 2.2 Equipment classification and vendor interface (programs for all safety-related components) 2.2.1 Describe the program for ensuring all safety-related components Complete are Response in 4/10/83 letter to NRC identified as safety-related in appropriate .documentation II
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,2.2..1.1 Criteria"for identifying corn= .Procedure review.to be -- Response ponents as safety-related (review engineering procedures to ensure a completed prior to startup in 4/10/83 letter to NRC -'ERYURE method exists for .identifying I
CARD safety-'related components and services) A~ P>mille OIE 2.2.1.2 ~+er4ere Car6 Description of the information Complete h andi i ng sys tern used to i Response in 4/10/83 letter to denti fy NRC safety related components
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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 2.2.1.3 Description of the process by Complete Response in l2/20/85 letter to NRC which station personnel use this information handling system to determine that an activity is
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safety-related and what procedures for maintenance, surveillance parts replacement and other activities defined in 10CFR50, Appendix 8, apply to safety-related components 2.2.1.4 Description of the management Complete Response in 4/10/83 letter to NRC controls utilized to verify that the procedures for preparation, validation and routine utilization of the i nformation handling system have been -followed . .'--- <<RYURE CARD 2.2.1.5 Demonstrate that the appropriate Ensure engineering procedures Response in 4/10/83 letter to NRC design verification and qualifi.cation .'.
ensure-that applicable. reg-.
testing is specified for procure- regu'latory requirements design .Also Available 0".>
ment of safety-related components bases and quality requirements Apertuee. C ~
are met when obtaining material and services 2.2.1.6 Licensees and applicants need Compl ete Response in 4/10/&4 letter to NRC only to submit for staff review the equipment classification program for safety-related components 2.2.2 Vendor Interface Program Procedures to be implemented Response--sn -12/20/85 letter.
prior to startup.
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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 Post Maintenance Testing (Reactor Trip System Com-ponents) 3.1.1 Revise administrative pro-cedures to ensure post-maintenance Review to be completed p'rior Response in 12/20/85 letter to testing for Reactor Trip Com- to startup NRC ponents prior to startup Review Tech Specs to ensure post- Review to be completed prior maintenance testing for Reactor -to startup Response in 12/20/85 letter to NRC Trip components prior to startup 3.1.2 Review of..SIL's recommendations to Review to be completed prior ensure appropriate test guidance is to startup Response in 12/20/85 letter to NRC included in procedures=-
3:1-:3 -Identify any post-maintenance test --Review-to-be- completed-prior-
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requirements in -technical specifi- to startup Response in 12/20/85 letter to NRC
- cations which can be demonstrated to degrade rather than enhance safety SL 3.2 Post-Maintenance Testing safety-related components)
(all other ; ~RYURC CARD Also Available 06 Aper)ore Car,d
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TABLE 1 STAT S OF GENERIC LETTER 83-28 REGULATORY ACTION ITEMS NINE MILE POINT UNIT 2 SECTION TITLE DECEMBER 1985 SCHEOULE/STATUS COMMENTS 3.2.1 Revise administrative procedures to ensure post-maintenance Review to be complete prior Response in 12/20/85 to startup letter to testing for safety-related NRC equipment Review Technical Specifications Review to to ensure post-maintenance testing be complete prior for safety-related equipment to startup 3.2.2 Review of SIL's to ensure appropriate test guidance is included in pro- Review to be complete prior to startup cedures.
3.2.3 Identify any post-.maintenance test-requirements in technical specifi-cations which can be demonstrated to degrade rather than enhance safety
'45 Reactor Tiip System Reliability Complete (System Functional Testing) Response APERTURE in 12/20/85 letter to NRC Functional Testing of scram pilot valves .and backup scram valves. fl Evaluate existing intervals for Q~
on-1 i ne f unct i ona tes ti ng r equi red 1
by,techni cal speci fi cati ons CARD Also Available OA Aperture CarO
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