ML18039A085

Forwards Response to Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events. Safety-related Engineering Specs Will Contain Qualification Testing Requirements,Per FSAR Section 3.11

ML18039A085
Person / Time
Site:	Nine Mile Point
Issue date:	04/10/1984
From:	Rhode G NIAGARA MOHAWK POWER CORP.
To:	Schwencer A Office of Nuclear Reactor Regulation
References
CON-IIT07-447-91, CON-IIT07-448-01, CON-IIT7-447-91, CON-IIT7-448-1 GL-83-28, NMP2L-0029, NMP2L-29, NUREG-1455, NUDOCS 8404160070
Download: ML18039A085 (38)

Text

NIAGARA MOHAWK POWER CORPORATION

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NIAGARA MOHAWK SDD ERIC SOUI.CVARD WCST SYIIACUSC, N Y IStOt GERALD K. AHDDE SEIIIOA VICE PAEEICENT April 10, 1984 (NHP2L 0029)

Nr. A. Schwencer Licensing Branch No. 2 Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regultory Commission Washington, DC 20555

SUBJECT:

Nine Mile Point Unit 2 Docket No. 50-410 Attached is the Niagara Mohawk Power Corporation's Nine Nile Point Unit 2 response to Generic Letter 83-28 which concerns the "Required Actions Based on Generic Implications of Salem ATWS Events."

Sincerely, G. K. Rhode Senior Yice President GKR/TRL:lf

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~9 UNITED STATES OF AHERICA NUCLEAR REGULATORY COMHISS ION In the Hatter of )

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Niagara Hohawk Power. Corporation Docket No. 50-410

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(Nine Hile Point Unit 2) )

AFF I DAVIT a Senior o

Gerald K.

Niagara o aw Rhode, being duly sworn, states that he is/Vice President ower orporation; that he is authorized on the part of said Corporation to sign and fi1e with the Nuclear Regulatory Comnission the documents attached hereto; and that all such documents are true'nd correct to the best of his know1edge, information and belief.

Y k dd 9 f~. I'dy Subscribed and sworn to before me, a Notary Public in and f,kddd'ot for the State of New

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Oi'I ~I90812 ATTACHMENT A Required Actions Based on Generic.Im lications of SALEM ATMS Events POST-TRIP REVIEW (PROGRAM DESCRIPTION AND PROCEDURE)

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. The criteria for determining the acceptability of restart.

2. The responsibilities and authorities of personnel who will perform the review and analysis of these events.

3. The necessary aualifications and training for the responsible

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personnel.

4. The sources of plant information necessary to conduct the review and analysis. The sources of information should include the measures and eauipment 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)

5. The methods and criteria for comparing the event information

.with known or expected plant behavior (e.g., that safety-related eauipment oper ates as reauired by the Technical Specifications or other performance specifications related to the safety function).

6. The criteria for determining the need for independent assessment of an event (e.g., a case in which the cause of the event cannot be positively identified, a competent group such as the Plant Operations Review Committee, will be consulted prior to authorizing restart) and guidelines on the preservation of physical evidence (both hardware and software) to support independent analysis of the event.

Response

Administrative controls will be developed at Nine Mile Point Unit 2 which will contain procedures and data collection requirements related to the post-trip review.

The Nine Mile Point Unit 2 response to item lel will be submitted prior to startup.

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1.2 POST-TRIP REVIEM - DATA ANO INFORMATION CAPABILITY Position Licensees and applicants shall have or have planned a capability to record, recall and display data and information to permit diagnosing the causes of unscheduled reactor shutdowns prior to restart and for ascertaining the proper functioning of safety-related eauipmnt.

Adeouate data and information shall be provided to correctly diagnose the cause of unscheduled reactor shutdowns and the proper functioning of safety-related eauipment during these events using systematic safety assessment procedures (Action 1.1). 'The data and information shall be displayed in a form that permits ease of assimilation and analysis by persons trained in the use of systematic safety assessment procedures.

A report shall be prepared to describe and justify the adeauacy of eauipment for diagnosing an unscheduled reactor shutdown.

The report shall describe as a minimum:

1. Capability for assessing seauence of events (on-off indications)

a. Brief description of eouipment (e.g., plant computer, dedicated computer, strip chart)

b. Parameters monitored

c. Time discrimination between events

d. Format for displaying data and information

e. Capability for retention of data and information

f. Power source(s) (e.g., Class IE, non-Class IE, noninterruptable) 2~ Capability for assessing the time history of analog variables needed to determine the cause of unscheduled reactor shutdowns and the functioning of safety-related eauipment.

a. Brief description of eauipment (e.g., plant computer, dedicated computer, strip charts)

b. Parameters monitored, sampling rate and basis for selecting parameters and sampling rate

c. Duration of time history (minutes before trip and minutes after trip)

d. Format for displaying data including scale (readability) of time histories

e. Capability for retention of data, information and physical evidence (both hardware and software)

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f. Power source(s) (e.g., Class IE, non-Class IE, noninterruptable)

3. Other data and information provided to assess the cause of unscheduled reactor shutdowns.

4. Schedule for any planned changes to existing data and information capability.

~Res ense A response to this item will be submitted prior to the startup of Nine Mile Point Unit 2.

EQUIPMENT CLASSIFICATION AND VENOOR INTERFACE (REACTOR TRIP SYSTEM COMPONENTS)

Position Licensees and applicants shall confirm that all components whose functioning is reauired to trip the reactor are identified as safety-related on documents, procedures and information handling systems used in the plant to control safety-related activities, including maintenance, work orders and parts replacement. In addition, licensees and applicants shall establish, implement and maintain a continuing program to ensure that vendor information 1s complete, current and controlled throughout the life of the plant and appropriately referenced or incorporated in plant instructions and procedures. Vendors of these components should be contacted and an interface established. Where vendors cannot be identified, have gone out of business, or will not supply the information, the licensee or applicant shall assure that sufficient attention is paid to eouipment maintenance, replacement and repair to compensate for the lack of vendor backup and to assure reactor trip system reliability. The vendor interface program shall include periodic communication with vendors to assure that all applicable information has been received.

The program should use a system of positive feedback with vendors for mailings containing technical information. This could be accomplished by licensee acknowledgment for receipt of technical mailings. The program shall also define the interface and division of responsibilities among the licensees and the nuclear and nonnuclear divisions of their vendors that provide service on reactor trip system components to assure that reauisite control of, and applicable instructions for maintenance work are provided.

~Res onse The Nine Mile Point Unit 2 response to this item will be provided prior to startup.

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p ~s 2.2 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS)

Position s Licensees.and applicants shall submit, for staff review, a description of their programs for safety-related* eauipment classification and vendor interface as described below:

2.2.1 For eauipment classification, licensees and applicants shall describe their program for ensuring that all components of safety-related systems necessary for accomplishing reauired safety functions are identified as safety-related on documents, procedures and information handling systems used in the plant to control safety-related activities, including maintenance, work orders and replacement parts.

~Res onse Control of safety-related activities at Niagara Mohawk is accomplished by implementation of a guality Assur ance Program for safety-rel ated sytems, components and structures. Implementation of this program is achieved through administrative controls governing design, procurement, instalIation, testing, operating and maintenance by resoonsible Niagara Mohawk organizations. Responsibility for classification of eauipment is vested in the Nuclear Engineering and Licensing Department of Niagara Mohawk.

The Eauipment Classification List (9-List) identifies those systems, components and structures to which the guality Assurance Program

'pplies. Activities associated with these systems, components and structures are reauired to be accomplished in accordance with the guality Assurance Program.

2.2.1.1 The criteria for identifying components as safety-related within systems currently classified as safety-related, this shall not be interpreted to reauire changes in safety classification at the systems level.

~Res ense General criteria relative to classifying components as safety-re'lated within safety-related systems are contained in FSAR Section 3.2 and Nuclear Regulatory Commission Regulatory Guide 1.26, Rev. 3. In addition, Engineering Procedures will provide a vehicle for various departments within Niagara Mohawk to reouest a determination as to the safety-related classifications of components and services. When appropriate, the Eouipment Classification List (9-List) will be updated to reflect such determinations.

a e y-re ate structures, systems, and components are those that are relied upon to remain functional during and following design basis events to ensure: (1) the integrity of the reactor coolant boundary, (2) the capability to shut down the reactor and maintain .it in a safe shutdown condition, and (3) the capability to prevent or mitigate the conseauences of accidents that could result in"potential offsite exposures comparable to the guidelines of 10 CFR Part 100.

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safety-related components (e.g., computerized eauipment list) and the methods used for its development and validation

~Res onse The current Eauipment Classification List (9-List) is provided in the FSAR. Responsibility for preparation and control of the Eauipment Classification List (g-List), as well as review and approval, will be specified in Engineering Procedures.

2.2.1.3 A description of the process by 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 the introduction to 10 CFR 50, Appendix 8, apply to safety-related components.

~Res onse A response will be provided prior to startup.

2.2.1e4 A description of the management controls utilized to verify that the procedures for preparation, validation and routine utilization of the information handling system have been followed

~Res onse Safety-related activities will be governed by various administrative controls which implement the guality Assurance Program. Adherence to the guality Assurance PrograttL will be monitored primarily through the use of audits and inspections. These audits and inspections will encompass the various safety-related activities and will be performed at various freauencies. For example, maintenance activities on safety-related eauipment will be subject to guality Assurance inspections on a routine basis. Other audits or inspections will be performed less often but cover a longer period of operation or activity. Items of noncompliance identified as a result of these audits and inspections will be documented in accordance with provisions of the guality Assurance plan and will be carried as open items until resolved.

2.2.1.5 A demonstration that appropriate design verification and aualification testing is specified for procurement of safety-related components.

The specifications shall include aualification testing for expected safety service conditions and provide support for the of testing documentation to support the limits of life licensees'eceipt recommended by the supplier.

~Res onse Safety-related engineering specifications will contain aualification testing reauirements. Eauipment aualification information is discussed in FSAR Section 3.11.

Attributes such as design verification and qualification test'ing associated with procurement of safety-related components will bl.

addressed in appropri ate engineering pr ocedures. Engineer ing Procedures will identify procedural provisions to ensure that the applicable regulatory requirements, design bases and quality requirements" are met when obtaining material and services.

2.2. le6 Licensees and applicants need only to submit for staff review the equipment classification program for safety-related components.

Although not required to be sUbmitted for staff review, your equipment classification program should also include the broader class of structures, systems and components important-to-safety required by GDC-1 (defined in 10 CFR Part 50, Appendix A, "General Design Criteria, Introduction" ).

~Res nns'e With respect to the equipment classification program in use at Niagara Mohawk for structures, systems and components Important to Safety, we are participating in the Utility Safety Classification Group and are seeking a generic resolution to the Staff's concern in this regard thr ough the efforts of the Group. He do not agree that th 1 t structure and components important to safety constitute a broader class than the safety-related set. Nevertheless, we belie ve that nonsafety-related plant structures, systems and components have been designed and are maintained in a manner commensurate with their importance.

2.2.2 For vendor interface, licensees and applicants shall establish, implement and maintain a continuing program to ensure that vendor i n.formation for safety-related components is complete, current and controlled throughout the life of their plants, and appropriate 1 y f enced or incorporated in plant instructions and procedures.

Vendors of safety-related equipment should be contacted an d an interface established. Where vendors cannot be identified, have gone out of business, or will not supply information, the licensee or app lican t s hall assure that sufficient attention is paid to equipment maintenance, replacement, and repair, to compensate for the 1 a ckof vendor backup, to assure reliability commensurate with its safety function (GDC-1). The program shall be closely coupled with action 2.2.1 above (equipment qualification). The program shall inclu e

'periodic. communication with vendors to assuage that all applicable information has been received. The program should use a system of positive feedback with vendors for mailings containing technical information. This could be accomplished by licensee acknowledgment for receipt of technical mailings. It shall also define the i t rface and division of responsibilities among the licensee and the nuclear and nonnuclear divisions of their vendors that provi de service on safety-related equipment to assure that requisite control of and applicable instructions for maintenance work on safety-related equipment are provided.

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~Res ense Niagara Mohawk is actively participating in a Nuclear Utility task '-

Action Committee (NUTAC) on Generic Letter 83-28, item 2.2.2. It is

.expected that this Committee wil.l present its recommendations to the participating utilities in mid-1984. Niagara Mohawk will then review these recommendations and will submit the Nine Mile Point Unit 2 response prior to startup.

3.1 POST-MAINTENANCE TESTING (REACTOR TRIP SYSTEM COMPONENTS)

Position

.The following actions are applicable to post-maintenance testing:

1. Licensees and applicants shall submit the results of their review of test and maintenance procedures and Technical Specifications to assure that post-maintenance operability testing of safety-related components in the reactor trip system is reauired to be conducted and that the testing demonstrates that the eauipment is capable of performing its safety functions before being returned to service.

2. Licensees and applicants shall submit the results of their check of vendor and engineering recommendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the technical specifications, where reauired.

3. Licensees and applicants shall identify, if applicable, any post-

'aintenance test reauirements in existing Technical Specifications which are perceived to degrade rather than enhance safety. Appropriate changes to these test reauirements, with supporting justification, shall be submitted for staff approval.

~Res onse The Nine Mile Point Unit 2 response to this item will be provided prior to startup.

3.2 POST-MAINTENANCE TESTING (ALL OTHER SAFETY-RELATEO COMPONENTS)

Position The following actions are applicable to post-maintenance testing:

1. Licensees and applicants shall submit a report documenting the extending of test and maintenance procedures and Technical Specifications review to assure that post-maintenance operability testing of all safety-related eauipment is reauired to be conducted and that the testing demonstrates that the eouipment is capable of performing its safety functions before being returned to service.

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2. Licensees and applicants shall submit the results of

.engineering recommendations to ensure that any their'heck'f-vendor and appropriate test guidance is included in the test procedures or the Technical Specifications where and'aintenance reauired.

3. Licensees and applicants shall identify, if applicable, any post-maintenance test reauirements in existing Technical Specifications which are perceived to degrade rather than enhance safety. Appropriate changes to these test reauirements, with supporting justification, shall be submitted for staff approval.

~Res onse The Nine Mile Point Unit 2 response to this item will be provided prior to startup.

4.1 REACTOR TRIP SYSTEM RELIABILITY (VENDOR-RELATED MODIFICATIONS)

~Res onse Not applicable to Nine Mile Point Unit 2.

4.2 REACTOR TRIP SYSTEM RELIABILITY (PREVENTATIVE MAINTENANCE AND SURVEILLANCE PROGRAM FOR REACTOR TRIP BREAKERS)

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'ot applicable to Nine Mile Point Unit 2.

4.3 REACTOR TRIP SYSTEM RELIABILITY (AUTOMATIC ACTUATION OF SHUNT TRIP ATTACHMENT FOR WESTINGHOUSE AND B&W PLANTS)

~Res onse No applicable to Nine Mile Point Unit 2.

4' REACTOR TRIP SYSTEM RELIABILITY (IMPROVEMENTS IN MAINTENANCE AND TEST PROCEDURES FOR B&W PLANTS)

~Res onse Not applicable to Nine Mile Point Unit 2.

4.5 REACTOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING)

Position On-line functional testing of the reactor trip system, including independent testing of the diverse trip features, shall be performed on all plants.

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The diverse trip features to be tested include the breaker undervoltage and shunt trip features on Westinghouse, BEW (See Action 4.3 above) and CE plants; the circuitry used for power interruption with the silicon controlled rectifiers on BEW plants (see Action 4.4 above); and the scram pilot valve and backup scram valves (including all initiating circuitry) on GE plants.

~Res onse Niagara Mohawk is participating in a Boiling Water Reactor Owners Group to address this item. Considering the similarity of the reactor trip system of virtually all boiling water reactors, an Owners Group is the most effective means of developing an appropriate response to this item.

s General Electric will evaluate the adeauacy of the current specifications for functional testing of the reactor trip systems and will address functional testing of the scram pilot valves and backup scram valves. It is anticipated that the results of this evaluation will be available to incorporate the results in our procedures.

A response will be provided prior to star tup.

Plants not currently designed to permit periodic on-line testing shall justify not making modifications to permit such testing.

Alternatives to on-line testing proposed by licensees will be considered where special circumstances exist and where the objective of high reliability can be met in another way.

'Res onse A response will be provided prior to startup.

In addition, Nine Mile Point Unit 2 will record the. scram times of certain control rods upon every reactor scram.

This scram time testing will demonstrate the action of the pilot scram valves and scram inlet and discharge valves.

Existing intervals for on-line functional testing reauired by Technical Specifications shall be reviewed to determine that the intervals are consistent with .achieving high reactor trip system availability when accounting for considerations such as:

l. uncertainties in component failure rates

2. uncertainties in common mode failure rates

3. reduced redundancy during testing

4. operator errors during testing

5. component "wear-out" caused by the testing

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. ~Res onse Niagara Mohawk is participating in another comnittee of the"Boiling.

Water Reactor Owners Group formed to address potential Technical Specification improvements. This Committee is expected to finalize their program in late 1984 so that the results of the program can be incorporated in the Unit 2 Technical Specifications prior to operation.

A response will be provided prior to startup.

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'V lN I ERNAL CORRESPONDENCE FORM '1 12.2 R OWO 66.01.013 'H U NIAGARA MOHAWK FROM T. R. Loomis DlsTRIGT Syracuse

o, D. LoSurdo DATE May 15, 1986 FILE CODE r

SUBJECT Ver1f1cation of Commitments in Our April 15, 1986 Response to Generic Letter 83-28 r

Attachment 1 is a May 13, 1986 memo from S. Nicolaos to R. Randall concerning the commitment made in Section 2.2.2 of our April 15, 1986 response to Generic Lettet 83-28 (Attachment 2). In this memo, Mr. Nicolaos has identified the establishment of a vendor interface program which was recommended by the NRC reviewer in an NRC meeting in Washington, D.C. on March 31, 1986 (Attachment 3). Licensing requests that NC&V review the May 13, 1986 memo to ensure that it satisfies the commitment identified in your May 2, 1986 verification memo concerning Section 2.2.2 (Attachment 4).

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I oomls L1censing Engineer TRL:ja 1614G Attachments, xc: S. Nicolaos R. Randall h,'. Brause A. F. Zallnick, Jr.

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FROM S.C. Ni co laos f6 DfSTRfCT R.G. Randall DATE 5/13/86 FfLE CPDE 'hfP-.18408 SUBJECT Generic Letter 83-28 "Vendor Interface Program" References Letter from S.C. Nicolaos (NMPC) to A.J. Acton (Borg-Narner, Byron-Jackson Pump Division) 5/10/86, NMP-18405.

Letter from S.C. Nicolaos (NMPC) to G.L. Miller (Cooper-Bessemer, Energy Services Group) 5/10/86, NhiP-18404.

Letter from S.C. Nicolaos (NMPC) to R. Lauretig (Electro-Motive Division) 5/12/86, NMP-16971.

Letter from T.E. Lempges (NMPC) to E.G. Adensam (NRC), 4/15/86, Response to Generic Letter 83-28, NMP2L-0687.

In reference to the commitment made'n Section 2.2.2 regarding the development of a vendor interface program with two major vendors, other than the NSSS supplier, Technical Support has initiated this program per telephone conversation (attachments) with three major vendors of safety-related equipment. The Emergency Diesel Generator Vendors, Cooper-Bessemer and General hfotors, (EhfD); and Borg-Warner, Byron Jackson's Pump Division. Both Cooper-Bessemer and Borg-Narner have agreed to send their technical bulletins to the Technical Support Supervisor with an acknowledgement sheet in which Niagara Mohawk is responsible for completing and returning to the vendor, General Motors, Electro-Motive Division (EMD) has also agreed to send their technical information to the Technical Support Supervisor with an annual index, so that current listings can be audited.

T he Technical Support Department will establish, assess, and maintain a file of all these technical bulletins sent to Nine Mile Point. Therefore, it is the intention of this program to satisfy the NRC's requirements with regard to vendor interface programs. Nine Mile Point Unit 2 can consider this item closed (IOC Commitment List Item f(10, NMP-18401). 1 SCN:kh cc: (w/attachments) (w/out attachments)

G.D. Nilson T.E. Lempges eRig@Qg+55. R.B. Abbott D. LoSurdo N.C. Drews J.R. Spadafore A.F. Zallnick B. Neakley p~

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p NINE MILE POINT NUCLEAR STATION /P.O. BOX 32 LYCOMING, NEW YORK 13093/TELEPHONE f315) 343'-2110'ay 10, 1986 (NMP-18405)

Mr. Andrew J. Acton Sr. Sales Engineer Byron-Jackson Pump Division P.O. Box 110 Trumbull, Connecticut 06611

Dear Mr. Acton:

This letter will confirm our telephone conversation of 4/30/86 regarding Byron-Jackson's Technical Service Bulletins. Byron-Jackson will provide Niagara Mohawk with copies of all relevant Technical Service Bulletins as these bulletins are published. Niagara Mohawk will establish and maintain a file of all your technical bulletins received by Nine Mile Point and act on any that are applicable. Ne will also complete and return to Byron-Jackson, the acknowledgement sheet provided with the bulletin stating that we have received the bulletin. This positive feedback from Nine Mile Point will provide you with assurance that all technical information has been received. It is the intention of this program to satisfy the NRC's require-ments with regard to vendor interface programs contained in Generic Letter 83-28, "Required Actions Based on Generic Implications of Salem ATWS Events. "

If you have any questions, please do not hesitate to call me at (315) 349-2618.

~i Very truly C.

yours, Pu~~

Stephen C. Nicolaos Generation Engineer Technical Support SCN:kh

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-ai T'NIASARA MOHAWK NINE MILE POINT NVCLEAR STATION/P.O. BOX 32 LYCOMING, NEW YORK 13093/TELEPHONE'(315) 343-21'10 h/ay 10, 1986 (NMP-18404)

Mr. Glenn L. Miller Service h/anager Cooper-Bessemer Energy Services Group North Sandusky Street Mount Vernon, Ohio 43050

Dear Mr. Miller:

This letter will confirm our telephone conversation of 4/2/86 regarding Cooper-Bessemer Service News ("Green Sheets" ). Cooper-Bessemer will provide Niagara Mohawk with copies of all relevant Service News Bulletins as these bulletins are published. Niagara Mohawk will establish and maintain a file of all your technical bulletins received by Nine Mile Point and act on any that are applicable. We will also complete and return to you (the Energy Services Group), the acknowledgement sheet provided with the bulletin stating that we have received the bulletin. This positive feedback from Nine Mile Point will provide you with assurance that all technical information has been received. It is the intention of this program to satisfy the NRC's requirements with regard to vendor interface programs contained in Generic Letter 83-28, "Required Actions Based on Generic Implications of Salem ATWS Events."

If you have any questions, please do not hesitate to call me at (315) 349-2618.

Very truly yours, Stephen C. Nicolaos Generation Engineer Technical Support SCN:kh

T N(AGAPA N V tNWAWK NMP-16971 NINE MILE POINT NUCLEAR STATION/P.O. BOX 32 LYCOMING. NEW YORK 13093/TELEPHONE (315) 343.21 10 May 12, 1986 Mr. Rick Lauretig Department 704 Electro Motive Division General Motors Corporation La Grange, Illinois 60525 Dear Mr. Lauretig.

This letter is to confirm our telephone conversation of 5/7/86 regarding Maintenance Instructions and Power Pointer Bulletins. EHD will provide Niagara Mohawk with copies of all relevant Maintenance Instructions and Power Pointer Bulletins as these bulletins are published. Niagara Mohawk, under the Technical Support Supervisor, will establish and maintain a file of all your technical bulletins recieved by Nine Mile Point. Niagara Mohawk will also review the maintenance instruction index, which is distributed annually, to assure aU. current listings have been recieved and are maintained. It is the intention of this program to satisfy the NRC's requirements with regard to vendor interface programs contained in Generic Letter 83-28, "Required Actions Based on Generic Implication of Salem ATWS Events." Thank you for your cooperation and support.

If you have any questions, please do not hesitate to call me at (315) 349-2618.

Very truly yours, ytui~ ( / ~:M~c4.

Stephen C. Nicolaos Generation Engineer Technical Support SCN/meh

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(Cont'.d)

Response

The Operations Assessment Program (AP-3.4.2, 'DP-5) contain these attributes.

Guideline:

(4) Administrative procedures should require that plant procedures at least reference ,appropriate Equipment Technical Information (ETI).

(5) Appropriate Equipment Technical Information (ETI) should be incorporated into the performance and, quality review sections of safety-related procedures.

Response

S-HI-GEN-002, Maintenance Instructions for Nritin Procedures, and S-IDP-PO, Outline for I&C De artment -

Procedures contain provisions that require the use of Equipment Technical Information (ETI) in writing maintenance procedures.

Guideline:

(6) Vendors or outside contractors who perform or provide safety-related services shall be subject to adequate utility control and . shall conform to utility or utility-approved QA procedures and controls.

Respons'e: I~

Al 1 work performed on safety-re ated equi pment at Nine Hi e 1 1 Point Unit 2 must be performed with NMPC approved procedures, regardless of whether it is performed by NHPC employees or outside vendors or contractors. Consequently all work is performed in conformance with NMPC or NMPC approved QA procedures and controls.

Guideline:

Licensee response should show .that interfaces have been or are being established with at .least two or more major vendors of safety-related equipment other than.-'-.the 'NSSS; -Examples of. such vendors include: diesel .generator 'vendor,'-switchgear vendor,

,major, pumps vendor, or vendor'f'motor-".operated.;valves, ,".-'

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2.2.2 (Cont'd)

Response

NMPC strongly endorses the NUTAC report on Generic Letter 83-28 .

NMPC will attempt to establish a vendor interface program with two major vendors of safety-related equipment other than the NSSS. It is our intention to develop this relationship with the diesel generator vendor, and/or with the major vendor of motor operators for valves, and/or with the major vendor of valves, and/or with the vendor of safety-related switchgear. This relationship will be developed expeditiously, however due to uncertainties in the willingness of these companies to participate, no commitment date can be specified at this time.

It should be noted, however, that the existing SIL program covers the components in the GE scope of supply, which includes components in the following major systems: ECCS, including RCIC; ADS; SLC; RHCU; RPS; Recirculation; Neutron monitoring, including RSCS; RRCS; and Fuel Handling among others. Therefore the intent of this guideline is met without establishing two additional vendor interface programs.

Guideline:

Licensee response should show that they have committed to work with INPO to ensure accomplishment of INPO Implementation Responsibilities as described in Sections 3.2, 4.1.2, and 4.2.2.1 of the NUTAC/VETIP report.

Response

INPO has prepared revisions to NPRDS and SEE-IN as described in the attached letter.

Guideline:

The vendor interface program should include periodic contact with the NSSS vendor to assure that the latest versions of maintenance, test, service, and modification recommendations are in the licensee's possession.

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Response

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TDP-5 has been revised to require annual contact with General Electric regarding the .SIL program and an audit of the results to assure that all the SILs are in NMPC's possessio'n.

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