ML18051A904

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Comments on Nutac Recommended Program Approach to Generic Ltr 83-28,outlined in INPO 84-010, Vendor Equipment Technical Info Program. Nutac Recommendations & Program Acceptable
ML18051A904
Person / Time
Site: Palisades 
Issue date: 05/31/1984
From: Vandewalle D
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
GL-83-28, NUDOCS 8406050363
Download: ML18051A904 (3)


Text

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'"'"7 consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 May 31, 1984 Darrell G Eisenhut Division of Licensing Nuclear Reactor Regulation US Nuclear Regulatory Conunission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO GENERIC LETTER 83-28, VENDOR INTERFACE Consumers Power Company's letter, dated November 7, 1983 stated that we were participating in the INPO sponsored NUTAC on Generic Letter 83-28, Section 2.2.2, Vendor Interface, and that it was our intent to utilize the NUTAC reconunendations as guidance in developing a program to assure that revelant vendor technical information is controlled and incorporated as necessary into plant activities.

Consumers Power Company has reviewed the NUTAC recommenda-tions and concurs with the recommended program approach outlined in INPO 84-010, Vendor Equiment Technical Information Program (VETIP).

The NUTAC has developed a set of specific enhancements, described in section 3.2 of INPO 84-010, to the NPRDS and SEE-IN Programs.

These enhanced NPRDS and SEE-IN programs in addition to the maintenance of the routine utility/

vendor and utility/NRC interchange provide for an effective vendor interface program that meets the intent of Generic Letter 83-28.

The enhancements to NPRDS include:

an improved definition of NPRDS reportable components to include mechanical components, improvements in failure reporting guidance, allowance for follow-up information on failure reports, and the inclusion of systems and/or components that are beyond the basic NPRDS scope.

Enhancements to the SEE-IN Program include an improved ability to trend NPRDS data, and the generation of reports of failures caused by faulty or missing vendor-supplied information.

Section 4.1.l INPO 84-010, describes the responsibilities of the utility for implementation of VETIP.

These responsibilities fall into three catagories:

NSSS Vendor Contact, NPRDS/SEE-IN, and contact with other vendors.

The balance of this submittal describes Consumers Power Companys present programs in each of these areas and submits the plan and schedule for upgrading our present programs consistent with the reconunendations established by the NUTAC for a VETIP.

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PDR ADOCK 05000255 I

P PDR OC0584-0017A-NL02

D G Eisenhut Palisades Plant RESPONSE TO GENERIC LETTER 83-28, VENDOR INTERFACE May 31, 1984 NSSS Vendor Contact 2

A program is in place at Palisades that provides for the review and incorpora-tion of applicable technical information received from the NSSS vendor.

This program is administered by our Nuclear Activities Plant Organization (NAPO) which is an independent onsite technical review group.

In addition to information received from the NSSS vendor, NAPO also reviews and develops recommendations based on information contained in NRC Circulars and Information Notices.

NPRDS/SEE-In The Palisades plant participates in the INPO sponsored NPRDS and SEE-IN programs.

Information received from the SEE-IN program (SOER's, SER's) is reviewed and evaluated for applicability by NAPO.

Recommendations based on applicable information are developed and submitted to the plant Technical Superintendent for further action.

The NPRDS program is supported both at the plant and at the General Office in Jackson.

Other Vendors Information from vendors of safety related equipment other than the NSSS supplier is reviewed by NAPO or an appropriate cognizant engineer when received.

In addition, Consumers Power Company routinely contacts equipment vendors for technical information or failure analysis as required.

Implementation of VETIP, Plan and Schedule Consumers Power Company has divided the implementation of VETIP into two sections.

The first section involves the creation and implementation of an Administrative procedure to ensure that vendor manuals and other vendor supplied information received by Palisades (other than information handled under the cognizance of NAPO) are controlled, reviewed, and incorporated as necessary into plant activities. As stated in our letter dated November 7, 1983, Consumers Power Company has reviewed our current program for handling and control of vendor manuals and vendor manual updates.

That review has shown that programs do exist to form the basis of a VETIP program as recommended by the NUTAC.

While these programs do exist, they are not procedurally controlled.

Therefore, Consumers Power Company will develop procedures and implement a program to control vendor manuals and updates to those manuals by August 26, 1985.

The second section involves Consumers Power Company participation in NPRDS.

As a member of the NPRDS Users Group Consumers Power Company supports the enhancements to NPRDS recommended by the NUTAC as they relate to vendor interface.

Further, Consumers Power Company believes that the NUTAC recommen-dation will increase the usefulness of NPRDS.

However, the scope of the NUTAC recommendations for NPRDS have not, as yet, been adequately defined by INPO and the NPRDS User Group, therefore, the work effort necessary to implement an OC0584-0017A-NL02

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D G Eisenhut Palisades Plant RESPONSE TO GENERIC LETTER 83-28, VENDOR INTERFACE May 31, 1984 3

expanded NPRD program is unknown.

The NUTAC has recommended that INPO and the NPRDS Users Group establish by July 1, 1984, schedules for implementation of the recommended enhancements to NPRDS.

Consumers Power Company will submit its plan and schedule for implementing an enhanced NPRDS program 90 days after INPO and the NPRDS Users Group have promulgated their schedule for implementa-tion of the NUTAC recommendations.

Director, Nuclear Licensing CC Director, Office Nuclear Reactor Regulation Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC0584-0017A-NL02