ML18057A508
| ML18057A508 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/28/1990 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-83-28, GL-90-03, GL-90-3, NUDOCS 9010110162 | |
| Download: ML18057A508 (4) | |
Text
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consumers Power PDWERINli MICHlliAN'S PROGRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 September 28, 1990 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
GB Slade General Manager RESPONSE TO GENERIC LETTER 90-03, RELAXATION OF STAFF POSITION IN GENERIC LETTER 83-28, ITEM 2.2, PART 2, VENDOR INTERFACE FOR SAFETY-RELATED COMPONENTS Nuclear Regulatory Commission Generic Letter (GL) 90-03 ("Relaxation of Staff Position in Generic Letter 83-28, Item 2.2, Part 2, Vendor Interface For Safety-Related Components"), dated March 20, 1990, and Supplement No. 1, dated May 14, 1990, relaxed the position for formal vendor interface programs set forth in Generic Letter 83-28 {"Vendor Interface and Equipment Classification").
The letter requested that the licensees review their present vendor interface programs as necessary to assure that both of the elements below are included.
{a) A program with the NSSS vendor as described in the VETIP, which covers all the safety-related components within the NSSS scope of supply. This program should include provisions for assuring receipt by the licensee/applicant of all technical information provided by the NSSS vendor.
{b) A program of periodic contact with the vendors of other key safety-related components not included in (a) above.
Consumers Power Company letters of November 7, 1983, May 31, 1984, May 15, 1985, and July 26, 1985 described the vendor interface program {Item 2.2, Part 2 of GL 83-28) at Palisades which implements the elements of the Vendor Equipment Technical Information Program {VETIP) described in the Nuclear Utility Task Action Committee {NUTAC) Report, INPO 84-010.
In response to GL 90-03, the vendor interface programs have been reviewed and we confirm that they include both of the elements described above.
The following is a summary of our vendor interface programs.
Administrative procedures and programs that address all aspects of vendor information, evaluation and tracking as outlined in INPO 84-010, VETIP, provide for review of a wide variety of operating experience information with the intent to obtain, receive, track and ensure appropriate actions are taken for such vendor and operating
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experience information as INPO SEE-IN and Nuclear Plant Reliability Data Systems (NPRDS) products, NRC Bulletins and Information Notices, Part-21 notifications, vendor bulletins and vendor generated experience letters and notes, etc. NSSS vendor letters and bulletins, as well as major plant-wide equipment vendors are also factored into this review and evaluation program.
An Administrative program is established to receive, review and incorporate applicable vendor maintenance manual information such as maintenance instructions, parts information or test procedures. This program ensures vendor manual information receives appropriate reviews and approvals to ensure its applicability to installed plant equipment.
The requirements 10 CFR 50, Appendix B, are taken into consideration when assigning outside vendors to perform work on plant safety components.
Administrative procedures are in place which require work activities to be performed in accordance with properly established instructions.
For maintenance activities, work is conducted under the control of the maintenance order process which requires establishing proper instructions, performing appropriate inspections and post maintenance and operability testing and documenting the accomplishment before equipment can be returned to service. Administrative procedures further ensure that design and modification activities performed by contractors are conducted in accordance with plant requirements, ensuring work is performed in accordance with established, approved instructions.
Administrative programs are in place which result in periodic vendor contact for plant components related to safe and reliable operation.
The key to this interface rests with our System Engineering program in which engineers are assigned specific systems to monitor and ensure performance.
In performing defined responsibilities, the System Engineer is expected to interface with vendors for all components in assigned systems on an as needed basis. Documentation of these interfaces occurs as appropriate, including letters to vendor and equipment files, updates to vendor manuals or notes in work order packages.
In many areas, performance is well understood and no documentation is performed.
In addition to the above described programs that form the basis for meeting the vendor interface program of GL 83-28 as modified in GL 90-03 we are presently involved in activities which result in close interface with vendors.
Examples of these include:
Combustion Engineering Owners Group which involves periodic meetings with the NSSS vendor and representatives from all Combustion Engineering plants. This group and its subcommittees constantly addresses equipment and procedure related issues associated with NSSS as well as plant equipment as a whole.
2
' r' Valve Team - A specialized team with the responsibility to address all plant valve related questions and concerns.
Augmented by contract personnel with valve expertise, this team interfaces with vendors on an as needed basis to ensure valve performance is optimized.
Pump Team - Similar to the Valve Team, this team addresses pump related concerns, and frequently interfaces with the appropriate vendor to resolve pump related performance questions and issues.
Motor Operated Valve and Diesel Generator Working Groups -
These groups are vendor specific and result in frequent interface on component related issues. These working groups also discuss industry experience with other plants having similar equipment.
Performance Contracts - These types of contracts contain performance clauses which relate directly to operation of plant equipment.
An example is the performance contract between the turbine generator vendor and the plant. This has resulted in constant interface between the vendor and plant staff.
The above examples touch on some of the activities ongoing at Palisades in the area of periodic vendor interface. These activities have been developed and maintained based on the success they have achieved.
They are reviewed periodically to determine whether they remain beneficial. Changes may be made in the future if the cost to maintain these activities exceeds the benefits derived from them.
Overall, the expectations established in Generic Letter 90-03 have been addressed at Palisades, and no further actions have been identified. While the Generic Letter 90-03 focus is on safety related equipment and components, we have found the vendor interface activities discussed in this response to be beneficial for all plant components and we will continue these interface activities with appropriate vendors to ensure the continued and safe operation of the Palisades Plant.
~r.;.~
General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades 3
CONSUMERS POWER COMPANY Palisades Plant Docket 50-255 - License DPR-20 RESPONSE TO NRC GENERIC LETTER 90-03 At the request of the Commission and pursuant to the Atomic Energy Act of 1954 and the Energy Reorganization Act of 1974, as amended, and the Commission's Rules and Regulations thereunder, Consumers Power Company submits our response to NRC Generic Letter 90-03, dated March 20, 1990, entitled, "Relaxation of Staff Position" in Generic Letter 83-28, Item 2.2, Part 2, "Vendor Interface For Safety-Related Components."
CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this submittal are truthful and complete.
By~H~mS~
Nuclear Operations Sworn and subscribed to before me this~' fl:day of~
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ElaiTli"E Buehrer, Notary Public Jackson County, Michigan My commission expires October 11, 1993 1990.