ML20059J922
| ML20059J922 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 09/13/1990 |
| From: | Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| REF-GTECI-A-47, REF-GTECI-SY, TASK-A-47, TASK-OR AGM-NUC-90-244, GL-83-28, GL-90-03, GL-90-3, NUDOCS 9009210064 | |
| Download: ML20059J922 (3) | |
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!m-i SACRAlnsiNTO MUNICIPAL UTILITY DISTRICT C P. O. Box 15830, Sacramento CA 95852 183o,(916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA AGM/NUC 90-244 September 13, 1990 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Hashington, D.C.
20555 DOCKET NO. 50-312 RANCHO SECO NUCLEAR GENERATING STATION LICENSE NO. DPR-54 VENDOR INTERFACE PROGRAM FOR SAFETY-RELATED COMPONENTS
Reference:
Generic Letter No. 90-03, dated March 20, 1990, Relaxation of Stafi Position in Generic Letter 83-28, Item 2.2, Part 2 " Vendor Interface for Safety-Related Components" Attention:
Seymour Heiss This letter represents the Sacramento Municipal Utility District's (the District) response to Generic Letter 90-03.
This Generic Letter requires licensees to review their present vendor interface program.
Below is a discussion of the two elements that the Generic Letter requires included in a vendor interface program, a.
NSSS Safety-Related Components d
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Because of a public vote, Rancho Seco was shut down on June 7, 1989. Defueling was completed on December 8, 1989.
Confirmatory Order dated May 2, 1990, prevents the District from moving fuel intc the Reactor Building without prior NRC approval, og As was discussed in the granting of the partial exemption to 10 8tn CFR 55 (NRC to SMUD letter dated May 16, 1990, TAC No. 75520), the SO design basis accidents considered credible in the defueled a
condition are reduced to a Loss of Offsite Power and a Fuel
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Handling Accident.
The Reference states that the District should have an interface h
program with NSSS vendors which covers all the safety-related compcnents within the NSSS scope of supply.
Safety-related O,. e,, 2.
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, l
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IS. Weiss, AGM/NUC 90-244:
L and (3)'the capability to prevent or mitigate the consequences of-accidents that could result in' potential offsite exposures comparable-to-the guidelines of 10 CFR 100.
However, with the plant in the defueled condition, there are no design-basis events' involving NSSS-components that would affect the-integrity of the reactor coolant i
boundary or would' result in potential offsite exposures comparable to 10 CFR 100 guidelines. Therefore, because no: safety-related components are required to be operable in the defueled condition the District will not maintain an interface' program with NSSS vendors which covers safety-related components within the NSSS scope of sur If the defueled condition status of the plant should change, tr strict will again review its vendor interface program in
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accordance with Generic Letter 90-03.
b.
Other Key Safety-Related Components Only the Spent Fuel Pool (SFP) liner is considered a key safety-related component for the purposes of Generic Letter 90-03. -If -
the liner integrity was sufficiently breached then a loss of SFP water '
could occur.
However, the SFP liner was constructed on. site during ~
plant construction.
It is not a. component that was purchased from a-vendor. Therefore, there is no vendor interface for the SFP liner.
Since there are no other key safety-related components, the District -
has no vendor interface program for other key safety-related components.
Members of your staff with. questions requiring additional information'or.
clarification.may contact Michael Braun at (209) 333-2935, extension 4917.
Sincerely, c%
v Dan R. Keuter Assistant General Manager
- Nuclear; i
cc:
J. B.. Martin, NRC, Halnut Creek C. Myers, NRC, Rancho.Seco
'S. Reynolds,1NRC, Rockville, MD i
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EISTR'IBUTION INCOMING CORRESPONDENCE J
MS 41 General Manager MS 257
~AGM, Nuciear MS 252 1
Deputy AGM, Nuclear MS 292A Manager, Emergency Planning MS-253 Manager, Maintenance MS 269 Manager, Nuclear Human Resources MS 298 Manager, Nuclear Licensing MS 255 Manager, Nuclear Plant MS 271 Manager, Quality & Safety MS 257 1
g Manager, Technical Servires MS 298 CCTS Coordinator MS 224 RIC FILES MS 298 Jerry Delezenski i
MS 298 X
Licensing Files s
_X W C/MSRC Coordinator (R. Colombc)
MS 256 MS MS
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COMMITMENT INFORMATION-Responsible-1 Commitment #
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20666 -
- Te March 20, 1990 T0:
ALL POWER REACTOR LICENSEES AND APPLICANTS RELAXATION OF STAFF POSITION IN GENERIC LETTER 83-28. ITEM 2.2
SUBJECT:
PART 2 " VENDOR INTERFACE FOR SAFETY-RELATED COMPONENTS" (GENERIC LETTER NO. 90 03)
This letter is to clarify the staff position in Part 2_ of Item 2.2 of Generic Letter 83-28 (Vendor Interface for Safety-Related Components).
The original position reads as follows:
"For vendor interface, licensees and applicants shall establish, implement and maintain a continuing program to ensure that vender-information for safety-related components is complete, current and controlled throughout the life of their plants, and:is appropriately referenced or incorporated in plant instructions and procedures. Vendors of safety-related equipment should be contacted and an interft;:e Where vendors cannot be identified, have gone out of established.
business, or will not supply infonnation, the licensee or applicant shall assure that sufficient attention is paid to equipment maintenance, replacement, and repair, to compensate for the lack of vendor backup,.to assure reliability commensurate with its safety function (GDC-1). The program shall be closely coupled with action-2.2.1 (equipment' classification). The program shall include periodic ccamunication 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 It shall by licensee acknowledgement for receipt of technical mailings.'
also define the interface.and division of. responsibilities'among1 the licensee and the nuclear and non-nuclear divisions of their vendors that provide service on safety-related equipment to assure that requisite control _of and applicable instructions for maintenance work on safety-related equipment are provided."
Since this position was established, the industry has generally taken the position that the Vendor Equipment Technical Information Program (VETIP)_
described in the Nuclear Utility Task Action Comittee (NUTAC) Report, INPO 84-010 issued in March 1984, meets the intent of Generic Letter 83-28 Item 2.2 Part 2.' The VETIP program includes the Nuclear Plant Reliability Data System (NPRDS) and the Significant Event Evaluation and Information Network (SEE-IN), both managed by INP0.
It also includes existing programs the utilities now conduct with vendors.
In'particular, it includes ~
interaction with the NSSS vendor.
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' The staff has reviewed the VETIP program and has nad the benefit of considerable discussions with licensees regarding vendor interface.
It is now recognized-that implementing a formal vendor interface program for every safeWelated component is not practical.
It is also recognized that vendon, may not always be in the best position to analyze a. failure because 1
they may not be aware of the components' application, environment or L
maintenance history. Therefore, we conclude that the elements of VETIP provide a framework to improve the quality and availability of equipment
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technical information for use by utility licensees.
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Experience has shown that many vendors, in addition to NSSS vendors, do produce valuable information relating to their equinment.
For this reason, the steff j
concludes that an adequate vendor interface program should include:
,i (a) A prograin 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 c? all technical information provided by p
the NS',S vendort and (b) A program of periodic contact with the vendors of other key safety-related components not included-in (a) above.
The vendor interface program should also take into account the requirements of 10 CFR Part 50, Appendix B which requires the licensee or applicant to be It responsible for establishing and executing the quality assurance program.-
i states that the licensee or applicant may delegate to others the work of establishing and executing the quality assurance program or any part of it, but.
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the licensee or applicant shall retain responsibility for the progrce.
Therefore, the licensee or applicant should-have a program which assures-that procedures and instructions are properly' prepared and implemented and that quality assurance programs for design, maintenance or modification work performed'on safety-related equipment by outside. vendors or contractors are These programs should clearly establish and delineate properly implemented.
in writing the authority and duties of persons and organizations performing activities affecting this safety-related equipment.
- The programs in (a) above'should provide for the licensee or applicant to
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receive all updates to instruction and maintenance manuals, technical information bullstins, revised test procedures, and updated replacement parts information. The programs should include provisions which ensure the 1icensee. receives all such vendor issued information pertinent to its safety-related e_uipment.
q The program described in (b) above is not intended to be as extensive as the
.programin(a),butisintendedtobeagoodfaith,'documentedeffortto r
periodically contact the vendors of key, safety-related_ components (such as auxiliary feedwater pumps, batteries, inverters, battery chargers, cooling L
water pumps, and valve operators), not already included in the interface program of (a)-above, to obtain any technical information applicable to this
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equipment. Documented periodic contact via telephone is sufficient.
It is
= expected that a reasonable and prudent review of operating experience, availability of vendor information, and component safety significance using insights obtained from generic or plant specific probabilistic risk
-analyses will yield a set of component vendors that will make up each licensee's program.
In the event that vendors have gone out of business, cannot be identified, or will not supply information, the licensee or applicant should implement or continue to maintain a frogram that will assure that sufficient attention is paid to equipment maintenance, replacement, and repair to compensate for the lack of vendor backup such that equipment reliability commensurate with its safety function is assured.
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y Licensees and applicants are requested to review their present vendor interface programs and modify their programs as necessary to assure that both of the a
elements set out above are met.
Pursuant: to,Section 182 of the Atomic Energy Act.andl10CFR50.54(f),the'NRCrequiresthat: licensees.reporttotheNRC u
- within:180 daysiof. receipt of this-generic: letter whether or not they have y ty taken the'accions? requested.
Licensees undertaking the actions requested should confim that they have examined their vendor interface programs, that their programs either already
~ include both of the elements set out in this letter or that the elements have been scheduled for implementation.
If licensee actions are not complete at the time of their submittal, the licensee should submit a completion date for the remaining actions to be taken.
If the licensee declines to undertake the.
actions requested by this letter, the licensee is required to provide justifi-cation for the position.
The response to this letter is to be provided under oath or affirmation and is necessary to enable the Commission to determine whether or not your license
-should be modified, suspended, or revoked. The response shall be addressed to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D. C. 20555. The NRC will continue to monitor the effectiveness of licensee or applicant vendor interface program implementation through the inspection process and will use the responas to this letter to plan and locate resources for inspections. Where a licensee's failure to (1) obtain information from vendors. (2) evaluate information obtained from vendors, or (3) implement necessary actions based on informatian obtained from a vendor results in conditions adverse to quality, the NRC will make findings and take action in accordance with its regulaticas.
This' request is covered by the Office of Management and Budget Clearance Number 3150-0011, which expires January 31, 1991.
The estimated average burden hours b
is.320 person hours per licensee response (144 person hours per year per licensee thereafter), including assessment of the new recommendations, searching data sources, gathering and analyzing the data, and preparing the required letters. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for redu~cing this; burden, to the Records and Reports Management Branch, (MNBB-7714) Division of Infomation Support Services, Office of Information Resources Management, U.S. Nuclear Regulatory Commission, Washington, D. C. 20555; and to the Paperwork Reduction Project (3150-0011), Office of Management and Budget.
Washington, D
-C.
20503.
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-Backfit Discuss' ion The actions ' described in this generic letter are relaxations of the original position.taken in Generic Letter 83-28 and are not considered a backfit.in accordance,with NRC procedures. An evaluation of.this letter was perforned in <
accordance with the charter 'of the Comittee to Review Generic Requirements ~
(CRGR) and will be made available in the public document room with the minutes of the 178th meeting of the CRGR, I
=If you have any questions about this matter, please contact the NRC project.
manager or the technical contact listed below.
' Sincerely, James G. Partlow l
Associate Director for Projects'.
Office of Nuclear Reactor Regulation 4
Enclosure:
Listing of Recently Issued j
i Generic Letters-
. Technical Contacts:
J S. Newberry, NRR (301)492-0782 g
l D. LaBarge, NRR <
(301)492-1421 a
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LIST 0F RECENTLY ISSUED GENERIC LETTERS l Generic Date of-Letter No.
Sub.iect Issuance Issued To a
90-02 ALTERNATIVE REQUIREMENTS 02/01/90 ALL LWR LICENSEES' FOR FUEL ASSEMBLIES IN THE
'AND APPLICANTS-DESIGN FEATURES SECTION OF TECHNICAL SPECIFICATIONS 90-01 REQUEST FOR VOLUNTARY 01/18/90 ALL LICENSEES OF PARTICIPATION IN NRC OPERATING REACTORS &
REGULATORY IMPAC SURVEY CONSTRUCTION PERMITS FOR LWR NUCLEAR POWER-
. PLANTS 89-23 NRC STAFF RESPONSES TO 10/23/89 ALL HOLDERS OF QUESTIONS PERTAINING TO
-OPERATING LICENSEES IMPLEMENTATION OF 10 CFR AND CONSTRUCTION PART 26 - GENERIC LETTER PERMITS FOR NUCLEAR 89-23 POWER PLANTS 89-22 POTENTIAL FOR INCREASED ROOF 10/19/89 ALL LICENSEES OF LOADS AND PLANT AREA FLOOD OPERATING REACTORS AND RUNOFF DEPTH'AT LICENSED HOLDERS OF CONSTRUCTION i
NUCLEAR POWER PLANTS DUE TO PERMITS (EXCEPT BYRON RECENT CHANGE IN PROBABLE BRAIDWOOD, V0GTLE, MAXIMUM PRECIPITATION SOUTH TEXAS, AND RIVER CRITERIA DEVELOPED _BY THE BEND)-
NATIONAL WEATHER SERVICE (GENERICLETTER89-22) 89-21 REQUEST FOR INFORMATION 10/19/89 ALL HOLDERS OF.
CONCERNING STATUS OF OPERATING LICENSES IMPLEMENTATION OF UNRESOLVED AND CONSTRUCTION SAFETY ISSUE (USI) REQUIREMENTS PERMITS FOR NUCLEAR POWER REACTORS-89-20:
PROTECTED AREA LONG-TERM 09/26/89, ALL FUEL CYCLE HOUSEKEEPING FACILITY LICENSEES WHO POSSESS, USE, OR PROCESS FORMULA QUANTITIES 0F STRATEGIC SPECIAL NUCLEAR MATERIAL 89-19 REQUEST FOR ACTION RELATED TO 09/20/89 ALL LICENSEES OF RESOLUTION OF UNRESOLVED OPERATING REACTORS, SAFETY ISSUE A-47 " SAFETY APPLICANTS FOR IMPLICATION OF CONTROL
'0PERATING LICENSES SYSTEMS IN: LWR NUCLEAR AND HOLDERS.0F POWER PLANTS" PURSUANT TO CONSTRUCTION PERMITS 10CFR50.54(f)
FOR LIGHT' WATER REACTOR NUCLEAR POWER PLANTS m
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