ML20084C118

Submits Followup to Describing Status of Program Addressing Positions in Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events. Nutac Final Draft Rept on Generic Ltr 83-28 Encl

ML20084C118
Person / Time
Site:	Peach Bottom
Issue date:	04/23/1984
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML20084C120	List: ML20084C118 ML20084C123
References
GL-83-28, NUDOCS 8404270100
Download: ML20084C118 (10)

Text

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PHILADELPHIA ELECTRIC COMPANY 23O1 MARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 (215)841-4000 April 23, 1984 Docket Nos. 50-277 50-278 Mr. Darrell G. Eisenhut Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

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REFERENCES:

(1)

Generic Letter 83-28, " Required Actions Based on Generic Implications of Salem ATWS Events", July 8, 1983 (2)

Letter, J. F. Stolz, USNRC, to E. G. Bauer, Jr.,

PECo, " Clarification of Required Actions Based on Generic Implications of Salem ATWS Events", October 21, 1983 (3)

Letter, S. L. Daltroff, PECo, to D. G. Eisehnut, USNRC, Response to Generic Letter 83-28, November 4, 1983 Dear Mr. Eisenhut This letter is a follow-up to-the Reference 3 letter describing the current status of Philadelphia Electric Company's program to address the positions contained in Generic Letter 83-28, " Required Actions Based on Generic Implications of Salem ATWS Events", July 8, 1983.

Philadelphia Electric Company has been participating in industry-wide generic efforts conducted by the BWR Owners' Group and INPO to address certain positions in Generic Letter 83-28.

Additionally, where these generic efforts have not been applicable to Philadelphia Electric Company, we have taken actions that we believe conform to the positions in Generic Letter 83-28 applicable to Peach Bottom Atomic Power Station Units 2 and 3.

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Mr. Darrell G. Eisenhut April 23, 1984 Page 2 Those positions in Generic Letter 83-28, to which we committed-to respond in the Reference 3 letter, are restated below along with our response.

ITEM 2.1 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (REACTOR TRIP SYSTEM COMPONENTS)

Position Licensees and applicants shall confirm that all components whose functioning is required 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, for these components, licensees and applicants shall establish, implement and maintain a continuing program to ensure that vendor information is complete, current and controlled throughout the life of the plant, and appropriately referenced or incorproated 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 assur,e that-~ sufficient attention is paid ~to-equipment maintenance,. replacement, _and repair, to compensate :for lack of ~ vendor backup, 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.

o information. 'This could be accomplished by licensee acknowledgement forireceipt of technical mailings.. The program shall also define.the interface and division of responsibilities among D

the' licensees and the~ nuclear-and non-nuclear

-divisions _of their vendors that provide. service'~on reactor! trip system ~ components to assure that

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requisite-control of, and applicable instructions for maintenance work, are provided.

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Response

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All systems that contribute to the reactor trip function have been identified as being in the current O' list.

Consequently, all components on the identified systems, l'

unless specifically excluded, are subject to the quality assurance program.

Philadelphia Electric Company is i

continuing to evaluate the current Peach Bottom 'Q' list to determine what improvements can be made to enhance its use.

In accordance.with approved Peach Bottom Administrative procedures and Engineering and Research Departmental j

procedures regarding procurement, each item or service to be procured must be' reviewed to determine whether or not it is safety related.

This. review is performed by a cognizant i

member of the Plant Staff or the Engineering and Research Department as applicable.

The determination is guided as D

appropriate by the applicable codes and standards, the i.

Engineer-Contractor, and the.NSS Supplier.

We believe the i

current Peach Bottom.'Q'-list and the existing procedural.

controls governing'its use are adequate to meet.the intent of Generic Letter 83-28.

A cost / benefit analysis is being performed toLevaluate-whether 'O' list, expanded to include components-within 'O' listed systems, will enhance.its usefulness by eliminating these analyses mentioned above to~ determine. if a component within a 'O'-listed system-is safety related.

Certain components and sub-components contained within a

. system listed as safety'related, may not be safety-related in Q' list, if the entire system themselves.. Under the current '

i is listed asisafety.related,.the component in question must be analyzed to determine if.it'is safety related.

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Regarding Vendor Interface, Philadelphia Electric CompanyLis continuing:its participation in the BWR Owners Group Evaluation to update those manuals associated withJthe

. reactor protection' systems.

contributing to the reactor, trip-function.

LIn: conjunction with this' effort, Philadelphia Electric

? company has taken the-following actions.to improve our confidence that ~ vendor information is included in : plant "

instructions and procedures.

JA tabulation of.all.vendorfmanual's for both safety and non-

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safety'related_ equipment.has,been completed and all manuals.

that are' required have'been11dentified. LA-controlled ~ master!

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f file.for these manuals will be created at Peach Bottom under control of the Systems Support Division.

The Independent Safety Engineering Group (ISEG) is preparing procedures for the independent review of information supplied by the NSS Supplier for the on-going vendor interface program to assure that vendor manuals are maintained current for the life of the-plant and that plant procedures are in accordance with vendor recommendations.

Por reactor trip function i-components, this procedure will be utilized to address the following types of General Electric Company technical

. reporting:

Service Information Letters - (SIL)

Customer ~ (Urgent) Communications 10 CFR 21 Reporting Service' Advice Letters (SAL) i' Application Information Documents (AID) i The ISEG is reviewing these types of documents for'their applicability to Peach Bottom, and the associated

-administrative controls are expected to be proceduralized by-June 1,.1984.

As a'furth'er improvement-in our control of vendor manuals,.

the Engineering and Research Departmentiis'now treating.

vendor manuals as drawings._ By.doing this,:the vendor manual becomes part of the drawing' file and is subject to the Engineering and-Research Departmental Procedures (ERDP) regafding. drawing control and requires updating of.the manuals just as drawings are updated following modification work.

A new ERDP,fspecifically. addressing control of the

-vendor manuals in this manner, has been prepared and is in the approval process.

It is expected that this' procedure will be in effect by September 1,1984. ' Currently,.any l

vendor manual that is known to have changes, as a result of an in-progress plant modification, is being amended.

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-ITEM 2.2 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (PROGRAMS FOR ALL SAFETY-RELATED) -

COMPONENTS

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'For. vendor interface,Llicensees and applicants shall establishi implement and maintain a Lcontinuing program-to'ensureithat vendor

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Mr. Darrell'G. Eisenhut April 23, 1984 Page 5 complete, current and controlled throughout the life of their plants, and appropriately referenced or incorporated in plant instructions and procedures.

Vendors of safety-related equipment should be contacted and an interface established.

Where vendors cannot be identified, have gone out-of-business, or will not supply information, 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 (GDC01).

The program shall be closely coupled with action 2.2.1 above (equipment qualification). 'The 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 t

j mailings containing technical information.

This could-_be accomplished by licensee acknowledgment for receipt of technical mailings.

It shall also define the interface i

and division of responsibilities among 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 applicable instructions for maintenance work on safety-related equipment'are provided.

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Response

Philadelphia Electric Company l participated 11n theENuclear

, Utility Task Action Committee (NUTAC) on Generic Letter 83-L

.28, Section 2.2.2, along with 56 other utilities.- The report l'

issued by the NUTAC, titled, ' Vendor Equipment Technicalu

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_Information Program, February, 1984,' is attached for your

- reference.. It describes a Vendor Equipment Technical Information ~ Program (VETIP) ' that. responds to _ the concerns on vendor /information-and interface. addressed in Section 2.2.2 of:the generic letter.

The VETIP-is anEindustry-controlled program that does not rely,on vendor' action, other than'the NSS Supplier,:to provide information to utilities.-

We conclude thati this approach will1be more ' effective than the vendor-oriented program _ suggested in the generic letterl

. forfreasons. discussed on pages.5 and;6 of..the NUTAC report.

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Mr. Darrell G. Eisenhut April 23, 1984 Page 6 i.

In response to Section 2.2.2 of Generic Letter 83-28, we will assure conformance with the various elements of the Vendor Equipment Technical Information Program using the guidance i

provided in the NUTAC report.

The specific programs i

involving utility implementation responsibilities are described in Section 4.1.1 of the NUTAC report and summarized below.

Generally, we currently comply with most aspects of the program; however, the administrative controls need to be strengthened in several areas.

Development of the administrative procedures to ensure implementation of the i-programs described in Section 4.1.1 will be completed by

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March 1985.

These programs are summarized as follows:

1 1.

NSS Vendor

Contact:

This program consists of a technical bulletin system and necessary contact with the NSS Supplier.

Administrative controls will be i

established to ensure an assessment of the technical information by qualified personnel, and that the appropriate actions are taken as deemed necessary by the assessment.

I 2.

NPRDS:

The current level of participation in Nuclear Plant Reliability Data System will be expanded to meet the intent of the INPO recommendations.

3.

Other vendors:

We will continue to seek assistance and equipment technical information from'other safety-

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-related equipment vendors when our< evaluation of an equipment problem concludes that-such_ direct interaction I

is necessary or would be beneficial.

I 4.

Handling'of Equipment Technical Information:

Administrative procedures will provide control of incoming equipment. technical information that is l

. received ~from a vendor or from other industry or i

regulatory sources.

This-includes, but not limited to, i.

~ manuals, etc.), INPO :(NPRDS, SOER's), NRC (Bulletins, information received from vendors (drawings, instruction Information Notices,Jand NUCLEAR NETWORK).

Administrative procedures will be established to ensure it' receives the appropriate technical review, evaluation, distribution, and control for future reference.

Appropriate actions will:be taken as deemed necessary by the evaluation.

Technical information will be incorporated into1the maintenance or operating procedures, purchasing records, and training program as appropriate.

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Mr. Darroll G. EiC3nhut April 23, 1984 Page 7 5.

Internal Handling of Vendor Services:

The vendor, contractor or technical representative who will perform safety-related services will be an approved / qualified supplier, and will perform the service in accordance with Philadelphia Electric Company's QA program.

ITEM 3.1 POST-MAINTENANCE TESTING JREACTOR TRIP EVEM{c5Mii5NENTS) 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 Specifictions, where required.

Response

In the Reference 3 letter, we stated that this position would be addressed following completion of the BWR Generic Owners' Group effort.

This effort has not yet been completed regarding the updating of vendor manuals.

Our review of plant testing and maintenance procedures applicable to the reactor protection system (RPS) indicates that maintenance procedures are more greatly impacted by vendor information than are those procedures relative to plant testing.

Surveillance test (S.T. ) and routine test (R.T.) procedures are performed to verify acceptable system performance based on its original design.

The satisfactory performance of an-S.T. or R.T. procedure constitutes a review of the procedures.

An S.T. or R.T. which fails to be satisfactorily completed because of a procedural probleo is revised and submitted to the Plant Operation Review Committee for review and approval.

Additionally, the ISEG review of those NSS Supplier documents referred to in response to Item 2.1 supports the S.T. and R.T. program applicable to the RPS to ensure that these procedures reflect the latest vendor information.

We believe, based on this discussion, that the procedures for testing of the RPS reflect appropriate vendor guidance for proper performance of these procedures.

The Electric Production Department Maintenance Division is currently in the process of obtaining the services of a consultant to update all Peach Bottom maintenance procedures.

Approximately 320 procedures will be updated, and it is

..s Mr. Darrell G. Eisenhut April 23, 1904 Page 8 expected that such work will begin in May 1984 and require 3 years to complete the task.

Following completion of the Owners' Group effort, if completed in a teasonable time frame, we will provide the necessary, updated information to the consultant to be included in the review in updating RPS maintenance procedures.

Since at this time we do not know the time frame for completion of the owners' Group effort, we are evaluating plans to direct the consultant performing the review applicable to contact the vendor as each procedure is reviewed.

We will provide to the Commissich a' schedule for completing the update of RPS maintenance procedures by July 1, 1984.

ITEM 3.2 POST-MAINTENANCE TESTING JxccstaeaSarciv-aecaTeoCoMpoNENTS1 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 required.

Reagggag In accordance with the discussion in response to item 3.1 regarding plant testing, Philadelphia Electric Company will concentrate efforts towards the updating of safety-related maintenance procedures to ensure that these procedures reflect the latest vendor information.

Concurr' ant with the updating program as described, we are evaluating plans to have the consultant contact the appropriate vendors and to include any changes in vendors recommendationu in the revised procedures.

We will provide to the Commission by July 1, 1984, our specific plans to carry-out this review.

However, as the procedures are updated, participation in those industry programs, as described in the NUTAC teport, will maintain both the vendor manuals and maintenance procedures current.

We trust that this information contained in the above responses is sufficient for Nuclear Regulatory Commission review of Philadelphia Electric Company's current conformance with the positions stated in Ger.eric Letter 83-28.

We have provided, to the best of our knowledge, our current status regarding the NRC positions and in Generic Letter 83-28.

Schedules and our plans to achieve conformance with these positions have been proposed.

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Should you require any further information, please do

.not hesitate to contact us.

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COMMONWEALTH OF PENNSYLVANIA :

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COUNTY OF PHILADELPHIA 4

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5. L'. Daltroff, being first duly sworn, deposes and says:

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'I' hat he is Vice President of Philadelphia Electric Company; x

that he has read the foregoing response to Generic Letter 83-28 and w

knows_Jhe contents thereof; and that the statements and matters set s-.

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- forthi,G~erein are true and.. correct to the best of his knowledge,

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JUDITH Y. FRANKLIN -

Notary Public. Phila.. Phila. Co.

, My Commission Empires July 28,1987 J%

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