ML20086U413
| ML20086U413 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 02/29/1984 |
| From: | NUCLEAR UTILITY TASK ACTION COMMITTEE |
| To: | |
| Shared Package | |
| ML20086U411 | List: |
| References | |
| GL-83-28, PROC-840229, NUDOCS 8403070252 | |
| Download: ML20086U413 (63) | |
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AT TA C H M EN r 2 O
il MUDBC ON GENERIC LETTER 83-28, SECTION 2.2.2 1
s Vendor ,
Equipment Technical .
Information Program February,1984 i
c B403070252 840229 !
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FINAL DRAFT FEB 2 91984
.. DRAFT 2/84 GENERIC LETTER 83-28 SECTION 2.2.2 Draft Report Developed By -
Nuclear Utility Task Action Comittee for.
Generic Letter. 83-28, Section 2.2.2 February 9,1984
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' Publications produced by a . Nuclear Utility Task Action Committee (NUTAC) represent a consensus of the utilities participating in the NUTAC. These pso-
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-lications are not intended to be-interpreted as industry standards. Instead, the publications are offered as suggested guidance with the understanding that -
individual utilities are not obligated to use the suggested guidance. '
This publication has been produced by the NUTAC on Generic Letter 83-28, Section 2.2.2., with the support of the Institute of Nuclear Power Operations (INPO). . The officers of this NUTAC'were Chairman Edward P. Griffing and Vice Chairman Walter E.'Andrews.
-Utilities that' participated in this NUTAC include the following:
- Alabama Power Company Nebraska Public Power District American Electric Power Service. Corporation New York Power Authority Arizona Public Service _ Company Niagara Mohawk Power Corporation Arkansas-Power & Light Company Northeast Utilities Baltimore Gas and Electric Company Northern States Power Company
' Boston Edison Company Omaha Public Power District Carolina' Power & Light Company - Pacific Gas and Electric Company Cincinnati Gas & Electric Company- Pennsylvania Power & Light Company Cleveland Electric Illuminating Company Philadelphia Electric Company Connonwealth Edison Company Portland General Electric Company
- Consolidated Edison Company of New York, Inc. Public Service Company of Colorado Consumers Power Company- Public Service Company of Indiana, Inc.
Detroit Edison Company - Public Service Company of New Hampshire j
Duke Power Company- Public Service Electric and Gas Company Duquesne Light Company F.ochester Gas and Electric Corporation Florida Power Corporation' Sacramento Municipal Utility District
' Florida Power & Light Compary South Carolina Electric & Gas Company -
GPU Nuclear Corporation . Southern California Edison Company Georgia Power Company' Tennessee Valley Authority Gulf States Utilities Company Texas Utilities Generating Company '
Houston Lighting & PowerLCompany'- The Toledo Edison Company L ' Illinois Power Company Union Electric Company Iowa Electric Light and. Power Company ' Vermont Yankee Nuclear Power Corporation
-: Kansas Gas and Electric Company Virginia Electric and Power Company Long Island. Lighting-Company Washington Public Power Supply System
- Louisiana Power & Light Company Wisconsin Electric Power Company Maine Yankee Atomic Power Company Wisconsin Public Service Corporation Mississippi Power & Light Company Yankee Atomic Electric Company
.1984, Institute of Nuclear Power Operations. Limited reproduction by INPO members
-and participants for. Internal'. company use ~is permitted.
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ISTICE: _ This document was prepared by a Nuclear Utility Task Action Committee (NUTAC)- with the staff support of the Institute of Nuclear Power Operations (INP0).
- Neither this NUTAC, INPO, members of INPO, other persons. contributing to or assist-ing in the preparation of the document, nor any person acting on behalf of these ,
parties (a) makes any warranty or representation, expressed or implied, with respect to the accuracy, completeness, or usefulness of the information contained in this
,_ - document, or that the use of any'information, apparatus, method or process disclosed in this ' document may not ' infringe on privately owned rights,~ or (b) assumes any liabilities with respect to the .use of any information, apparatus, method, or Lprocess disclosed in this document.
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DRAFT 2/84 e
EXECUTIVE
SUMMARY
This report was prepared by the Nuclear Utility Task Action Committee (NUTAC) on Generic Letter 83-28 " Required Actions Based on Generic Implications of Salem ATWS Events," Section 2.2.2. It describes the Vendor Equipment Technical Information Program (VETIP) developed by the NUTAC in response to the concerns on vendor information and interface addressed in Section 2.2.2 of the generic letter. VETIP is a program that enhances information exchange and evaluation among utilities constructing or operating nuclear power plants and provides for more effective vendor interface.
The NUTAC,was comprised of representatives of 56 utilities that are members of the Institute 'of Nuclear Power Operations (INP0). Staff support for the NUTAC was provided by INPO. This report unanimously presents the final conclusions of the NUTAC and is provided to assist individual utilities in developing specific programs to meet the intent of the generic letter.
Generic Letter 83-28 was developed following investigations by the NRC on the Salem events. As a result of these investigations, the NRC determined that better control and utilization of information regarding safety related components might have helped to prevent these events. The NUTAC identified a program to-better ensure that plant personnel have timely access to such information.
The NUTAC efforts were guided by the recognition that individual utili-ties have the greatest experience with and are most cognizant of the applica-tion of safety-related equipment. Vendor involvement with such equipment is generally greatest during construction and initial operation of the plant.
Vendors are not familiar with the surveillance or maintenance histories, nor with the application of the equipment or its environment. This type of infor-mation is most readily available at the plant level within individual utili-ties.
Based on this recognition, the NUTAC investigated the mechanisms cur-rently available to facilitate information exchange among utilities. The NUTAC identified four activities that currently address information about i
m DRAFT 2/84 safety-related components. These are routine utility / vendor and utility /
regulator interchange, and the SEE-IN and NPRDS programs managed by INP0.
It was the assessment of the NUTAC that these existing activities, if properly integrated and implemented, would provide a framework for an overall program to ensure effective communication of safety related information among all utilities. Accordingly, the program developed te accomplish this goal (VETIP) utilizes the existing efforts as elements of a more comprehensive program.
The VETIP combines these existing programs, incorporating enhancements, with a coordinated program within each utility. A key element of the VETIP is the development by each utility of an active internal program to contribute information to the NPRDS and SEE-IN programs and to utilize the results of these programs.
The effectiveness ~ of the VETIP will be determined by the level of utility participation in these programs. To implement the VETIP, each utility should assess t'he type of information currently being provided to NPRDS and SEE-IN~
and expand the scope of reporting if appropriate. Additionally, each utility should evaluate current administrative controls for reporting information and for disseminating the results of the NPRDS and SEE-IN programs to the plant level. These administrative controls may require modification to ensure that j- effective coordination is established. Concurrent with these efforts, l -enhancements will be made to both NPRDS and SEE-IN by INP0 within its present institutional objectives.
l The VETIP has been developed-to ensure that nuclear utilities have prompt access to and effective handling of safety-related equipment technical infor-mation.- In addition, it is responsive to the intent of Generic Letter 83-28 Section 2.2.2. Further details are provided in the body of this report.
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, DRAFT 2/84 FOREWORD On February _ 22 and 25,1983, during startups of the Salem Unit 1 plant, both reactor trip breakers (Westinghouse model 08-50) failed to open on an auto-matic trip signal. As a consequence, the Nuclear Regulatory Commission (NRC) formed an investigating task force to determine the factual information perti-nent to the management and administrative controls that should have ensured p proper operation of the trip breakers.- The findings and conclusions of. the task force are documented in.NUREG-0977, "NRC Fact Finding Task Force Report on the ATWS Events at the Salem Nuclear Generating Station," Unit 1, on February -22 and 25,1983". A second task force determined the extent to which these investigative findings were generic in nature. The NRC subsequently issued NUREG-1000, " Generic Implications of ATWS Events at the Salem Nuclear Power Plant" and Generic Letter 83-28, " Required Actions Based on Generic Implications of Salem ATWS Events."
On September 1,1983, a group of utility representatives met at the offices of the Institute of Nuclear Power Operations (INPO) to discuss the establishment of an ad hoc ~ utility group to address issues relative to the NRC Generic Letter 83-28, Section 2.2.2. The representatives decided that such a group could provide direction that would be of generic benefit to the utilities and consequently formed the Nuclear Utility . Task Action Committee (NUTAC) on Generic' Letter 83-28, Section 2.2.2. - The specific charter for the NUTAC (Appendix A) was adopted, anu the target date for completion of activities was established as February 1984.
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.' DRAFT 2/84 TABLE OF CONTENTS Section Pace
- 1. INTRODUCTION ........................................................ 1
- 2. ACRONYMS AND DEFINITIONS.............................................. 2 2.1 Acrcnyms ........................................................ 2 2.2 Definitions...................................................... 3
- 3. Vendor Equipment Technical Information Program (VETIP)................ 5 3.1 Existing Programs....... ......................................... 6 3.1.1 Nuclear Plant Reliability Data System (NPRDS)........... 7 3.1.2 Significant Event Evaluation and Information Network (SEE-IN)................................................ 9 3.1.3 Interaction with Vendors............................... 12 3.1.4 Regul ato ry Reporti ng Requi rements . . . . . . . . . . . . . . . . . . . . . . 14 3.2 Recommended Enhancements to Existing Programs................... 15 3.2.1 Enhancements to NPRDS.................................. 15 3.2.2 Enhancements to SEE-IN................................. 17 3.3 S u mma ry E x a mp l e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 4 IMPLEMENTATION OF VETIP.............................................. 19
.4.1 Responsibilities.for Implementation............................. 19 4.1.1 Utili ty Implementati on Responsi bil i ti es . . . . . . . . . . . . . . . . 19 4.1.1.A Existing Programs...................................... 20 4.1.1.B Enhanced Programs...................................... 22.
4.1.2 INPO Impl ementati on Res ponsi bi l i ti es . . . . . . . . . . . . . . . . . . . 23 l
4.2 Schedule for Implementation..................................... 23' 4.2.1 Existing Programs.s .................................... 23 4.2.2 Enhancements to Existing Programs...................... 23 FIGURES l
Fi gu re 1 - VETIP Bl ock Di a gram. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 Fi gure 2 - Operating Experi ence Revi ew Process . . . . . . . . . . . . . . . . . . . . . . . 26 APPENDIXES APPENDIX A SPECIFIC CHARTER FOR NUCLEAR UTILITY TASK ACTION COMMITTEE ON GENERIC LETTER 83-28, SECTION 2.2.2 APPENDIX B ' LIST OF REFERENCES APPENDIX C SEE-IN FUNCTIONS APPENDIX 0 GENERIC LETTER 83-28, SECTION 2.2.2 iv
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- 1. INTRODUCTION The objective of Generic Letter 83-28, Section 2.2.2 (Appendix 0), is to improve the safety and reliability of nuclear power generating stations by ensuring that the utilities are provided with significant and timely tech-nical information concerning reliability of safety-related components. In a typical nuclear station, hundreds of vendors supply the thousands of components that perform safety-related functions. The variations in vintage and design of plants ensure that although common applications of specific components may exist, there are an equal or greater number of ualque applications. To attain the objective in a cost-effective and efficient manner, this NUTAC has developed the program outlined in this document. This positive program has been found to be the most realistic approach to attain the objective.
The Vendor Equipment Technical Information Program (VETIP) described in this document establishes a more formal interaction among the major organ-izations involved with commercial nuclear power generation. The goal of the interaction is to improve the quality and availability of equipment technical information for use by the utilities. The major components of the VETIP are an information transfer system and a centralized evaluation of industry experiences.
This document provides-the unanimous NUTAC position on the guidelines for an effective technical information program. The determination of each individual utility to support and utilize these guidelines is the key to I the effectiveness of this program for the industry as a whole. The I
program does not require the use of nor prescribe standard administrative procedures, but it allows the use of plant-specific procedures compatible witi- the utility's internal organization and needs. However, the recom-mendations in this document provide the basis for a uniform industry response to NRC questions and requirements relative to a technical infor-mation program. This program will be beneficial to the utilities and, at the same time, it will be responsive to Section 2.2.2 of the NRC Generic Letter 83-28.
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Architect-Engineer AE00 -
Office of the Analysis and Evaluation of Operational Data ATWS - Anticipated Transient Without Scram CFR -
Code of Federal Regulations EPRI -
Electric Power Research Institute ETI -
Equipment Technical Information IE3, IEN - Inspection and Enforcement Bulletins and Notices, issued by the NRC IEEE -
Institute of Electrical and Electronics Engineering INP0 - Institute of Nuclear Power Operations LER - Licensee Event Report, issued by a utility MOR - Monthly Operating Report NPRDS - Nuclear Plant Reliability Data System NRC - Nuclear Regulatory Commission NSAC - Nuclear Safety Analysis Center NSSS - Nuclear Steam Supply System NUTAC - Nuclear Utility Task Actipn Committee 0&MR -
Operations and Maintenance Reminder PRA -
Probabilistic Risk Assessment l QA - Quality Assurance SEE-IN - Significant Event Evaluation and Information Network SER - Significant Event Report SOER - Significant Operating Experience Report VETIP - Vendor Equipment Technical Information Program i
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DRAFT 2/84 2.2 Definitions Component - A component is a mechanical or electrical assembly _ (including instruments) of intercon-nected parts that constitute an identifiable device or piece of equipment. Examples of electrical components include a drawout circuit breaker, a circuit card, instruments, or other subassemblies of a larger device that meet this definition. Examples of mechanical components include valves, piping, pumps and pressure vessels, and associated prime movers and/or operators.
Equipment Technical Information (ETI) - For the purposes of this report, this term includes, es a minimum, the following docu-mentation:
o vendor-supplied engineering and technical information (drawings, uanuals, etc.) and changes thereto o equipment qualification data (provided by the equipment vendor or qualification lab) l o industry-developed information, including
- utility and NRC-originated information j (NPRDS,SER,IEB,IEN,etc.)
NU('. EAR NETWORK - An information service provided through INPO.
(NUCLEAR NETWORK replaced NUCLEAR NOTEPAD.)
NUREG - Guidance documents issued by the NRC.
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DRAFT 2/84 Safety-Related -
Safety-related structures, systems, and components are those relied upon to remain functional during and following design basis events to ensure (1) the integrity of the reactor coolant pressure 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 consequencesJof accidents that could result in potential off-site exposures comparable to the guidelines of 10 CFR Part 100.
Vendor - For the purposes of this report, this term is used to identify the manufacturer of the com-ponent concerned and/or those who provide the related equipment technical information.
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- 3. VENDOR EQUIPMENT TECHNICAL INFORMATION PROGRAM (VETIP) DESCRIPTION The VETIP includes interactions among the major organizations involved with commercial nuclear power generation. As illustrated in Figure 1, a utility exchanges safety-related equipment information with vendors, NRC, INP0 and other utilities via reports, bulletins, notices, newsletters, and meetings. The purpose of these information exchanges is to share equip-ment technical information to improve the safety and reliability of nuclear power generating stations. The NUTAC concluded that the lack of information is not a problem, but that the various information systems available are not integrated properly. The purpose of VETIP is to ensure that current information and~ data will be available to those personnel responsible for developing and maintaining plant instructions and pro-cedures. These information-systems and programs currently exist and are capable of identifying to the industry precursors that could lead to a Salem-type event. VETIP. is an industry-controlled and mainly hardware-oriented program that does not rely on vendor action, other than the NSSS supplier, to provide information to utilities. Instead, VETIP provides information developed by industry experience through SERs and SOERs to the vender for comment before it is circulated to the utilities concerned.
The majority of information provided by vendors is commercial in nature.
This usually is provided voluntarily by the vendor, but does little to improve the safety or reliability of existing equipment.
- A vendor-oriented program to provide information that would improve the safety and reliability of existing equipment relies on the vendor having an internal program to develop the information. Such programs typically are not in existence. Following desigr. and qualification testing, vendors l_ normally do not continue extensive testing or engineering programs in i anticipation of equipment problems. Subsequent failures discovered during l operations require several steps to complete the information feedback loop. For_ example, when a problem occurs and a local vendor represen-tative provides a solution, he would have to provide that information to the vendor headquarters. Then, the headquarters would need a tracking program to identify a trend and subsequently a program to provide the information to the industry. In addition, the vendor often is not in the l~
DRAFT 2/84 best-position to analyze the failure. The vendor is not always aware of the ci.mponent's application and environment nor its maintenance and sur-
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veillance history.
The VETIP recognizes that-the utility user is in a unique position. The utility user alone has immediate access to the maintenance and surveil-Llance history.of the equipment. The utility, not the manufacturer, knows the component's actual application and environment. The utility is the primary source of information on the failure, and the utility has the greatest need for the solution. As such, the utility is the central organizer in any approach to the solution, whether or not the manufacturer- ,
gets involved.- The utility is in the position to know of the failure analysis and its solution at the earliest possible time. The utility can then disseminate the information to other utilities, with an indication of its significance and urgency.
By sharing the operating history, problems, and solutions within the i
, nuclear industry . independent of-any normal vendor contacts, the other users will, be informed in a much more timely and uniform way. In this way,.the distribution of information is controlled entirely by the nuclear
-utility industry. The programs which comprise the VETIP are currently in existence. The recommended enhancements contained wi hin this report are suggested ways to improve the current use and application of these. exist--
ing programs. -
3.1 pxistingPrograms The existing systems and programs included in the VETIP cre the Nuclear Plant Reliability Data System (NPRDS[ and the Significant Event Evaluation and Information Network (SEE-IN), both managed by INPO.- Also, the-VETIP includes existing programs that the utilities h now conduct with vendors and other sources of ETI, particularly the p NSSS vendor interaction programs and the NRC reporting programs that disseminate significant failure information. Utility-vendor inter-action is further enhanced by the INP0 supplier participant practices.
p Through participation in this program, NSSS vendors and A/E fhs are working toward great'er participation in the NPRDS and SEE-IN programs.
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DRAFT 2/84 3.1.1 Nuclear Plant Reliability Data System (NPRDS)
NPRDS is an industrywide system managed by INP0 for monitoring the performance of selected systems and components at nuclear power plants. INPO member utilities have agreed to partici-
.pate in the program. U.S. plants in commercial operation (except for six atypical, early vintage units) supply basic engineering information and subsequent failure data on the selected systems and components.(typically six to seven thou-sand components from some 30 systems per unit). The value of NPRDS lies in the ready availability of this data base to operation and engineering groups for a broad range of applica-tions. The criteria used to determine the scope of NPRDS reports are as follows:
o systems and components that provide functions necessary for accident mitigation o systems and components for which loss of function can initiate a significant plant transient Uniform scoping and repcrting criteria are set forth in the Nuclear Plant Reliability Data System (NPRDS) Reportable System and Component Scope Manual (INP0 83-020) and in the Reporting Procedures Manual for the Nuclear Plant Reliability Data System.
To support the benefits that can be obtained from NPRDS usage, utilities submit three kinds of information to the NPRDS data
-base: engineering / test information, failure reports, and
, operating history. .The engineering / test record on a component contains information necessary ta identify the component and
'its application, such as manufacturer, model number, operating l- environment, size, horsepower, and test frequencies. The
! information is submitted when the component is placed in service and is stored in the data base. If that component fails to perform as intended, a report is submitted containing a description of the failure mode and cause, the failure's effect on plant operations, corrective actions taken, and other DRAFT 2/84
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-information necessary to essess the failure. On a quarterly basis,- utilities submit information ' the number of hours the plant is in different modes of operation. This information is used in conjunction with the engineering and failure reports to generate failure statistics for systems and ccmponents.
The data is retrievable from a computer, and the engineering and failure information can be combined in various ways. A search of the failure records can identify problems experi-enced with components in other plants and the corrective actions taken. There are several hundred searches of the data base in a typical month. Following are some example uses of the data base:
Utility and plant Staffs o accessing comprehensive equipment history files to support maintenance planning and repair o avoidance of forced or prolonged outages by identifying
. other plants with similar or identical equipment that may have spares.for a possible loan o determination of spare parts stocking, based on industry mean time between failures o comparison of component failure rates at a given plant with the industry average failure rates Design Groups o identification of common failure modes and causes o selection of vendors based on component application and i' performance
- o identification of component wearout and aging patterns o -studies of component performance as a function of operating characteristics, such as test frequency and operating envi ronment o input to plant availability improvement programs
I DRAFT 2/84 Operating Experience Reviewers o identification of significant failure modes affecting safety or availability o trending of component failure rates o development of failure probability estimates for use in fault tree analyses (reliability or PRA studies) -
NPRDS data is available to users through various quarterly and annual summary reports and through on-line access of the data from a computer terminal.
3.1.2 Significant Event Evaluation and Information Network (SEE-IN)
Since the early days of nuclear power plant operations, utili-ties and manufacturers have attempted to share what has been learned from plant operating experience. As nuclear tech-nology becomes more complex and more demanding, the need for sharing operating experience continues to grow and becomes
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more important. The safety benefits of avoiding problems already encountered and resolved more than justifies the costs and extra' effort required for utilities to keep each other informed. The Nuclear Safety Analysis Center (NSAC), with the support of its utility advisory group, began developing a program to share information learned from analyzing nuclear plant experiences. Shortly after its formation in late 1979, the Institute of Nuclear Power Operations (INPO) joined NSAC in the development and implementation of the program. The program has been named "Significant Event. Evaluation and Information Network" (SEE-IN). In 1981, the management of the
! SEE-IN program became the sole responsibility of INPO.
Objective The objective of SEE-IN is to ensure that the cumulative learning process from operating and maintenance experience is effective and that the lessons learned are reported in a timely manner to improve plant safety, reliability, and avail-ability. This objective is met by screening available nuclear
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plant event information systematically, identifying and evalu-ating the important or significant events, and communicating the results to the utilities and appropriate designers and manufacturers.
Scope The functional approach to SEE-IN is an eight-step process outlined in Appendix C. While INPO has the program management function, no single organization is responsible for performing all of these functions; eather, the responsibility is spread
, among key participants in the network. The principle organi-zations involved in the initial screening of plant event data are the utilities and INP0. Each nuclear utility has an in-house program to screen events that occur in its nuclear plant (s). INPO has a broader charter to screen all nuclear plant events. The sources of input to the screening process include NPRDS, NUCLEAR NETWORK, NRC-mandated reports, IEBs,
'IENs,'etc. The provision to control the data normally is-governed by agreements between INP0 and the supplying organi-zation (e.g., utilities, NRC, NSSS vendors, international participants,etc.). When a significant event or trend has been identified from the screening process, a Significant Event Report (SER) is prepared by INPO and transmitted to the r
utilities and other participants on NUCLEAR NETWORK. This l event then undergoes an action analysis by INP0. .The purpose of the action analysis is to investigate the event or trend in l
( more detail and to develop and evaluate practical remedies.
I .For events requiring utility action, the results of the action analysis are communicated to the utilities, normally in the form of a Significant Operating Experience Report (SOER). In these instances, recommendations are made to resolve the
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- underlying problems. The implementation of applicable recom-l mended remedial actions is the responsibility of the individ-L ual utility. Implementation may include changes in plant procedures, equipment design, and/or operator training pro-grams. The two final steps in the SEE-IN process are (1) l.
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feedback and evaluation of actions taken by the utilities as a result of information provided through SEE-IN and (2) periodic assessment of the process effectiveness by INP0.
The SEE-IN program provides copies of draft SERs and SOERs to the affected vendors for review. Vendor comments are.consid-ered in preparation of final SEE-IN reports. Once finalized, the reports are sent to the utilities.
The SEE-IN program includes a cross-reference capability to identify SERs, SOERs, LERs, etc. which report component
. problems that could cause a significant event. This cross-reference facilitates utility review of the component's prior *
. history before using that component in a safety-related appli-cation. .
Program Operation Plant operating experience data is reviewed from several perspectives including design, component and system perfor-mance, plant procedures, human factors, personnel training, maintenance and testing practices, and management systems to identify significant events and trends.
Fornal Review Sources A formal review is conducted on NRC information notices,-
- j. bulletins, AE00 reports, event-related generic letters, etc.
A formal review also is conducted on industry-prepared infor-j mation (including those required by NRC) such as LERs, monthly operating reports, NRC event-related reports, NSSS technical bulletins, NPROS data, NUCLEAR NETWORK operating experience entries, international operating experience reports, construc-tion-deficiency reports, safety defect reports, and trends identified as significant in the INPO NPRDS and LER data
[ bases. The formal review includes a dual, independent screen-ing process. The review status is documented and tracked by computer.
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,, DRAFT 2/84 Other sources of operating experience information are used by the SEE-IN prog.am on an ad hoc basis as reference or supple-mental material but do not receive a formal review. The sources include such items as NRC.NUREG documents, EPRI and NSAC reports, and other industry reports or data concerned with plant operating experience. The INP0 process for screening is shown in Figure 2.
Utility Contact (SEE-IN)
In addition to the formal and reference information sources, another vital information source is direct contact with power L' plant techn'ical personnel on an ad hoc basis. Each utility designates a SEE-IN contact to respond to questions from INPO on plant events. The majority of such communications is handled over the telephone or via NUCLEAR NETWORK. Files are maintained by INP0 on nuclear utilities and contain names and telephone numbers of designated contacts, telecopier numbers, status of nuclear units (i.e., operating, under construction .
or planned) and NSSS vendor (s).
3.1.3 Interaction With' Vendors-In the interest of operating the plant safely and efficiently, the utility-vendor contact is essential. To accomplish this goal, utilities already interact with various vendors.
The contractual obligations for furnishing equipment and software (manuals, drawings, etc.) are fulfilled upon accep-tance at the plant site. Interaction between utilities and vendors due to deficiencies may be brought about by the reporting requirements of 10CFR21 and 10CFR50.55(e). The con-tinuing contract with vendors for warranty obligation 3 or maintenance work are two examples of active interaction after an initial purchase. - In addition, much of the interaction with the vendors during plant life is initiated in response to 1
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DRAFT 2/84 significant fail'ures, to failure trends experienced at the plant, to spare parts procurenent, or to subsequent purchase orders of new equipment.
The interaction with the NSSS vendor, who typically supplies a large portion of the safety-related, plant equipment, is gener-ally more active than with the other vendors. There are existing channels through which the NSSS suppliers disseminate information of interest to their client utilities. These include the following:
o In regular meetings, NSSS representatives outline recent developments and maintenance / design recommendations. Any special concerns of the utility can be addressed jn follow-
.up correspondence with the NSSS supplier's service depart-ment.. ,
o Bulletins or advisories from the NSSS supplier's service
-department alert client utilities. to special problems experienced by similar plants. Typically included in this correspondence are a descriptica of the problem and the corrective actions taken to resolve it. Recommendations for preventive actions or for particular cautions to be considered by the utility usually are included.
o Owners groups provide an additional forum for the exchange
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I of information that may be of generic interest to member utilities. For example, problems in the design or oper-ation of a system or component may be shared with the group
- and potential resolutions identified. 'The owners groups' efforts often are directed at seeking improvements or anti-L cipating problerrs rather than being only reactive in nature, f Improvements in availability or testing and maintenance procedures are examples of positive results that have come about through owners groups activities. The NSSS supplier l
rr.akes his broadly-based knowledge available to the group for the specialized evaluations that may be required.
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. 7./84 ORAFT 3.1.4 Regulatory Reporting Requirements Other existing sources of information are the documents that result from the NRC's reporting requirements. These documents include 10CFR21 reports, 10CFR50.55(e) reports, Licensee Event Reports, and NRC Inspection & Enforcement (IE) Bulletins and Information Notices. 10CFR21 specifies reporting requirements relating to component or system deficiencies that may create a substantial safety hazard. This reporting provices the nuclear utility industry notification of significant noncom-pliances and defects identified by other utilities, architect-engineers, constructors, vendors, and manufacturers associated with nuclear facilities.
10CFR50.55(e) requires that the holder of a construction permit notify the NRC of each deficiency found in design and construction, which were it to remain uncorrected, could affect the safe operation of the nuclear power plant adversely.
10CFR50.73 requires the holder of an operating license for a nuclear power plant to submit a Licensee Event Report (LER)
These LERs are incor-for events described in 50.73(a)(2).
porated into the INPC LER data base which provides information to identify and isolate precursor events and identify emerging trends or patterns of potential safety significance.
l The NRC Office of Inspection and Enforcement (IE) issues various documents, including bulletins and information f
notices, to inform licensees and construction permit holders of significant concerns that may result from the NRC evalua-tion of reports, as required by 10CFR21.21, 50.55(e), and
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50.73. ~These documents provide the nuclear utilities with information on events and concerns that are considered sig-nificant by the NRC.
' 3.2 Recommended Enhancements to Existing Programs The following are recommended enhancements to the existing programs. INPO and the NPROS Users Group should investigate the feasibility of these recommendations. If found feasible, an implementation program should be developed.
3.2.1 Enhancements to NPROS o The present definition of component in NPRDS (extracted from IEEE 603-1980) is more applicable to electrical components. - The definition should be improved to describe 4
mechanical components b,etter.
o The present failure reporting guidance needs improvement in the following areas:
-- - Guidance is needed to provide better information for analyzing the role of piece parts as a factor in caus-
< ing component. failures.
-- The guidance should be revised to indicate that utilities should supply information when inadequate 4 vendor information is~ identified as a causal or contributing factor-in a failure. The guidance should provide users of the data base the ability to readily retrieve those failures involving inadequate vendor
' information (example, key-word sorting, coding).
-- Present failure reports are often sketchy in providing details of tne failure analysis conducted by utti-ities. The guidance should emphasize the importance of providing more complete results of failure analysis when one is conducted. Although detailed failure
~ analyses are' not always conducted for every failure,
,- --.-_.-__,s_-.. . . . _ . _ , . . _.._ -.-... .--_. _ -
DRAFT 2/84 when they are conducted they should be provided in NPRDS failure reports. In this way, the SEE-IN program and other utilities can derive more benefit from the work of each utility.
o Utilities should develop internal methods to ensure that their NPRDS reports are clear and complete and that the
, program guidance is followed appropriately.
o For some failures it may not be possible for utilities to provide a complete failure description within the time frames for reporting to NPRDS. Utilities should still submit preliminary failure reports within the established time frame. Utilities should revise these reports when the necessary information is available. However, the present system does not provide methods for utilities to indicate that reports will be revised later. NPRDS should be modified to permit each utility to readily identify which
, of their reports still requires follow-up information.
Utilities should report a failure event promptly and include an initial analysis. Detailed and complete infor-mation should be provided in a timely manner once final analysis has been completed, o The present scope of NPRDS reporting may not meet all the needs of individual utilities for monitoring the relia-bility of their own safety-related components. Each utility that decides that additional systems and components should be added to their basic scope of NPRDS systems and components should request that INP0 accept thase systems.
INP0 will consider these requests, identify the additional resource requirements needed to handle these requests, and notify utilitief when it is able to accept additional information.
DRAFT 2/84 3.2.2 Enhancements to SEE-IN o Reports should be generated for potential failures caused by faulty or missing vendor-supplied information or other ETI. The VETIP recognizes that the utility will uncover errors in ETI (e.g., during review of the information,
, writing of instructions, testing, etc.) before anyone else. -It is recommended that ETI faults be reported over NUCLEAR NETWORK for review by INPO under the SEE-IN
. program.
o - The SEE-IN program should be broadened by INP0 to improve the ability to trend NPRDS data. Present methods of trend-ing are largely qualitative and subjective in nature. They depend largely on the ability of analysts to recognize the
~
need to look for. degrading or unacceptable system and com-ponent reliability. INP0 should develop methods to use NPRDS in a more quantitative fashion to detect trend prob-lems. This enhancement is presently under development by ,
INPO.
3.3 Summary Example One problem that led to the Salem event was that the information con-tained in the NSSS vendor technical bulletin (issued in 1974) was not processed appropriately and therefore not incorporated into plant procedures. If the systems which comprise the VETIP were functional in the early 1970s, this oversight probably would not have occurred or would have been rectified. Westinghouse had prepared the tech-nical bulletin based on a precursor event that occurred at another nuclear unit. This-type of precursor event would have required that an LER be written and submitted to the NRC. At the same time, an NPRDS failure report would have been subritted to the INPO data base. .INPO also would have reviewed the Westinghouse technical bulletin and the LER. The current criteria for significance screen-ing used by-INP0 personnel identify this type event as a significant single failure. It is highly likely that an SER would have been generated by INP0 and disseminated to utilities via NUCLEAR NETWORK.
., .. . - ~, - - .- . - - . - . . _ - . - . - -
DRAFT 2/84 9
Utilities would have reviewed the SER through their Operating Experience Report review programs.
In addition, utilities would have had an ongoing program with their NSSS vendors to obtain ETI. Utilities would have had systems in place to track and process this information. Therefore, there are two pathways which would have ensured this type of information was received and evaluated by the utility:
o NPRDS/SEE-IN (SERs, SOERs) o NSSS vendor technical bulletins The utility's' VETIP procedures would have assessed this information and effected positive action to correct the failed component.
-, - n -
DRAFT 2/84
. 4 IMPLEMENTATION OF VETIP 4.1 Responsibilities For Implementation 4.1.1 Utility Implementation Responsibilities 4.1.1.A Existing Programs o NSSS Vendor Contact Each utility should have with its NSSS supplier, a program in place to obtain technical information.
This program consists of a technical bulletin system and necessary direct contact with the NSSS supplier.
o NPROS/SEE-IN Each utility should indicate or reaffirm its active participation in the NPRDS and SEE-IN programs. The utility should supply the necessary basic information and should report failures and problems on a timely basis. Adequate internal controls should be in place to ensure that this activity is timely, consistent, and controlled and should include incorporation of future revisions to these programs.
o Other Vendors Each utility should' continue to seek' assistance and ETI from other safety-related equipment vendors when the utility's evaluation of an equipment or ETI problem concludes that such direct interaction is necessary or would be beneficial . These problems and those of lesser significance will continue to be reported by means of the NPRDS and/or the SEE-IN programs.
DRAFT 2/84 o Internal Handling of Equipment Technical Information The utility should process incoming ETI so the objectives noted below are achieved.
Administrative procedures should provide control of incoming ETI whether it arrives directly from the vendor or from other industry or regulatory sources (i.e., NUCLEAR NETWORK, NPRDS, SEE-IN, NRC bulletins, etc.),
so it receives the appropriate engineering / technical review, evaluation, and distribution for the following:
prompt warnings to key personnel timely incorporation into maintenance or operating procedures, equipment data / purchasing records, and training programs future procedure review and revision cycles notification on NUCLEAR NETWORK of significant ETI The incorporation of such safety-related information (or changes) remains within the scope of the utility's review and approval requirements.
The administrative program should require that maintenance or operating procedures cite appropriate ETI in the reference section of the procedure.
ORAFT 2/84
- -- Within the performance section of the procedure, appropriate ETI should be incorporated and approved in the engineering, technical and quality review of the safety-related procedure.
o Internai Handling of Vendor Services The vendor, contractor or technical representative who will perform safety-related services should be an approved / qualified supplier of such nuclear safety related services. Furthermore, the services should be specified in the procurement o- documentation so that, depending on the circum-stances, a combination of the following controls are established:
The service is performed using utility procedures that have been approved after a technical and quality review cycle typical for other utility service, maintenance, repair, or operating procedures.
-OR-The service is performed using the vendor, con-tractor or technical representative procedures that have been reviewed and approved in accordance with utility procurement program, QA program, and administrative review program so that their docu-ments are processed and approved in a manner equivalent to the utility procedures concerning similar activities.
-AND-
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9 DRAFT 2/84
-O The activity will be performed under the cognizance of the utility QA/QC program.
-OR-The activity will be performed under the cog-nizance of the vendor, contractor or technical representative QA/QC program that has been reviewed separately and approved in accordance with the utility QA program. In addition, during the performance of the service, the utility QA program will monitor the effectiveness of their performance and compliance with its approved program by suitable surveillance, inspection and audit.
s In addition to the above, ETI provided in conjunc-tion with performance of vendor services should be handled as described above.
4.1.1.B Enhanced Programs o NPRDS Each utility should incorporate the enhancements to the NPROS recommended in Section 3.2. This could involve revisions to existing administra-tive programs or procedures. It also could require revised training or other actions-needed to ensure a meaningful and effective implementa-tion of the NPROS program enhancements.
o SEE-IN Each utility should incorporate the enhancements to the SEE-IN program recommended in Section 3.2. As in the NPRDS program, this could involve L revisions to existiag administrative programs or
- l. . procedures or to training or other activities so l
4 I
DRAFT 2/84
. the data reported to the SEE-IN program is complete and detailed enough to support the system enhancements being undertaken by INPO.
4.1.2 INPO Implementation Responsibilities o Existing Programs The NUTAC determined that present NPT.0S/SEE-IN programs, properly used, currently provide an adequate framework for the effective exchange of information.
o Enhanced Programs INPO should implement the enhancements of the NPRDS and SEE-IN programs (noted in Section 3.2) to augment this VETIP.
4.2 Sr.hedule for Implementation 4.2.1 Existing Programs Utilities that find that their existing internal program and
, procedures do not support those outlinea in Sections 3.1 and 4.1.1.A above should make the necessary timely revisions as part. of the established review and updating cycle for such documentation. A specific schedule should be established by the individual utility with a target date for full implementation by 1/1/85.
4.2.2 Enhancements to Existing Programs
-4.2.2.A INP0 should work with the NPRDS users group with the goal of establishing schedules by July 1,1984, for implementation of the enhancements of the NPRDS program.
4.2.2.B Utilities should incorporate the enhancements to the NPRDS and SEE-IN programs, recommended in Section 3.2 and 4.1.1.B above into their internal program and procedures on a timely basis.
_ . . _. _ _ ~ _ . . _ ,
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DRAFT 2/84 i t
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4.2.2.C Schedules should be established which'are consistent '
with an overall goal to implement the rec'omended enhancements to both programs by January 1,1986, e
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Figure 2
_i..
DRAFT 2/84 APPENDIX A SPEC!FIC CHARTER FOR NUCLEAR UTILITY TASK ACTION COMMITTEE ON GENERIC LETTER 83-28, SECTION 2.2.2
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6 i i u a is a
. l APPENDIX A j
, SPECIFIC CHARTER FOR i NUCLEAR UTILITE TASK ACTION COMMITTEE l CN GENERIC LETTER 83-28, ,
1 SECTICN 2.2.2 This Nuclear Utility Task Action Ccmmittee (NUTAC) has been established by a group of utility representatives who have reccg-nized a need for nucisar industry guidance on Generic Letter 83-28, Section 2.2.2. The establishment.of this NUTAC has been in accordance with the general charter governing the organization and operation of a NUTAC, as approved by the Institute of Nuclear Pcwor Operations (INPC) Board of Directors. This NUTAC is ccm-mitted to ecmpliance with this specific charter, its bylaws, and the general charter. This charter has been reviewed and approved by the chairman of the Analysis and Engineering Division Industrf Review Group and the president of INPO, and the president of INPO authorizes staff support for this NUTAC.
This ccamittee has adopted the fo11cving objective to ensure fulfillment of the goal of achieving induserf consensus and guid-anca on Generic Letter 83-28, Section 2.2.2.
o development' of guidance for use by utilities in response to Generic Letter 83-28, Section 2.2.2 To ensure that this objective results in pecducts that are of generic benefit to the utilities, voting membership en this ccm-mittee is limited to per=anent empicyees of U.S. nuclear utili-ties. The chairman and vice chairman of this ccamittee will be i permanent empicyees of U. S. nuclear utilities and will be l elected by the NUTAC f cm a list of candidates approved by the l
chairman of the sponsoring IRG. To further ensure that this i NOTAC provides products that are of generic benefit to utilities, the NOTAC chairman will :r.aintain close liaison with the sponscr-l ing INPC Industry Review Group. .
l l
Additionally, this NUTAC shculd establish liaisen with other l recognized industrf grcups, such as AIF, ANS, EEI, EPRI, and NSSS owners groups and will maintain ecmmunication en this induserf initiative with the NRC, as appropriate.
1 Approved: /> ,,// L7 8 Chairman, . h I Chairmani NUTAC # '
Cate IRC- Date Al-M L ww"E% % m vice Chairman, suTAC 4arte Prestcent, INPQ du/ss Oate i A-1 ,
l
9 (
ORAFT 2/84 APPENDIX B LIST OF REFERENCES m ie i i i .
DRAFT 2/84
- . APPENDIX B List of References
- 1. NRC Generic letter 83-28 dated July 8,1983 Required Actions Based on Generic Implications of Salem ATWS Events
- 2. NUREG 0977 - NRC Fact-Finding Task Force Report on the ATWS Events at Salem Nuclear Generating Station Unit 1 on' February 22 and 25,1983
- 3. NUREG 1000 - Generic Implications of ATWS Events at the Salem ' . ' lear Power Plant
- 4. Significant Event Evaluation and Information Network (SEE-IN) Program Description (INP0 83-001)
- 5. Nuclear Plant Reliability Data System (NPRDS) Reportable System and
' Component Scope Manuai (INP0 83-020)
- 6. Reporting Procedures Manual for the Nuclear Plant Reliability Data System
- 7. 10CFR21 - Reporting of Defects and Noncompliance
- 8. 10CFR50 - Domestic Licensing of Production and Utilization Facilities 9 .' IEEE 603-1980 - Standard Criteria for Safety Systems for Nuclear h Generating Stations I
l-I l'
l-l l B-1 I
~ .
k j ORAFT 2/84 4
APPENDIX C SEE-IN FUNCTIONS 9
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s , . . . _ _ , . . . - _. . _ , _ _ , _ _ - - - . - - , _ , . . _ _ _ _ _ _ _
DRAFT 2/84 APPENDIX C SEE-IN Functions
- 1. Pro <ide basic report of plant event. (utilities)
- 2. Screen events for significance and transmit Significant Event Reports (SERs) via NUCLEAR NETWORK. (utilities and INPO with s ' dor input soli-cited when specific product is identified)
- 3. Provide backup data on contributing factors and probable causes and con-sequences. (utilities and vendors) 4.. Perform action analysis on significant events to evaluate possible options for short-term remedies and feasible long-term solutions that might be implemented. (utilities, INPO, and vendors)
- 5. Disseminate information, along with an alert of potential implication, to the utilities. (INPO)
- 6. Evaluate the information and implement remedits as appropriate. (utili-ties)
- 7. Provide feedback on implementation actions. (utilities and INPO)
- 8. Evaluate periodically the effectiveness of the process, including steps 1-7 above. (INP0)
C-1
DRAFT 2/84 APPEN0lX D NRC GENERIC LETTER 83-28 SECTION 2.2 i
f
If %, UNITED sT TEs II '% NUCLEAR 8EGULATORY COMMISSION
! I wasm= atom. o. c. zossa
( ..., ,f July 8, 1983 TO ALL LICENSEES'0F OPERATING REACTORS, APPLICANTS FOR OPERATING LICENSE, AND HOLDERS OF CONSTRUCTION PERMITS Gentlemen:
SUBJECT:
REQUIRED ACTIONS BASED ON GENERIC IMPLICATIONS OF SALEM ATJS EVENTS (Generic Letter 83-28)
The Commission has recently reviewed intermediate-tens actions to be taken by .
licensees and applicants as a result of the Salem anticipated transient without
. scram (ATWS) events. These actions have been developed by the staff based on
- infonnation contained in NUREG-1000. " Generic Implications of ATJS Events at the Salen Nuclear Power Plant." These actions address issues related to reactor trip system reliability and general management capability.
The actions covered by this letter fall into the following four areas:
- 1. Post-Trip Review - This action addresses the program, procedures and data collection capability to assure that the causes for unscheduled
,- reactor shutdowns, as well as the response of safety-related equipment, are fully understood prior to plant restart.
- 2. Equipment Classification and vendor Interface - This action addresses the programs for assuring that all components necessary for accomplishing required safety-related functions are properly identified in documents, 7 procedures, and infonnation handling systens that are used to control
~~
safety-related plant activities. In addition, this action addresses the establishment and maintenance of a program to ensure that vendor information for safety-related components is complete.
- 3. Post Mair.tenance Testing - This action addresses post-maintenance operability testing of safety-related components.
4 Aeactor Trip System Reliablity Improvements - This action is aimed at assuring that vendor-reconunended reactor trip breaker modifications and associated reactor protection system changes are completed in PWRs, that a comprenens-ive program of preventive maintenance and surveillance testing is implemented for the reactor trip breakers in PWRs, that the shunt trip attachneat activates automatically in all PWRs that use circuit breakers in their reactor trip system, and to ensure that on-line functional testing of the reactor trip system is perfonned on all LWRs.
D-1 830708o169
1Due enclosure to this letter breaks down these actions into several components.
You will find that all actions, except four (Action 1.2, 4.1, 4.3, and 4.5) ,
require sof tware (procedures, training, etc.) changes and/or modifications and do not affect equipment changes or require reactor shutdown to complete.
Action 1.2 may result in some changes to the sequence of events recorder or
. existing plant computers, but will not result in a plant shutdown to implement.
Actions 4.1, 4.3 and 4.5.2, if applicable, would require the plant to be shutdowi in order to implement.
The reactor plant designs.trip All system is fundamental to reactor safety for all nuclear power transient and accident analyses are .
successful operation to assure acceptable consequences. predicated Therefore, on theits actions listed below, which relate directly to the reactor trip system, are of the highest priority and should be integrated into existing plant schedules first. .
1.1 Post-Trip Review (Program Description and Procedure) 2.1 Equipment Classification and Vendor Interface (Reactor Trip System Cmaponents) 3.1 Post-Maintenance Testing (Reactor Trip System Components) 1 4.1 Reactor Trip System Reliability (Vendor-Related Modifications)
- 4.2.1 and 4.2.2 Reactor Trip System Reliability (Preventive Maintenance and Surveillance Program for Reactor Trip Breakers) 4.3 Reactor Trip System Reliability (Automatic Actuation of Shunt-trip Attachment for Westinghouse and 88W plants)
Most ofsystems.
related the remaining intermediate-term actions concern all other safety-
!~ These systems, while not sharing the same relative importance to safety as the reactor trip system, are essential in mitigating the conse-quences of transients and accidents. Therefore, these actions should be integrated into existing plant schedules over the longer-tenn on a medium priority basis.
Some of the actions discussed in the enclosure will best be served practical.
by Owners' .
Group participation, and this is encouraged to the extent Accordingly, pursuant to 10 CFR 50.54(f), operating reactor licensees and l
applicants for an operating license (this letter is for information only
- for those utilities that have not aootiec for an ooeratino license) are requesteo to furnisn, unoer oatn ano affirmation, no later enan 120 days from the date of this letter, the status of current conformance with the positions ,
contained herein, and plans and schedules for any needed improvements for conformance with the positions. The schedule for the implementation of these improvements is to be negotiated with the Project Manager.
I D-2 I
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1
. Licensees and applicants may request an extension of time for submittals of the required infonnation. Such a request must set forth a proposed schedule and justification for the delay. Such a request shall be directed to the Director Division of Licensing, NRR. Any such request must be submitted no later than 60 days from the date of this letter. If a licensee or applicant does not intend to implement any of the enclosed items, the response should so indicate and a safety basis should be provided for each item not intended to be impl4mented. Value-impact analysis can be ased to support such responses or to argue in favor of alternative positions that licensees might propose.
For Operating Reactors, the schedules for' implementation of these actions shall be developed consistent with the staff's goal of integrating new requirements, considering the unique status of each plant and the relative safety importance of the improvements, combined with all other existing plant progr&ms. There fore, schedules for implementation of these actions will be negotiated between the
- NRC Project Manager and licensees.
For plants undergoing operating license review at this tima, plant-specific schedules for the implementation of these requirements shall be developed in a manner similar to that being used for operating reactors, taking into c.insideration the degree of completion of the power plant. For construction permit holders not under OL review and for construction pennit applicants, the requirements of this letter shall be implemented prior to the issuance -
o!L an operating license.
This request for information was approved by the Office of Management and Budget under clearance- ntsnber 3150-0011 which expires April 20, 1985.
Comments on burden and duplication may be directed to the Office of Management and Budget, Reports Management Room 3208, New Executive Of fice
.Ru11 ding , Washington, D. C. 20503.
Sincerely, MNN Darrell G. 'Eisennut, Director LL Division of Licensing
Enclosure:
Required Actions Based on Generic Implications of Salem ATJS Events D-3
2.2 EQUIPMENT CLASSIFICATI0M AND VENDOR INTERFACE (PROGRAMS FOR alt.
SAFETY RELATED COMPONENTS) ,
Position t.icensees and applicants shall submit, for staff review, a description of their programs for safety-related* equipment classification and vendor interface as described below:
- 1. For equipment classification, licensees and applicants shall describe their program for ensuring that all components of safety-related systems necessary for accomplishing required 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. This description shall include:
- 1. The criteria for identifying components as safety-related within systems currently classified as safety-related.
This shall not be interpreted to require changes in safety classirication at the systems level.
- 2. A description of the information handling system used to ,
identify safety-related components (e.g., computeri:ed equipment list) and the methods used for its development and validation.
- 3. A description of the process by which station personnel
. use this information handling system en determine tnat an activity is safety-related and.wnat procedures for main-tenance, surveillance, parts replacement and other activities defined in the introduction to 10 CFR 50, Appendix ti, apply to safety-related components.
- 4. A description of the management controls utili:ed to verify that the procedures for preparation, validation and routine utilization of the information handling system have been followed.
- 5. A demonstration that appropriate design verification and qualification testing is specified for pec'curement of safety-related components. The specifications snall incluce quali-fication testing for expected safety service conditions and provide support for the licensees' receipt.of testing documen-tation to support the limits of life recoussended by the supplier.
=saf ety-relateo structures, systems, and components are those that are relied upon to remai'n functional during and following design basis events to ensure:
(1) the integrity of the reactor coolant boundary, (2) the capability to snut down the reactor and maintain it in a safe shutcown condition, and (3) Ene capability to prevent or mitigate the consequences of accidents that ceuld result in potential offsite exposures comparable to the guidelines of 10 CFR Part 100. D-4
-.8-t
- 6. 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").
- 2. 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 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 (GCC-1). The program shall be closely coupled with action 2.2.1 above (equi pnent 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 positiv'e feedback with vendors for mailings containing technical information. This could be accompitsned by. licensee acknowledgment for receipt of tecnnical mailings. It shall also define the interface and division of responsibilities among the licensee ano the nuclear and nonnuclear divisions of their vendors that provide service on safety-related equipnent to assure that requisite control of
. and applicable instructions .for maintenance wort on safety-related equipment are provided.
Acolicabili ty ,
This action applies to all licensees and OL applicants.'
Type of Review For licensees, a post-implementation review will be conducted. NRR will perform the review and issue a Safaty Evaluation.
For OL' applicants, the NRR review will be performed consistent with the licensing schedule.
Documentation Recuired Licensees and applicants should submit a report that describes the equipment classification and vendor interface programs outitned the position above.
D-5 e
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ATTACHMENT 4 SUPPLEMENTAL INFORMATION 4
2/84 Supplemental Information to be used in conjunction with NUTAC (Nuclear Utility Task Action Committee) for Generic Letter 83-28, Section 2.2.2)
REPORT 7
Dated February,1984 L
t
2/84 SUPPLEMENTAL INFORMATICN The following is a set of objectives, program elements and general guidance that is offered as information and assiscance to utilities that may find such
-information useful in preparing, updating or implementing their own internal handling program for Equipment Technical Information (ETI).
I. Th'e objectives of an ETI Handling program are:
A. Ensure receipt and processing of ETI B. Ensure timely evaluation of ETI and determination of any required action C. Timely performance of all required action
- 0. Feedback the review of.ETI and the completed actions to ensure ETI has been properly processed E. Ensure records of review and action are maintained II. In order to accomplish these objectives, the utility administrative procedures for handling ETI should contain the following elements:
[ A. Formalized receipt i B. Logging and filing
-C. Technical sorting and coordination i 0. Evaluation and action recommendation E. Action decision F. Scheduling.:and accomplishing action G. Verification of completed action H. Feedback to logging and filing l-
,, , - . . . . , ~ . . - . -,
2/84
~
III. The following paragraphs present a general method for handling ETI:
A. Figure 1 presents, in the format of a generalized logic and document flow diagram, an outline of an internal handling arrangement to receive, process, and preserve incoming ETI.
- 8. The process has been divided into five (5) function-related blocks.
The responsibilities assigned to a block may be performed by one group or multiple groups could be responsible for specific incoming ETI, i.e., one group receives NRC generated ETI, another receives INPO generated ETI, etc. Also, one group could perform the respon-sibilities of more than one block (for example, the Licensing De-partment receives, legs, files, sorts, and ccordinates ETI received from the NRC). The responsibilities of the function-related blocks are:
- 1. Receipt
- a. Should be aware of all sources of ETI for which it has receipt responsibility. potential sources are shown in Table 1.
- b. Should be accessible ey all sources for which it has receipt responsibility.
- c. Management should ensure a cooy of ETI is sent to the accro-priate receipt group.
-z-
2/84
- 2. Logging / Filing
- a. Should know what has been received and when it was pro-cessed.
- b. Maintains status of ETI by receiving feedback that each required action is complete.
- c. Should combine redundant ETI en the same topic, i.e., GE SIL and associated NRC Bulletin or Information Notice.
e
- d. Acknowledge receipt, if required, to originator of the incoming ETI.
- 3. Technical Sort and Coordinate '
- a. Determines areas of responsibility to ensure proper cis-tribution.
e i b. Have the authority to assign and follow up response dates, or have access to someone that does:
- c. Should nnt be the only review for applicability.
- d. Should assign distribution that ensures information reaches, as a minimum, the department head (s) concerned. That level t
is defined for a particular discipline as that person directly responsible for repair, testing, operating, design, etc.
~
- - 2/84
- e. Should receive feedback of action decided and action com-pleted.
- f. Should send feedback to Logging / Filing to close out log.
- 4. Review and Action
- a. Should be department head level as def'nec acave.
- b. Should be capable of determining applicacility or able to pass to those who are.
- c. Capable of initiating necessary changes or specific actions required. (See Table 2 for Typical Actions.)
- d. Should be aware of additional areas where enanges need to be instituted to ensure proper distribution anc comoliance.
- e. Should be capable of determining impact and determining cost effectiveness,
- f. Responsible for the feecback to Technical Sort for action decided and action completed.
- g. Should be capable of getting back into the information flow path to determine location, availability, completeness, etc.
of any information of concern.
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2/84 T
., C. 'The individual utility should organize the program by whatever administrative or departmental structure is most appropriate. The program will meet the stated objectives if the responsibilities described above for each function-related block are carried out for all incoming ETI. (See Table 3 for a partial list of publications and documents of concern to this program.)
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2/34 REVIEd ETI &
1.CGGING TECH. 50RT SOURCES ~
r & -= & ACTICN (See
- RECEIPT FILING CCORDINATE (See Table 1) Table 2) 3 R TECH. SORT ,
CCCROINATE I
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1' Figure 1. Flow Diagram for Handling ETI
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SOURCES OF EQUIPMENT TECHNICAL INFORMATION !
INPUT DESIGNATOR SOURCE ABCD NSSS A B. C NSSS Owners Group-ABC0 Architect / Engineer ABCD Other Vendors (Voluntary) 0 (Utility) Purchasing Documents / Correspondence AB See-In Program (SER, SOER, O&MR)
-NRC (I&E Bulletins, Circulars & Notices; Generic LTRS)
B NUCLEAR NETWORK A C NOMIS C (Utility) ISEG, Ops. Experience & Analysis A C QA or NRC Audit Programs, NSARC (off-site corporate review group)
C (Utility) PM Program & repair history / trending
.C (Utility) Surveillance program & trending C
(Utflity) Personnel in professional / technical meetings or dis-cussions or committees / organizations (ANS, ANSI, ASME, etc.)
C (Utility) Personnel by reading other professional or technical
' journals, pubs., literature, reports, etc. (AIF, EPRI, EEI, magazines,'etc.)
ABC Mail or telephone ir'Jrmation from off-site corporate offices or BC other utilities or' direct from professional / technical persons.
Computer or other data links.
A
. C Direct interaction with vendor technical reps or their hand-carried hardware, software and experience.
Input Desionator A. Mail or courier B. Telecopy/TWX/ computer C, In-house origin
, 0. Purchasing / Stores documentation TABLE 1 w _
- 2/84 ACTIONS TAKEN BY ASSIGNED DEPARTMENTS Actions to be taken by the departments assigned include:
Analyze and evaluate incoming ETI Publish appropriate information Revise Training Material Revise Training Activities Revise Procedures Revise Ooerating Techniques Revise Technical Specifications Revise Procurement Documents Revise Prints Publications, ETI Files Revise List of Safety-Related Equipment Revise Design of Equipment or Systems Revise Test Procedures Revise PM or Surveillance Content or Schedule Revise Spare Parts or Consumables Stock Scoce or Geoth Advise Industry via NUCLEAR NETWORK For ETI that is not applicable; annotate th's fact and send to Technical Sort.
Prepare reports of completed actions and send to Technical Sort.
Prepare schedule for completion of future action and send to Technical Sort.
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. 2/84 TABLE 3 LIST OF REFERENCES I.
1.isted below are existing publications and other documents that present the regulatory and industry requirements and guidance that contribute to a coherent, efficient, and useful administrative handling system for ETI:
A. NRC and Industry Recui-ements and Recommendations ANSI N18.7-1972 ANS-3.2/ ANSI N18.7-1976 ANSI /ANS-3.2-1982 NQA-1-1979 ANSI N45.2 ANSI N45.2.9 10 CFR50 10 CFR50 Appendix B Regulatory Guide 1.28 Regulatory Guice 1.33
~ Regulatory Guide 1.88 NRC Standard Review Plan for PSAR anc FSAR, f.e.:
NUREG - 75/087 NUREG-0800 Other NRC NUREGS:
NUREG-0600 NUREG-0694
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- 2/84 NUREG-0731 NUREG-0737 NUREG-0977 NUREG-1000 NUREG-1022
- 8. Industry Guidance o INPO Criteria 83-030, dated August, 1983 " Performance Cbjectives and Criteria for Near Term Operating Plants," gives this informa-tion for operating plants as well as NTOLs (See TS.3, pages 43 and 44).
o Guideline for use of Nuclear Notepad,(INPO Guideline 83-015 of May, 1983) ,
o INPO Good Practices MA-301 Plant Material Deficiency Identification MA-302 Trend Analysis MA-303 Control and Calibration of M&TE MA-304 Control of Vendor Manuals TS-401 Operations Surveillance Program
! TS-402 Plant Modification Control Program TS-403 Industry Operating Experience Review Program TS-404 Monthly Synopsis of Operating Experience TS-406 In-House Operating Experience Review Program TS-502 Incorporating Ocerating Experience into Training Programs
2/84 o In addition, the below listed " Good Practices" are now under devel-
, opment and are expected to present additional guidance that should be considered and incorporated as appropriate:
CY _ Trending of Chemistry Analytical Data MA-305 Predictive Maintenance (Vibration Analysis)
MA-307 Preventive Maintenance MA-310 Maintenance History CA-104 Quality Program for Equipment Important to Reliaole Power Station Operation 09 _ Use and Control of Procedures TS-410 Surveillance Scheduling Program 0
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8 ATTACHMENT 5 RATIONALE 1
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RATIONALE
- 1. GENERAL This document has been prepared to assist utilities in responding to any concerns which may be identified regarding the Vendor Equipment Technical Information Program (VETIP) developed by the NUTAC on Generic Letter 83-28, Section 2.2.2. It contains an assessment of the intent of Section 2.2.2 and how this intent is met by the VETIP.
Several methods of meeting the intent of Section 2.2.2 were addressed by the NUTAC and rejected. An assessment of the problems associated with these methods and reasons for rejection are given.
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, 2. LINE-BY-LINE ANALYSIS OF 2.2.2 2.1 "For vendor interface, licensees and applicants shall establish, implement and maintain a continuing program to ensure that vendor information for safety-related components is complete, current and controlled throughout the life of their plants, and approp,riately referenced or incorporated in plant instructions and procedures."
The VETIP concept is based on providing an industry-controlled, hardware-oriented system that puts maximum emphasis on safe opera-tion, as results from properly using and maintaining safety-related components, with the benefit of complete and current vendor informa-tion. This information is provided, evaluated and distributed * '
properly by the VETIP, in a timely manner. The VETIP is an ongoing, industry wide concept that will function throughout the life of each participating plant and will continually update information concern-ing safety-re' lated components. The numerous channels of such infor-nation, as described by the.-VETIP, are the means by which an ongoing, updated supply of current vendor information is provided to each licensee, many times via redundant paths.
In Section 4 of the NUTAC report, complete licensee implementation responsibility is addressed, that ensures the proper administrative controls are incorporated in appropriate plant instructions and procedures, which will distribute the information where it belongs.
These same controls will administratively provide for information updating, as the information is made available via the VETIP network.
An adequate interface is provided by the VETIP for vendors of safety-related equipment, as well as between utilities themselves, INp0, the NRC, and NSSS suppliers. Each of these sources and recipients of information provide for an industry-wide level of common information, such that when new information concerning a safety-related component is known, all other VETIP participants will receive this same infor-mation in a timely manner.
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4 2.2
' Vendors of safety-related equipment should be contacted and an inter-face established.
2.2.1 Response See response to 2.5.
2.c 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, replace-ment, and repair, to compensate for the lack of vendor backup, to assure reliability commensurate.with its safaty function. The pro-gram shall be closely coupled with action in 2.2.1 above.
2.3.1 Response Each utility should identify the specific practices used to maintain and repair equipment which has little or no vendor backup. The SEE-IN portion of the VETIP provides for an evaluation of these practices (VETIP, page 11, Program Operal tion). Operating experience is reviewed from many perspec-tives, including maintenance and testing practices.
The VETIP also provides access to determine which other utili-ties have the same equipment so tnat maintenance and repair '
practices can be discussed and experiences can be shared.
NPRDS provides this function. The initial input data to NPROS '
for each utility will also require that equipment classifica-tion be addressed in order to determine the safety-related equipment which must be a. part of the NPROS data base.
Classification is thus addressed by tr.e VETIP program.
Equipment qualification data and documents are considered to be Equipment Technical Information, per the definitions given in the VETIP report.
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' Thus, the VETIP provides a mechanism to address the concerns l
related to equipment which does not have sufficient vendor backup. .
2.4 The program shall include periodic communication with vendors to assure that all aoolicable information has been received.
All current technical information on a piece of vendor equipment is normally provided under the terms included in procurement documents.
Receipt inspection processes should verify this is received. It has been found that NSSS vendors supply information updates, and this is included in the VETIP. In addition to the NSSS interface, periodic communication is made with other vendors associated with* spare and replacement part procurement, and requests for service assistance.
Most importantly, any essential technical information is received, from the vendor, as a part of the SEE-IN evaluation process on equip-ment malfunctions. Through these periodic communication channels, all applicable information is sought or provided. Positive indica-tion of raceipt is a function of internal utility administration, but in all cases should provide evidence that information has been received.
. Any formal program to solicit vendor information on a regular peri-odic basis would be of minimal benefit, unless the vendor is known to ha'te a continuing product development program, with active service representative feedback. Currently, only the NSSS suppliers do this. Most other information available is that supplied with the original equipment or information on new equipment.
2.5 The program should use a system of positive feedback with vendors for mailings contsining technical information. This could be accom-plished by licensee acknowledgement for receipt of technical mail-ings.
-c The VETIP addresses the fact that technical information is rece by utilities from various sources. In the case of NSSS vendors, rigorous distribution / acknowledgement procedures are in effect to ensure that pertinent infumation is received and used by respective utilities. The NUTAC.has concluded, however, that in the case of non-NSSS vendors, reliable technical information exchanges procedures are not always utilized. Of course, when technical information is received from vendors, each utility must handle it in accordance with t
their appropriate document control procedures, but the VETIP is not structured to rely on this mechanism to provide the necessary infor-mation exchange.
Instead, the empha' sis is on enhanced 'ndustry.
l communications through such programs as NPRDS and SEE-IN. These programs incorporate positive feedback mechanisms from utilities, as well as vendors, to ensure receipt and use of appropriate technical information.
Also through recommended enhancements in the SEE-IN program, problems caused by outdated or incorrect vendor technical information will be identified and resolved effectively.
2.6 It.shall also define the interface 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 ensure that requisite control of and applicable instructions for maintenance work on safety-related equipment are provided.
The fundamental point of this position is that utilities must have requisite control of vendors performing work on safety related equip-ment.
This control can be accomplished as discussed in Section 4.1.1.a of the NUTAC report under " Vendor Services".
The means to achieve this control are summari:ed as follows:
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Require services be performed by a technical representative from
.an approved and qualified supplier of such nuclear safety related
- . services.
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O o Require services be performed with approved utility procedures or with vendor or contractor safety-related procedures approved by the utility. These procedures should identify the interface and division of responsib111ttes for services to be performed.
o Require the services be performed under the cognizance of the utility QA/QC program or under the cognizance of the vendor or contractor QA/QC program that has been approved and audited by the utility QA programs.
o Require ETI provided in conjunction with the performance of- vendor services be handled consistent with the methods outlined in Section 4.1.1.a of the NUTAC rep rt under " Internal Handling by Utili ties" .
o In the manner discussed above, utilities can achieve complete comoliance with this position.
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- 3. OTHER METHODS CONSIDERED The NUTAC considered two formal vendor contact methods. The first was a utility-specific vendor contact program. The second was an industry-specific or centralized vendor contact program.
3.1 Utility Soeciff e Program The evaluation of this program was based on the results achieved by Salem.
The additional ETI received by Salem was minimal and did not appreciably contribute to safety or reifability improvement. It was felt that a program which would allow utfif tis: to receive ETI related to equipment problems in a timely manner wo :
'stter serve industry needs to improve reliability and thus improve c.e s ' ty.
3.2 Central Vendor Contact There is no reason to expect that better or more timely ETI would be
. forthcoming from vendors to an independent organization than to a utility. Thus, such an organization will not provide a vehicle to improve the reliability and safety of the nuclear plants.
In addition, the potential legal liability of such an organization would preclude its establishment even if such an organization could provide better ETI.
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' OVERVIEW OF THE VETIP IN EXCHANGE FOR THE SPECIFIC OETAILS OF T PARAGRAPH 2.2.2 CF THE GENERIC LETTER 83-28 The NUTAC approach is realistic, attentive to safety and is achievable.
It is unanimously endorsed as an acceptable program of the original NRC presentation.
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