ML20102C397

Forwards Rev 2 to Section 2.1, Equipment Classification & Vendor Interface, in Response to 841217 Request.Rev Provides Addl Info on Master Equipment List.Info Re Equipment Classification Will Be Provided by June 1985

ML20102C397
Person / Time
Site:	Hope Creek
Issue date:	02/28/1985
From:	Mittl R Public Service Enterprise Group
To:	Schwencer A Office of Nuclear Reactor Regulation
References
GL-83-28, NUDOCS 8503060236
Download: ML20102C397 (7)

Text

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Put>hc Sereco O I)#S G Cornpany Electnc and Gas 80 Park Plaza, Newark, NJ 07101/ 20' 430-8217 MAILING ADDRESS / P.O. Box 570, Newark, NJ 07101 Robert L. Mitti General Manager Nucle:r Assurance and Regulation February 28, 1985 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Attention: Mr. Albert Schwencer, Chief Licensing Branch 2 Division of Licensing Gentlemen:

RESPONSE TO NRC GENERIC LETTER 83-28 HOPE CREEK GENERATING STATION DOCKET NO. 50-354 Pursuant to our letter of December 17, 1984, from R. L. Mittl to A. Schwencer on the above subject, attached is Revision 2 of Section 2.1, " Equipment Classification and Vendor Interface," of Public Service Electric and Gas Company's response for the Hope Creek Generating Station.

This revision provides additional information on the Master Equipment List and supercedes Rev. 1 of Section 2.1 transmitted to you on December 17, 1984. Additional information on the Equipment Classification and Vendor Interface and Post Maintenance Testing will be provided in June 1985.

If you require additional information, do not hesitate to contact us.

Very truly yours,

- ,i N( h,s/

B50306023g gynygg DR ADOCK 05000054 g PDR f

At tachment - Hope Creek Generating Station Response to The Energy People Generic Letter 83-28 Section 2.1, Revision 2 h)

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Mr. Albert Schwencer 2 2/28/85 C D. H. Wagner (w/ attach.)

USNRC Licensing Project Manager A. R. Blough (w/ attach.)

USNRC Senior Resident Inspector LC8 01/02 L

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

, Licensees and applicants shall confirm that all com-ponents 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, in-cluding maintenance, work orders, and parts replace-ment. In addition, for these components, licensees and applicants shall establish, implement, and main-tain a continuing program to ensure that vendor infor-mation is complete, current and controlled throughout the life of the plant, and appropriately referenced or incorporated 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 assure that suf ficient attention is paid to equipment maintenance, replacement, and repair, to compe nsate for the 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 information. This could be accomplished by licensee acknowledgement for receipt of technical ma ilings . The program shall also define the interface and division of responsibilities among the licensees and the nuclear and non-nuclear divisions of their vendors that provide service on reactor trip system components to assure that requisite control of and applicable instructions for maintenance work are provided.

Response l As described in Section 3.1.2.5 of NUREG 1000, the G.E. boiling water reactor trip system design dif fers from the PWR design.

Parameters from several BWR systems are monitored by the Reactor Protection System (RPS) and the Redundant Reactivity Control System (RRCS). Either or both of these systems can ef fect a reactor trip by communi-M P84 50/04 9-bp Rev. 2

cating a reactor trip signal to the Control Rod Drive (CRD) system which accomplishes rapid control rod insertion.

The RPS is designed to initiate a reactor trip upon sensing specific plant parameters when they exceed predetermined limits or identifying events which re-quire a reactor trip. The RPS receives input via four redundant and independent trip channels from various switches and trip units which identify that a para-meter has exceeded its limit or that a trip initiating event has occurred. The RPS logic decides whether or not to trip the reactor by applying a "one-out-of-two-twice" criterion to the four trip channels. A reactor trip is accomplished by deenergizing both solenoids on each control rod drive scram valve which initiates rapid insertion of each control rod into the reactor core. In addition, an RPS trip energizes two redundant backup scram valves, either one of which ef fects a reactor trip by venting the instrument air header which feeds the control rod drive scram valves.

The RRCS is a backup system to the RPS which i ndepe nd-ently initiates a reactor trip upon sensing Rx vessel low level, Rx vessel high pressure or a manual initia-tion signal. The RRCS ef fects a scram by deenergizing two redundant Alternate Rod Insertion ( ARI) valves, either one of which will vent the instrument air header which feeds the control rod drive scram valves.

For all reactor trips, the rapid insertion of all control rods is accomplished hydraulically by the Hydraulic Control Units (HCU's) of the Control Rod Drive System.

Both the RPS and RRCS are designed to deenergize to trip, therefore loss of power will initiate a reactor trip. Similarly, the HCU's are des igned such that loss of power or loss of instrument air will initiate a reactor trip.

PSE&G complies with Section 2.1 of Generic Letter 83-28 by insuring that all components whose f unctioning is required to trip the reactor are identified as safety related. PSE&G has:

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, s (a) Identify all safety-related trip events and verify that all components whose functioning is required to sense the occurrence of a trip event and relay the information to either the RPS or the RRCS are identified as safety related.

(b) Verify that the RPS and RRCS have been designed and implemented as safety related systems and all active components which have been identified by design as required to initiate a reactor trip are identified and maintained as safety related components.

(c) Verify that the HCU's and other active components of the CRD system which have been identified by design as required to accomplish the rapid insertion of the control rods are identified and maintained as safe ty related components.

The addition of these components to the Hope Creek Generating Station Master Equipment List (MEL), will be comple ted in June 1985. The MEL is a computerized list of plant components. It contains inf o rmat ion such as: equipment identification, general equipment inf o rmation, applicable system information, quality assurance requirements including safety classification, general location information, drawing information, purchase order references, and applicable vendor technical manual numbers. Vendor technical manuals are required to be submitted by purchase order with the procured equipment. Vendor technical manuals contain information concerning operations and maintenance of supplied components. The technical manuals, in addition to other vendor supplied documentation, are tracked'and controlled through a computerized document control system which also lists the current revision received. This document control system is being further enhanced to cross-reference vendor technical manuals and other applicable vendor information to plant instructions and procedures.

The purpose of the vendor interf ace program is to ensure that current information and data will be made available to those personnel responsible for develop-ing and maintaining plant instruct ions and proce-dures. These information systems and programs cur-rently exist and are capable of identifying the ind-ustry precursors that could lead to a Salem-type event. It should be noted that the vendor interface M P84 50/04 11-bp Rev. 2

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program is industry controlled and is mainly hardware oriented program that does not rely on vendor action, other than the NSSS vendor to provide inf o rma tion directly to utilities. Instead, the vendor interf ace program relies on information developed by industry experience through the INPO Significant Event Evalua-tion and Information Network (SEE-IN) and the Nuclear Plant Reliability Data System (NPRDS).

The following is supplied by G.E. to ensure vendor information to PSE&G.

(a) Safety Concerns 10CFR21 Reporting - The General Electric Company has established a reporting system to handl3 safe ty con-cerns that complies with the requirements of 10CFR21.

Urgent Communications - In addition to the 10CFR21 reports, a procedure for handling urgent communica-tions to BWR owner / operators has been established for use in providing f ast notification of safety con-cerns. These communications are usually in the form of a short letter which provides a brief explanation and advice or precautionary measures to be observed to avoid potential operational hazards. Due to their urgent nature, these communications are processed to operating plants by the most ef fective method (i.e.,

telex, telecopy, cable, special mail handling, etc.)

(b) Several other information systems exist to pro-vide channels of communication for various types of inf o rma tion:

Service Information Letters (SILS) - These documents are usually brief, providing recommendations for equipment modification, plant design improvements, or changes to procedures to improve plant performance.

Service Advice Letters - These documents are issued by GE Product Departments other than the San Jose based Nuclear Energy Product Departments and are used to provide notification of product problems and/or serv-ice information on a broad range of GE consumere and industrial products. Those Service Advise Letters that are recognized by the issuing product department as applying to devices used in nuclear plants are specially identified and are flagged for distribution to all nuclear plants.

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Turbine Information Letters (TILs) - TILs are issued by GE's Large Steam Turbine Generator Department to provide descriptions of product problems / improvements and to recommend modifications that will mitigat e problems or improve product performance.

Operation and Maintenance Manuals - These documents are issued by all GE product departments to provide instructions for installation, operation, and main-tenance of GE designed repairable equipment and sya-tems. Final revisions to the manuals provided for the NSSS scope of supply are delivered as contractually required, but usually are shipped at about the time of plant commercial operation.

Application Information Documents - are white papers that describe potential operating problems and provide design change or operating recommendations to mitigate or avoid them. These documents are primarily aimed at requisition plants, but are also forwarded to operat-ing plants when they have any applicability to those plants.

Other documents are available and are as follows:

. INPO Operations and Maintenance Reports

. INPO Significant Operating Experience Reports

. INPO Significant Event Report

. NRC Generic Letters

. NRC Bulletins

. NRC Information Notices PSE&G has establshed a Response Coordinating Team (RCT) for HCGS which evaluates and processes the above information notices and correspondence.

The RCT is a multi-departmental organization comprised of Engineering, Operations, Quality Assurance, and Licens ing personnel. The RCT reviews the documents listed above, transmits them to af fected organiza-tions/ departments within PSE&G for action or incor-poration and maintains the applicable records to document the disposition of said documents.

The program described above ensures that reactor trip system and other safety related system vendor informa-tion is reviewed and controlled, and will be continued throughout the life of the plant. Furthermore, it will be appropriately referenced or incorporated in plant instructions and procedures. No changes in this me thod are planned.

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