ML20128E424
| ML20128E424 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/24/1985 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | John Miller Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, LIC-85-214, NUDOCS 8505290383 | |
| Download: ML20128E424 (4) | |
Text
,t Omaha Public Power District 1623 Harney Omaha Nebraska 68102 402/536 4000 l
May 24,1985 L IC-85-214 Mr. James R. Miller, Chief Of fice of Nuclear Reactor Regulation Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
References:
(1)
Docket No. 50-285 (2)
Letter OPPD (W. C. Jones) to NRC (J. R. Miller) dated November 4,1983 (LIC-83-267)
(3) letter NRC (J. R. Miller) to OPPD dated March 25, 1985
Dear Mr. Miller:
Request for Additional Infomation Following Preliminary Staf f Review of Licensee Response to Generic Letter 83-28 The Omaha Public Power District received the subject request for additional i
information (Reference (3)).
This letter requested additional infomation l
within 60 days regarding items 2.1 and 2.2.2 of Reference (2). Accordi ngly,
l please find attached the District's response to these items.
Sincerely, R. L. Andrews Division Manager Nuclear Production RLA/DJM/rh Attachment cc:
LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.
Washington, DC 20036 Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, NRC Senior Resident Inspector 9505290393 850520 0I PDR ADOCK 05000285 P
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Request for Additional Information Following Preliminary Staff Review of Licensee Response to Generic Letter 83-28 REQUEST Item 2.1 (first part) - Incomplete Licensee needs to submit results of work with NPRDS implementation that will confim completeness of the existing Electrical CQE List.
In addition, the licensee should submit the results of their review of applicable procedures and surveillance tests to assure that RTS components are identified as safety-related.
RESPONSE
The District has completed the review of the Reactor Protective System CQE and the NPRDS equipment list. The Electrical CQE List was found to be accurate and complete, and has subsequently been formally issued.
Review of the District's CHAMPS (Computerized History and Maintenance Planning System) database which provides a partial listing of CQE items was completed October 1, 1984. Comparison of the CHAMPS database to the interim CQE list revealed that certain interim CQE list items were not contained in the data-base. The CHAMPS listing included active items only, passive items such as resistors, fuses, teminal blocks, indicating lights, etc., were not included in the CHAMPS listing. The District contracted with a vendor to collect this additional infomation and the component infomation for these additicr.a1 items was collected, coded on data sheets and the data sheets forwarded to Data Pro-cessing for key punching. The key punching has been completed and the indepen--
dent verification of the additions will be done to ensure that information has been correctly entered into the system. The CHAMPS database will be used to help facilitate the use of the CQE list. The official CQE list is a hardcopy document which provides a basis and listing of CQE equipment.
The District has completed its review of the Reactor Protective System Proce-dures for adequacy of controls to ensure correct actions are taken with regard to the Reactor Protective System (RPS). This review was conducted in conjunc-tion with a broader review to ensure proper controls ~as committed to in Item 2.2.1.3 of the District's response to Generic Letter 83-28. The District has found that the existing controls are adequate with RPS activities controlled by Surveillance Tests, which provide acceptance criteria, reporting of problems discovered and review process; Maintenance Orders, which must identify equip-ment as CQE and which control all repairs including parts and necessary review; and Station Modification Control, which must also identify CQE activities. The only exception to this is RPS light bulbs which are treated and stored as CQE but whose replacement may be done by Operations, as required, or I&C Techni-cians under preventive maintenance. The District believes that proper training and personnel awareness make this activity acceptable. This approach is con-sistent with that used for all safety-related activities at the Fort Calhoun Station, and has proven to be an acceptable, safe method of operation.
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' REQUEST
- Item 2.1 (second part) - Incomplete Licensee needs to submit the results of his efforts to upgrade vendor technical infomation for reactor trip system components and to establish interfaces with 4
- vendors of that equipment to maintain vendor technical information current and complete. Licensee should note comments on NUTAC for Item 2.2.2 in this re-gard.
RESPONSE
1 The District has verified with the vendors of the reactor trip system (i.e.,
the circuit breaker used for manual trip and the contactor used for automatic trip) that the information held by the District is the latest revision and does, in. fact, apply to the components used in the District's reactor trip system. Additionally, the procedures used to perform maintenance and testing on these components have been reviewed to ensure they are current.
Interface with vendors is discussed in Item 2.2.2 below.
g REQUEST Item 2.2.2 - Incomplete Licensee needs to present their evaluation of the NUTAC program and describe how it will be implemented at Fort Calhoun. The staff found the NUTAC program fails to address the concern about establishing and maintaining an interface between all vendors of safety-related equipment and the utility. Accordingly the licensee will need to supplement their response to address this concern.
This additional information should describe how current procedures will be modified and new ones initiated to meet each element of the Item 2.2.2 concern.
I
RESPONSE
Item 2.2.2 The District's response dated November 4,1983 to Generic Letter 83-28, Section 2.2.2, stated that the District was an active participant in the INP0 Nuclear Utility Task Action Committee which had been specifically chartered to develop guidance for use by utilities in response to Generic Letter 83-28, Section 2.2.2.
Additionally, we responded that we would review NUTAC's report in order to determine to what extent the findings might be incorporated into the Dis-j.
trict's practices with regard to the control of vendor information for safety-related equipment.
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The District has completed its review of NUTAC's Report on Generic Letter 83-28, Section 2.2.2., " Vendor Equipment Technical Information Program" as well as INP0's Good Practice MA-304, " Control of Vendor Manuals." Several meetings have been held.with responsible District departments in order to review the current status of vendor infomation, to discuss various alternatives with regard to the implementation of controls on vendor information and to develop both short and long term goals for the implementation of a final solution. A considerable effort was made to coordinate and fully utilize existing control mechanisms so that the program could be easily integrated into Station activ-ities.
In addition, the District has retained the services of on engineering consultant to assist in the development of a vendor manual control program.
Based on the results of our review of the NUTAC Report, INP0's Good Practice and our several meetings, the District has instituted a three (3) phase program which, when fully implemented, will satisfy tha concerns of Generic Letter 83-28, Section 2.2.2.
The three (3) phase program includes the following:
Phase I Development and trial testing of vendor information indexing and control proce-dures. The control procedure fully utilizes the concepts established by NUTAC as well as other means to verify the currentness of vendor infomation. These procedures will be issued by June 1,1985.
Phase II Vendor information received prior to June 1,1985, will be inventoried and in-put into the database of CHAMPS. Completion of the indexing process will establish initial control and accountability. The vendor information will then be verified by attempting to contact the supplier.
Vendor information received after June 1,1985, will be reviewed and approved for use prior to controlled dissemination. This portion of Phase II will be on-going and will not be subject to a completion date.
Phase III Vendor information received prior to June 1,1985, and inventoried in accor-dance with Phase II procedures will be reviewed and approved for use prior to controlled dissemination.
Schedule The Phase I effort has been essentially completed and will be fully completed by June 1,1985, when the indexing and control procedures are issued. Phase 11 activities have been initiated.
A schedule for the completion of the Phase II and Phase III efforts will be pro-vided to the Commission prior to the next qcheduled refueling outage.
It is an-ticipated that a more meaningful schedule can be developed after the procedures have been fully implemented and the personnel assigned have had an opportunity to gain experience as to the status of vendor information received prior to June 1, 1985.
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