ML20128L008

Forwards Revised QA Procedures,Including Rev 0 to QA Procedure 3, QA Classification & Rev 1 to QA Procedure 19, Sys Auditing, in Response to 850328 Request for Addl Info Re 831104 Response to Generic Ltr 83-28

ML20128L008
Person / Time
Site:	Rancho Seco
Issue date:	05/23/1985
From:	Reinaldo Rodriguez SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Thompson H Office of Nuclear Reactor Regulation
Shared Package
ML20128L011	List: ML20128L008 ML20128L040 ML20128L050 ML20128L071
References
GL-83-28, RJR-85-269, NUDOCS 8505310267
Download: ML20128L008 (5)

Text

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$SMUD SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, P.O. Box 15830, Sacramento, CA 95813; (916) 452-3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA RJR 85-269 May 23,1985 DIRECTOR OF NUCLEAR REACTOR REGULATION ATTENTION HUGH L. THOMPSON, JR. DIRECTOR DIVISION OF LICENSING U S NUCLEAR REGULATORY COMMISSION WASHINGTON D C 20555  :

DOCKET 50-312 RANCHO SECO NUCLEAR GENERATING STATION UNIT NO 1 GENERIC LETTER 83-28, REQUEST FOR ADDITIONAL INFORMATION Your letter, dated March 28, 1985, requested additional information to complete your review of the District's November 4,1983 (RJR 83-7?S) response to Generic Letter 83-28, " Required Actions Based on Generic Implications of Salem ATWS Events". Attached is our response to your information request.

If you have any questions feel free to contact Robert Roehler of my staff at

,(916) 452-3211, extension 4905.

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R. J. odriguez g Assistant Generals anager, Nuclear Attachment B505310267 B50523 PDR P

ADOCK 05000312 PDR ho['

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I ATTACHMENT NRC Reauest:

Item 2.1 (Part 1) - Incomplete.

A listing of RTS components reviewed, due 10/1/84, has not been received. A specific statement confirming that these components (RTS) are identified as safety-related on documents, procedures, drawings and information handling systems is needed.

Response

The District's October 5, 1984 submittal (RJR 84-441) updated the schedule for completing our RTS component review. Our new schedule indicated that this review would be completed by February 1, 1985.

e We have completed this review and the components listed are identified as safety related (Class 1) on the Master Equipment List (MEL). The MEL is the o QA list for equipment / components. The handling of components in documents, procedures, drawings and _information handling systems is based on the MEL classification of the component. As discussed in our November 4,1983 submittal, Item 2.2, the Maintenance Information Management System (MIMS),

which includes the MEL, identifies the procedures, drawings, and documents for components and controls all work on the components.

In previous conversation with members of your staff, the RTS listing is not required to complete your review of this item. Your staf f also agreed that our original submittal did not commit to provide this list.

NRC Request:

Item 2.1 (part 2) - Incomplete Licensee should describe his program for periodically contacting vendors to ensure that all vendor technical information is being received, how maintenance infornation is developed for components whose vendors are no longer available, how maintenance and testing procedures are revised to incorporate up-to-date information, and how the performance of these procedures is controlled.

Response

As stated in our November 4, 1983 submittal (RJR 83-725) B&W was the supplier for the RTS components. The B&WOG tasked B&W to provide a list of RTS safety related components and the most current vendor information. The District has completed its review of this information and has updated the MEL and vendor library based on this review.

The District considers that these actions complete the requirements of item 2.1 and that the programs of item 2.2 will be relied upon for maintenance of current vendor information.

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QualityAs'suranceLProceddre Q P.3 whichgis!the basissfor3classificEtion was

[, 'nct included in Appendix A'aststated. h ti M q g,j 'g l s

Response

<p L.'g;,)* vQa %),'i u ..+ l g Quality Assurance.Proceddre QAP.3 isgattached. ,. /

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J NRC Request:

• Uf( y { V 11!em 2.2.1 - (4) Incomplete. m .

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Response'shouldincludeinformationoncor'r'htive!a'ct'iInthatwillbetaken e

'if deficiencies are found.

Response: -

The corrective action-to be taken.is unique depending on the results of

- findings of a. specific audit. The requirements for ensuring that adequate-corrective action is taken is discussed below.-

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sQuality. Assurance. Procedure QAP.19 establishes and defines the program for

= auditing the: operation, maintenance, repair and modification of Rancho Seco. -The procedure requires prompt corrective action and followup audits to determine.the adeq'uacy andl effectiveness of the corrective actions taken.

. Quality Control Instruction QCI.2 provides the instructions-for the audit program. sThe audited group is responsible for determining corrective action to be taken to resolve any nonconformances identified by QA audits. QA and the Management Safety Review Committee (MSRC) followup is: required to ensure lthat prompt corrective action'is made.and-that the resolution or corrective action is acceptable.

E Copies.of QAP.19 and QCI.2 are attached for your infonaation.

NRC Recuest:

' Item 2.2.2.=- Incomplete.-

NUTAC-is a generic response that will need to be supplemented by plant specific information that details.how-Rancho Seco will implement the NUTAC program. This information, du'e in May,1984 has not been received. In

. addition the staff found the NUTAC program fails to address the concern about' establishing ~and. maintaining an interface between all safety-related equipment vendors and the utility. The-licensee is, therefore, required to supplement his response to describe how such an interface will be developed,

~. maintained, and the current information obtained incorporated into operating, maintenance, and test procedures.

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- Response:

The Vendor Equipment Technical Information Program (VETIP) as defined in the March 1984 NUTAC document is considered a valid response to section 2.2;2 of

- the NRC Generic Letter 83-28. The District is implementing the program as z l described therein. Accordingly, it is requested that the NRC reanalyze and '

reconsider your request for additional information.

NRC Request:

Item 3.1.3 - Incomplete.

Licensee should report the results of their review.

Response

We have.not to date identified any post maintenance test requirements in existing technical specifications that degrade rather than enhance safety.

Existing procedure requirements ensure that this issue is part of our ongoing review of plant operations, configuration changes, and procedure changes.

NRC'Recuest; Item 3.2.3 - Incomplete.

Licensee should complete their review and report the results.

Response

See response to item 3.1.3.

NRC Recuest:

Item 4.5.2 - Incomplete.

Licensee should identify and describe modifications being made to permit on-line testing.

I

Response

The modification referred to is the addition of. automatic actuation of the shunt trip attachment (Item 4.3); which'. includes on-line testablility.- No other modifications were necessary to permit on-line testability.

NRC Recuest:

Item 4.5.3 - Incomplete.

Licensee should describe the program, discuss.the results, and furnish plant specific information regarding'how the.results will be implemented at Rancho ~

Seco. ,

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TResponse: . , N, J -l gy; , , '<j 3' 4 ,, p . 4, .

!The'B&WOG ATWS Committee Amended Response -to. Generic Letter 83-28 dated April 8, -1985 (J. Ted . Enos ' to Mr.4 Thompson) describes the results of the

' evaluation undertaken tosresolve this item. The results demonstrate that i

.the current one month surveillance test interval for the Reactor' Trip'. System f is consistent with high reliability!VBased .on,these; results the District- +

considers <the' one month test'iriterval to' be' adequate? and that the present one month test-interval is consistent with achieving high reactor trip system availability. .

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