ML20138H886
| ML20138H886 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/23/1985 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Zwolinski J Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, NUDOCS 8510290172 | |
| Download: ML20138H886 (12) | |
Text
e GPU Nuclear NggIgf 100 Interpace Parkway Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Nurrber:
October 23, 1985 John A. Zwolinski, Chief Operating Reactors Branch No. 5 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dear Mr. Zwolinski;
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Generic Letter 83-28 GPUN's November 4, 1983 response to Generic Letter 83-28 described our intent to conduct a technical review of all vendor manuals for safety-related components.
Our initial efforts in scoping and planning these tasks have convinced us of a very poor cost benefit return, and that generally the INP0 sponsored Nuclear Utility Task Action Cormiittee's (NUTAC) approach offered a more realistic and beneficial approach. As a result, GPUN has decided to implement the NUTAC Vendor Equipment Technical Information Program.
Ilease find attached our plans and expected schedules relative to Vendor Interface and Equipment Classification issues as well as specific responses to your request of April 5, 1985.
In addition, by copy of this letter to Mr. Martin we are providing our plans and expected schedules as indicated in GPUN's response to Inspection No.
50-219/84-31.
Very truly yours pg 02 h 05IO23 P
05000219 PDR P.B.
1e ler l
VP & Director, Oyster Creek PBF:gpa 2177f/001 Attachment A055 i
GPU Nuclear is a part of the General Pubhc Utihties System I
. =_.._-
i.
.. e cc: Administrator, Region I U.S.' Nuclear Regulatory Commission i'
631 Park Avenue King Of Prussia, PA 19406 NRC Resident Inspector Dyster Creek Nuclear Generating Stations i
Forked River, New Jersey 08731 J. Donohew U.S. Nuclear Regulatory Commission L
7920 Norfolk Avenue Bethesda, Maryland 20014 Mr. Thomas T. Martin l
U.S. Nuclear Regulatory Commission j.
King of Prussia, PA 19406 l
l t
i l
t l
1 I
l I
Attachment I Oyster Creek Nuclear Generating Station Generic Letter 83-28 1)
NRC's Comments on Items 2.1, 2.2.1 and 2.2.2 The following are brief descriptions of the deficiencies in your responses dated November 14, 1983, and Augut,t 16 and November 20, 1984, to the above items in the generic letter.
These are guidelines for your corrective action in responding to these items.
Item 2.1 (Part 1) - Incomplete Describe and provide a schedule to implement a program to assure that components needed to perform reactor trip functions are identified as safety-related on all documents and in information handling systems.
Item 2.1 (Part 2) - Incomplete You are required to establish a vendor interface program for RTS components.
Information submitted shall describe how the program assures that vendor technical information is kept current, complete, and controlled throughout the life of the plant and how the program will be implemented at Oyster Creek.
Item 2.2.1 - Incomplete (1) Your previous responses do not present criteria for classifying components as safety-related as required.
" Engineering judgement on a case-by-case basis" is not sufficient. Provide this criteria.
(2) Provide additional information describing the Equipment Quality Classification List, its maintenance, and how it is validated.
(3)Submitadescriptionofhowtheexistingprogramwillbemadeto comply with the requirements of this item of the generic letter.
(5) Describe how the two referenced procedures and 8.he Operational Quality Assurance Plan are used for design vertfication ard qualification testing of safety-related cuy onents. Examples should be included to demonstrate their usage.
(6) Describe how the referenced procedures are used to assure that structures, systems, M components important to safety comply with the requiremens of GDC-1.
I
_ Item 2.2.2 - Incomplete.
The response shall include a complete description of a program for establishing and maintaining an interface with all vendors of safety-related equipment to assure that vendor technical information for that equipment is kept current, complete, and controlled over the life of the plant. Where maintenance or test work is performed by other than licensee personnel, the division of responsibility between licensee and contractor for control of maintenanco instructions and procedures shall be described.
. General NRC Comments:
In the NRC Region I Inspection Report No. 50-219/84-31 dated January 17, 1985, you were requested to provide the details, with schedules and milestones, of your action plan for developing and implementing a component level Quality Classification List, Venor Manual Interface and Post-Maintenance Testing Program within 90 days of your receipt of the inspection report. We request that you also provide a copy of this response to us for our review.
GPUN Responses to NRC Connents on 2.1, 2.2.1, and 2.2.2 Item 2.1 (Part 1)
Please refer to Attacnment 2 the Quality Classification List Program Description.
Item 2.1 (Part 2)
GPUN actively participated in tne INP0 sponsored NUTAC wnich was formed to develop an appropriate vendor interface program on an industry-wide basis. GPUN has detenained that NUTAC s VETIP is responsive to the Generic Letter and that the program will be implemented at its facilities.
The attached program description ( Attachment 3) delineates our plan and expected senedule for Vendor Technical Manual Control.
Implementing procedures are being developed and will be available for review by 4th Quarter of 1965.
Item 2.2.1 (1) GPUN Procedure 5000-ADM-7313.02 is tne document wnicn provides the methodology for Quality Classification of Systems, Structures and Components.
This methodology considers the design and licensing basis of the component; what plant function the component perfonas; the components mode of operation, and significance of that component's function to plant safety and operation. The methodology includes a checklist approacn which results in a unique report whicn is issued as a controlled document after its review and approval.
The independent monitoring and audit function performed by GPUN Quality Assurance ensures compliance with the GPUN Operational QA Plan.
(2) Please refer to the above.
(3) Tne GPUN Operational Quality Assurance Plan requires tnat safety-related activities be prescribed by documented procedures and that these activities De dCComplished in aCCordance With tne procedures.
In addition, measures are established to control and coordinate the approval and issuance of procedures wnich prescribe safety-related activities.
These procedures include operating and special orders, operating procedures, test procedures, equipment and material control procedures, maintenance or modifications procedures and refueling procedures.
These procedures are available on-site for review.
l (S) Purchase Requisitions PR 5300-06-0040, PR 6300-85-0140 and PR 5513-85-0362 were issued for equipment requiring environmental
. qualification (EQ). Specific environmental conditions were specified in the purcnase requisitions along with our minimum Documentation Requirements Table (Refer to GPUN Procedure 5000-ADM-6230.01 ) requesting specific QA data. The data were received and routed to tne Engineering Assurance (EA) Department via a Vendor Transmittal Form (Refer to GPUN Procedure 5000-ADM-7316.02 ) for their review. The EA Department reviewed the submittals to approve the EQ Testing and place tilat item in our EQ program. The above purchase requisitions are reviewed and approved by the Quality Assurance Department before procurement can begin.
GPUN Procedure 125.2 " Conduct of Spare Parts Engineering" contains a Spare Parts Data Sheet which identifies pertinent data related to the component. The component level QCL being developed in Items 2.2.1 (l&2) will supply classification data to the Spare Parts Engineer.
(o) Both GPUN Standard ES-Oli and GPUN Procedure 125.2 fall under the GPUN Operational Quality Assurance Program for structures, systems and components that are classified Important to Safety.
Tne application of the GPUN Operational QA Program assures that the appropriate qJJity standards and records, as specified in General Design Criteria I of 10CFR50, are properly maintained for structures, systems and components that are classified as Important to Safety.
(GPUN 0QA Plan, Section 2.2.a).
Item 2.2.2 As previously stated, GPUN intends to implement the INP0 sponsored NUTAC VETIP. This program does not irclude the solicitation of vendor infonnation.
It is NUTAC's position that any formal program to solicit vendor information on a regular periodic basis would be of minimal benefit, unless the vendor is known to have a continuing product development program with active service representative feedback.
Currently, interfaces are established with the NSSS Supplier and several other major equipment vendors to supply design, operation, and maintenance recommendations based on their continuing Product Development Programs.
The approved GPUN Operational Quality Assurance Plan contains requirements for the qualification and use of external organizations for activities such as maintenance.
The following is extracted from the 0QA Plan:
Procurement Documents The requirements for the preparation, review, approval and control of procurement documents shall be delineated in detailed procedures.
These procedures shall delineate requirements to assure that procurement documents:
Identify those records which vendors or contractors shall retain, maintain, and control; and those which vendors or contractors shall deliver prior to use or installation of the item.
. Qualification and Selection of External Organizations Procedures shall be established to accomplish the evaluation and selection of external organizations. Contracts or purchase orders for material, equipment or services covered by the scope of the Quality Assurance Program shall be awarded either to:
External organizations who have been qualified by the QAD as having a Quality Assurance Program commensurate with the equipment or services to be provided, or The external organization will be required, by procurement documents, to work under the direct control of the GPUN Quality Assurance Program.
In these instances, the supplier will not be required to have a separate Quality Assurance Program.
When GPUN's approval of an external organization's Quality Assurance Program is required, it shall be reviewed and approved by GPUN prior to initiation of the activity affected by their program.
General Connents GPUN's May 9, 1985 response to Inspection Report No. 60-219/84-31 is attached.
2)
NRC Connents on Items 3.1.3 and 3.2.3 In your responses to the generic letter for those items, you have not stated whether or not you have identified any post-maintenance test requirements in existing Technical Specifications (TSs) which degrade rather than enhance safety.
You are requested to state if you have identified such requirements in existing TSs and propose appropriate changes to these test requirements with supporting justification.
In your letter dated November 14, 1983, you stated in your response to the above items that:
(1) a Technical Specification change would be submitted to add requirements for post-maintenance testing of reactor protection system (RPS) components, and (2) a review of existing Technical Specifications would be made to detennine if additional or revised Technical Specification requirements on post-maintenance testing for safety-related components other than RPS were needed to be submitted. No schedule to complete this was provided in your letters dated November 14, 1983 and August 16 and November 2U,1984.
You are requested to provide a discussion of the status and details of your review of the Technical Specifications to meet items 3.1.3 and 3.2.3 and the schedule and milestones to complete the revied and submit i
Technical Specifications changes to the Staf f.
. GPUN response to Items 3.1.3 and 3.2.3 With respect to post-maintenance testing requirements in existing TSs which degrade rather than ennance safety, our Novemoer 14, 1983 response indicated that Oyster Creek's TSs do not require post-maintenance testing for the RPS components, and as such tne issue is not gennane to these components. GPUN has completed its review of all post-maintenance testing requirements in the existing TSs relative to safety-related components and have found none that are perceived to degrade safety.
Our November 14, 1983 response stated that a Technical Specification Change (TSC) would be submitted requiring post-maintenance testing on RPS components. The response also stated that a TSC for post-maintenance testing relative to safety-related components may be required.
Since our November 14, 1983 submittal, GPUN has reconsidered its position relative to the desire to incorporate post-maintenance testing requireaents into the Oyster Creek TSs. As a result, GPUN does not intend to submit TSCs for the inclusion of post-maintenance testing requirements into the Oyster Creek TSs but rather incorporate post-maintenance testing requirements into the plant procedures as described in our response to Inspection Report No. 50-219/84-31.
3)
NRC Comments on Item 4.b.3 In your letter dated August Ib arid Novemoor 20,19u4, you stated tnat the existing intervals for on-line functional testing required by tne plant Tecnnical Specifications are being reviewed to detennine if the intervals are consistent with acnfeving hign reactor trip system availability and the results will be provided to the staff by Septemoor 1986. You stated this effort will be accomplished as part of your participation in the GWR Owner's Group's Technical Specification Improvement Prograu which will respond to this item.
You are requested at this time to provido a discussion in some detail of the status of your effort to complete this review and respond to the staff.
Your response should include whether or not you are adopting the generic DWR Owner's Group Technical Specification Improvement prugram position on this item.
Tne September,1995, date to provide the results of your review on this item is acceptable and this submittal must address the concerns of items 4 b.J.1 to 4.5.3.b of the generic letter and propose appropriate technical specification changes if they are needed.
GPUN response to Item 4.6.3 l
Pursuant to your request for additional infonnation dated April b,1985, l
GPUN provided its endorsement of NEDC-J0844 via letter to Mr. Zwolinski dated June 12,1985 (attached). As indicated in the letter GPUN has detonnined that the Oyster Creek Plant has a low RPS failure frequency and that the existing on-line functional testing interval supports this.
In addition, we consider our letter to be responsive to the issue in its entirety and see no need for a Septomoor,1985 submittal.
i i
l GPUN QUALITY CLASSIFICATION LIST PROGRAM DESCRIPTIO4 AND MILESTONE l
OVERVIEW As discussed in our previous submittals, GPUN presently has provisions in place to identify the safety classification of major systems, components and structures at the plant as well as provisions for controlling safety-related activities associated with these items. Our program to identify the safety-related components within these existing systems and structures is provided below:
Program The individual components of the safety-related systems and structures will be identified by an engineering review. Upon identification, the components shall be classified after consideration of their design basis, licensing basis, mode of operation, and functional impact upon plant operation and safety.
The classification methodology includes a check list approach that results in a unique report which is issued as a controlled document after it is reviewed and approved. Once classified, the components will be incorporated into standard ES-Oll "Methodogy and Control of GPUN Quality Classification" which is used directly by GPUN personnel to specify the quality classification applicable to activities associated with the components With respect to the proper handling of safety-related activities,., the GPUN Operational Quality Assurance Plan requires that safety-related activities be prescribed by documented procedures and that these activities be accomplished in accordance with the procedures.
Milestones The following milestones are scheduled to support completion of a Quality Classification listing.
Consistent with Generic Letter 83-28, the RTS has been given a higher priorty.
Activity (Milestone).
Date
- 1. Establish Quality Classification Section of 1st Qtr. 85 Engineering Assurance Department.
(Complete)
- 2. Establish RTS component level Quality Classi-fication List based on existing version of 5000-ADM-7313.02 4th Qtr. 85
- 3. Draft revision to 5000-ADM-7313.02 issued 3rd Qtr. 85 for Technical Functions review.
(Complete)
Activity (Milzstone)
Date
- 4. Finalize 5000-ADM-7313.02 revision and issue for GPUN review (1st draft).
4th Qtr. 85
- 5. Formalized listing of Plant Systems to be classified.
4th Qtr. 85
- 6. Procedure issued (5000-ADM-7313.02).
1st Qtr. 86
- 7. Training started.
1st Qtr. 86
- 8. Safety-related component level Quality Classification List back-fit complete for valves, pumps, motors, switchgears, tanks, heat exchangers and instruments.
3rd Qtr. 86 l
GPUN VEND 0R DOCUMENT CONTROL PROGRAM DESCRIPTION & MILESTONES OVERVIEW GPUN has established a program for Vendor Document Control. The program provides for the review and dissemination of vendor correspondence, review of Technical Manuals for newly purchased equipment, and review of Vendor Technical Manuals for existing equipment (backfit manuals).
PROGRAM I. Vendor Correspondence GPUN currently has procedures (GPUN Procedures 5000-ADM-7316.02 and 5000-ADM-7370.92) in effect to ensure that vendor documents are properly reviewed for its impact on existing documents (procedures, manuals, policies, etc.) and that the information is disseminated to the appropriate personnel for action. These procedures will be reviewed and revised as necessary to ensure that industry generated inf.nmation such as that discussed in the INP0 sponsored Vendor Equipment Technical Information Program (VETIP) is properly reviewed, assessed, and acted upon.
II. Technical Manuals for New Equipment GPUN currently has a procedure (GPUN Procedure 5000-ADM-7316.03) in place for the review and issuance of Vendor Technical Manuals for new equipment. This procedure includes a standard checklist for.
guidance during the review and provisions for returning the document to the Vendor when necessary for resolution of comments.
l 1
. III. Technical Manuals for Existing Equipment GPUN will conduct technical reviews of selected Vendor Technical Manuals. The following will be performed during the review process.
Determine applicability of the manual to our equipment Perform check of manual against installed equipment Review existing procedures (Maint., Operations) for consistency with manual Ensure document reflects the experience / knowledge gained during previous maintenance or operation routines Contact the vendor to determine if GPUN has their latest recommendations applicable to our equipment Verify document is legible Classify the manual as one of the four established control levels described below:
LEVEL GPUN CONTROL MANUAL CHARACTERISTICS I
Controlled Dist.;
Manual is highly technical or specific, vendor Active Vendor normally submits updates, manual is used Interface and frequently.
GPUN procedures rely on technical VETIP; Revisions accuracy of information contained in manual.
to Manual Controlled II Controlled Dist.;
Manual is highly technical or specific, vendor passive vendor does not routinely update manual, manual is interface (VETIP);
used frequently.
Revisions to Manual Controlled III Controlled Dist.;
Manual contains general information, manual is Passive Vendor seldom used, adequate procedures exist, vendor Interface (VETIP);
may be out of business.
Revisions to Manuals distributed.
s s
IV Appears on Manual infrequently used, manual is for inventory list equipment not in use or equipment which is not plantequipment(e.g.hotwaterheater, personal computers, fork lifts, etc.).
- o. GPUN currently estimates that a total of approximately 350 manuals will be selected for Technical Review and subsequently placed into the Level I & II categories above. The manuals will be selected from the following areas:
Manualc referenced in safety related procedures Manuals used in conjunction with procedures Manuals for equipment defined as reactor trip systems by NUREG 0800 Manuals on equipment for which the component replacement cost is high Manuals on equipment for which plant personnel want reviewed / controlled but are not within the above MILESTONES The backfit review project is expected to occur thru 1988 at which time the project will be complete and the selected backfit manuals will have been processed. The following are the key milestones for the backfit project.
Issue implementing procedures for review of manuals associated with existing equipment 4th Qtr. 85 Issue priority list of manuals to be reviewed 4th Qtr. 85 Issue contract for engineering assistance to 3rd Qtr. 85 perform reviews (Completed)
Review / revise existing procedures to ensure 1st Qtr. 86 INPO VETIP is implemented adequately Complete backfit review project 4th Qtr. 88 i
I
..(
j s
MNQCIM7 GPU Nuclear Corporation loo Interpace Parkway j
Parsippany, New Jersey o7oS4-114s (2o1)263-6500 TELEX 136-482 Writer's Direct Dial Number:
May 9, 1985 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Comission King of Prussia, Pa.
19406 Deur Mr. Martin:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection No. 50-219/84-31 The following is provided in response to your letter of January 17, 1985 concerning the subject matter.
With respect to Equipment Classification, GPUN presently has provisions in place to identify the safety classification of major systems, components and structures at the plant as well as provisions for controlling safety-related activities associated with these items. The recently established Engineering Assurance group has been assigned the responsibility of developing a component level Quality Classification List (QCL) and it is our intent to respond to this issue by the end of the 3rd quarter of 1985.
With respect to Vendor Interface, GPUN intends to provide this information by the end of the 2nd quarter of 1985 as conveyed to Mr. Epan during the course of this inspection.
With respect to Post-Maintenance Testing, GPUN is currently developing a Post-Maintenance Testing Program which addresses the concerns of Generic Letter 83-28. The key elements consist of:
0f 49 $/
,q i)h' GPU Nuclear Corporation is a subsidiary of General Pubhc Utihties Corporation
- /
- A.-
Y s 1.
Identification of the appropriate QCL components.
2.
Development of administrative plant procedures to define a program for the preparation, use, maintenance and control of the Post-Maintenance Testing data base.
3.
Identification of the appropriate vendor and engineering te.st quidance.
4.
Development of generic Post-Maintenance Testing requirements and guidelines for their use.
5.
Review of existing plant procedures relative to the generic Post-Maintenance Testing requirements and INP0 Good Practices.
The implementation of the program will be phased based upon availability of the various elements.
the Cycle 11 Refueling Outage which will implement the first phas final completion of such items as our vendor interface prog The development of the QCL list.
Very truly yours, "U
Vice President and Director Oyster Creek Ir/1670f cc:
Dr. Thomas E. Murley, Administrator Region 1 U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, Pa.
19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, N. J.
08731 J. Donohew U.S. Nuclear-Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20014
~
GPU Nuclear Corporation NUCIM7 100 Interpace Parkway Parsrppany, New Jersey 07054-1149 (201)263-6500 TELEX 136-482 Writer's Direct Dial Nurnber:
June 12, 1985 Mr. John A. Zwolinski, Chief Operating Reactors Branch No. 5 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Mr. Zwolinski:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Generic Letter 83-28 Reference (1) NRC Letter dated April 5, 1985, John A. Zwolinski to P.
B. Fiedler, " Request For Additional Information Following Preliminary Staff Review of Licensee Responses to Generic Letter 83-28" (2) NEDC-30844 dated January 1985, "BWR Owners' Group Response to NRC Generic Letter 83-28, Item 4.5.3" (3) G. Apostolakis et al, " Assessment of the Frequency of Failure to Scram in Light-Water Reactors", Nuclear Safety 20(6): 690-705 (Nov - Dec 1979)
The following information is provided in response to your April 5, 1985 letter concerning Item 4.5.3 of Generic Letter C3-28.
General Electric Company, on behalf of the BWR Owners Group has performed an analysis which addresses the reliability of the Reactor Protection System for Boiling Water Reactors (NEDC-30844). This analysis has evaluated the availability of the RPS for the existing intervals for on-line functional testing taking into consideration the uncertainties due to component failure rates, common cause failures, operator errors, component "wearout" and reduced redundancy due to testing.
The results of the analysis, performed using a generic availability model representative of the General Electric BWRs, show that the RPS failure frequency is low and that the existing on-line functional testing for the RPS supports this. Additional analyses performed by GE address the differences between specific plants and the generic model. The significant differences between the Oyster Creek design and the generic design analyzed by GE are the type of relays used in the sensor logic channels and in the redundancy of scram contactors.
u p ' : gli; *
, j./
- I' l
. 1 If ' '
o,- \\ 1
'\\\\
GPU Nuclear Corporation is a subsidiary of General Pubhc Utihties Corporation
2-Incorporating these differences in t.1e analysis, the results s RPSfailurefrequencyisstilllowandapproximately1.5x10gowthatthe per year.
This result is comparable to results of other studies referenced in this analysiswhichshoypointestimagesoftheRPSfailurefrequencyinthe to 9.0 x 10- per year.
range of 1.9 x 10-3 Additionally the analysis (NEDC-30844) addresses two other areas to which the RPS failure frequency is sensitive; these are common cause failure and human error. At the extreme, the upper bound error factors for common cause failureandhumanerrorproduceestimatesofRPSfailurefrequencgforthe Oyster Creek type plant of approximately 6.1 x 10-3 and 1.4 x 10- per year respectively. These values are at the upper bound of the studies referenced in the analysis.
Whentheupperboundofbothcommoncauseandhumanerroraregakentogether and translated to " failure on demand", the result is 1.8 x 10
. This is comparabletotheupperboundoftheRPSfajlurefrequencydistribution provided in Reference 3, which is 1.2 x 10- per demand.
Based on the foregoing discussion, GPUN endorses NEDC-30844 to the extent that it substantiates that the Oyster Creek Plant has a low RPS failure frequency and that the existing on-line functional testing supports this when the differences and sensitivities cited above are taken into consideration.
Very truly yours, Vice President and Director Oyster Creek 1r/0487t cc: Administrator Region I S
U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pa.
19406 NRC Resident Inspector
~
Oyster Creek Nuclear Generating Station Forked River, N. J.
08731 s
)