ML20140C990

Suppl 1 to Safety Evaluation Supporting Util 851114 Response to Generic Ltr 83-28,Item 3.2.2 Re Test & Maint Procedures

ML20140C990
Person / Time
Site:	Farley
Issue date:	03/19/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20140C956	List: ML20140C951 ML20140C990
References
GL-83-28, NUDOCS 8603250545
Download: ML20140C990 (2)

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Enclosure SAFETY EVALUATION (SUPPLEMENT 1)

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BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO GENERIC LETTER 83-28, ITEM 3.2.2 JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 DOCKET N05. 50-348 AND 50 ..,

Evaluation and Conclusion By letters dated September 6, 1983, November 4, 1983, February 6, 1984, February 15, 1984, June 25, 1984 and July 17, 1985, Alabama Power Company (APCo),

the licensee of Farley Plant, Units 1 and 2, provided information regarding.their compliance to Sections 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1, and 4.5.1 of GL 83-28.

We evaluated the licensee's responses against the NRC positions described in the GL for completeness and adequacy. We concluded that the responses to Items 3.1.1, 3.2.1, 3.2.1, 4.1,- and 4.5.1 were adequate and met the intent of GL 83-28; however, the licensee's response to Action Item 3.2.2 was incomplete, thus requiring additional information to determine acceptability. In a letter dated June 13, 1985, NRC requested the licensee to provide additional information regarding Item 3.2.2. The licensee responded to our request for addition information in a supplemental response dated July 17, 1985. This response was reviewed and was also determined to be unacceptable. Subsequently, the Safety Evaluation Report with identified deficiencies for Item 3.2.2 was transmitted to the licensee in a letter dated September 10, 1985. The licensee responded to our request for additional information in a second supplemental response dated November 14, 1985. We have ' evaluated this response and concluded that it is acceptable and meets the intent of GL 83-28. In this response, APCo provided reasonable justification that appropriate vendor and engineering test guidance has been included in test and maintenance procedures. Their response also stated that the intent of Item 3.2.2 is satisfied without the completion of a specific re-review of procedures and recommendations. The licensee stated that the initial development of test and maintenance procedures for Farley Nuclear Plant were based on recommendations provided by vendors in the form of technical manuals, recommendations provided by the Architect / Engineers, recommendations made by vendor representatives during startup and testing of equipment, and recommendations made by engineers with expertise 'in startup and operation of nuclear power facilities.

Additionally, the licensee indicated that over the course of plant life, i procedures have been modi fied to be consistent with the plant specific application of the equipment. The licensee also stated that plant procedures require that technical bulletins, whether solicited or unsolicited, be reviewed by APCo personnel to- determine the applicability of the recommendation. The licensee stated that this review is based on experience gained over the course of plant life and engineering judgement. The licensee stated that in order to ensure that maintenance and test procedures for equipment furnished by the major supplier are maintained current, they have developed a contact program with Westinghouse Corporation, Colt Industries, and General Electric Corporation. The 8603250545 060319 PDR ADOCK 05000348 p PM

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i licensee has entered into a contractual agreement to require acknowledgement receipt of vendor information. As part of.the contract, the vendor has supplied the . licensee with a list of all previously issued re. commendations applicable to FNP and annually the vendor will issue a cummulative listing summarizing bulletins issued during the course of the year. The licensee confirmed that this

contact program ensures that all technical information issued by these vendors has been reviewed for applicability since commencement of commercial operations.

i The licensee also indicated that after the issuance of GL 83-28 they established procedures for the formal review of vendor technical bulletins. The procedures provide guidance to' personnel on the receipt, review, and appropriate actions to' be taken for vendor bulletins applicable to FNP. Based on review of the j information submitted by the licensee in their supplemental response dated November 14, 1985, we conclude that the licensee's actions on GL 83-28 Action Item 3.2.2 are acceptable and meet the intent of GL 83-28.

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