ML20207S984
| ML20207S984 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/17/1987 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-83-28, NUDOCS 8703230022 | |
| Download: ML20207S984 (3) | |
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Alabama Power Company 600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291-0400 Telephone 205 250-183S IenioYvce7r sioent MENDM the southem electrc system 10CFR50.62 March 17, 1987 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:
Joseph M. Farley Nuclear Plant - Units 1 and 2 Generic Letter 83-28. Section 2_.2.2 Section 2.2.2 of Generic Letter 83-28 required licensees to establish, implement and maintain a continuing interface program to ensure that vendor information for safety-related components is complete, current and controlled throughout the life of the plant (s). By letter dated December 15, 1986, the NRC issued to Alabama Power Company a Safety Evaluation Report (SER) based on the Alabama Power Company responses to Section 2.2.2 dated November 4, 1983, June 25, 1984, and April 22, 1985. Based on the SER, the NRC found the Alabama Power Company program for addressing Section 2.2.2 to be acceptable. However, the SER states that the Alabama Power Company program for formal contact with the NSSS and two major Non-NSSS vendors should be expanded to include periodic contact with vendors of key components (such as the auxiliary feed pumps, safety related batteries, ECCS pumps and safety related valve operators) to facilitate the exchange of current technical information.
As stated in the Alabama Power Company response dated June 25, 1984, Alabama Power Company has developed a Vendor Equipment Technical Information Program (VETIP) structured around the Nuclear Plant Reliability Data System (NPRDS) and the Significant Event Evaluation and Information Network (SEE-IN) programs. This program, in addition to the formal contact programs established by Alabama Power Company with Westinghouse Electric Corporation (NSSS Supplier), Colt Industries, and General Electric, is an efficient and realistic approach to ensure that vendor equipment problems are recognized, evaluated and corrective actions taken.
In addition to the reviews conducted through these programs, Alabama Power Company procedures require a formal review of technical information issued in the form of unsolicited vendor technical information, Incident Reports, NRC Circulars and Hotices, 8703230022 870317 O
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Licensee Event Reports, Generic Letters, and Westinghouse Owners' Group Correspondence. - These reviews, coupled.with the VETIP and the contact programs with the NSSS Supplier'and two non-NSSS suppliers, provides -
- assurance that identified vendor. equipment: problems are handled in an efficient manner' and that proper corrective actions are taken. These programs have been discussed with the NRC on numerous occasions, _
particularly in a meeting scheduled by the NRC and held in Bethesda, Maryland on April 4,1985 between Mr. R. P. Mcdonald, Senior Vice President of Alabama Power Company, and the NRC Staff.- As documented by NRC letter:
' dated April 15, 1985, the NRC Staff agreed to review the objective of Section 2.2.2 of Generic Letter 83-28 in light of the discussions held during this meeting. During the twenty (20) months between the discussions of April 15', 1985 and issuance of the NRC SER on December 15, 1986, the NRC never indicated, either formally or informally, the need to further substantiate Alabama Power Company's position. Nevertheless, the NRC. issued the SER " based" on Alabama Power Company's responses which included requirements not acceptable to Alabama Power Company.
The original NRC requirement identified in Generic Letter 83-28 that a contact program be established with vendors of all safety-related components is not feasible and is unjustifiable. Such a contact program would require the identification of all vendors of safety-related components, which would require extensive research. Alabama Power Company estimates that this identification process would require approximately $800,000 for the Farley Nuclear Plant, Units 1 and 2.
Upon identification of the vendors of safety-related components, a formal contact would then be required with the vendor. outlining-the desire to establish a formal contact program. This would, 'in turn, require the vendor. to establish a program with its subvendors in addition to informing utilities of ongoing problems and to dedicate personnel to a specific piece of equipment for review and trending of field problem reports. This imposed requirement upon the vendor would ultimately result in additional costs which would then be passed on to the utility.
In most cases, vendors will have no incentive to establish such a program other than monetary reasons.
In addition to these concerns, it has been the experience of Alabama Power Company that vendor changes to manuals, bulletins, etc., typically occur only af ter significant frequent problems are experienced in the field. The VETIP program, which serves as a direct communication vehicle for the identification of such problems, is a more efficient and realistic approach to address the concerns expressed in Generic Letter 83-28, Section 2.2.2, than direct vendor contact programs.
It is the position of Alabama Power Company that the VETIP, the existing vendor contact programs established by Alabama Power Company with Westinghouse, General Electric and Colt Industries, and Alabama Power Company procedures meet the intent of Section 2.2.2 of Generic Letter 83-28. Any attempt to establish a formal contact program with vendors of
" key" components would require Alabama Power Company to examine all components other than those supplied by the NSSS and two major non-NSSS
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vendors to classify certain components as " key" components. Since " key" components have not been defined, a realistic technical approach to address Alabama Power Company and classify " key" components cannot be accomplished.
maintains that the programs developed and employed at Farley Nuclear Plant s
provide a realistic approach to comply with Section 2.2.2 of Generic Letter 83-28.
In conclusion, the SER issued to Alabama Power Company by the NRC on December 15, 1986 imposes additional requirements on Alabama Power Company.
These requirements were not addressed or agreed to in the April 4,1985 meeting with the NRC.
It is therefore Alabama Power Company's contention that the SER should be revised by the NRC to delete the requirement that additional contact programs be established with vendors of key components.
If there are any questions, please advise.
Respectfully submitted, ALBAMA POW R'CM ANY Yh R. P. Mcdonald RPM /RGW:ks-D65 cc: Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford