ML20215M066

Final Conformance to Generic Ltr 83-28,Item 2.2.2--Vendor Interface Programs for All Other Safety-Related Components: Perry Unit 1, Informal Rept

ML20215M066
Person / Time
Site:	Perry
Issue date:	05/31/1987
From:	Stoffel J EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20215M061	List: ML20215M056 ML20215M066
References
CON-FIN-D-6001 EGG-NTA-7627, GL-83-28, NUDOCS 8706260266
Download: ML20215M066 (16)

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. . ) National? "l 4 M CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.2--

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DISCLAIMER i

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l This book was prepared as an account of work sponsored by an agency of the United l States Government. Neither the United States Governmunt nor any agency thereof, l

nor any of their employees, mskes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product or process disclosed, or represents that its use would not infringe privately owned rights. References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favonng by the United States Govemment or any agency thereof. The views and opinions of  !

authors expressed herein do not ne:essarily state or reflect those of the United States Government or any agency thereof. ,

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EGG-NTA-7627 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LE1TER 83-28, ITEM 2.2.2-- l VFNDOR INTERFACE PROGRAMS FOR ALL OTHER SAFETY-RELATED COMPONENTS '

PERRY-1 l

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Docket Nos. 50-440/50-441 1

J. W. Stoffel i

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I Published May 1987 1

idaho National Engineering Laboratory l EG&G Idaho, Inc. l Idaho Falls, Idaho 83415 i

Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 under DOE Contract No. DE-AC07-76ID01570 FIN No. 06001

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ABSTRACT  !

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This EG&G Idaho, Inc., report provides a review of the submittals from j the Cleveland Electric Illuminating Company regarding conformance to Generic Letter 83-28, Item 2.2.2, for the Perry Nuclear Power Plant. l 1

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Docket Nos. 50-440 ii ,

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FOR EWORD .  ;

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This report is supplied as part of the program for evaluating _

licensee / applicant conformance to Generic . Letter _83-28, " Required Actions 1 Based'on Generic Implications of Salem ATWS Events." This work is being conducted for the U.S. Nuclear, Regulatory Canmission, Office of Nuclear.

Reactor Regulation, Division of PWR Lice'rsing-A, by EG&G Idaho, Inc., NRR 'l and I&E Support Branch.  :

The U.S. Nuclear Regulatory Commission funded' this work under the authorization B&R No. 20-19-40-41-3, FIN'No. 06002.

1 Docket Nos,. 50-440' iii

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CONTENTS A B S TR A C T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - 11 F0 R E WOR D ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

1. . INTRODUCTION ..................................................... 1 a

2. R E V I E W - CO NTE NT = AN D FORM AT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

-' 3. ITEM 2.2.2 - PROGRAM DESCRIPTION .............................. .. 3 3.1 Guideline .................................................. 3 3.2 Evaluation................................................. 3 3.3 Conclusion ................................................. 4

4. PROGRAM WHERE VENDOR: INTERFACE CANNOT PRACTICABLY BE E S TA B L I S HE D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1 4.1 Guideline .................................................. 5 4.2 E v a l u at i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 4.3 Conclusion ................................................. 6

5. RESPONSIBILITIES OF LICENSEE / APPLICANT AND VENDORS THAT PROVIDE l SERVICE ON SAFETY-RELATED EQUIPMENT .............................. 7- j

.4 5.1 Guideline .................................................. 7 i 7 1 5.2 Evaluation .................................................

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5.3 Conclusion ................................................. 7. ,

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6. CONCLUSION ....................................................... 8 j

7. REFERENCES ......................................................... 9 (

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CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.2--

VENDOR INTERFACE PROGRAMS FOR ALL OTHER SAFETY-RELATED COMPONENTS:

PERRY-1

1. INTRODUCTION On February 25,'1983, both of the scram circuit breakers at Unit 1 of t- the Salem Nuclear Power Plant failed to open upon an automatic reactor trip-signal from the reactor protection system. This incident was terminated l manually by the operator about 30 seconds after the initiation of the j automatic trip signal. The failure of the circuit breakers was determined to be related to the sticking of the undervoltage trip attachment. Prior

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to this incident, on Fcbruary 22, 1983, at Unit 1 of the Salem Nuclear

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Power Plant, an automatic trip signal was generated based on steam j generator low-low level during plant startup. In this case, the reactor 'l was tripped manually by the operator almost coincidentally with the j automatic trip.

Following these incidents, on February 28, 1983, the NRC Executive Director fcr Operations (ED0), directed the NRC staff to investigate and l report on the generic implications of these occurrences at Unit 1 of the Salem Nuclear Power Plant. The results of the staff's inquiry into the generic implications of the Salem unit incidents are reported in NUREG-1000, " Generic Implications of the ATWS Events at the Salem Nuclear Power Plant." As a result of this investigation, the Commission (NRC)

I requested (by Generic Letter 83-28 dated July 8, 1983 ) all licensees of operating reactors, applicants for an operating license, and holders of construction permits to respond to the generic issues raised by the analyses of these two ATWS events.

This report is an evaluation of the responses submitted by the Cleveland Electric Illuminating Company, the licensee for the Perry Nuclear

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Power Plant, for Item 2.2.2 of Generic Letter 83-28. The documents  ;

reviewed ae, a part of this evaluation are listed in the references at the end of thi; report. This material provided by the licensee also applied to Unit No. 2; however, this unit was subsequently cancelled.

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2. REVIEW CONTENT AND FORMAT

-Item 2.2.2 of Generic Letter'83-28-requests the licensee or applicant to submit, for.the staff review, a description of their programs for

. interfacing with the vendors of all safety-related' components including supporting information, in ' considerable detail, as indicated in the s guideline section for_each~ case.within this report.

o These guidelines treat cases where direct vendor contact programs are pursued, treat! cases where such contact cannot practically be' established,  !

and establish responsibilities of licensees / applicants and vendors that-provide service on-safety-related' components or equipment.-  ;

As previously indicated,L the cases' of Item 2.2.2 are evaluated ~ in a separate.section in which the guideline is presented; an evaluation of the licensee's/ applicant's response is made; and conclusions about the programs

-of the licensee or applicant for their vendor interface program for safety-related components and. equipment are drawn.

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3. ITEM 2.2.2 - PROGRAM DESCRIPTION .

i' 3.1 Guideline The licensee or applicant response should describe their program for I s establishing and maintaining interf aces with vendors of safety-related -

components which ensures that vendors are contacteo on a periodic basis and  ;

a t that receipt of vendor equipment. technical information (ETI) is acknowledged ]

or otherwise verified.

This program description should establish that such interfaces are' established with their NSSS vendor, as well as with the vendors of key safety-related components such as diesel generaters, electrical switchgear, l auxiliary feedpumps, emergency core cooling system (ECCS) pumps, batteries, battery chargers, and valve operators, to facilitate the exchange of current' technical information. The description..should verify that controlled j procedures exist for handling this vendor technical information which ensure  ;

that it is kept current and complete and that it is incorporated into plant operating, maintenance and test procedures as is appropriate.-

3.2 Evaluation The licensee for the Perry Nuclear Power Plant responded to these requirements with a submittal dated April 6, 1984.2 This submittal- l includes information that describes their past and current vendor interface programs. In the review of the licensee's response to this item, it was assumed that the information and documentation supporting this program is available for audit upon request. We have reviewed the information  !

submitted and note the following.

i The licensee's response states that they actively participate in the Nuclear Utility Task Action Committee (NUTAC) program. The Vendor Equipment >

Technical Information. Program (VETIP) was developed by NUTAC. VETIP r

includes" interaction with the NSSS vendor and with other electric 3- )

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t ' t- utilities.hTypical NSSS vendor contact with the licensee includes, but is I' not:liditekto: i0CFRReporting,UrgentCommunications, Service 4, Information Letters, Turbine Information Letters, Service Advice Letters,  ;

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Operation and Maintenance Manuals, Application Information Documents, Field Disposition liistructions and Field Deviation Desposition Requests. The

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i 7s, lic.ensee also states that new or revised procedures to implement the a

^ M NUTAC/VETIP pr'og' ram are to have been in place by June 1984

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,m i$ pg r One of; the VETIP implementation responsibilities is to seek assistance j g and equipme$t technical information from the vendors of safety-related

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> equipment (other than the NSSS vendor) when the' licensee's evaluation of an ,

, equlpment problem or an. equipment technical information problem concludes I that such l interaction; iinecessary or would be beneficial. Section 2.2.2 of s

the generic letter. states that formal vendor interfaces should be l established with ven/ dors / esides b the NSSS vendor. The licensee has not I indicated that any hi$1 interface program has been established'with i

vendorsotheNthasLtfeNSSS-vendor.

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_ , 3.3 Conclusion -

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We conclude that,\with the exception of interaction with the vendors of l

other safety-related equipment, the licensee's response regarding program'

^ description is complete.and, therefore, acceptable. The licensee should I establish a program to periodically contact vendors of. key components (such as auxiliary feedwater pumps, safety-related batteries, ECCS pumps and' .

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, safety-related valv,e operators) to facilitate the exchange of current t

\g - 4 technical infobkion.l1.lh the case of the diesel generator and '

ym safety-re1Sted eledtrical switchgear vendors, the licensee shculd establish -}

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interface similar.to that with the NSSS vendor, if practicable. 9 '

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4. PROGRAM WHERE VENDOR INTERFACE CANNOT PRACTICABLY BE ESTABLISHED 4.1 Guideline The licensee / applicant response should describe their program for compensating for the lack of a formal vendor interface where such an 5 interface cannot be practicably established. This program may reference the NUTAC/VETIP program, as described in INP0 84-010, issued in March 1984. If the NUTAC/VETIP program is referenced, the response should describe how procedures were revised to properly control and implement this program and to incorporate the program enhancements described in Section 3.2 of the NUTAC/VETIP report. It should also be noted that the  !

lack of either a formal interface with each vendor of safety-related equipment or a program to periodically contact each vendor of safety-related equipment will not relieve the licensee / applicant of his 3 responsibility to obtain appropriate vendor instructions and information where necessary to provide adequate confidence that a structure, system or  ;

component will perform satisfactorily in service and to ensure adequate quality assurance in accordance with Appendix B to 10 CFR Part 50.

4.2 Evaluation The licensee provided a brief description of the vendor interface program. Their description references the NUTAC/VETIP program. The licensee stated that plant instructions and procedures were to be in place by June 1984 to assure that the VETIP program is prcperly controlled and implemented.

VETIP is comprised of two basic elements related to vendor equipment

• problems; the Nuclear Plant Reliability Data System (NPRDS) and the Significant Evert Evaluation and Information Network (SEE-IN) programs.

VETIP is designed to ensure that vendor equipment problems are recognized, evaluated and corrective action taken.

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l Through participation in the NPRDS program, the licensee submits engineering information, failure reports and operating histories for review under the SEE-IN program. Through the SEE-IN program, the Institute of Nuclear Power Operations (INPO) reviews nuclear plant events that have been reported through the NPROS programs and Nuclear Network and NRC reports.

Based on the significance of the event, as determined by the screening ,

l review, INPO issues a report to all utilities outlining the cause of the event, related problems and recommends practical corrective actions. These <

l reports are issued in Significant Event Reports, and Significant Operating Experience Reports and as Operations and Maintenance Reminders. Upon receipt of these documents, the licensee evaluates the information to ,

determine applicability to the facility. This evaluation is documented and corrective actions are taken as determined necessary.

1 The licensee's response states that procedures to review and evaluate  ;

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incoming equipment technical information and to incorporate it into j existing procedures were to be in place by June 1984. l l

4.3 Conclusion j 1

We find that the licensee's response to this concern is adequate and acceptable. This finding is based on the understanding that the licensee's ]

commitment to implement the VETIP program includes the implementation of the enh,ncements described in Section 3.2 of the NUTAC/VETIP program to the extent that the licensee can control or influence the implementation of these recommendations. l l

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5. RESPONSIBILITIES OF LICENSEE / APPLICANT AND VENDOR THAT PROVIDE SERVICE ON SAFETY-RELATED EQUIPMENT 5.1 Guideline The licensee / applicant response should verify that the responsibilities of the licensee or applicant and vendors that provide t service on safety-related equipment are defined such that control of applicable instructions for maintenance work on safety-related equipment are provided.

5.2 Evaluation The licensee's response commits to implement the NUTAC/VETIP program.

They further state that their present and revised programs and procedures adequately implement this program. The VETIP guidelines include implementation procedures for the internal handling of vendor services.

i 5.3 Conclusion We find the licensee's commitment to implement the VETIP recommendations acceptable, with the understanding that the licensee's commitment includes the objective for " Internal Handling of Vendor Services" described on page 23 of the March 1984 NUTAC report.

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6. CONCLUSION Based on our review of the licensee's response to the specific I requirements of item 2.2.2 for Perry-1, we find that the licensee's interface program with its NSSS supplier, along with the licensee's commitment to implement the NUTAC/VETIP program, is acceptable. This is .

based on the understanding that the licensee's commitment to implement the ,

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NUTAC/VETIP program includes the objective for " Internal Handling of Vendor Services" described on page 23 of the March 1984 report and includes the enhancements described in Section 3.2 of the report to the extent that the licensee can control or influence such enhancements. l In addition, the licensee should establish a program to periodically I i

contact vendors of key components (such as auxiliary feedwater pumps, l safety-related batteries, ECCS pumps and safety-related valve operators) to facilitate the exchange of current technical information. In the case of the diesel generator and safety-related switchgear vendors, a formal interface, such as that established with the NSSS vendor, should be established, if practicable.

We find the same conclusion applies to Perry-2; however, this project was subsequently cancelled.

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7. REFERENCES

1. Letter,. NRC (D. G. Eisenhut), to all Licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits,

" Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," July 8,1983.  ;

2. Letter, Cleveland Electric Illuminating Company. -(MurrayR.'Edelman) to NRC, " Response to Generic Letter'83-28," April 6,1984.

3. Vendor Eauinnent- Technical Information Program, Nuclear Utility Task l Action Committee on Generic Letter 83-28, Section 2.2.2, March 1984, I INP0 84-010.

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• May 1987 l P. PER70RMING ORGANi2 Af ton NAM 4 AND MalLING ADOntSt Isar-m to Coms e PROJ4CTITASE/ WORE UNtf NuMSSR EG&G Idaho, Inc. i P. 0. Box.1625 l Idaho Falls', ID 83415 D6001

10. $PONSORiNG ORG ANIZ ATION NAME AND MAILING ADDRESS flarfum te Cent Ile.fYPtOPREPORY Division of PWR Licensing - A

. Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission . PeaiOOcOviaior,-~ e m -,

Washington, DC 20555

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