ML20238C364
| ML20238C364 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 09/01/1987 |
| From: | Andrews R OMAHA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-83-28, LIC-87-596, NUDOCS 8709100061 | |
| Download: ML20238C364 (6) | |
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Omaha Public Power District 1623 Harney Ornaha, Nebraska 68102 402/536-4000 September 1, 1987 LICJ87-596 U. S. Nuclear Regulatorv Commission 1
ATTN: Document Control Lesk 1
Washington, DC 20555 i
References:
1.
Docket No. 50-285 2.
Letter from OPPD (W. C. Jones) to NRC (D. G. Eisenhut) dated November 4, 1983 (LIC-83-267) 3.
Letter from 0 PPD (R. L. Andrews) to NRC (J. R. Miller) dated May 24, 1985 (LIC-85-214) 4.
Letter from NRC (W. A. Paulson) to OPPD (R. L. Andrews) dated Mrrch 9, 1987 5.
Letter trom NRC (W. A. Paulson) to OPPD (R. L. Andrews) dated May 14, 1987 6.
Letter from OPPD (R. L. Andrews) to NRC (Document Control Desk) dated April 28, 1987 (LIC-87-278)
Gentlemen:
SUBJECT:
Generic Letter 83-28, Requests for Additional Information References 2 and 3 submitted the Omaha Public Power District's response to Generic Letter 83-28.
Based on these submittals References 4 and 5 requested that additional information be provided.
Reference 6 requested an extension to allow the responses to both requests be provided at the same time.
Please find attached the additional information which was requested.
If you have any questions, please contact us.
Sincerely, d.I hau+t 1 /et R. L. Andrews Division Manager Nuclear Production RLA/me cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Ave., N.W.
Washington, DC 20036 l
A. Bournia, NRC Project Manager j
R. D. Martin, Regional Administrator P. H. Harrell, NRC Senior Resident Inspector 8709100061 870901 3 \\
PDR ADOCK 05000285 i
p PDR 4s m.:
t meioumeni wun i auampponunay Mdif> F emale
fTTACHMENT I
l The fcliowing additional information is provided for items 2.1 (Part 2) and 2.2 (Part 2) of Generic Letter 83-28 as requested by Reference 4.
1.
Item 2.1 (Part 2) " Vendor Interface (RE6ctor Trio System Components")
l Our review of OPPD's submittals indicates that OPPD has identified an interface with their nuclear steam supply system vendor. However, we cre unable to determine that OPPD's vendor interface program encompasses a periodic and continuirg faedback mechanism.
Item 2.1 (part 2) states that
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the vendor interface program shall include periodic communication with j
vendors to assure that all applicable information has been received.
j Please describe how your program assures that all relevant material is received properly evaluated, implemented and maintained during the life of i
the plant.
l Responsg:
Fort Calhoun Station Administrative Standing Order G-62 was written to control vendor technical information which includes originally supplied vendor manuals, vendor supplied addendums and may include NRC Bulletins and INP0 notices.
The purpose of this procedure is to establish a continuing program to ensure and demonstrate that vendor technical information for installed safety-related equipment is complete, current, accurate and controlled. The procedure details the steps to be taken to ensure proper receipt, evaluation, implementation and maintenance of vendor technical information. As part of the establishnant of the Vendor Manual Program, vendors have been contacted to update existin; information.
However, since the program is still in the process of completing initial reviews of the vendor manuals and verifying the information, detailed steps to define the nature of the periodic communication with the vendors have not yet been j
in'srporated.
The procedure will be reviewed and updated by January 15, 1988 to reflect the need to perform periodic communication with vendors of key components.
2.
Item 2.2 (Part 2) "Eauipment Classification (Proarams for All i
Safety-related Comoonents)"
Item 2.2.1 - Proaram l
OPPD's responses do not confirm that all safety-related components are designated as safety-related on plant documents such as procedures, system l
descriptions, test and maintenance instructions, operating procedures, and l
in information handling systems so that personnel performing activities that affect such safety-related components are aware that they are working i
on safety-related components and are guided by safety-related procedures and constraints.
Please state whether your equipment classification conforms with the above
,l staff position.
If all safety-related components are not designated as l
safety-related on the relevant documents, please provide specific descriptions of the exceptions and provide a justification for such 7
l exceptions ter staff review.
CResoonse:
OP' D does not designate components as safety related on relevant documents P
such as procedures, system descriptions, test and maintenance' instructions, operating procedures, and in all information handling systems.
The justification is that alternate methods have been developed to'ensute that personnel performing activities that affect Critical Quality Element (CQE) components are aware that they are working on CQE components and are guided by approved procedures that have been appropriately constrained.
The: alternate method relies on the. use of a CQE List. The term CQE was
- originally developed to designate components that were_ covered by the Quality Assurance Plan. As required by the NRC (AEC),'0 PPD classified the piping and mechanical components by putting flags on the piping and instrumentation diagrams (P& ids) to delineate safety classifications per the guidance of ASME Boiler and Pressure Vessel Code,Section III,1971 as modified by the guidelines contained in ANSI 18.2-1973.
The CQE List was developed to describe the purpose of the flags and the history of the relationship of the construction codes and standards to the location of the flag boundaries. The CQE List has been amended over the years to address the safety-classification and/or criteria of electrical components, structures, consumables, parts, and computer software.
As an adjunct to the CQE List, the Computerized History and Maintenance Planning System (CHAMPS) data base was developed.
The data base contains active, mechanical and electrical components and includes a field to document whether a component is CQE.
CHAMPS is used to write maintenance orders and keep a maintenance history on each component. The CHAMPS data base originally received an independent review against the CQE List.
Procedures are relied upon to ensure that the data base is kept current by requiring documentation for new equipment that is installed under a modification request.
To perform work on CQE components normally either a maintenance order, a preventative maintenance procedure, or safety related design change order is required. Maintenance orders and preventative maintenance procedures that are generated using CHAMPS are printed with the CQE classification given in the data base.
For maintenance orders, the classification is checked again by the Supervisor-Technical or designated alternate who assures the classification is correct for the equipment involved.
If the Supervisor-Technical believes that the work could impact equipment with a higher CQE classification, he can change the classification to reflect this.
This review prcvides a higher degree of assurance than simply designating whether an attached maintenance procedure applies to a CQE component. To install a modification, a safety relattd design change order is required for changes / impacts to CQE, fire protection, and radioactive waste processing system components.
In some cases, a special procedure is
' developed to perform testing or repetitive tasks. These special procedures are reviewed an0 approved by the PRC prior to implementation.
This approval process provides adequate control of work that will impact CQE components. Surveillance procedures are generally performed on CQE or
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limited CQE components and therefore are not marked as " safety related".
l The personnel designated as responsible for the performance of surveillance tests and special procedures either know cr work under the direction of a supervisor knowledgeable of'which components are CQE.
l
- Response (continued)
This alternate method of. providing a centralized document that provides not only a means to determine whether a component _is CQE but includes the i
guidance on why it.is CQE assures as high a degree of control. as designating.each document. Therefore, the Operating Procedures, Operating Instructions, System Descriptions, drawing retrieval system data base, records management system data base, and test instructions are not
-designated as safety related. Maintenance procedures, calibration procedures,-etc., that are performed under a maintenance order are designated because'the maintenance order has the CQE classification denoted.
3.
Item 2.2 (Part 2). " Vendor Interface (Proarams for All Safety-related
, Components)"
Please provide verification that he responsibilities and instructions for vendor-supplied services on saf' j-related equipment are defined and i.
controlled appropriately (consistent with p. 23 of the March 1984 NUTAC
-report'on Generic Letter 83-28, Section 2.2.2).
Response
The basic requirements for procurement of CQE services are set forth in the Quality Assurance Plan and are implemented through the Purchasing Manual and through the procedures of the organization within OPPD responsible for the procurement request.
CQE services are performed either by a vendor working under an OPPD approved QA/QC program or by a vendor working under OPPD supervision and therefore under the auspices of OPPD's Quality Assurance Plan.
Documentation that a CQE service will be performed under i vendor's QA/QC program is designated on the procurement documents generated by the Material Management Information System by the statement that the vendor is an " Approved Vendor". The " Approved Vendor" designation means that the Vendor's QA/QC program has been reviewed and approved by OPPD's Quality Assurance Division.
Procurement documents for services that will be performed under OPPD's QA/QC program are not annotated to reflect this information.
The following information is provided as requested by Reference 5.
4.
Item 2.2 (Part 21. " Vendor Interface (Proarams for All Safety-related Components}"_
l The staff finds the NUTAC/VETIP program acceptable for those instances where a vendor interface cannot be practicably established, e.g., where a vendor has gone out of business. However, the-licensee should commit to establish a program to periodically contact vendors of key components (such as auxiliary feed pumps,. 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 with the NSSS vendor should be established if practicable.
Response
A commitment was made in the response to Item 1 to review and update Standing Order G-62 to reflect the need to perform periodic communications with vendors of key components by January 15, 1988. The vendor of the diesel generators has gone out of business. OPPD plans to include the vendors of safety related switchgear in its list of key component suppliers and does not plan to establish a formal interface, v.,
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