NRC Generic Letter 1990-03

NRC Generic Letter 1990-003: Relaxation of Staff Position in Generic Letter 83-28, Item 2.2 Part 2 Vendor Interface for Safety-Related Components

ML031140578
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Washington Public Power Supply System, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Clinch River
Issue date:	03/20/1990
From:	Partlow J G Office of Nuclear Reactor Regulation
To:
References
GL-83-028 GL-90-003, NUDOCS 9003140089
Download: ML031140578 (6)

^s-UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555March 20, 1990TO

ALL POWER REACTOR LICENSEES AND APPLICANTSSUBJECT: RELAXATION OF STAFF POSITION IN GENERIC LETTER 83-28, ITEM 2.2PART 2 "VENDOR INTERFACE FOR SAFETY-RELATED COMPONENTS"(GENERIC LETTER NO. 90-03)This letter is to clarify the staff position in Part 2 of Item 2.2 of GenericLetter 83-28 (Vendor Interface for Safety-Related Components).The original position reads as follows:"For vendor interface, licensees and applicants shall establish,implement and maintain a continuing program to ensure that vendorinformation for safety-related components is complete, current andcontrolled throughout the life of their plants, and is appropriatelyreferenced or incorporated in plant instructions and procedures. Vendorsof safety-related equipment should be contacted and an interfaceestablished. Where vendors cannot be identified, have gone out ofbusiness, or will not supply information, the licensee or applicant shallassure that sufficient attention is paid to equipment maintenance,replacement, and repair, to compensate for the lack of vendor backup, toassure reliability commensurate with its safety function (GDC-1). Theprogram shall be closely coupled with action 2.2.1 (equipmentclassification). The program shall include periodic communication withvendors to assure that all applicable information has been received.The program should use a system of positive feedback with vendors formailings containing technical information. This could be accomplishedby licensee acknowledgement for receipt of technical mailings. It shallalso define the interface and division of responsibilities among thelicensee and the nuclear and non-nuclear divisions of their vendors thatprovide service on safety-related equipment to assure that requisitecontrol of and applicable instructions for maintenance work onsafety-related equipment are provided."Since this position was established, the industry has generally takenthe position that the Vendor Equipment Technical Information Program (VETIP)described in the Nuclear Utility Task Action Committee (NUTAC) Report, INPO84-010 issued in March 1984, meets the intent of Generic Letter 83-28,Item 2.2 Part 2.- The VETIP program includes the Nuclear Plant ReliabilityData System (NPRDS) and the Significant Event Evaluation and InformationNetwork (SEE-IN), both managed by INPO. It also includes existing programsthe utilities now conduct with vendors. In particular, it includesinteraction with the NSSS vendor.90031 40089

-2 -The staff has reviewed the VETIP program and has had the benefit ofconsiderable discussions with licensees regarding vendor interface. It isnow recognized that implementing a formal vendor interface program for everysafety-related component is not practical. It is also recognized thatvendors may not always be in the best position to analyze a failure becausethey may not be aware of the components' application, environment ormaintenance history. Therefore, we conclude that the elements of VETIPprovide a framework to improve the quality and availability of equipmenttechnical information for use by utility licensees.Experience has shown that many vendors, in addition to NSSS vendors, do producevaluable information relating to their equipment. For this reason, the staffconcludes that an adequate vendor interface program should include:(a) A program with the NSSS vendor as described in the VETIP, whichcovers all the safety-related components within the NSSS scope ofsupply. This program should include provisions for assuring receiptby the licensee/applicant of all technical information provided bythe NSSS vendor; and(b) A program of periodic contact with the vendors of other keysafety-related components not included in (a) above.The vendor interface program should also take into account the requirements of10 CFR Part 50, Appendix B which requires the licensee or applicant to beresponsible for establishing and executing the quality assurance program. Itstates that the licensee or applicant may delegate to others the work ofestablishing and executing the quality assurance program or any part of it, butthe licensee or applicant shall retain responsibility for the program.Therefore, the licensee or applicant should have a program which assures thatprocedures and instructions are properly prepared and implemented and thatquality assurance programs for design, maintenance or modification workperformed on safety-related equipment by outside vendors or contractors areproperly implemented. These programs should clearly establish and delineatein writing the authority and duties of persons and organizations performingactivities affecting this safety-related equipment.The programs in (a) above should provide for the licensee or applicant toreceive all updates to instruction and maintenance manuals, technicalinformation bulletins, revised test procedures, and updated replacement partsinformation. The programs should include provisions which ensure thelicensee receives all such vendor issued information pertinent to itssafety-related equipment.The program described in (b) above is not intended to be as extensive as theprogram in (a), but is intended to be a good faith, documented effort toperiodically contact the vendors of key, safety-related components (such asauxiliary feedwater pumps, batteries, inverters, battery chargers, coolingwater pumps and valve operators), not already included in the interfaceprogram of la) above, to obtain any technical information applicable to this

-3 -equipment. Documented periodic contact via telephone is sufficient. It isexpected that a reasonable and prudent review of operating experience,availability of vendor information, and component safety significanceusing insights obtained from generic or plant specific probabilistic riskanalyses will yield a set of component vendors that will make up eachlicensee's program. In the event that vendors have gone out of business,cannot be identified, or will not supply information, the licensee orapplicant should implement or continue to maintain a program that willassure that sufficient attention is paid to equipment maintenance, replacement,and repair to compensate for the lack of vendor backup such that equipmentreliability commensurate with its safety function is assured.Licensees and applicants are requested to review their present vendor interfaceprograms and modify their programs as necessary to assure that both of theelements set out above are met. Pursuant to Section 182 of the Atomic EnergyAct and 10 CFR 50.54(f), the NRC requires that licensees report to the NRCwithin 180 days of receipt of this generic letter whether or not they havetaken the actions requested.Licensees undertaking the actions requested should confirm that they haveexamined their vendor interface programs, that their programs either alreadyinclude both of the elements set out in this letter or that the elements havebeen scheduled for implementation. If licensee actions are not complete atthe time of their submittal, the licensee should submit a completion date forthe remaining actions to be taken. If the licensee declines to undertake theactions requested by this letter, the licensee is required to provide justifi-cation for the position.The response to this letter is to be provided under oath or affirmation and isnecessary to enable the Commission to determine whether or not your licenseshould be modified, suspended, or revoked. The response shall be addressed tothe U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,Washington, D. C. 20555. The NRC will continue to monitor the effectivenessof licensee or applicant vendor interface program implementation through theinspection process and will use the responses to this letter to plan andlocate resources for inspections. Where a licensee's failure to (1) obtaininformation from vendors, (2) evaluate information obtained from vendors, or(3) implement necessary actions based on information obtained from a vendorresults in conditions adverse to quality, the NRC will make findings and takeaction in accordance with its regulations.This request is covered by the Office of Management and Budget Clearance Number3150-0011, which expires January 31, 1991. The estimated average burden hoursis 320 person hours per licensee response (144 person hours per year perlicensee thereafter), including assessment of the new recommendations,searching data sources, gathering and analyzing the data, and preparing therequired letters. Send comments regarding this burden estimate or any otheraspect of this collection of information, including suggestions for redutingthis burden, to the Records and Reports Management Branch, (MNBB-7714) Divisionof Information Support Services, Office of Information Resources Management,U.S. Nuclear Regulatory Commission, Washington, D. C. 20555; and to thePaperwork Reduction Project (3150-0011), Office of Management and Budget,Washington, D. C. 20503.

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Backfit Discussion

The actions described in this generic letter are relaxations of the originalposition taken in Generic Letter 83-28 and are not considered a backfit inaccordance with NRC procedures. An evaluation of this letter was performed inaccordance with the charter of the Committee to Review Generic Requirements(CRGR) and will be made available in the public document room with the minutesof the 178th meeting of the CRGR.If you have any questions about this matter, please contact the NRC projectmanager or the technical contact listed below.Sincerely,J4~7 sLJeJames G. PartlowAssociate Director for ProjectsOffice of Nuclear Reactor RegulationEnclosure:Listing of Recently IssuedGeneric LettersTechnical Contacts:S. Newberry, NRR(301) 492-0782D. LaBarge, NRR(301) 492-1421 LIST OF RECENTLY ISSUED GENERIC LETTERSGenericDate ofTeV cancaIssued Toe..k A41Letter No. zUDJecL ---..-- ._____-._90-0290-0189-2389-2289-2189-2089-19ALTERNATIVE REQUIREMENTS 02/01/90FOR FUEL ASSEMBLIES IN THEDESIGN FEATURES SECTION OFTECHNICAL SPECIFICATIONSREQUEST FOR VOLUNTARY 01/18/90PARTICIPATION IN NRCREGULATORY IMPAC SURVEYNRC STAFF RESPONSES TO 10/23/89QUESTIONS PERTAINING TOIMPLEMENTATION OF 10 CFRPART 26 -GENERIC LETTER89-23POTENTIAL FOR INCREASED ROOF 10/19/89LOADS AND PLANT AREA FLOODRUNOFF DEPTH AT LICENSEDNUCLEAR POWER PLANTS DUE TORECENT CHANGE IN PROBABLEMAXIMUM PRECIPITATIONCRITERIA DEVELOPED BY THENATIONAL WEATHER SERVICE(GENERIC LETTER 89-22)REQUEST FOR INFORMATION 10/19/89CONCERNING STATUS OFIMPLEMENTATION OF UNRESOLVEDSAFETY ISSUE (USI) REQUIREMENTSPROTECTED AREA LONG-TERM 09/26/89HOUSEKEEPINGALL LWR LICENSEESAND APPLICANTSALL LICENSEES OFOPERATING REACTORS &CONSTRUCTION PERMITSFOR LWR NUCLEAR POWERPLANTSALL HOLDERS OFOPERATING LICENSEESAND CONSTRUCTIONPERMITS FOR NUCLEARPOWER PLANTSALL LICENSEES OFOPERATING REACTORS ANDHOLDERS OF CONSTRUCTIONPERMITS (EXCEPT BYRONBRAIDWOOD, VOGTLE,SOUTH TEXAS, AND RIVERBEND)ALL HOLDERS OFOPERATING LICENSESAND CONSTRUCTIONPERMITS FOR NUCLEARPOWER REACTORSALL FUEL CYCLEFACILITY LICENSEESWHO POSSESS, USE,OR PROCESS FORMULAQUANTITIES OFSTRATEGIC SPECIALNUCLEAR MATERIALALL LICENSEES OFOPERATING REACTORS,APPLICANTS FOROPERATING LICENSESAND HOLDERS OFCONSTRUCTION PERMITSFOR LIGHT WATERREACTOR NUCLEARPOWER PLANTSREQUEST FOR ACTION RELATED TO 09/20/89RESOLUTION OF UNRESOLVEDSAFETY ISSUE A-47 "SAFETYIMPLICATION OF CONTROLSYSTEMS IN LWR NUCLEARPOWER PLANTS" PURSUANT TO10 CFR 50.54(f)

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Backfit Discussion

The actions described in this generic letter are relaxations of the originalposition taken in Generic Letter 83-28 and are not considered a backfit inaccordance with NRC procedures. An evaluation of this letter was performed inaccordance with the charter of the Committee to Review Generic Requirements(CRGR) and will be made available in the public document room with the minutesof the 178th meeting of the CRGR.If you have any questions about this matter, please contact the NRC projectmanager or the technical contact listed below.Sincerely,) & original signed by:Gary M. HolahanJames G. PartlowAssociate Director for ProjectsOffice of Nuclear Reactor RegulationEnclosure:Listing of Recently IssuedGeneric LettersTechnical Contacts:S. Newberry, NRR(301) 492-0782D. LaBarge, NRR(301) 492-1421DISTRIBUTION:Central FilesNRC PDRPD0-1 ReadingDLaBarge*SEE PREVIOUS PAGE FOR CONCURRENCE:PDI-1 :PDI-1 :AEOD :PDI-1 :DRP DRSP :DST:CVogan* :DLaBarge:rsc*DAllison* RCapra* MSlosson* RDudley* AThadani*:2/26/90 :2/26/90 :2/26/90 :2/26/90 :2/26/90 :2/26/90 :3/1/90DRIS DOEA / ' NR 3 PMAS:NRRBGrimes* CBerlinger* L)GPartlow:sam HSmith*3/5/90 3/6/90 3/j /90 3/9/90OFFICIAL RECORD COPYDocument Name: ALL PROJECT MGRS/GL83 28