Relaxation of Staff Position in Generic Letter 83-28, Item 2.2 Part 2 "Vendor Interface for Safety-Related Components" (Generic Letter 90-03)

March 20, 1990


TO:       ALL POWER REACTOR LICENSEES AND APPLICANTS 

SUBJECT:  RELAXATION OF STAFF POSITION IN GENERIC LETTER 83-28, ITEM 2.2
          PART 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 
Generic Letter 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 vendor 
     information for safety-related components is complete, current and 
     controlled throughout the life of their plants, and is appropriately 
     referenced or incorporated in plant instructions and procedures.  
     Vendors of safety-related equipment should be contacted and an 
     interface established.  Where vendors cannot be identified, have gone 
     out of business, or will not supply information, the licensee or 
     applicant shall assure that sufficient attention is paid to equipment 
     maintenance, replacement, and repair, to compensate for the lack of 
     vendor backup, to assure reliability commensurate with its safety 
     function (GDC-1).  The program shall be closely coupled with action 
     2.2.1 (equipment classification).  The program shall include periodic 
     communication with vendors to assure that all applicable information 
     has been received.  The program should use a system of positive 
     feedback with vendors for mailings containing technical information.  
     This could be accomplished by licensee acknowledgement for receipt of 
     technical mailings.  It shall also define the interface and division of 
     responsibilities among the licensee and the nuclear and non-nuclear 
     divisions of their vendors that provide service on safety-related 
     equipment to assure that requisite control of and applicable 
     instructions for maintenance work on safety-related equipment are 
     provided."

Since this position was established, the industry has generally taken the 
position that the Vendor Equipment Technical Information Program (VETIP) 
described in the Nuclear Utility Task Action Committee (NUTAC) Report, INPO 
84-010 issued in March 1984, meets the intent of Generic Letter 83-28, Item 
2.2 Part 2.  The VETIP program includes the Nuclear Plant Reliability Data 
System (NPRDS) and the Significant Event Evaluation and Information Network 
(SEE-IN), both managed by INPO.  It also includes existing programs the 
utilities now conduct with vendors.  In particular, it includes interaction 
with the NSSS vendor. 



9003140089 
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The staff has reviewed the VETIP program and has had the benefit of 
considerable discussions with licensees regarding vendor interface.  It is 
now recognized that implementing a formal vendor interface program for every 
safety-related component is not practical.  It is also recognized that 
vendors may not always be in the best position to analyze a failure because 
they may not be aware of the components' application, environment or 
maintenance history.  Therefore, we conclude that the elements of VETIP 
provide a framework to improve the quality and availability of equipment 
technical information for use by utility licensees. 

Experience has shown that many vendors, in addition to NSSS vendors, do 
produce valuable information relating to their equipment.  For this reason, 
the staff concludes that an adequate vendor interface program should 
include:

     (a)  A program with the NSSS vendor as described in the VETIP, which 
          covers all the safety-related components within the NSSS scope of 
          supply.  This program should include provisions for assuring 
          receipt by the licensee/applicant of all technical information 
          provided by the NSSS vendor; and

     (b)  A program of periodic contact with the vendors of other key 
          safety-related components not included in (a) above.

The vendor interface program should also take into account the requirements 
of 10 CFR Part 50, Appendix B which requires the licensee or applicant to be 
responsible for establishing and executing the quality assurance program.  
It states that the licensee or applicant may delegate to others the work of 
establishing and executing the quality assurance program or any part of it, 
but the licensee or applicant shall retain responsibility for the program.  
Therefore, the licensee or applicant should have a program which assures 
that procedures and instructions are properly prepared and implemented and 
that quality assurance programs for design, maintenance or modification work 
performed on safety-related equipment by outside vendors or contractors are 
properly implemented.  These programs should clearly establish and delineate 
in writing the authority and duties of persons and organizations performing 
activities affecting this safety-related equipment. 

The programs in (a) above should provide for the licensee or applicant to 
receive all updates to instruction and maintenance manuals, technical 
information bulletins, revised test procedures, and updated replacement 
parts information.  The programs should include provisions which ensure the 
licensee receives all such vendor issued information pertinent to its 
safety-related equipment. 

The program described in (b) above is not intended to be as extensive as the 
program in (a), but is intended to be a good faith, documented effort to 
periodically contact the vendors of key, safety-related components (such as 
auxiliary feedwater pumps, batteries, inverters, battery chargers, cooling 
water pumps, and valve operators), not already included in the interface 
program of (a) above, to obtain any technical information applicable to this
.

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equipment.  Documented periodic contact via telephone is sufficient.  It is 
expected that a reasonable and prudent review of operating experience, 
availability of vendor information, and component safety significance using 
insights obtained from generic or plant specific probabilistic risk analyses 
will yield a set of component vendors that will make up each licensee's 
program.  In the event that vendors have gone out of business, cannot be 
identified, or will not supply information, the licensee or applicant should 
implement or continue to maintain a program that will assure that sufficient 
attention is paid to equipment maintenance, replacement, and repair to 
compensate for the lack of vendor backup such that equipment reliability 
commensurate with its safety function is assured. 

Licensees and applicants are requested to review their present vendor 
interface programs and modify their programs as necessary to assure that 
both of the elements set out above are met.  Pursuant to Section 182 of the 
Atomic Energy Act and 10 CFR 50.54(f), the NRC requires that licensees 
report to the NRC within 180 days of receipt of this generic letter whether 
or not they have taken the actions requested.  

Licensees undertaking the actions requested should confirm that they have 
examined their vendor interface programs, that their programs either already 
include both of the elements set out in this letter or that the elements 
have been scheduled for implementation.  If licensee actions are not 
complete at the time of their submittal, the licensee should submit a 
completion date for the remaining actions to be taken.  If the licensee 
declines to undertake the actions requested by this letter, the licensee is 
required to provide justification for the position. 

The response to this letter is to be provided under oath or affirmation and 
is necessary to enable the Commission to determine whether or not your 
license should be modified, suspended, or revoked.  The response shall be 
addressed to the U.S. Nuclear Regulatory Commission, ATTN:  Document Control 
Desk, Washington, D. C. 20555.  The NRC will continue to monitor the 
effectiveness of licensee or applicant vendor interface program 
implementation through the inspection process and will use the responses to 
this letter to plan and locate resources for inspections.  Where a 
licensee's failure to (1) obtain  information from vendors, (2) evaluate 
information obtained from vendors, or (3) implement necessary actions based 
on information obtained from a vendor results in conditions adverse to 
quality, the NRC will make findings and take action in accordance with its 
regulations. 

This request is covered by the Office of Management and Budget Clearance 
Number 3150-0011, which expires January 31, 1991.  The estimated average 
burden hours is 320 person hours per licensee response (144 person hours per 
year per licensee thereafter), including assessment of the new 
recommendations, searching data sources, gathering and analyzing the data, 
and preparing the required letters.  Send comments regarding this burden 
estimate or any other aspect of this collection of information, including 
suggestions for reducing this burden, to the Records and Reports Management 
Branch, (MNBB-7714) Division of Information Support Services, Office of 
Information Resources Management, U.S. Nuclear Regulatory Commission, 
Washington, D. C. 20555; and to the Paperwork Reduction Project (3150-0011), 
Office of Management and Budget, Washington, D. C.  20503. 
.

                                    - 4 -


Backfit Discussion 

The actions described in this generic letter are relaxations of the original 
position taken in Generic Letter 83-28 and are not considered a backfit in 
accordance with NRC procedures.  An evaluation of this letter was performed 
in accordance with the charter of the Committee to Review Generic 
Requirements (CRGR) and will be made available in the public document room 
with the minutes of the 178th meeting of the CRGR. 

If you have any questions about this matter, please contact the NRC project 
manager or the technical contact listed below. 

                                 Sincerely,



                                 James G. Partlow
                                 Associate Director for Projects
                                 Office of Nuclear Reactor Regulation

Enclosure:
Listing of Recently Issued Generic Letters

Technical Contacts:
S. Newberry, NRR
(301) 492-0782

D. LaBarge, NRR
(301) 492-1421
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