ML17055C891
| ML17055C891 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/02/1987 |
| From: | Donohow J Office of Nuclear Reactor Regulation |
| To: | Mangan C NIAGARA MOHAWK POWER CORP. |
| References | |
| GL-83-28, TAC-53692, NUDOCS 8703110256 | |
| Download: ML17055C891 (10) | |
Text
March 2, 1987 Docket No. 50-220 Mr. Charles V. Mangan Senior Vice President Niagara Mohawk Power Corporation 301 Plainfield Road
- Syracuse, New York 13212
Dear Mr. Mangan:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION - GENERIC LETTER 83-28, ITEM 2.2 (PART 1)
Re:
Nine Mile Point Nuclear Station, Unit No.
1 In letters dated November 8, 1983 and December 31, 1985, you submitted responses to Item 2.2 (Part 1) of Generic Letter 83-28.
The staff has reviewed the available information and finds that it needs the information and/or clarification requested in the enclosure in order to complete its review.
You should provide the requested information on a schedule to he negotiated with your NRC Project Manager.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under PL 96-511.
Sincerely, 87031 102S6 870302 R
ADOCK QS000220 PDR
Enclosure:
Information Request BWR Project Directorate ¹ Division of BWR Licensing Jack N.
Dono w, Jr., Acting Director 1
cc w/enclosure:
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Mr. C. V. Mangan Niagara mohawk Power Corporation Nine Mile Point Nuclear Station, Unit No.
1 CC:
Troy B. Conner, Jr., Esquire Conner 5 Wetterhahn Suite 1050 1747 Pennsylvania
- Avenue, N.
W.
Washington, D. C.
20006 Frank R. Church, Supervisor Town of Scriba R. D. 82
- Oswego, New York 13126 Niagara Mohawk Power Corporation ATTN:
Yir. Thomas Perkins Plant Superintendent Nine Mile Point Nuclear Station Post Office Box 32 Lycoming, New York 13093 Resident Inspector U. S. Nuclear Regulatory Commission
,Post Office Box 126
- Lycoming, New York 13093 John W. Keih, Esquire Niagara Mohawk Power Corporation 300 Erie Boulevard Hest
- Syracuse, New York 13202 Regional Administrator, Region I U. S. Nuclear Regulatory Commission
- 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. Jay Dunkleberger Division of Policy Analysis and Planning New York State Energy Office Agency Building 2 Empire State Plaza
- Albany, New York 12223
ENCLOSURE RE(jUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ITEM 2.2 (PART 1)
OF GENERIC LETTER 83-28 EQUIPMENT CLASSIFICATION (ALL OTHER SAFETY-RELATED COMPONENTS)
NIAGARA YOHA>AK PO>JER CORPORATION NINE MILE POINT NUCLEAR STATION, UNIT NO.
1 DOCKFT NO. 50-220 The licensee for Nine Mile Point Nuclear Station, Lnit No.
1 responded to Item 2.2 (Part
- 1) of Generic Letter 83-28 in submittals dated November 8, 1983, and December 31, 1985.
The staff has reviewed these responses and finds additional information is needed for some of the sub-items of Item 2.2 (Part 1).
The review guidelines used by the staff for these sub-items are listed below, followed by a brief evaluation of the licensee's submittals, and a
suranation of the additional information requested by the staf<.
Item P.P.1 - Proqram Guideline Licensees and applicants should submit a program description that provides assur-ance that all safety-related components are designated as safety-related in all plant documents, drawings, procedures, and in information handling systems that are used in accomplishing safety-related activities such as work orders for repair, maintenance, and surveillance testing and orders for procurement of replacement parts.
Evaluation The licensee states that the Equipment Classification List (0-list> is the information handling system referred to.
However, the licensee has not stated that all safety-related components are identified as such on all plant documents, drawings and procedures.
The licensee should verify that all safety-related parts and components are identified as such on all plant documents,
- drawings, and procedures used in accomplishing safety-related activities.
Item 2.2. 1. 1 - Identification Criteria Guideline The criteria for identifying components as safety related should be presented.
This should include a description of the means for handling sub-components or parts and procedures for initiating the identification of components as safety related or non safety related if no previous classification existed.
Evaluation The licensee states that Engineering Procedure EP 020 is used to determine whether a component or part is safety related, but does not provide a
description of this procedure.
The licensee's response also refer s to Regulatory Guide 1.26, Revision 3 dealing with quality group classification.
The licensee should describe the criteria used in the classification of, safety-related structures,
- systems, components and parts along with a detailed description of the procedural controls governing the inclusion or deletion of components, sub-components and parts to its listing of safety-related items.
Item 2.2. 1.2 - Information Handlin S stem Guideline The licensee's description of the information handling system for component classification should confirm that a listing of safety-related equipment detailed to the component level has been compiled that includes such components as
- switches, motors, relays, transmitters, pumps, pipes, fittings, tanks, and valves.
The description should show (a) how the listing was originally prepared; (b) how new safety-related items are entered; (c) how changes in classification of listed items are made; (d>
how listed items are verified; (e) how unauthorized changes tc the listing are prevented; and (f) how the listing will be maintained and distributed to users as an official, single, consistent, and unambiguous version.
Evaluation The licensee describes how the 0-list was originally prepared in accordance with, Engineering Procedure EP 020.
The g-list for Unit 1 is included as an appendix to that procedure.
Engineering Procedure EP 190 provides the means for new safety-related items to be entered into the 0-list or to change the classification of existing entries of the 9-list.
The licensee's submittal does not describe how the listed items are verified as correctly entered, how unauthorized changes to the 9-list are prevented, nor how the listing is maintained and distributed as an official, single, consistent and unambiguous document.
The licensee should provide additional information describing how the listed items are verified, how unauthorized changes are prevented and how the listing is maintained and controlled as an official, single, consistent and unambiguous version as indicated in guideline items (d), (e) and (f) above.
Item 2.2. 1.3 - Use of E ui ment Classification Listin Guideline The licensee's description should show how station personnel use the equipment classification information handling system to determine:
(a) when an activity is safety related, and (b) what procedures are to be used for maintenance
- work, routine surveillance testing, accomplishment of design
- changes, performance of engineering support work, accomplishment of setpoint changes, and performance of special tests or studies.
pg i
Evaluation The licensee's response describes the utilization of the g-list to determine when an activity is safety-related.
The licensee states that procedural checks and balances are utilized to preclude non-safety-related procedures being applied to safety-related equipment.
However, the licensee did not describe how the g-list was consulted to determine the correct use of procedures for such activities as those listed in the Guideline above.
The licensee should address how the equipment classification information handling system is used by station personnel to trigger the use of the appropriate procedures for the accomplishment of such activities as design
- changes, performance of engineering support work, the accomplishment of setpoint changes and in the performance of special tests and studies.
Item 2.2. 1.5 - Desiqn Verification and Procurement Guideline The licensee's submittal should show that the specifications for procurement of replacement safety-related components and parts require that the supplier include in their documentation, verification of design capability and evidence of testing that aualifies the components and parts for service under the expected conditions over the service life.
Evaluation The 'licensee states that engineering procedures, such as EP 90, "Controlled Design and Design Verification" and EP 100, "Control of'-Procurement Activities,"
contain requirements concerning design verification and qualification testing.
The 'requirement for the vendor to submit evidence of testing is not specifically addressed by the licensee.
The licensee should describe how procurement speci-fications specifically require the supplier to include verification of design capability and evidence of testing that qualifies the components and parts for service under the expected conditions over the life of the component or part.
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