ML17250A935
| ML17250A935 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 08/17/1989 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML17250A934 | List: |
| References | |
| GL-83-28, NUDOCS 8908250246 | |
| Download: ML17250A935 (7) | |
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION REPORT ENCLOSURE 1
R.
E.
GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244 GENERIC LETTER 83-28 ITEM 2.2.1 E UIPMENT CLASSIFICATION PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS
1.0 INTRODUCTION
Generic Letter 83-28 was issued by thc NRC on July 8, 1983 to indicate actfoni to be taken by licensees and applicants based on the generic fmplications of,.
the Salem ATWS events.
Item 2.2.1 of that letter states that licensees and applicants shall describe in considerable detail the1r program for classify1ng all safety-related components other than RTS components as safety-related on plant documents and in information handling systems that are used to control plant activ1ties that may affect these components.
Specifically, the licensee/
applicant's submittal was requ1red to contain information descr1bing (1) The criteria used to 1dcntify these components as safety-related; (2) the information handling system which identifies the components as safety-related; (3) the manner in which station personnel use this information handling system to control act1vities affecting these components; (4) management controls that are used to verify that the 1nformation handling system is prepared, mainta1ned, validated, and used in accordance with approved procedures; and (5) design verif1cation and qualff1cation test1ng requirements that are part of the spec1ficatfons for procurement of safety-related components.
The licensee for the R. E. Gfnna Nuclear Power Plant submitted responses to Gener1c Letter 83-28, Item 2.2.1 in submittals dated November 4, 1983, August 23, 1985 and June 4, 1987.
We have evaluated these responses and f1nd that they are acceptable.
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2.0 EVALUATIONS ANO CONCLUSIONS In these sections the licensee's responses to the program and each of five sub-items are individually evaluated against guidelines developed by the staff and conclusions are drawn regarding their inaividual and collective acceptability,
- 1. Identification Criteria Guideline:
The licensee's response should describe the criteria used to identify safety-related equipment and components.
(Item 2.2.1.1)...
Evaluation:
The licensee's response states that safety-related equipment is defined as that necessary to assure:
1.
The integrity of the reactor coolant system pressure
- boundary, 2.
The capability to shut down the reactor or to maintain it in a shutdown condition, or 3.
The prevention or mitigation of the consequence of accidents that could result in potential offsite exposures.
==
Conclusion:==
We find the stated criteria meet the staff's requirements and are acceptable.
- 2. Information Handlin S stem Guideline:
The licensee's response should confirm that the equipment classification program includes an information handling system that is
used to identify safety-related equipment and components.
Approvea procedures which govern its development, maintenance, and validation should exist.
(Item 2.2.1.2)
Evaluation:
The licensee's submittals identify the information handling system as consisting of a manual listing of safety-related components.
These submittals also state.that its deve>pment"and validation're controlled by a formal review and approval procedure.
Changes to the listing (Appendix A
of the station's guality Assurance Hanual) are prepared by the responsible engineer in the Engineering Department, are reviewed by guality Assurance, and are approved by the Hanager of the Nuclear Engineering Department.
==
Conclusion:==
Me find licensee's response meets the staff requirements and is acceptable.
3.
Use of Information Handlfn S stem Guideline:
The licensee response should confirm that their equipment classification program includes criteria and procedures which qovern the use of the information handling system to determine that an activity is safety-related and that safety-related procedures for maintenance, surveillance, parts replacement and other activities defined in the sntroduction to 10CFR50, Appendix 8, are applied to safety related components.
(Item 2.2.1.3)
Evaluation:
The licensee states that the guality Assurance Hanual and its appendices are the mechanism used in determining whether an activity, system, or component is safety-related.
procedure A-1603 imposes the use of Appendix A in determining whether an activity is safety-related or not.
This
- 4 procedure is used in requesting maintenance work on safety-related equipment, maintenance work requests (MMR), and trouble reports.
It also describes the routing and disposition of the tQR.
The licensee also briefly describes the following procedures which contain the criteria and guidance needed to determine the status and govern the performance of safety related activities.
A-502 A-600 A-52 Plant procedure adherence requirements Plant procedure content and format requ1rements Procedures regarding changes (temporary and permanent) to administrat1ve procedures Tracks the allowable out-of-ser vice time for equipment A-801 Control of accepted material parts and components A-802 Identification and marking of accepted mater ial parts and components A-401 Control of procurement documents A-701 Receipt and acceptance of material and parts A-1501 Control of nonconforming items
==
Conclusion:==
We conclude that the licensee has descr1bed plant administrative controls and procedures which govern the ident1fication and performance of safety related activities, meet the staff requirements for'this 1tem and are acceptable.
4.
Hang ement Controls Guideline:
The licensee/applicant should confirm that management controls used to verify that the procedures for preparation, validation, and rout1ne utilization of the information handling system have been and are being followed.
(Item 2.2.1.4)
Evaluation:
The licensee's response states that managerial controls are part, of the plant administrative procedures, requiring plant operations review cceeittee (PORC) review and superintendent approval.
The licensee's responses describe how managerial controls (which are audited semiannually) are used to assure that the equipment classification information handling system has been properly prepared, that its contents have been validated, that it is being maintained current and that it is being used to determine equipment classification as intended.
Other controls are document reviews, quality control surveillances, quality assurance
- audits, and by work in progress monitoring.
Nainte>>ance work orders and procedure data packages.
are reviewed by the Maintenance Manager to ensure that administrative controls are adhered to.
==
Conclusion:==
We conclude that this response addresses the staff's concern
~nd is acceptable.
5.
Desi n Verification and Procurement Guideline:
The licensee/applicant's response should document that past usage demonstrates that appropriate design verification and qualification
.testing is specified for the procurement of safety-related components and parts.
The specifications should include qualification testing for expected safety service conditions and provide support for licensee's receipt of testing documentation which supports the limits of life recommended by the supplier.
If such documentation is not available, confirmation that the present program meets these requirements should be provided.
(Item 2.2.1.5)
Eva 1uation:
The licensee states (fn Reference
- 2) that the present design control process provides for the required design verfffcat1on, qualification testing and aocumentatfon to support the life,limfts.
==
Conclusion:==
Although the licensee dfd not specify the design criteria applied to this item, we conclude that the licensee has addressed the cohcerns of this item and that the response for this item fs acceptable.
6.
"Im ortant To Safet
" Com onents Guideline:
Generic Letter 83-28 states that lfcensee/applicant equipment classsffcation programs should include (fn addition to the safety-related components) a broader class of components designated as "Important to Safety."
- However, s1nce the generic letter does not require licensee/
applicant to furn1sh this information as part of their response, staff review of this sub-1tem will not be performed.
( Item 2.2.1.6) 7.
~Pro ram Guideline:
Licensees/applfcants should confirm that an equipment classiffcat1on program exists which provides assurance that all safety-related components are designated as safety-related on plant documents such as drawings, procedures, system descriptions, test and maintenance instructions, operating procedures, and information handling systems so that personnel who perform activft1es that affect such 'safety-related components are aware that they are working on safety-related components and are gu1ded by safety-related procedures and constraints.
(Item 2.2.1)
Evaluation:
The licensee's response to these requirements was contained in submittals dated November 4, 1983, August 23, 1985 and June 4, 1987.
These submittals describe the licensee's program for identifying and classifying safety-related equipment and components which meet the staff requirements as indicated in the preceding sub-item evaluations.
==
Conclusion:==
Me conclude that the licensee's program addresses the staff concerns regarding equipment and component classification and is acceptable.
3.0 REFERENCES
4
'l 1.
NRC Letter, 0. 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.
Rochester Gas and Electric Corporation letter, J.
E. Haier to Director of Nuclear Reactor Regulation, NRC, "Generic Letter 83-28,"
November 4, 1983.
3.
Rochester Gas and Electric Corporation letter, R.
W. Kober to Director of Nuclear Reactor Regulation, NRC, "Generic Letter 83-28,"
August 23, 1985.
4.
Rochester Gas and Electric Corporation letter, R.
M. Kober to C. Stahle,
- NRC, "NRC Letter of March 27, 198? from C. Stahle to R. Kober Request,'for Additional Information on Generic Letter 83-28, Item 2.2," June 4, 1987.