ML18005A346

Rev 1 to Plant Program Procedure PLP-108, Environ Qualification Program (10CFR50.49).

ML18005A346
Person / Time
Site:	Harris
Issue date:	02/26/1988
From:	Harness J CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML18005A336	List: ML18005A335 ML18005A337 ML18005A339 ML18005A342 ML18005A343 ML18005A344 ML18005A346 ML18005A347 ML18005A348 ML18005A350 ML18005A351 ML18005A352 ML18005A353 ML18005A356 ML18005A357 ML18005A358 ML18005A364 ML18005A365
References
PLP-108, NUDOCS 8803160293
Download: ML18005A346 (31)

Text

OS4 CAROLINA POWER & LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT PLANT OPERATING MANUAL VOLUME 1 PART 2 PROCEDURE TYPE: Plant Program Procedure NUMBER: PLP-108 TITLE: Environmental Qualification Program (10CFR50.49)

REVISION 1

- mernvE FEB 2 6 1988 APPROVED: i4 -$ 8 Signature Date J.L. HARNESS

"-ANT GENERAL MANAGER TITLE:

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OS4 CAROLINA POWER 6 LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT PLANT OPERATING MANUAL VOLUME 1 PART 2 PROCEDURE TYPE: Plant Program Procedure NUMBER: PLP-108 TITLE: Environmental Qualification Program (10CFR50.49)

REVISION 1 APPROVED:

Signature Date J L HA.R.NESS TITLE:

'>>> t'ENERAt. MANAaER Page 1 of 28

OS4 Table of Contents Seetian ~Pa e

1. 0 PURPOSE 4

2.0 REFERENCES

4 3 ' DEFINITIONS/ABBREVIATIONS . 6 4.0 GENERAL 10 5.0 IMPLEMENTATION 16 6 ' DIAGRAMS/ATTACHMENTS 22 Attachment 1 - Responsibility Matrix 23 Attachment 2 - Category II Equipment 27 PLP-108 Rev. 1 Page 2 of 28

084 List of Effective Pa es

~Pa e Revision 1 through 28 PLP-108 Rev. 1 Page 3 of 28

OS4

l. 0 PURPOSE The purpose of this pzocedure is to:

1.1 Provide genezal policy statements and definitions to explain and document methods for compliance with the Environmental Qualification (EQ) Rule 10CFR50.49, (Refezence 2.1).

1.2 Describe the Shearon Harris Nuclear Power Plant (SHNPP) EQ program elements and theiz'ontrols to ensure consistent application.

1.3 Assign genez'al responsibilities for implementation of the EQ program elements'his procedure is intended to provide a general outline of the SHNPP EQ program. Specific details of program elements and controls are further defined in the applicable procedures.

2 ' REFERENCES 2.1 10CFR50.49, Environmental Qualification of Electric Equipme'nt Important to Safety for Nuclear Power Plants 2.2 Regulatory Guide 1.97, Instrumentation for Light"Mater-Cooled Nuclear Powez Plants to Assess Plant Conditions During and Following an Accident (See References 2.41 and 2.42) 2.3 NED Design Guide - DG-VIII.34P Prepazation and Control of Shearon Harris Environmental Qualification Mastez List 2.4 CP&L Corporate Quality Assurance Program e

2.5 MOD-103, Engineering Evaluations 2.6 NUREG-0588, Interim Staff Position on Environmental Qualification of Safety-Related Equipment 2.'7 IEEE Standard 323-1974, IEEE Standard foz Qualifying Class 1E Equipment for Nuclear Power Generating Stations (also Reference IEEE Standard 323"1971) 2.8 IE Bulletin 79"01B, Guidelines for Evaluating Envizonmental Qualification of Class 1E Electrical Equipment in Operating Reactors (DOR Guidelines) 2.9 AP"014, Criteria for Qualified Safety Reviewers 2.10 MOD-206, Temporary Modifications 2.11 AP"618, Justification for Continued Operation 2.12 AP"615, NRC Repozting Requizements PLP-108 Rev. 1 Page 4 of 28

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OS4 2.0 EEEEEEHCEE (eeeeieeed) 2 '3 AP-616, Evaluating and Reporting of Defects and Noncompliance in Accordance with 10CFR Part 21 2.14 NRC Generic Letter 86-15, dated September 22, 1986, Information Relating to Compliance with 10CFR50.49, Environmental Qualification of Electric Equipment Important 1

to Safety for Nuclear Power Plants (Supplements NRC Generic

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rl~ Letter 85-15, dated August 6, 1985)

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~ 2.15 NED Design Guide DG-VIII Documentation Review Cuidelines

'9, Equipment Qualification I

2.16 MMM-012, Maintenance Work Control Procedure (Automated Maintenance Management System) 2.17 NLS 1.1, Incoming Nuclear Regulatory Commission (NRQ Correspondence 2.18 NLS 1.2, Compliance with NGCM 304-01 "Outgoing NRC Correspondence VerificationEE 2.19 AP-611, Outgoing NRC Correspondence 2.20 AP-609, Revie~ of Incoming NRC/INPO Correspondence 2.21 AP-031, Operational Experience Feedback 2.22 AP-026, Corrective Action Program 2.23 MOD-204, Modification Implementation 2.24 MOI 2.2, Communications and Correspondence Control 2.25 MOI 3.22, Processing, Control and Resolution of Modifications

) 2.26 OQA-202, Document Review

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II 2.27 CQAD 40-2, Vendor Shop Inspection

'l 2.28 OQA-402, Receipt Inspection 2.29 OQA-301, Mechanical Inspection 2.30 OQA"302, Electrical and Instrumentation Equipment 2.31 MMM-025, Maintenance Environmental Qualification Program 2.32 PLP-400, Pos>~Maintenance Testing 2.33 CM-P0001, Post-Maintenance Testing Requirements for

0 Limitorque Motor-Operat'ed Valves PLP-108 Rev. 1 Page 5 of 28

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e ' l ", +< Material Issue 2.35 TMM-104, Determination of Technical and QA Requirements for Procurement Document 2.36 TMM-110, Receiving Packaging, Storage and Maintenance Requirements for Spare Parts, Material and Components 2 '7 TMM-111, Spare Parts Determination for Plant Equipment 2.38 PMC-005, Storage of Materials 2.39 CQAD 80-1, Procedure for Corporate QA Audits 2.40 OQA-201, Surveillance Program 2.41 CP&L Letter Number LAP 83"405, September 6, 1983, Submitted to NRC from M. A. McDuffie to H. R. Denton (Reference 2.2) 2.42 CP&L Letter Number NLS 85-109, June 3, 1985, Submitted to NRC from S. R. Zimmerman to H. R. Denton (Reference 2.2) 2.43 CP&L Letter Number NLS-85-269, August 27, 1985, A. B. Cutter to H. R. Denton tt t II 2.44 OMM-003, Equipment Inoperable Record r

2.45 AP-610, Processing Vendor Recommendations, Vendor Manual Revisions and Equipment Technical Information.

2.46 NUREG 1038, Safety Evaluation Report Related to the Operation of Shearon Harris Nuclear Power Plant, Units 1 and 2 2.47 AP-600, Plant Change Request Initiation 2.48 MMM-013, Maintenance History Records I

3.0 DEFINITIONS/ABBREVIATIONS Fr The following definitions are provided to ensure a uniform understanding of the terms as they are used in this document and as they apply to the SHNPP EQ program.

3.1 E ui ment. (Electrical) rt A manufactured product assembled with components or modules. It i

has definable performance characteristics and can be removed, tested, and replaced as a unit. Examples of typical electrical tt r

equipment include: 'otors, motor"operated valve actuators, motor starters, motor control centers, terminal blocks, relays t switches, circuit breakers, solenoid valves, and transmitters.

PLP"108 Rev. 1 Page 6 of 28

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OS4 3.1 E ui ment (Electrical) (continued)

For the purpose of this document, the term "device" is used interchangeably vith equipment.

3.2 ~Com onents Components arc items (piece parts) from which the equipment is assembled> for example, r'esistors, capacitors, vires, conaectors, transistors, springs, gaskets, O-rings, etc.

3.3 E ui meat Versus Com onent Ia some cases, equipmcnt may also fulfill the definition of a component. Therefore, thc folloving guidelines arc additionally offered to clarify equipment versus component and corresponding qualification requirements.

l. ~Eui ment performs a stand-alone funotion (i.et ~ a solenoid valve used to isolate a sample line) ~

Qualification is demonstrated for the equipment consistent with the equipment's design requirements'

~ ~Com anent performs its fuootion as part of a more complex assembly; the component function is an 'element of the systemized operation of the equipment (e.g., a relay used in an MCC). The component's qualification is demonstrated if the component can perform its required safety function as part of the equipment's required operation; the component may not undergo separate qualification.

1. EQ equipment for SHNPP is Quality Class A (safety-related) electrical equipment located in a harsh environment that is required for the performance of the folloving actions for Design Basis Accident (DBA):

Maintain the integrity of the reactor coolant pre'ssurc boundary, Shut down the reactor and maintain it in a safe coadition, Prevent off-site radioactive releases or mitigate the consequences of off-site exposures to levels less than in 10CFR100.

2. Additionally, devices located in a harsh environment that hav: been defined as required only for Regulatory Guide le97 (Reference 2.2) (postaccident monitoring) indication functions have been included on the EQ Master List ~

PLP-108 Rev. 1 Page 7 of 28

OS4

3. In addition, for the purpose of the SHNPP EQ program and corresponding procedures, EQ equipment also includes common components that are used for interconnecting to EQ equipment (e.g., cables, connectors, splices, etc.) ~

3.5 Master List The Master List (formally identified as the SHNPP Environmental Qualification Equipment List or EQ List) is a list on EDBS of EQ equipment that requires environmental qualification as controlled by Harris Plant Engineering Section Manual of Instructions, NED Design Guide DG"VIII.34 (Reference 2.3) ~

3.6 Harsh Environment An area where the environment may change significantly from the normal expected environment due to the effects of abnormal or accident conditions including humidity, submergence, pressure, chemical spray, temperature or radiation. This includes any area re that has a resultant temperature increase from normal design r temperature of 10'C (18'F) or greater.

The generation and maintenance of documentation to assure that the equipment, will perform its required safety function under harsh I

environmental conditions, i.e. qualified. Qualification may be

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>j demonstrated by type-testing of identical equipment or analysis in conjunction with type-testing of similar equipment, operating experience, or partial test data.

3.8 One of the following qualification levels applies to the 18 equipment's demonstrated qualification'.

i. ~Cate or T The reqnirementa of RURRG 0588 -(Reference 2.6) define Category I qualification as applicable to equipment qualified to IEEE Standard 323-1974 (Reference 2.7) (i.e., a complete sequential test program [using the same test specimen throughout the program] per IE Bulletin 79-01B (Reference 2.8), which envelops the required qualification parameters).

Category I also requires that aging simulation and margin be considered within the sequential test program.

qualification applies to equipment qualified to IEEE Standard 323-1971 (Reference 2.7). Note that Category

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II allows for the use of materials aging analyses in lieu of iging simulation within the qualification test program.

PLP-108 Rev. 1 Page 8 of 28

OS4 3 ' One of the foLLowing qualification levels applies to the equipment's demonstrated qualification: (continued) 3 ~ DOE Guidelines Per IE Bulletin 79-0IB, operating plants were required to demonstrate qualification of installed equipment through the use of analysis/evaluation supported by partial test data (i.e., for temperature, pressure, and humidity conditions). There is currently no EQ equipment on the SHNPP Master List that was qualified using 79-OIB ~

Tests made on one or more samples of equipment (e.g., prototypes) to verify the adequacy of design and manufacturing processes.

Type-testing to Category I criteria, for example, requires the equipment to be aged (subject to all environmentaL influences) and operated under post-DBA conditions to assure that the equipment .

will perform its function for the required operating time.

3. 10 Servi.ce Conditions Parameters affecting the functional capabiLity of equipment or systems as a result of normaL operating requirements, extreme anticipated operating requirements, and postulated conditions expected for design basis accidents.

3.11 ~Mar ia Margin is the difference between the most severe specified service conditions of the plant and the conditions used in type testing to account for ne-maL variations found in commercial production of equipment and :easonable errors in defining satisfactory performance. Margin is intended to increase the severity Level of the test to provide (a margin of) assurance that the test conditions account for variations in production.

These margins are in addition to any conservatisms applied during the derivation of local environmental conditions of the equipment unless these conservatisms can be quantified and shown to contain appropriate margins.

Qualified Life is the period of time for which satisfactory performance of a device (equipment) can be demonstrated for a specific set of service conditions. The qualified life defines the end-of-installed life for the equipment and is determined by testing and/or analysis. At the end of the qualified life, the equipment must be replaced or refurbished, unless ongoing qualification demonstrates that the qualified Life may be extended.

PLP-108 Rev. I Page 9 of 28

OS4 3 '2 alified Life (continued)

The qualified life is typically based upon agc-limiting components within the equipmcnt that have been found by test or analysis to degrade over time. The degradation is due to exposure to aging mechanisms (such as elevated temperature, radiation, or vibration), vhich may prevent the equipment from performing its function.

3 '3 Environmental uglification Data Packa e (E DP)

An assemblance of environmental qualification data received from a vendor or generated by'P&L to document environmental qualification. Documentation is completed in accordance vith HPES MOZ 7.4.B. (Reference 2 'S) ~

3.14 0 erabilit Time The maximum time folloving the start of a DBA in which an EQ device is required to perform its function, (operable). The operability time for EQ devices is specified in the Environmental Qualification Data Package (EQDP).

The person within the SHNPP Technical. Suppozt Unit responsible for the c'oordination of the SHNPP EQ program.

3.16 E Technical Reviewer Individual(s) responsible for performing technical reviews of procedures, plant design changes, temporary modifications, JCOs, and engineering evaluations affecting EQ equipment. An EQ Technical Reviever shall be a qualified EQ safety zeviewer as designated by the Plant General Manager per AP-014 (Reference 2.9) and should be knowledgeable of SHNPP EQ procedures, FSAR requizements, Regulatory commitments, and EQDPs.

4~0 GENERAL The program outlined in this procedure vill be used to control activities that have an impact on the qualification of applicable equipment or on the documentation that supports the equipment's qualification basis. The appropriate controls outlined in this program will be implemented through the applicable procedures by responsible organizations, as listed in Attachment 1.

PLP-108 Rev. 1 Page 10 of 28

OS4 The following th~ee tasks must be addressed to achieve compliance to 10CFR50.49:

1. Demonstrate qualification of currently installed equipment.

2~ Establish a program to maintain the equipment s qualification integrity throughout its qualified life.

3~ Pursue upgrading of replacement EQ equipment to the current qualification standards. (See Attachment 2 for listing of applicable Category ZZ equi.pment.)

10CFR50.49(b) identifies three categories of electric equipment that requi.'re environmental qualification if required to operate in a harsh environment. These categories equipment as defined by 50.49(b)(1).

are.'afety-related Nonsafety"related equipment whose failure under postulated DBA conditions could prevent a safety-related equipmentlsystem from performing its required safety function 50.49(b)(2)l. (NOTE-'here is no equipment currently in this category at SHNPP, Reference 2.43.)

Certain postaccident monitoring equipment that is specified

.in Regulatory Guide 1.97 [50.49(b)(3)j.

The methodology tb determine which equipment is to be environmentally qualifi.ed is based on reviewing plant systems which perform safety functions. The equipment within such systems, which are necessary for the performance of the safety function, are identified and qualified environmentally to demonstrate acceptable performance throughout its installed life.

Plant safety-related systems are identified in Drawing CAR 2165-A001. The specific equipment within safety-related systems, which is located in a harsh environment is identified on the EQ Master List. Equipment defined in the scope of 10CFR50.49 is included in the Shearon Harris EQ Program.

Postaccident monitoring equipment (per RG 1.97 commitments), that is located in a harsh environment, is included in the EQ Master List+

Changes will occur in the equipment scope as plant modifications are performed. Changes will be controlled in accordance with procedures described in Section 5.0.

PLP"108 Rev. 1 Page 11 of 28

OS4 4.4 Polic on uglification Bases

1. alification of E ui ment Installed Durin Construction Phase - The licensing basis for equipment installed during the construction period uas 10IEG 0"588, Category II. However, some equipment was qualified to NUREG-0588, Category I, zequirements ~

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List after issuance of the operating license should be qualified to Category I levels unless a valid "sound reason to the contrary" applies. If the contrary is invoked, the equipment must meet the a sound reason to qualification levels of Category II equipment. The "sound reason to the contrary" must be justified by, a documented Engineering Evaluation in accordance with MOD-103.

3. Re lacement E ui ment-

a. Re lacement of Cate oz I E ui ment - Replacement of curzently installed Category I qualified equipment shall be with Category I qualified replacement equipment.

b. Re lacement of Cate or II E ui ment - For Category II qualified equipment currently installed, Section (1) of 50.49 requires operating plants ta upgzade replacement equipment to Categozy I requirements unless there aze "sound reasons to the contrary" (for not upgrading). SHNPP will comply with this Section of 50.49 through evaluation on a case"by-case basis for the replacement of Category II qualified plant equipment in accordance with MOD-103 '

~ Tem orar Re lacement of E E ui ment (1) Temporary replacements without demonstrated qualification may be installed only in emergency or abnormal operating conditions where immediate actions are required to protect the health and safety of the public, to protect equipment or personnel, or to prevent the deterioration of plant conditions to a possible unsafe or unstable level. These temporary replacements (modifications) shall be contzolled per MOD-206 (Reference 2.10),

and a JCO prepared in accordance with AP-618 (Reference 2.11) for review and approval by PNSC. The PCR/JCO shall include an evaluation that provides reasonable assurance that as a result of a design basis accident, a required PLP-108 Rev. 1 Page 12 of 28

OS4 4.4 Polic on alification Bases (continued) safety-related function vill not be degraded, and the operator vill not be provided misleading information.

(2) Temporary replacements vithout demonstrated qualification shall bc revieved with Regulatory Compliance to determine if NRC notification or a Licensee Event Report (LER) is required in accordance vith AP-615 and AP-616 (Reference 2.12 and 2.13) ~

(3) Temporary replacements vithout demonstrated qualification should be tracked by the EQ

~ Coordinator until demonstrated qualification can be established andlor a qualified replacement is installed.

Treatment of Identified uglification Problems-Qualification problems refer to situati'ons vhere the quaLification of equipment is questioned or cannot. bc determined. ExampLes of such situations include cases where:

Nev information is available which requires analyses.

Documentation is found to be missing from a qualification file.

Equipment is inadvertently omitted from the Master List.

Improperly performed maintenance challenges qualification.

Periodic maintenance required by the EQDP cannot be performed due to plant conditions.

NRC Generic Letter 86-15 (Reference 2.14), provides guidance on what action should be taken when deficiencies are identified. At SHHPP, whenever a potential EQ deficiency is identified steps shall be taken to ensure that a Significant Operational Occurrences Report (SOOR) is initiated in accordance with AP-615, if required. For all EQ-reLated SOORs, an Engineering Evaluation is initiated in accordance with MOD-103. The Shift Foreman vill request Technical Support to perform the Engineering Evaluation to determine qualification status.

PLP"108 Rev. 1 Page 13 of 28

OS4

~, I 4.4 Polic on lification Bases (continued)

For equipment addressed in plant Technical Specifications, a tracking EIR in accordance with OMM-003 (Reference 2.44) should be established pending resolution of the evaluation. The results of this evaluation will be used to determine operability.

a. Zf tbe equipment is evaluated te be Ituaiified:

44, (1) For equipment supported by an existing EQDP (without revision) and a satisfactory EQ maintenance history (where applicable), no r'ut further action is required.

(2) For equipment suppozted (in part) by an existing EQDP that requires revision to address the qualification problem, an Engineering Evaluation in accordance with MOD-103 may be used (in lieu of a revision to the EQDP) until the qualification problem is li r resolved.

NOTE: The Engineering Evaluation, in accoz'dance with MOD-103, shall provide zeasonable assurance that the equipment is qualified based upon partial test data of the same or similar equipment and/or material that envelops the equipment's operability time requizements ~ When applicable, the Engineezing Evaluation should address the requirement for satisfactory completion of maintenance activities that are identified as required to maintain the equipment's qualification.

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(3) An action item should be established by the EQ Coordinator to tzack the Plant Change Request (PCR) initiated in accozdance with AP-600

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(Reference 2.47) to zevi se the EQDP if requiz'ed, per paz'agraph 4.4.4.a above.

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b. Zf the installed equipment is evaluated to be I

'ustified for continued o eration, but not fully qualified:

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'R (1) A justification for continued operation (JCO)

-"qI shall be prepared per AP"618. This JCO, I

prepared consistent with the critera of

'4 10CFR50.49(i), shall be reviewed and approved by PNSC.

NOTE: The JCO shall provide reasonable assurance that postulated equipment failure resulting from the DBA i exposuze does not compromise plant safety, i.e., based on available information (e.g. partial test data), there I is reasonable assurance that the equipment can be PLP-108 Rev. 1 Page 14 of 28 I

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OS4 4.4 Polic on alification Bases (continued) successfully qualified through additional test and/or analysis, or qualification documentation can be obtained from outside sources. The JCO shall also determine whether failure of the equipment will cause the failure of other safety-related functions/equipment or result in misleading information to the operator. Additionally, where applicable, the JCO shall document if any of the safety functions will be accomplished by some designated alternate equipment (that is qualified) or administrative controls will be used.

if Prior to presentation of the JCO to PNSC, the EQ Coordinator (or designee) should review and concur with the JCO.

(2) The qualification problem shall be reviewed with Regulatory Compliance to determine reportability in accordance with AP"615.

(3) The qualification problem should be tracked as a Corrective Action Program, '(CAP) item in accordance with AP-026 (Reference 2.22) by Regulatory Compliance.

because of the qualification problem:

(1) A documented evaluation is not required, unless Plant Management directs otherwise.

(However, Operations should be notified that the evaluation process has been completed, but that reasonable assurance cannot be

.established to qualify or justify the equipment for continued operation.)

(2) The installed equipment shall be declared inoperable by the Shift Foreman based upon its unacceptable (unqualified) condition, but. not necessarily taken out of service.

NOTE: For equipment covered in plant Technical Specifications, the appropriate Technical Specification LCO (when applicable) shall be invoked, per OMM-003.

For non-Technical Specification-related equipment, appropriate actions shall be determined by Plant Operations Manager c-. designee based upon the evaluation/notification processes given the significance of the degraded safety function.

PLP-108 Rev. 1 Page 15 of 28

OS4 4.4 Polic on alification Bases (continued)

(3) The qualification problem shall be reviewed by Regulatory Compliance to determine reportability in accordance with AP-615.

(4) The unacceptable (unqualified) equipment shall be replaced with~ualified equipment in accordance with MMM-012, (Reference 2.16).

(5) Resolution of the qualification problem should be tracked as a CAP item in accordance with AP-026 '

~ 0 IMPLEMENTATION 5.1 Pro ram Elements The program elements that must be controlled by the SHNPP EQ program are:

l. Identification of EQ equipment as defined by the EQ Master List.

2. Documentation which demonstrates the qualification of the EQ equipment.

3 ~ Design control measures associated with plant modifications affecting EQ equipmenr..

4. On-going activities required to maintain the qualification of the EQ equipmenr..

5.2 Responsibilities Implementation of the EQ program is the responsibility of personnel performing EQ-related work activities for SHNPP. These activiries include design, installation, maintenance, procurement, material control, quality assurance, surveillance, etc.,

inherently required for safety-related equipment work activities. The Project Vice President has overall responsibility for the EQ program. The Plant General Manager (PGM) has responsibility to coordinate implementation of the EQ program.

The EQ Coordinator (EQC) is responsible for assessment of the EQ program. The EQC shall assess that activities of responsible task organizations are coordinated, individuals engaged in EQ activities are properly trained, and activities supporting environmental qualification of equipment are completed in a timely manner. The EQC should periodically revie~ procedures and EQ documentation to assure EQ program adequacy and report to management apparen., deficiencies for remedial action if required.

PLP-108 Rev. 1 Page 16 of 28

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respective EQ responsibilities.

The following organizations development,

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Organizations responsible foz EQ program elements viLL develop procedures, and/or instructions delineating implementation of have primary performance and control of the program elements:

responsibility for I

.j 1. Site En ineerin Unit (SEU) is responsible for'ontrol s ~'sI of plant modifications'.

wj The Nuclear En ineerin De artment (NED) is responsible d,A I

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for ensuring that Environmental Qualification is

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addressed in plant design activities. This includes control of EQDPs and vendor manuals' ta 3 ~ Maintenance incorporates identified EQ-related maintenance requirements into procedures and maintains equipment in a manner that criLL not degrade qualification.

4. Technical Su ort provides technical inputs in EQ spaze parts procurement. In addition, Technical Support is IS zesponsible for Temporary Modifications and Eng'ineering Evaluations and screening of PCRs in support of the EQ program.

5. QAA/ C has responsibility foz program support in areas of audits, surveillance, document review and inspections'.

Re ulator Com liance is responsible for evaluating potential EQ deficiencies for repoztability to the NRC

,and disseminating information from NRC generic letters and bulletins.

7. On-site Nuclear Safet reviews and coordinates NRC information notices, vendor bulletins, and other industry information for EQ applicability to SHNPP.

g. O~eeaeians bas responsibility for declaring operability and assuring EQ requirements are incorporated into Operations procedures.

9. Material Contzol is required to maintain spare parts in accordance ~ith EQ. requirements.

5.3 Pro ram Controls Ongoing plant design and maintenance activities have a dynamic impact on the SHNP: EQ progzam elements. To ensure continual compliance to LOCFR50.49p these program elements viLL be controlled through the following progzammatic and procedural methods.

PLP-108 Rev. 1 Page 17 of 28

OS4

1. Control of the E List - NED generated and maintains an Environmental Qualification Equipment Master List using the Equipment Data Base System (EDBS). This process is described and documented in NED Design Cuide DC-VIII.34.

2~ Control of E Documentation-

a. NED establishes an Environmental Qualification Data Package (EQDP) on each type of equipment. NED Design Cuide DC-VIII.19 defines the creation, revision, and control of the EQDP. The EQDP contains two types of information.

(1) The equipment's current qualification basis, which is demonstrated by applicable test reportslanalyses and evaluations.

(2) Ongoing equipment maintenance and/or operational requirements/recommendations to maintain the equipment throughout its qualified life, as defined by the EQ Maintenance summary.

b. NED maintains Vendor Technical Manuals for EQ equipment in accordance with AP-610 (Reference 2.45).

C ~ Maintenance will document work done and parts used on EQ equipment via the Work Request and Authorization (WR&A) per the Maintenance Work Control Procedure MMM-012.

d. Qualification problems vill be reviewed by Regulatory Compliance to determine reportabi1.ity in accordance with AP-615.

e. Regulatory Compliance will coordinate the preparation of JCOs in accordance with AP"618.

f. Regulatory Compliance will coordinate the preparation of 10CFRg21 evaluations that affect EQ. If required, the report shall be prepared and submitted to the NRC by Regulatory Compliance in accordance with AP-616.

g. The Nuclear Licensing section will prepare and coordinate responses to NRC generic letters and IE Bulletins in accordance with NLS1 1 F and NLS1.2 (References 2.17 and 2.18). Regulatory Compliance reviews the response to assure that applicable EQ commitments are addressed and integrated into PLP-108 Rev. 1 Page 18 of 28

OS4 Contzols (continued)

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the EQ Progzam in accordance vith AP-611

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(Reference 2.19). Regulatory Compliance screens NRC Bulletins and genez'ic letters foz'pplicability to SHNPP per AP-609 (Reference 2.20) and assigns action items per AP-031 as required.

On-site Nuclear Safety revievs NRC Information Notices, vendor bulletins, and other industry, information for applicability to SHNPP through the Operational Experience Feedback (OEF) progzam in accordance vith AP-031 (Refezence 2 '1). Action items are assigned as zequired using the Corrective Action Pzogram (CAP), AP-026 '

~ SEU is responsible for review and control of (coordination of) EQ-related Ebasco (BOP) Vendor supplied information, (MOI 2.2 (Reference 2.24) and AP-031)e

3. Control of Plant Modifications a ~ Site Engineering Unit (SEU) is responsible to provide design and installation details for plant systems/equipment in accozdance vith MOD-204 (Reference 2.23) for plant modifications.

b. NED vill be responsible for providing input during the plant modification process on EQ questions.

Changes to environment or to equipment affecting its qualification vill be documented in the design package and EQDP if required. Procedures MOD-204 and HPES MOI 3.22 (Reference 2.25) covez'his process.

C ~ Modification packages and implementing pzocedures are revieved by QA/QC in accordance vith OQA"202 and MOD-204 (Reference 2.26) to ensure adequate inspection is prescribed.

d Vendor supplied EQ equipment is verified to meet specified requirements by a combination of shop inspections performed by Corporate Quality Assurance personnel per CQAD 40-2 (Refezence 2.27) and/or receipt inspection performed by site QA/QC in accoz'dance with OQA-402 (Reference 2.28).

e. Field inspections (hold points) as designated by the modification package are performed by QA/QC in ace J'rdance with OQA-301 and OQA-302 (Reference 2.29 4P and 2.30, respectively).

PLP-108 Rev. 1 Page 19 of 28 "P

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OS4

0 Plant Modification Unit (PMU) and/or maintenance is responsible foz installation of plant modifications in accozdance with installation instructions contained in the modification packages and MMM"012~

g. Technical Support sczecns PCRs, engineering evaluations and temporary mods for EQ applicability in accordance with MOD-204, MOD-103 and MOD-206.

4~ Control of E related Maintenance Activities To ensure the ongoing qualification of the EQ equipment as required by 10CFR50.49(e)(5), the plant shall implement a qualification maintenance program.

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a. NED will maintain the EQDP and EQ Master List to include any change in EQ requirements or equipment due to plant modifications, design feedback, industry, or NRC information and operational experience feedback. Information will then be formally transmitted to the EQC and appropriate plant organizations. This is done in accordance with NED Design Guide DG-VIII.19 and NED Design

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DG-VIII.34.

b. Maintenance will review additions'eletions, or changes to EQ Maintenance Requirements and revise procedures and AMMS in accordance with the Maintenance Environmental Qualif ication Program MMM-025 (Reference 2.31). Maintenance will perform required EQ Maintenance activities as required by the Woz'k Request and Authorization 'n accordance with MMM-012.

C ~ Maintenance will identify Post-.Maintenance Testing Requirements in accordance with PLP-400 (Reference 2.32) and Post-Maintenance Testing Requirements for Limitorque MotorWperated Valves in accozdance with CM-P0001 (Reference 2.33).

~, d. Maintenance will identify zoot causes of EQ equipment failures when technically possible, l

provide input to NED for ongoing qualification, and provide input to Technical Support for trending in accordance with MMM"013, (Reference 2.48).

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e. Work Requests and maintenance procedures are reviewed by QA/QC in accordance with OQA-202 to ensure adequate inspection is prescribed.

PLP-108 Rev. 1 Page 20 of 28

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Vendor-supplied equipment is verified to meet specified requirements by a combination of shop inspections performed by Corporte Quality Assurance personnel in accordance with CQAD 40-2 and receipt inspection performed by site QA/QC in accordance with OQA-402. Reworked equipment is inspected by QA/QC per PMC-003 (Reference 2.34) before returning to stock+

g. Field inspections (hold points) as designated by the Work Request and/or maintenance procedures are performed by QA/QC in accoz'dance with OQA-301 and lf I l OQA-302

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Technical support provides EQ technical inputs for spare parts procurement, storage, and maintenance program as indicated in TMM-104, 110, and

'5, Ill (Reference 2 2.36 and 2 '7, respectively).

1 ~ Material Control personnel are required to verify shelf life of materials has not expired at the time of issue per PMC-003. The use of EQ material in the plant with expired shelf life zequires an evaluation in accordance with MOD-103.'ngineering 3 ~ Storage conditions of level ASB storage areas is monitored by Materials Control personnel per PMC-005 (Reference 2.38). 1f storage conditions exceed the allowable Limits of TMM-110, Technical Suppozt evaluates the effect on the stored EQ equipment in accoz'dance with MOD-103 pzior to use in the plant.

5. Plant Pro zam Assessment

a. The EQ Coordinator will periodically assess the EQ program and review the adequacy of program controls'his assessment will form the basis foz any changes to existing controls that may be required

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b. Periodic audits of the SHNPP EQ program are performed by Corporate Quality Assurance personnel in accordance with CQAD 80-1 (Reference 2.39) to verify compliance with LOCFR50.49 requirements.

C ~ Adequacy and effectiveness of the SHNPP EQ program is verified through suzveillances by site QA/QC personnel in accordance with OQA"201 (Refezrnce 2.40) ~

.0 PLP-108 Rev. 1 Page 21 of 28

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Attachment 1 (continued)

Responsibility Matrix Implementing Res onsibilit PLP Ste Res . Unit Procedure

37) Installation of Plant 5.3.3. f PMU/Maint. MMM-012 Desi Chan es

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38) Screen PCRs for E. Q. 5 ' 'og T.ST MOD-204 i Applicability MOD-103 MOD-206

39) Transmit EQDP or Master 5.3.4.a DC-VIII '9 List Chan es to E C DC-VIII '4

40) Identify Post Maintenance 5.3.4.c Maint. PLP-400 Testin Re uired CM-P0001

41) Identify Root Causes of 5.3.4.d Maint. MMM-013 E.Q. Equip'ailures and Provide Data to TS/NED r

42) Maintains Vendor Technical 5.3.2.b NED AP-610 Manuals

• 4

0 PLP-108 Rev. 1 Page 26 of 28 4

OS4 4

0 Limitorque Motor Operators Attachment Category 2

II Equipment 3LL-L1SA-1 2CS-V585SA 1 ~ 3CZ-B33SB-1 3LL-L2SB-1 2CS-V586SB-1 2MD-V36SA-1 2LS-V518SB-1 2CS-V587SA 1 2MD-V77SB-1 2RC-0525SB-1 2CS-V588SB-1 2MS-V8SA-1 2SI-V530SB 1 2CS-V589SA-1 2MS-V9SB-1 2SI-V530SB 1 2CS-V600SB-1 2RH-F512SB 1 2SI-V555SB-1 2CS-V590SB 1 2RH-F513SA-1 2SI-V554SB-1 2CS-V601SB-1 1RH-V500SB 1 2WL-D650SB-1 2CS-V602SB 1 1RH-V501SA-1 2WG-D291SB-I 2CS-V603SA-1 1RH-V502SB-1 2AF-V10SB-1 2CS-V604SB-1 1RH-V503SA-1 2AF-V19SB-1 2CS-V605SA-1 2RH-V506SB-1 2AF-V23SB-1 2CS-V606SB-1 2RH-V507SA-1

'AF-V116SA-1 2CS-V609SB-1 1RC-V526SN-1 2AF-V117SA-1 2CS-V611SB-1 1RC-V528SN-1 2AF-V118SA-1 2CS-V757SA-1 1RC-V527SN-1 3AF-V187SA-1 2CS-V758SB-1 2SI-V500SA-1 3AF-V188SB-1 2CS-V759SB-1 2SI-V501SB~1 3CC-BSSA-1 2CS-V760SA-1 2SI-V502SA-1 3CC-B6SB-1 2CT"V2SA-1 2SI-V503SA-1 3CC-B19SA-1 2CT-V3SB-1 2SI-V504SB-1 3CC-B20SB-1 2CT-V6SA-1 2S1-V505SB-1 2CC-V170SB-1 2CT-V7SB-1 2SI-V506SA-1 2CC-V169SA-1 2CT-V8SA-1 2SI-V535SA-1

.4, 2CC"V172SB-1 2CT-V21SA-1 2SI-V536SB"1 2CC-V182SB-1 2CT-V25SA-1 2SI-V537SA-1 2CC-V183SB-1 2CT-V43SB-1 2SI-V570SB-1 2CC-V184SA-1 2CT-V49SB-1 2SI-V571SA-1 2CC-V190SB-1 2CT-V145SB-1 2SI-V572SB-1 2CC-V191SA-1 3CT-V85SA-1 2SI-V573SA-1 3CC-V165SA-1 3CT-V88SB-1 2SI-V574SB-1 3CC-V167SB-1 3CZ-B1SA-1 2SI-V575SA-1 3AV-BlSA-1 3CZ-B2SB-1 2SI-V576SB-1 3AV-B2SA-1 3CZ-B5SA-1 2SI-V577SA-1 3AV-B3SB-1 3CZ-56SB-1 2SI-V578SB-1 3AV-B4SB-1 3CZ-B7SA-1 2SI-V579SA-1 3AV-B5SB-1 3CZ-B8SB-1 2SI-V587SA-1 3AV-B6SA-1 3CZ-B17SA-1 3SW-B5SA-1 2CS-L520SA-1 3CZ-B18SB-1, 3SW-B6SB-1 2CS-L521SB-1 3CZ-B19SA-1 3SW-B8SA-1 2CS-L522SB-1 3CZ-B20SB-1 3SW-B13SB-1 2CS-L523SA-1 3CZ-B21SA-1 3SW-B14SB-1 2CS-L610SA-1 3CZ-B22SB-1 2SW-B45SA-1 2CS-V516SA-1 3CZ-B23SA-1 2SW-B46SA-1 2CS-V517SB-1 3CZ-B24SB-1 2SW-B47SA-1 2CS-V522SB-1 3CZ-B25SA-1 2SW-B48SB-1 2CS-V523SB-1 3CZ-B26SB-1 2SW-B49SA-1

~ 2CS-V524SB-1 PLP-108 Rev. 1 3CZ-B32SA-". 2SW-B50SB-1 Page 27 of 28

OS4 Attachment 2 (continued)

Limitorque Motor OPerators (continued) 2SW-B51SB-1 2SW-B52SB-1 3SW-B70SA-1 3SW-B71SA-1 3SW-B72SB-1 3SW-B73SB-1 3SW-B74SA-1 3SW-B75SA-1 3SW-B76SB-1 3SW-B77SB-1 ASCO Solenoid Valves 3CC-L1SA-1 3CC-L2SB"1 2RC-D525SB-1 2SI-V530SB-1 2SI-V550SB-1

~ 2SI-V554SB-1 2WG-D291SB-1 2WL-D650SB-1

.0 PLP-108 Rev. 1 Page 28 of 28