ML18051A667
| ML18051A667 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/09/1983 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| GL-83-28, NUDOCS 8311170078 | |
| Download: ML18051A667 (5) | |
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consumers Power company General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-0550 November 9, 1983 Mr Darrell G Eisenhut, Director Division of Licensing Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
CORRECTION TO CONSUMERS POWER COMPANY LETTER DATED NOVEMBER 7, 1983 The first four pages of Attachment 1 to Consumers Power Company's letter dated November 7, 1983, entitled "Response to Generic Letter 83 Required Actions Based on Generic Implications of Salem ATWS Events" were misprinted.
Please replace the first four pages of Attachment 1 with the attached pages.
Director of Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment OC1183-0005A-NLOO
ATTACHMENT 1 ISSUE 2.1 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (REACTOR TRIP SYSTEM COMPONENTS)
NRC Position (Equipment Classification)
Licensee and applicants shall confirm that all components whose functioning is required to trip the reactor are identified as safety-related on documents, procedures, and information handling system(s) used in the plant to control safety-related activities, including maintenance, work orders and parts replacement.
Consumers Power Company Response Consumers Power Company's letter dated September 6, 1983 stated in part that Consumers Power Company would provide a report describing the present program for classification of the components of the reactor trip system.
That letter, however, requested an extension of time for review and verification that all components of the reactor trip system were specifically identified as being safety-related.
In addition, our letter of September 6, 1983 indicated that the Vendor Interface portion of the Equipment Classification Issues would be treated as a separate item.
Therefore, this section of Consumers Power Company's response to Generic Letter 83-28 provides a description of the present program for controlling safety-related activities on the reactor trip system and for ensuring that the reactor trip system components are classified as safety-related on all documents, procedures and information handling systems.
Palisades Nuclear Plant Administrative Procedure 10.08, "Q-List/Equipment Data Base," is the controlling procedure for the determination of the classifica-tion of all systems and equipment in the plant.
This procedure identifies the plant Q-List and provides guidelines for the quality classification of plant equipment, material, services, and activities. It is the responsibility of the Plant Manager to maintain and implement this procedure and to maintain t~e approved Q-List.
The Palisades Plant Q-List consists of the Equipment Data Base (EDB), and the appendices of Procedure 10.08.
The Q-List delineates those structures, systems and components that are important-to-safety and require the applica-tion of the QA program.
Section 8.1 specifically includes as part of the Q-List; "the system, portions of systems or component (that) is designed to provide reactor shutdown."
Administrative procedures at the Palisades Plant requires that prior to any normal maintenance, including preventative maintenance, on systems or equip-ment at the plant, that a Maintenance Order (MO) be processed.
Administrative Procedure 2.01, "Processing of Maintenance Orders," describes the procedure for the processing of maintenance orders at the Palisades Plant.
This proce-dure applies to all maintenance and specifically requires that the safety status, ie, Q or non-Q, of the system or equipment be determined prior to the OC1083-0007D-NLOO Page 2 of 10 maintenance activity.
In addition, this procedure requires that if the safety status of the component or system cannot be determined from the Q-List that the equipment be designated as Q on the maintenance order and that a Q-List Interpretation Form be initiated.
This step ensures that all equipment, unless it is specifically listed as non-Q, is treated as if it were Q for all maintenance activities.
In addition, the administrative procedures that control major and minor modifications and minor field changes to equipment at the Palisades Plant require that the safety status of the equipment or system being modified be determined and that a safety evaluation be completed and reviewed prior to any work being performed.
For the procurement of replacement parts for safety-related systems or equip-ment, Procedure 10.03, Procurement of Materials, requires that the originator of the procurement documentation determine the safety-related status of the system, material, or part using the Q-List as a reference.
Subsequent review by the individual's functional superintendent and a Quality Assurance repre~
sentative assures adequate control when procuring replacement parts.
In addition to the procurement of replacement parts, Procedure 10.08 states that vendor-supplied services are deemed to be Q-listed if that service involves activities which may affect Q-listed components, structures, or systems.
The existing procedures, as described above, are adequate as to ensure that the components of the reactor trip system are identified and controlled as safety~related during the performance of maintenance activities and when procuring replacement parts. Verification that the components of the reactor trip system are specifically identified as being safety-re'iated will be performed as part of the program plan for response to Generic Letter 83-28.
(See Attachment 3.)
OC1083-0007D-NLOO
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NRC Position ISSUE 2.2 EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE (Programs for All Safety-Related Components)
Page 3 of 10 For equipment classification, licensees and applicants shall describe their program for ensuring that all components of safety-related systems necessary for accomplishing required safety functions are identified as safety-related on documents, procedures and information handling systems used in the plant to control safety-related activities, including maintenance, work orders and replacement parts.
This description shall include:
- 1.
The criteria for identifying components as safety-related within systems currently classified as safety-related.
This. shall not be interpreted to require changes in safety classification at the systems level.
- 2. A description of the information handling system used to identify safety-related components and the methods used for its development and validation.
- 3.
A description of the process by which station personnel use this informa-tion handling system to determine that an activity is safety-related and what procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10 CFR 50, Appendix B, apply to safety-related components.
- 4.
A description of the management controls utilized to verify that the procedures for preparation, validation and routine utilization of the information handling system have been followed.
- 5.
A demonstration that appropriate design verification and qualification testing is specified for procurement of safety-related components, The specifications shall include qualification testing for expected safety service conditions and provide support for the licensees' receipt of testing documentation to support the limits of life recommended by the supplier.
- 6.
Licensees and applicants need only to submit for staff review the equip-ment classification program for safety-related components.
Although not required to be submitted for staff review, your equipment classification program should also include the broader class of structures, systems and components important to safety required by GDC-1.
Consumers Power Company Response
- 1.
Safety-related structures, systems, components and related consumables are identified in a Q-List, which was developed and is maintained in accor-dance with the criteria of Regulatory Guide 1.29 as clarified by Item OC1083-0007E-NLOO
Page 4 of 10 No 20a, Appendix A, Part 2 of Topical Report CPC-2A.
Nuclear Operation Department Standard (NODS) A21 which is based on the above Reg Guide, provides further detail, namely, that the following systems and components and their supports are to be included in the Q-List:
- a.
The reactor coolant pressure boundary.
- b.
The reactor core and reactor vessel internals.
- c.
Systems* or portions of systems that are required for:
- 1) emergency*
core cooling; 2) post-accident containment heat removal; or
- 3) post-accident containment atmosphere cleanup (eg, hydrogen removal system).
- d.
Systems* or portions of systems that.are required for:
- 1) reactor shutdown; 2) residual heat removal; or 3) cooling the spent fuel storage pool.
- e.
Those portions of the steam systems of boiling water reactors extend-ing from the outermost containment isolation valve up to but not including the turbine stop valve, and connected piping up to and including the first valve that is either normally closed or capable of automatic closure during all modes of normal.reactor operation.
- f.
Those portions of the steam and feedwater systems of pressurized water reactors extending from and including the secondary side of steam generators up to and including the outermost containment isolation valves, up to and including the first valve (including a safety or relief valve) that is either normally closed or capable of automatic closure during all modes of normal reactor operation.
- g.
Cooling water, component cooling and auxiliary feedwater system* or portions of these systems, including the intake structures, that are required for:
- 1) emergency core cooling; 2) post-accident containment heat removal; 3) post-accident containment atmosphere cleanup;
- 4) residual heat removal from the reactor; or 5) cooling the spent fuel storage pool.
- h.
Cooling water and seal water systems* or portions of these systems that are required for functioning of reactor coolant system components important to safety, such as reactor. coolant pumps.
- i.
Systems* or portions of systems that are required to supply fuel for emergency equipment.
- j. All electric and mechanical devices and circuitry between the process and the input terminals of the actuator systems involved in generating signals that initiate protective action.
- k.
Systems* or portions of systems that are required for:
- 1) monitoring of systems important to safety and 2) actuation of systems important to safety.
OC1083-0007E-NLOO
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