ML18054A931
| ML18054A931 | |
| Person / Time | |
|---|---|
| Site: | Palisades |
| Issue date: | 08/21/1989 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML18054A930 | List: |
| References | |
| GL-83-28, NUDOCS 8908280198 | |
| Download: ML18054A931 (6) | |
Text
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1.0 INTRODUCTION
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0. C. 20555 SAFETY EVALUATION REPORT PALISADES NUCLEAR PLANT DOCKET NO. 50-255 GENERIC LETTER 83-28, ITEM 2.2.1 EQUIPMENT CLASSIFICATION PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS ENCLOSURE 1 Generic Letter 83-28 was issued by the NRC on July 8, 1983 to indicate actions to be taken by licensees and applicants based on the generic implications of the Salem ATWS events.
Item 2.2.1 of that letter states that licensees and applicants shall describe in considerable detail their program fer classifying 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 activities that may affect these components. Specifically, the licensee/
applicant's submittal was required to contain information describing (1) the criteria used to identify 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 activities affecting these components; (4) management controls that are used to verify that the information handling system is prepared, maintained, validated,* and u*sed in accordance with approved pro-cedures; and -(5} design verification and qualification testing requirements that are part of the specifications for procurement of safety-related components.
The licensee for the Palisades Nuclear Plant submitted a response to Generic Letter 83-28, Item 2.2. 1 in the submittal dated November 9, 1983.
We have evaluated this response and find it acceptable.
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- p
- 2.0 EVALUATION$ AIJD CONCLUSIONS In these sections the licensee's responses to the*program and each of five sub-items are i~dividually evaluated against guidelines developed by the staff and conclusions are drawn regarding their individual and collective acceptability.
- 1.
Identification Criteria Guideline:
The licensee's response should desctib~ the crit~~ii u~ed t~
identify safety-related equipment and components.
(Item 2.2.1.1)
Evaluo.tion:
The licensee's submittal states that safety-related equipment is identified in a Q-1ist. The Q-list was developed and is maintained in accordance with the criteria of Regulatory Guide 1.29 as clarified by item number 20a, Appendix A, part 2 of Topical Report C PC-2A.
==
Conclusion:==
The staff concludes that the licensee's response to this item is complete and acceptable.
- 2.
Ir.formation Handling System 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.
Approved procedures which govern its development, maintenance, and val1dation shouid exist. (Item t.2. 1.2)
- Evaluation:
The licensee's submittal shows a Q-list composed of an Equipment Data Base and Appendices of an Administrative procedure. Classification of safety-related equipment is done in accordance with procedures and their QA program.
The Q-list is developed and validated by licensee's technical staff and reviewed by QA and Technical Superintendent.
==
Conclusion:==
We conclude that the licensee's submittal meets this item's requirements and is acceptable.
- 3.
Use of Information Handling System:
Guidelines:
The licensee response should confirm that their equipment classification program includes criteria and procedures which govern 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 introduction to 10CFRSO, Appendix B, are applied to safety related components.
(Item 2.2. 1.3)
Evaluation:
The licensee's submittal identifies the use of the Q-list, Nuclear Operation Department Standards, Maintenance Orders and Administrative Procedures for use with safety-related equipment. Collectively these documents contain the controls to ensure that safety-related equipment is properly handled.
==
Conclusion:==
The staff concludes that the licensee's submittal properly addresses this item and is acceptable.
- 4.
Man~gement Controls Guideline:
The licensee/applicant should confirm that management controls used to verify that the procedures for preparation, validation, and routine utilization of the information handling system have been and are being followed.
(Item 2.2.1.4)
Evaluation:
The licensee's submittal states th~t all applicabl~ documerii~ are pr6pe~lj reviewed and approved prior to implementation. Periodic surveillances and audits are performed by QA to ensure the Q-list information is being properly utilized.
==
Conclusion:==
The staff concludes that the licensee has properly addressed this item and their submittal is acceptable.
- 5.
Design Verification and Procurement Guideline:
The licensee/applicant's response should document that past usage demonstrates that appropriate design verification and qualification testing is_specjfied for the procurement -0f 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 recorrmended 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)
- Evaluation:
The licensee submittal states that there are standard administrative procedures controlling the procurement of materials which establish the requirements, responsibilities and method of procurement. All procurement documents receive technical, QA and administrative reviews to ensure that adequate technical and quality requirements have been specified by the originator of the documents.
Cone lus ion:
The staff concludes that the licensee's response to this item is complete and are acceptable.
- 6.
"Important To Safety" Corrments Guideline: Generic Letter 83-28 states that licensee/applicant equipment classification programs should include {in addition to the safety-related components) a broader class of components designated as "Important to Safety." However, since the generic letter does not require licensee/
applicant to furnish this information as part of their response, staff -
review of this sub-item will not be performed.
{Item 2.2. 1.6}
- 7.
Program Guideline:
Licensees/applictnts should confirm that an equipment classification 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 activities that affect such safety-related components are aware that they are working
- on safety-related components a~d are guided by safety-related procedures and constraints. (Item 2.2.1)
Evaluation:
The licensee's response to these requirements was contained in a submittal dated November 9, 1983. This submittal described 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:==
We conclude that the licensee's program addresses the staff concerns regarding equipment and component classification and is acceptable.
3.0 REFERENCES
- 1.
NRC Letter, O. G. Eisenhut to ali 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 63-28)," July 8, 1983.
- 2.
Consumers Power Corr~any letter, D. J. VandeWalle to D. G. Eisenhut, NRC, November 9, 1983.