ML18152A804

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SER Accepting Util 831104 & 850208 Responses to Item 2.2.1 of Generic Ltr 83-28, Equipment Classification Programs for All Safety-Related Components. Basis for NRC Acceptance Documented in EGG-NTA-7378
ML18152A804
Person / Time
Site: Surry  Dominion icon.png
Issue date: 03/29/1988
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML18152A803 List:
References
NUDOCS 8804050211
Download: ML18152A804 (7)


Text

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1.0 INTRODUCTION

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION REPORT SURRY POWER STATION, UNITS 1&2 DOCKET NO. 50-280/281 GENERIC LETTER 63-28, 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 des,ribe in considerable detail their program for classifying all safety-related components other than RTS components as safety-related on plant documents and in infonnation handling systems that are used to control plant activities that may affect these components. Specif;cally, the licensee/

applicant's submittal was required to contain information describing (1) the criteria used to identify these components as safety-related; (2) the infonnation handling system which identifies the components as safety-related; (3) the manner in which station personnel use this infonnation handing system to control activities affecting these components; (4) management controls that are used to verify that the infonnation. handling system is prepared, maintained, validated, and used in accordance with approved procedures; and (5) design verification and qualification testing requirements that are part of the specifications for procurement of safety-related components.

The licensee for the Surry Power Station, Units 1&2 submitted responses to Generic Letter 83-28, Item 2.2.1 in submittals dated November 4, 1983 and February 8, 1985.

We have evaluated these responses and find that they are acceptable.

2.0 EVALUATION AND CONCLUSIONS In these sections the licensee's responses to the program and each of five sub-items are individually evaluated ~gainst guidelines developed by the staff and conclusions are drawn regarding their individual 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 the criteria utilized for classification of safety-related structures, systems, and components are consistent with the definition and requirements stated in 10 CFR 100, Appendix A, Paragraph III(c).

==

Conclusion:==

The licensee's criteria met the requirements of the item of Generic Letter 83-28 and are acceptable.

2. Infonnation Handling System Guideline:

The licensee's response should confinn 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 validation should exist. (Item 2.2.1.2)

e Evaluation:

The licensee's response stat~s that the infonnation handling system consists of Station Administrative Procedure ADM/73 which contains a listing of safety-related structures, systems, and components.

The listing contained in the procedure does not provide a detailed listing of every component of safety-related systems but provides a general breakdown by system and major component parts. Subcomponents of safety-related systems are considered to be safety-related. The procedure containing the 11st is a controlled station document and requires the review and approval of the Station Nuclear Safety and Operating Conm1ttee (SNSOC).

Where questions arise during classification of specific structures, systems or components, requests are forwarded to the station engineering staff for resolution. Appropriate reviews are required prior to the removal from or addition to the list.

The licensee indicates that development of a new and more complete listing of safety-related components is in plannin.g but no specific date for completion has been set.

==

Conclusion:==

We conclude that this response and the licensee's program satisfies the staff's concern and is, therefore, acceptdble. The licensee should provide a schedule for completion of the new listing and confinn its implementation.

3. Use of Infonnation Handling System Guideline:

The licensee's response should confirm that their equipment classification program tncludes criteria and procedures which govern the use of the infonnat1on handling system to detennine that an activity 1s safety-related and that safety-related procedures for maintenance, surveillance, parts replacement and other activities defined in the

<t introduction to 10 CFR 50, Appendix B, are applied to safety-related components.

(Item 2.2.1.3)

Evaluation:

The licensee's response indicates that responsible station personnel use the equipment listing and corporate procedures to designate the safety classification of the equipment and the procedures required to perfonn the work.

Th~ Sdfety classificat1on and procedures are.

indicated on the work activity fonns used for all repair and modification work perfonned at the plant. If anyone within the plant is unsure of the classification of a component, the procedures require that he check with the station engineering staff.

==

Conclusion:==

We conclude that the licensee has described plant administrative controls and procedures which meet the staff requirements for this item and are acceptable.

4. Management Controls Guideline:

The licenset!/applicant should confirm that management controls used to verify that the procedures for preparation, validation, and routine utilization of the infonnation handling system have been and are being followed.

(Item 2.2.1.4)

Evaluation:

The licensee 1s response states that changes in the approved classifica-tion listing must be approved by the SNSOC, and.the Quality Assurance Department perfonns audits of activities covered by the plant instructions and procedures. Thus, the audit program provides verification of the routine utilization of the infonnation handling system.

-' Lt. Conclusfon:

We find this description of the licensee's program of management controls meets the staff requirements and 1s 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 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 docuff~ntation which supports the limits of life reconmended by the suppl1er. If such documentat1on is not available, conf1nnat1on that the present program meets these requirements should be provided.

(Item 2.2.1.5)

Evaluation:

The l1censee's response states that the guideline and policy for procurement of equipment for use at each station is contained in Section 4 and Section 7 of the Nuclear Power Station Quality Assurance Manual (NPSQAM) and related station administrative procedures. These documents provide direction regarding review of purchase documents, requirements for standard tests or inspections and supporting quality assurance_documentation, requirements for review when "comnerc1al grade" materials or components or substitute materials or components are used in lieu of those originally specified. General guidance is also provided regarding the use of "Engineering Specifications" for new materials or components added during plant design changes.

  • Normal replacement parts and maintenance items are procured through purchase requisitions which contain the required information referenced in the NPSQAM and station admfois.trative procedures.

The information and deta i1 is inc 1 uded in the purchase document and a re nonnci"l ly standard nuclear industry requirements. Special items may be procured using formal specification documents and the specifications 1nclude such considerations as env1ronmental aria testing conditions.

Material and equipment for plant modifications are procured through methods similar to those described above.

The same governing documents apply to this procurement cycle. The difference is primarily in the area of approval for monetary corrmitrnents and expenditures.

==

Conclusion:==

We find the licensee's procedures meet the staff requirements for this item and are acceptable.

6.

11 Important To Safety" Components 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.

11 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/applicants 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 saf~ty-related components ar~

awdre that they are working on safety-related components and are guided by safety-related procedures and constraints.

(Item 2.2.1)

Evaluation:

The licensee's response to these requirements was containea in submittals dated November 4, 1983 and February 8, 1985. These submittals describe the licensee's program for identifying and classifying safety-related equipment and components which meets the staff requirement 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, D. 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.

Virginia Electric and to H. R. Denton, NRC,

3.

Virginia Electric and to H. R. Denton, NRC, Dated:

Maren 29, 1988 Principal Contributor:

D. Lasher Power Company Letter, W. L. Stewart November 4, 1983, Serial Number 617.

Power Company Letter, W. L. Stewart February 8, 1985, Serial Number 85-063.