ML20044B599
| ML20044B599 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 12/30/1992 |
| From: | Femreite B SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 9301190199 | |
| Download: ML20044B599 (5) | |
Text
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1 SIEMENS n
December 30,1992 U.S. Nuclear Regulatory Commission i
Region V 1450 Maria Lane Walnut Creek, CA 94596-5368
,s Attri: Mr. John B. Martin, Regional Administrator
Subject:
Siemens Power Corporation (SPC) Criticality Safety Analysis Update Program Ref: Letter, R.G. Frain to Director, Office of Enforcement, US NRC,."Siemens Power Corporation (SPC) Reply to Notice of Violation (NRC Inspection Report No. 70-1257/92-06),"
dated November 20,1992.
Dear Mr. Martin:
Attached please find a copy of the program plan for the review, evaluation, and updating of SPC's criticality safety analyses. This plan expands and refines our preliminary approach as presented to NRC ~in Walnut Creek on September 22,1992. As discussed in our meeting with Mr. Wenslawski of your staff in Richland on December 11,1992, the plan more fully defines our long term corrective actions for CSA updating as committed to in the referenced
.J Response to Notice of Violation.
Also as discussed with Mr. Wenslawski, SPC has developed an organizational framework for j
conduct of the update program and Phase 1 of the project is underway. We will keep NRC i
Region V aware of our progress in this important safety effort, if you have questions, please contact L. J. Maas of SPC at 509-375-8537.
Very truly yours, B.~
Fe eite Richland lant Manager BNF:pm cc:
U.S. Nuclear Regulatory Commission y
_} d Director, Office of Enforcement
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I 93OLL10 L913 '
Siemens Power Corporation Nuclear Division Engineering and Manufacturing Facihty 2101 Hom Rapids Road Do n= 1 % hhland WA 99352 4130 Tel: 509) 375-8100 Fax: (509) 375-8402
t Siemens Power Corporation 3
Criticality Safety Analysis Update Proaram Introduction Many of Siemens Power Corporation's (SPC's) Criticality Safety Analyses (CSAs) which support the operation of the plant's equipment and processes are over 10 years old. While changes made to such processes and equipment have been undertaken carefully and with proper scrutiny of criticality and other safety disciplines,it is prudent to review the CSAs both for applicability to current conditions and for compliance with NRC requirements for a sound criticality safety control program. The primary intent of this update program is to confirm the accuracy and adequacy of existing CSAs, thereby confirming the criticality safety of current operations. Beyond this primary purpose, an effort will be made to group the existing CSAs into systems and to incorporate each system (e.g., rod loading) into consolidated system CSAs, using the validated assumptions and accident scenarios of all the component CSAs.
This update program is divided into the three phases described below. The expected completion dates or durations are provided for each phase; changes may occur if the amount of work required to complete each task changes.
~
There are differences between this program and that outlined for the NRC on September 22 in Walnut Creek. The original estimate of 12 months duration for the program has been lengthened considerably as a result of reviewing similar programs for other facilities, added work scope, etc.
In addition the categofzation of CSAs has been changed to categorize on the basis of the safety impact of identified dcficiencies rather than type of control.
Description i
Phase 1 INITIAL REVIEW AND SYSTEM GROUPING OF EXISTING CSAs Review existing CSAs and validate existing assumptions. The product of this phase will be a validation of all assumptions used in previous analyses and a sorting of the CSAs into one of three categories (see step 3 under phase 18, below). The steps required to complete this phase are listed below:
Phase 1 A (Expected to be completed by 4/30/93):
1.
SPC's consultant will review existing CSAs and summarize the existing assump-tions, accident conditions, required design features and initial judgements on double contingency. This effort will require 1-2 months to complete.
2.
A Criticality Safety Review Team (made up of personnel from Plant Operations, Engineering, and the Criticality Safety Component) will be established to divide areas of the plant into process systems.
3.
The Project Manager will compile packages for each process system. The package will include the existing CSAs, flow diagrams, equipment locations, a summary of assumptions, and listed accident conditions.
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4 December 30,1992 1
Page 2 Phase 1B (Expected to be completed by 6/30/93):
1.
Manufacturing Engineering and/or Plant Operations will use the packages prepared in step 3 of phase 1 A, above, and validate assumptions, equipment locations, and listed accident conditions. The results of this validation process will be documented with the package. Weaknesses or new accident scenarios identified will be evaluated as part of phase 2.
2.
Safety, Security and Licensing (SS&L) will review the results of step 1 of phase 1B for potential reporting under NRC Bulletin 91-01 and compliance with license requirements.
3.
SS&L will review CSAs for adequacy and will sort the CSAs into three categories:
Category 1 - The CSAs for the system need major or urgent reanalyses. The reanalyses for such systems proceed immediately or very near term (less than 4 weeks). The criteria for being category 1 are those areas where there are unfounded assumptions or incomplete accident analyses, Any such systems that may pose an immediate threat to the health and safety of workers will be immediately shut down pending completion of needed corrective actions.
Category 11 - The CSAs for the system have some deficiencies, but can be corrected by addenda for an interim period.
Category lli - CSAs for the system are adequate and will not be revised as part of this update program. These CSAs will be formatted as part of the periodic review described later.
Phase 2 REANALYSIS / DOCUMENTATION OF CATEGORY l CSAs Reanalyze category I system packages which have been prioritized by potential safety impact and operational requirements. The duration of this phase is expected to be 7 months depending on the number of CSAs in this category. The steps to be taken for these reanalyses are as follows:
1.
Manufacturing Engineering will provide as built drawings for each process system, including detailed piping diagrams.
2.
Manufacturing Engineering, Plant Operations, and the Criticality Safety Component will establish credible accident scenarios for each process system.
3.
Manufacturing Engineering will mark pertinent as-built drawings as containing dimensions or other design features important to criticality safety and will specify on the drawings that neither the drawings nor the systems may be modified without approval from the Criticality Safety Component.
4.
The Criticality Safety Component will complete a CSA for each system.
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Page 3 i
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As part of the second party review process the criticality safety review team will f
validate layout configurations, dimensions, assumptions and credible accident scenarios for the system.
1 6.
The Criticality Safety Component will complete a matrix of all validated assump-tions for each CSA. This matrix is to be maintained up-to-date.
7.
The Plant Manager willindicate, by signature on the CSA, that the safety margin and residual risk established by each CSA are appropriate.
8.
The Criticality Safety Component will place all criticality safety requirements for each process system in a Criticality Safety Specification.
9.
The Criticality Safety Component will place all limits and controls directly controllable or observable by an operator on Limit and Instructional cards.
10.
Plant Operations will incorporate needed limits and controls into operating procedures.
11.
Plant Engineering will place required surveillances on the automatic recall system.
12.
The Criticality Safety Component will document all assumptions on a data base.
This data base is to be maintained up to date.
Phase 3 REANALYSIS / DOCUMENTATION OF CATEGORY ll CSAs
\\
Roanalyze category 11 system packages for creation of addenda. The expected duration of this phase is 12 months from the completion of phase 2. The steps to be taken for this reanalysis are as follows:
1.
Manufacturing Engineering will provide as-built drawings for each process system as needed based on preliminary review of assumptions and accident conditions.
4 2.
Manufacturing Engineering will mark pertinent as-built drawings as containing dimensions or other design features important to criticality safety and will specify on the drawings that neither the drawings nor the systems may be modified without approval from the Criticality Safety Component.
3.
The Criticality Safety Component will complete CSA addenda for each system to tie all the CSAs together and to address any minor deficiencies.
4.
The Criticality Safety Component will complete a matrix of all validated assump-tions for cach Criticality Safety Analysis. This matrix is to be maintained up-to-date.
5.
The Criticality Safety Component will place all criticality safety requirements for each process system in a Criticality Safety Specification.
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r December 28,1992 -
Page 4 6.
The Criticality Safety Component will place all limits and controls directly F
controllable or observable by an operator on Limit and instructional cards.
7.
Plant Operations will incorporate needed limits and contrcis into operating procedures.
8.
Plant Engineering will place required surveillances on the automatic recall system.
9.
The Criticality Safety Component will document all assumptions on a data base.
This data base is to be maintained up to date.
Periodic Review A periodic review will be conducted of all assumptions made in CSAs such that each CSA is completely reviewed at least every five years. It will be scheduled and conducted by the criticality safety review team. This periodic review is not part of the CSA update program, but rather a routine maintenance program for CSAs.
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