ML20196H836

Forwards Request for Addl Info Re Items 2.1 & 2.2 of Generic Ltr 83-28 Concerning Equipment Classification & Vendor Interface on Reactor Trip Sys Components.Open Item Re Scheduling Implementations Should Be Addressed in Response

ML20196H836
Person / Time
Site:	Limerick
Issue date:	03/04/1988
From:	Clark R Office of Nuclear Reactor Regulation
To:	Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
References
GL-83-28, NUDOCS 8803140074
Download: ML20196H836 (8)

Text

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Docket No.: 50-352/353 March 4, 1988 Mr. Edward G. Bauer, Jr.

Vice President and General Counsel

-Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

SUBJECT:

GENERIC LETTER 83-28. ITEMS 2.1 AND 2.2 RE: LIMERICK GENERATING STATION, UNITS 1 AND 2 Items 2.1 and 2.2 of Generic Letter 83-28 (Salem ATWS Event) concern equipment classification and vendor interface on reactor trip system components and all-other safety related components. You advised us regarding your proposed actions and the status of your implementation of these actions in your letters of November 10, 1983, May 8, 1984 and May 29 and June 7, 1985. Our review of these submittals discloses the need for confimatory or clarifying information as described in the erclosed requests for additional information (enclosures 1 and 2).

We have inspected your implementation of the proposed actions regarding the subject items June 24,1987)(.e.g., ThereSection is an open2.2iten of regarding Inspection Report No.

scheduled 50-352/87-12 implementation of dated the programs which you should address in your response.

Sincerely.

Original signed by Richard J. Clark Richard J. Clark, Project Manager Project Directorate I-2 Division of Reactor Projects I/II

Enclosures:

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• s.,...../ March 4, 1988 Docket No.: 50-352/353 Mr. Edward G. Bauer, Jr.

Vice President and General Counsel Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101

SUBJECT:

GENERIC LETTER 83-28, ITEMS 2.1 AND 2.2 RE: LIMERICK GENERATING STATION, UNITS 1 AND 2 Items 2.1and2.2ofGenericletter83-28(SalemATWSEvent)concernequipment classification and vendor interface on reactor trip system components and all other safety related components. You advised us regarding your proposed actions and the status of your implementation of these actions in your letters of November 10, 1983, May 8, 1984 and May 29 and June 7, 1985. Our review of these submittals discloses the need for confirmatory or clarifying information as described in the enclosed requests for additional information (enclosures 1 and 2).

We have inspected your implementation of the proposed actions regarding the subject items (e.g., Section 2.2 of Inspection Report No. 50-352/87-12 dated June 24, 1987). There is an open item regarding scheduled implementation of the programs which you should address in your response.

Sincerely, Rc . rk, Project Manager P oject Directorate I-2 Division of Reactor Projects I/II

Enclosures:

As stated cc: See next page

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.. .. i Mr. Edward G. Bauer, Jr Limerick Generating. Station Philadelphia Electric Company Units 1 & 2  ;

l cc:

Troy B. Conner, Jr. , Esquire Mr. Robert Gramm Conner and Wetterhahn Senior Resident Inspector .

1747 Pennsylvania Ave., N.W. U.S. Nuclear Regulatory Corsnission '

Washington, D. C. 20006 P. O. Box 58 Mr. Charles Mengers S7-1 Philadelphia Electric Company Chairman Board of Supervisors of 2301 Market Street Limerick Township Philadelphia, Pennsylvania 19101 646 West Ridge Pike Limerick, Pennsylvania 19468 Mr. David Honan N2-1 Philadelphia Electric Company Dept of Environmental Resources 2301 Market Street ATTN: Director, Office Radiologic Philadelphia, Pennsylvania 19101 Health P. O. Box 2063 Mr. Grahm M. Leitch. Acting Plant Manager Harrisburg, Pennsylvania 17105 Limerick Generating Station Post Office Box A Thomas Gerusky, Director Sanatoga, Pennsylvania 19464 Bureau of Radiation Protection PA Dept. of Environmental Resources Mr. James Linville P. D. Box 2063 U.S. Nuclear Regulatory Comission Harrisburg, Pennsylvania 17120 Region I 475 Allendale Road Governor's Office of State King of Prussia, PA 19406 Planning and Development ATTN: Coordinator, Pennsylvania State Clearinghouse P. O. Box 1323 Harrisburg, Pennsylvania 17102 i

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D ENCLOSURE 1 LIMERICK GENERATING STATION, UNITS 182 DOCKET NO. 50-352/353 REQUEST FOR ADDITIONAL INFORMATION FOR GENERIC LETTER 83-28, ITEM 2.1 (PART 1)

Introduction We have reviewed the responses to Generic letter 83-28, Item 2.1 (Part 1) dated May 8, 1984, May 29, 1985, and June 7, 1985 provided by Philadelphia Electric Company, the licensee for Limerick, Units 182, and find we need the following information. The licensee is requested to provideo additional information for these items as described below.

Evaluation and Specific Information Request Evaluation The first submittal stated that plant procedures were still in the development stage and that the developed documents would reflect the requirements of this item of the generic letter.

In subsequent submittals, the licensee / applicant confirmed that all systems which contribute to the reactor trip function had been identified in the current "Q-List" and that all components of the identified systems are subject to the quality assurance program unless specifically excluded by the plant safety evaluation program. The submittals stated that the licensee / applicant's progran requires that each item or service to be procured must be reviewed to determine if it is safety-related.

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Hoever, based on our review of the licensee's/ applicant's submittals, we found  ;

that the list of components required to trip the reactor have not been completed 1 to the component level. We also found that the submittals did not confim that the licensee's/ applicant's program meets the requirements for identification of safety-related components on relevant plant documents. The licensee / applicant needs to supplement his response to fully address these requirements.

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9 ENCLOSURE 2 l

LIMERICK GENERATING STATION, UNITS 182 DOCKET NO. 50-352/353 REQUEST FOR ADDITIONAL INFORMATION FOR GENERIC LETTER 83-28, ITEM 2.2 (PART 1) t The applicant for the Limerick Generating Station, Units 1 & 2 responded to item 2.2 (Part 1) of Generic Letter 83-28 by submittals dated November 10, 1983, May 29, 1985, and June 7, 1985. The staff has reviewed these responses and finds additional information is needed for some of the sub-items of Item 2.F.(Part1). The review guidelines used by the staff for these sub-items are listed below, followed by a brief evaluation of the applicant's submittals, and a listing of that the staff concludes is necessary to complete this item.

Iteg_2.2.1 - Program Requested Information Licensees and applicants should submit a program description which provides .

assurance that safety-related components are designated as safety-related on plant documents, drawings, procedures, and in information handling systems i that are used in accomplishing safety-related activities such as work orders for repair, maintenance, and surveillance testing and orders for procurement of replacement parts.

Evaluation The licensee has provided a description of the equipment classification program and controls associated with the identification of safety-related activities for repair, maintenance, and procurement. However, the response does not

clearly address whether all components designated as safety-related in the 0-11st are also properly designated on plant documents, procedures and in the ,

information handling systems. Also, within the responses, the licensee I

4 provided dates when the programs would be fully implemented, but there has been no response indicating that the programs as described are, in fact, implemented and that no changes have been made in the described programs. The licensee should provide ariditional information that address the above issues.

Item 2.2.1.1 - Identification Criteria Requested Infonnation The criteria for identifying components as safety-related should be presented.

This should inciude a description of the means for handling sub-components or parts and procedures for initiating the identification of components as safety-related or non-safety-related if no previous classification existed.

Evaluation The licensee's submittal provides the classification criteria used to determine whether a structure, system or component is safety-related. This is consistent with the definition given in item 2.2.1. However, the licensee did not identify the procedures used to initiate the identification of components as safety-related if no previous classificatinn existed. The licensee shnuld provide additional information that addresses this latter situation.

Item 2.2.1.3 - Use of Equipment Classification t.isting Guideline The licensee's description should show how station personnel use the equipment classification infonnation handling system to detennine: (a) that an activity is safety-related, and (b) that safety-related procedures are to be used for maintenance work, routine surveillance testing, accomplishment of design changes, performance of engineering support work, accomplishment of setpoint changes, and perfonnance of special tests or studies.

Evaluation The licensee's response stated that safety-related activities are required by administrative maintenance procedures to be conducted under the maintenance request form (MRF) system. This MRF system will be automated by an equipment data base management system called the Computerized History and Maintenance Planning System (CHAMPS). The CHAMPS program will automatically insert the Q-list status of the component into the computerized MRF thereby eliminating any human involvement in review of a hard copy of the Q-list. The licensee stated that this system would be fully operational by January 1985. If this system is at the present time fully operational and functions as described in the November 10, 1983 response, the concerns of the sub-items are addressed as far as maintenance is concerned. However, it is not clear how the CHAMPS will be used in the accomplishment of other activities such as routine surveillance testing, design changes, engineering support work, setpoint changes, and performance of special tests or studies. Also, it has not been addressed how station personnel use the MRF or other means to identify the appropriate plant instructions and proceduret to be used for the accomplishment of setpoint changes, and the performance of special tests or studies. The licensee should address the staff concerns described above.

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