ML20205T002

SER Accepting Util 831104,840330 & 870504 Responses to Item 2.2.1 of Generic Ltr 83-28 Re Equipment Classification Programs for All safety-related Components

ML20205T002
Person / Time
Site:	Beaver Valley
Issue date:	08/10/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20205S998	List: ML20205S995 ML20205T002
References
GL-83-28, NUDOCS 8811140069
Download: ML20205T002 (6)

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NUCLEAR REGULATORY COMMISSION UNITED STATES y )3 p, j WASHINGTON, D. C. 20555

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SAFETY EVALUATION REPORT DOCKET NOS. 50-334/412 BEAVER VALLEY POWER STATION, UNITS 1&2 GENERIC LETTER 83-28, ITEM 2.2.1 ,

EQUIPMENT CLASSIFICATION PROGRAMS FOR ALL SAFETY-RELATED COMP 0NENTS

1.0 INTRODUCTION

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 ps applicants shall describe 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 m3y affe:t these components. Specifically, the licensee /

applicant's submittal was required to contain info ration 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 handing sys%M to control activities affecting these components; (4) management controls tact are used to verify that the information 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 nf safety-related components.

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licensee for the Beavar Valley Power Station, Units 182 submitted responses

.. eeneric Letter 83-28. Item 2.2.1 in submittals dated November 4,1983, Horch 30, 1984, and May 4, 1987. We have evaluated these responses and find

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Evaluation l ~

In these sections the licensee's responses to the orogram'and each of five sub-items are individually evaluated against guidelines-developed by the staff

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and conclusions are drawn regarding their individual and cnllective acceptability.

1. Identification Criteria Guideline: The licensee's response should describe Qe criterie used to identify sa'ety-related equipment and components.

(Item 2.2.1.1)

Evaluation:

The licensee's response presented their criteria far identifying d and classifying equipment and components as safety-related )<hich meet the requirements of this item of Gener ic Letter 83-28.

Conclusion:

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

2. Information Handling System Guideline: The licensee's response should confirm that tre equipment classification program includes an infonnation handling system that is used to identify safety-related equipment and i componeitts. Approved procedures which govern its development. l maintenance, and validation should exist. (Item 2.2.1.2) 1

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Evaluation:

The licensee's submittal identifies the Master Equipment List (MEL) as the computeri:ca index that is used to identify safety-related components. The submittal describes the methods and procedures used for its development and validation. This list is available for use throughout the plant and at other licensee facilities and thereforu is a_ sing 1;;, official, consistent, and unambiguous document as required by the staff position.

Conclusion:

We conclude that this response and the licensee's program satisfies the staff's concern and is, therefore, acceptable.

3. Use of Information Handling System Guideline: The licensee response should confirm ; hat their '

equipment classification program includes criteria and procedures which govern the use of the infonnation handling system to cetermine that an activity is n*cty-related and that safety-related procedurer for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10CFR50, Appendix B, are applied to j safety related components. (Item 2.2.1.3) -

Evaluation:

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The licensee states in their response that station procedures which govern activities such as maintenance .nodification, and nrocurement reference the MEL for use in determining equipment and component  :

classification. This list is,therefore, consulted by station and licensee personnel prior to the initiation of any such activities.

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Conclusion:

l We conclude that the actions and procedures described in the l

licensee's response meet the staff's position and are acceptable. )

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4. Management Controls  !

l 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 folicwed. (Item 2.2.1.4)

Evaluation:

The licensee states in their response that the MEL was prepared and verified and further, that is is controlled and updated in

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accordance with written procedures which are subject to audit by the QA department. Thus, management through the QA department is kept advised of the acceptability and use of the MEL.

Conclusion:

We conclude that this response addresses the staff's concern and is acceptable.

5. Design Verification and Procurement Guideline: Toe 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 J

(> provide support for licencee's receipt of testing documentation which st.,noorts the limits of life recommended by the supplier. If such documentation is not available, confimation that the present program meets these requirements should be provided. (Item 2.2.1.5)

Evaluation:

The licensee's submittals state that Procurement Quality Documenta-tion foms provide the overall controls over procurement activities for Class 1E electrical components, replacement, and spare parts.

By telephone conversation with the licensee, the staff established that these forms control procurement activities for all safety-related coorponents, however, procurements for Class 1E electrical components received an additional check by the Engineering Department prior to release for concerns regarding shelf life limitations. The original procurement specifications which include design verification and qualification testing are used to procure replacement and spare parts.

Conclusion:

We conclude that the program described in the response as clarified in the telephone conversation meets the staff requirements and is acceptable.

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! 6. "Important To Safety" Components Guideline: Generic Letter 83-28 states that licensee / applicant equipmentclassificationprogramsshouldinclude(inaeditionto 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) l

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7. Program Guideline:

Licensees / applicants should confirm that an equipment classifi-cation program exists which provides issurance 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 infonnation handling systems so that personnel who perform activities that affect such safety-related components are aware 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 contained in submittals dated November 4,1983, May 4,1987 for Unit 1 and March 30, 1984 for Unit 2. These submittals describe the licensee's program for identifying and classifying safety-related equipment and cor.:ponents which meets the staff's rt.quirements 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.

Dated July, 1937

' Principal Contributors D. Lasher, reviewer J. Mauck, acting branch chief The staff was assisted by EG&G, Idaho, in this effort. The contractor's contribution is documented in a technical evaluation report EGG-NTA-7244 (NRC public document accession number 8707160868).

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