ML20214R004
| ML20214R004 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/29/1987 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 5211-87-2099, GL-83-28, NUDOCS 8706050291 | |
| Download: ML20214R004 (6) | |
Text
r GPU Nuclear Corporation
- Nuclear
- ,ome e,eo s
Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:
May 29, 1987 5211-87-2099 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Gentlemen:
Three Mile Island Nuclear Station, Unit 1 (THI-1)
Operating License No. DPR-50 Docket No. 50-289 Response to Request for Additional Information on GL 83-28, Items 2.1 and 2.2 Enclosed is GPUN's response to your request for additional information of March 13,1987 on Items 2.1 and 2.2 of Generic Letter 83-28. Clarification of some of the items was received during conversation with the reviewer in mid April. Some of the information provided updates the GPUN submittals of November 8,1983 and August 5,1985.
Sincerely,
. D.
kill Vice President & Director, TMI-l HDH/SM0/spb:0878A cc:
G. Edison, USNRC Enclosure 8706050291 870529
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PDR ADOCK 05000289 29 P
PDR Ag1 I
I GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
r
.9 Enclosure A.
Item 2.1 (Part 1) Equipment Classification (Reactor Trip System components)
Item 2.1 (Part 1) require applicants to confirm that all components whose function is required to trip the reactor are identified as safety-related on documents, procedures and information handling systems used in the plant to control safety-related activities, includir.g maintenance work orders, and parts replacement.
The licensee's submittals stated that the reactor trip system components fall within the scope of systems identified as "important-to-safety" which includes the reactor protection system and the trip portion of the control rod drive system. Furthermore, the licensee stated that a review of a variety of documents such as plant surveillance procedures, maintenance procedures and work requests associated with reactor trip components indicates that a quality classification of important-to-safety is identified on each document.
Based on the licensee's submittals, the NRC staff determines that all components to trip the reactor have not been identified as safety-related. The licensee is requested to provide a discussion of how the ifcensee's program-is equivalent to the staff position or specifically describe how their program deviates from the staff position and include a justification for each deviation.
Response
The classification of components for the reactor trip systems is located in GPUN Technical Functions Standard ES-Oll, Methodology and Content of GPUN Quality Classification List, Exhibit E.
The component level Quality Classification List (QCL) for reactor trip system components was completed during the third quarter of 1986. The QCL now classifies the components as Nuclear Safety Related (NSR) or Regulatory Req 11 red (RR).
Further explanation of the new classification system is described in our response to Item 2.2.1-Criteria for Identifying Components.
The QCL indicates that all the reactor trip system components are classified as Nuclear Safety Related with the following exceptions:
1.
Anticipatory Reactor Trip Sensors Feedwater Pump Pressure Switches (PS 915-918 & 945-948)
Turbine Trip Pressure Switches (PS 919 & PS 924-926)
These components are located in the Turbine Building which according to the FSAR is a non-seismic building. This issue was discussed extensively in TMI-l SER (NUREG 0680 Supp. 3) and TMI-l FSAR Section 7.1.2.2.C.8.
The NRC concluded although the Anticipatory Trip was.
r not fully safety grade it employed the best materials available and was considered acceptable. By our classification system, these components are classified " Regulatory Required" (RR) but have the,
same level QA applied as would be applied to Nuclear Safety Related items.
2.
Control Rod Drive Assembly Modules (Electronic Trip Assemblies and SCRs)
These modules were purchased commercial grade and are treated as Nuclear Safety Related (NSR) for maintenance and testing as outlined in Section 4.4 of GL 83-28. These components were also part of the B&W Owners Report on Trip System components which was issued on April 25, 1984.
B.
Item 2.1 (Part 2) Vendor Interface Program and Feedback System The licensee should describe their interface program with B&W, as well as a feedback system, which addresses how this program accomplishes the following:
1.
Applies to all safety-related Reactor Trip System components; 2.
Ensures receipt of vendor Equipment Technical Information (ETI) is acknowledged or otherwise verified; 3.
Ensures the vendor is contacted on a periodic basis to determine that all ETI has been received; 4
Includes means to assure ETI is kept current and complete, preferably through the use of controlled procedures for adding, deleting or revising this information; 5.
Contains procedures to review, evaluate, and incorporate (relevant parts) ETI into plant procedures and instructions.
Response
B&W and their subsidiary divisions have designed anc,or supplied several major components / systems that require continued maintenance. Therefore, GPUN and B&W have established various methods of interface. The interface program accomplishes those items identified by the NRC by the following:
1.
B&W and its subsidiaries are the suppliers of only some of the components of the Reactor Trip System. The interface is described in more detail below.
2.
B&W has three methods of transmitting equipment information to GPUN.
These are:
g a) Parts Bulletins - These transmit information on spare parts for components supplied by B&W and information on product upgrades due to products becoming obsolete or technical advances.
Although no contractual agreement binds B&W to send these to GPUN, internal B&W procedures direct B&W to supply these.
b) Operating Plant Service Bulletins and Site Instructions - Service bulletins supply generic information on potential problems and make recommendations.
Site instructions provide information on potential problems specifically addressed to TMI.
These are provided to GPUN by internal B&W procedures. By B&W procedure, GPull is requested to formally acknowledge receipt of these letters, c) Preliminary Safety Concerns - B&W transmits letters to GPUN advising us of the nature of a potential safety concern.
B&W advises GPUN quarterly of the status of the PSCs that have been sent to GPUN. These are reviewed quarterly at B&W Owners Group meetings. A meeting of the B&W Owners is held annually to perform a more detailed review of the PSCs that have been issued during the year.
3.
B&W is not formally contacted on a periodic basis to determine if all equipment technical information has been received. However, because of the frequent contact GPUN has with B&W because of B&W Owners Group, Steering Committee and Executive Committee activities (an average of two meetings per month), and the B&W representative on site, we feel no formal process is necessary.
4 TMI-l procedure AP 1065 " Vendor Document Control" and Technical Functions procedure EP-021 " Technical Manuals" provide requirements for the addition, deletion and revision of equipment information in vendor manuals.
5.
The review, evaluation and incorporation of equipment information into plant procedures and instructions is controlled by AP 1065, EP-021 and EP-017 " Review of Industry /GPUN Operating Experience."
C.
Item 2.2 (Part 1) Equipment Classification (Programs for All Safety-Related Components) 1.
Item 2.2.1 - Program The licensee's responses (see Item 2.1 Part 1) do not confirm that all safety-related components are designated as safety-related on plant documents such as procedures, system descriptions, test and maintenance instructions, operating procedures, and in information handling systems so personnel performing activities that affect such safety-related components are aware they are working on safety-related components and are guided by safety-related procedures and constraints.
The licensee is requested to provide a discussion of how their program is equivalent to the staff's position or describe how their program deviates from the staff position and include a justification for each deviator.
Response
The new equipment classification system (described in the next section) which employs two terms NSR and RR, is carried over into the software via the use of the Operation Quality Assurance Plan and the Safety Review Process.
Documents such as procedures, system descriptions, instructions, and control systems are classified commensurate with the activity performed. The activities referenced above are currently labeled with the appropriate classification, namely "Important to Safety" (ITS), or "Not Important to Safety" (NITS), until conversion to the NSR and RR approach is complete for software.
The concern of the NRC is that personnel are aware that they are working on safety-related components and are therefore guided by safety-related procedures and constraints. GPUN personnel are to follow procedures to perform tasks regardless of the classification given to the procedure.
2.
Item 2.2.1 - Criteria for Identifying Components The licensee's response does not state whether the results of the study of the present classification program resulted in modification to the equipment classification system.
The licensee needs to state whether review of the equipment classification program has resulted in modifications to the program.
If so, the modifications should be described.
Response
As stated earlier, a component level Quality Classification List was completed during the third quarter of 1986. The list is composed of approximately 9,000 components for TMI-1. The components are classified as " Nuclear Safety Related" (NSR) or " Regulatory Required" (RR). The classification of each component, with its basis (checksheet/worksheet), is on a computerized data base which is accessible from the corporate office and the site.
The classification system of " Nuclear Safety Related" and "Important to Safety" (ITS) was modified as a result of a study which indicated that the term Important to Safety had been misused and that
" Regulatory Required" was a more suitable term.
Regulatory Required includes those components which are not NSR but for which TMI-1 has committed to in documents to the NRC such as the FSAR, Tech. Specs., --
r EQ, Appendix R or IE Bulletins.
Nuclear Safety Related has retained its. original meaning. The terms " Benefits Reactor Shutdown" and "No Significance are not longer used.
Regulatory Required, like Important to Safety, uses a graded approach to QA. However, for those components in tne reactor trip system.
which are classified as Regulatory Required, the same level QA is applied as would be applied to NSR items. lhe exception to this is the control rod drive assembly modules, which are treated as nuclear safety related for maintenance and testing only. Therefore, the QA program requirements for NSR items apply to these two activities only for these modules.