ML20215J860
| ML20215J860 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/04/1987 |
| From: | George Thomas PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-83-28, NYN-87061, NUDOCS 8705080292 | |
| Download: ML20215J860 (7) | |
Text
__
George S. Thomas vio.houdens Nuclear Moducson Pt&Ic Servion of New Hampshire New Hampshire Yankee Division NYN-87061 May 4, 1987 United States Nuclear Regulatory Commission Washington, DC 20555 Attention:
Document Control Desk
References:
(a) Facility Operating License NPF-56, Docket No. 50-443 (b) USNRC Letter, dated March 3, 1987, " Request for Additional Information, Items 2.1 (Part 2) and 2.2 (Part 1) of Generic Letter 83-28", Mr. V. Nerses to Mr. R. J. Harrison
Subject:
Additional Information for Items 2.1 (Part 2) and 2.2 (Part 1) of Generic Letter 83-28
Dear Sir:
In response to the referenced request for additional information, enclosed please find our response to' Items 2.1 (Part 2) and 2.2 (Part 1).
l This submittal concludes our response to all requests for information described in Reference (b).
Very truly yours, y
e George S. Thomas Enclosure cc:
Mr. James M. Allan Deputy Regional Administrator U.S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 Mr. Anthony C. Cerne NRC Senior Resident Inspector Seabrook Station Seabrook, NH 03874 76' 8705080292 870504 g})
PDR ADOCK 05000443 p
PDR P.O. Box 300. Seabrook, NH 03874. Telephone (603) 474-9574
(.
7, ENCLOSURE TO NYN-87061 ByLletter dated March.3, 1987, the NRC requested additional information regarding Generic Letter. 83-28, Items 2.1 (Part 2) and 2.2 (Part 1).
The following is New HampshireLYankee's (NHY) response to each specific request.
Request A. ; Item 2.1 (Part 2) " Vendor Interface (Reactor Trip System Components)"
Our review of the applicant's submittal indicates that the licensee has identified an interface with their nuclear.-steam supply system vendor.
However, we are unable to: determine ~that the licensee's vendor interface program encompasses a periodic and continuing feedback mechanism. Item 2.1 (Part 2)' states that the vendor interface program shall include periodic communication with vendors to assure that all. applicable information has been~ received. The licensee needs to state that their reactor trip system is included in the Westinghouse Interface Program.
Response
The Seabrook Station Reactor Trip' System is' included in the Westinghouse Interface Program.. As Seabrook Station's NSSS supplier, Westinghouse provides Technical Bulletins to update, supplement or. revise maintenance procedures, manuals, and testing requirements for Westinghouse-supplied components. -All-Westinghouse-supplied Technical Bulletins that effect safety-related equipment require a return receipt from Seabrook Station to
-acknowledge that the information was received. Westinghouse also supplies an updated index on an annual basis for all Technical Bulletins trans-mitted.during the previous submittal period. The index is transmitted:as
- a Technical Bulletin and as such requires the return receipt to acknowledge receipt.
Upon receipt of a Technical Bulletin at Seabreok Station, it is assigned to.the appropriate department (s) for review and implementation as applicable. The distribution and review of the Technical' Bulletins is performed in accordance with the.NHY Operating Experience Review Program. An annual review of the effectiveness of the Operating Experience Review Program is performed.-
Seabrook Station-is also an active member of the Westinghouse Owners Group (WOG) and as such is included in all correspondence issued by Westinghouse on-behalf of the WOG, including proposals and recommendations associated with the Reactor Trip System Components. These Westinghouse proposed technical changes are transmitted to the designated NHY WOG representa-tives. This information is then submitted to NHY's Document Control Center for distribution and evaluation.. _.
Request B.
Item 252 (Part 1) Equipment Classification (Programs For All Safety-.
. Related Components):
1.
Item 2.2.1 - Program
.The applicant's response does 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 that personnel performing activities that affect such safety-related components are aware that they are working-on safety-related.compo-nents and are guided by safety-related procedures and constraints..
The applicant needs to state that their equipment classification conforms with the above Staff position.
If all safety-related components are 'not designated as safety-related-on the relevant documents, the licensee should specifically describe the exceptions and provide a justification for such exceptions for Staff review.
Response
~
Seabrook Station designates relevant plant documents as safety-related when the documents are associated with safety-related components.
Operational procedures for maintenance activities, system and component operations, and surveillance tests are designated as safety-related by a unique alphanumeric identifier. Each procedure identifier consists of a two letter prefix, unit number, category designator, identification number and, if applicable, the commonality suffix number (e.g., IX1631.001). The first letter in the procedure number prefix identifies the department responsible for the-procedure. The second letter in the procedure number prefix identifies safety-related, non-safety related, not related to safety or technical specifications surveillances. The following defines the second letter prefix identification categories:
"D' - denotes those procedures that are not related to nuclear safety, apply only to a single department, and require an independent review and the approval of the department supervisor and Station Manager.-
"N" - denotes those procedures associated with Non-Nuclear Safety Class systems, structures, and components.
"S" - denotes those procedures associated with nuclear safety, specifically those related to operation and maintenance of Safety Class structures, systems, and components identified in the Operational Quality Assurance Program.
"X" - denotes-those procedures satisfying the requirements of the Technical Specification surveillances.
7
' Response'(continued)-
SystemLdescriptions and the_ relevant computerized information_ handling; systems for:Seabrook Station also identify _the associated safety class.
The system descriptions contain a section describing the safety class for
'that. system. Additional'information'for the information handling systems-are described in' Section B.3 of this response.
' Engineering - activities during-ihitial' design, construction and startup
" utilized the equipment classification criteria cited in Seabr ok St tion o
a FSAR, Chapter 3, Section 2, Classification of Structures, Components, and Systems.
The performance of these engineering activities resulted in final design documents which retain the appropriate safety classification for systems, components and structures. Drawings, calculations, specifications and computerized lists are considered design documents.-
l Based on the above, the' equipment classification for safety-related
[
systems, components, and structures conform with the NRC Staff position.
l Request
. 2.
Item 2.2.1.2 - Identification Criteria The applicant's response does not confirm that the criteria to be used in the new component level equipment classification listing is consistent with the definition of safety-related structures, systems'and components g
given in:the footnote to the generic letter for Item 2.2.-
The applicant needs to state that their criteria for classifying safety-related components are consistent with the definition given.
J'
' Response j
Seabrook Station FSAR Chapter 3, Section 2, Classification of Structures,
~
Components and Systems, Subsection 3.2.2, details the criteria for i
equipment classification.
These criteria are consistent with the Staff position given in the footnote to Generic _ Letter 83-28 for Item 2.2 and as-further elaborated by Regulatory Guide 1.26, " Quality Group Classification and Standards for Water, Steam, and' Radioactive Waste Containing Components of Nuclear Power Plants", and ANSI N18.2A - 1975, "American National Standard Revision and Addendum to Nuclear Safety. Criteria for the Design of Stationary Pressurized Water Reactor Plants".
New Hampshire Yankee is presently in the process of developing new engineering design standards that will incorporate a detailed description
-for safety class determination. The engineering design standard -for
.E safety class determination is consistent with the footnote for Item 2.2 in Generic Letter 83-28.
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- Request 3.
Item 2.2.1.2 - Information Handling System The applicant's response does not confirm that_the information handling system. includes a list of safety-related equipment and that procedures exist which govern its development and validation.
The applicant needs to state that their equipment classification program conforms with the above Staff ' position.
Response
United Engineers and Constructors (UE&C) developed and utilized computer generated lists during the initial design, construction and startup of Seabrook Station. These lists contain data fields which indicate the applicable safety' classification ~for systems, and components..UE&C developed, implemented, verified and maintained these systems utilizing appropriate administrative and technical procedures..These procedures include specific instructions for documenting and independently verifying safety-related design' parameters.
UE&C developed'and maintained the following lists.
A.
Equipment List Provides safety class information for major pieces of equipment and components required for Seabrook Station.
B.
Line' List - Provides safety class information for each line shown on.
l the Seabrook Station's piping and instrument diagram.
l; C.- Class-1E List - Lists all electrical equipment which are determined to' i
be safety-related and are designated as Class-lE.
i.
D.
Standard Instrument' Schedule - Provides safety classification l
(Class-lE or non-lE) for instruments required for Seabrook Station.
E.
Cable Schedule Program ~- Provides safety classification for cables and raceways at Seabrook Station.
These lists represent the type of equipment classification data available in Seabrook Station's information handling system. The lists are being turned over to NHY for use in operational activities.
Existing NHY procedures detail the activities and instructions for the turnover of design documents. The above computer lists are considered design documents. Maintenance of these lists is covered by an engineering program which re-verifies list data fields and incorporates outstanding change documents upon physical completion of the work. -
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Response (continued)
' Additional computerized lists for purchasing, operation, surveillance tests, and maintenance activities have been developed by NHY.
These lists are used to assist in their associated activities and are usedlLn conjunction with manual tracking methods. The following are used on a daily basis to support these activities.
A.
Commonality List - Provides safety class information for purchasing mechanical, electrical, and instrument and control components at Seabrook Station.
B.
Specappraisal - Provides scheduling and designates the' appropriate procedure for Technical Specification surveillances.
C.
Seabrook Interim Maintenance System - Provides a listing of repetitive tasks performed by the Maintenance Department and is used as a tool in the planning of daily work activities.
The Specappraisal and Seabrook Interim Maintenance System do not specifically list safety class, but refer the user to procedures that are designated as safety-related as described in Section B.1 of this response.
Request 4.
Item 2.2.1.3 - Use of the Equipment Classification Listing The applicant's response has not confirmed that criteria and procedures exist which govern the use of the information handling system to determine that an activity is safety-related and what procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10 CFR 50, Appendix B, apply to safety-related components.
The applicant needs to state that their program contains provisions to govern the use of the information handling to assure that a safety-related activity is identified as safety-related and that the proper procedures are selected and implemented.
Response
. The NHY Design Control Program (NYDC) governs the instructions for performing design and design change activities. These instructions provide procedural controls for identifying safety-related designs and applying the appropriate technical, administrative and quality reviews.
Each NHY design, within the scope of the NYDC, receives a 10 CFR 50.59 applicability review and a design evaluation. The computerized lists and other controlled design documents serve as inputs to the design process for new designs.
Procedures establish the methods for controlling and maintaining the controlled lists which comprise the information handling system used by engineering.
- .s Response (continued)
- The information. handling system used for purchasing, operation, surveil-lance tests, and maintenance are controlled;by individual programs for each activity. These computerized programs and their lists are.used.in conjunction with manual data systems to verify the accuracy of the infor-mation being supplied for the required activity.
The computerized data bases are. continually being revised and updated.
Should a discrepancy between the. manual data base and the computerized data base be found, the discrepancy is reviewed and the incorrect data base is revised. This system of comparison of the two data bases is performed to ensure that the correct information is available for use.
Request 5.
Item 2.2.1.4 - Management Controls -
The applicant's response has not confirmed that management controls are utilized to verify that the procedures for preparation, validation and routine utilization of the information system have been followed.
The applicant needs to state _that their program conforms to the above Staff position.
Response
New Hampshire Yankee utilizes a series'of management controls to verify that appropriate inputs, process activities and outputs of the information handling system are-procedurally controlled, reviewed, and approved.
Management controls include the use of_the Station Operational Review Committee (SORC) for all changes requiring a 10 CFR 50.59 review as well as periodic Quality Assurance audits and surveillances of'the information handling system program. Other management controls are contained within the procedures discussed in response B.4 above.'