ML20236A290

SER Supporting Util Response to Generic Ltr 83-28,Item 2.2.1 Re Equipment Classification Programs for All safety-related Components

ML20236A290
Person / Time
Site:	Mcguire, McGuire
Issue date:	10/14/1987
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20236A264	List: ML20236A261 ML20236A290
References
GL-83-28, NUDOCS 8710220177
Download: ML20236A290 (7)

Text

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1 ENCLOSURE I

SAFETY EVALUATION REPORT I MCGUIRE NUCLEAR STATION, UNITS 1&2 DOCKET N05. 50-369/370 GENERIC LElitR 83-28, ITEM 2.2.1 E0VIPMENT CLASSIFICATION PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS

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 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 information handling systems that are used to control plant activities that may affect these components. Specifically, the licensee /

applicant's submittal was required to contain information describing (1) The criteria used to ident'ify 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 system to control activities affecting these components; (4) management controls that f 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 of safety-related components.

The licensee for the McGuire Nuclear Station, Units 182 submitted responses to Generic Letter 83-28, Item 2.2.1 in submittals dated November 4, 1983, February 1,1984 and March 30, 1987. We have evaluated these responses and find that they are acceptable.

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,7 l 2.0 EVALUATIONS AND CONCLUSIONS In these sections the licensee's responses to the program and each of five sub-  :

items are individually evaluated against. guidelines developed by the staff and j conclusions are drawn regarding their individual and collective acceptability.

1. Identification Criteria Guideline: The licensee's response should describe the criteria used to identify safety-related equipment and components. (Item 2.2.1.1)

Evaluation:

The licensee's response contains criteria for identifying safety-related equipment and components which state that a component is considered safety-related if it is required to assure: (a) the integrity of the reactor coolant system pressure boundary, (b) the capability to achieve and maintain a safe shutdown or (c) the capability to prevent or to mitigate the consequences of an accident that could result in potential offsite exposures. ,

. Additionally, the licensee has identified other considerations and guidance that are used in determining the safety-related status for structures, systems and components.

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Conclusion:

We find the stated criteria meet the staff's requirements and are acceptable.

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

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Evaluation:

The licensee's response described how the information handling system (component identification) was prepared, verified,'and approved. The safety listing was originally prepared during the station design phase.. Changes to '

the station design are controlled, such that new safety-related items are identified in accordance with the same quality assurance program that identified these items in the originO station design. The procedures for revising the component. list are contained in the Quality Standards Manual.

Conclusion:

I We conclude that this. description of the licensee's information handling system show that it meets the staff requirements and is acceptable.

3. Use of Information Handling System  ;

Guideline: The licensee response should confirm that their equipment classification program includes criteria and procedures which govern the use of the infomation handling system to detemine that an activity is  !

safety-related and that safety-related procedures for maintenance,

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surveillance, parts replacement and other activities defined in the introduction to 10CFR50, Appendix B, are applied to safety related components. (Item 2.2.1.3) ,

Evaluation:

l The licensee's response provided a description of the station personnel's use of the McGuire Nuclear Station Quality Standards Manual for Structures,

j. Systems and Components. This manual contains the equipment classification listings or directs the user to supplemental component lists. A criteria checklist for the determination of equipment classification was also i

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included. The procedures for preparing a work request (a prerequisite for maintenance work) require the use of the equipment classification information handling system to determine the safety classification of the equipment involved and the identification of the plant instructions and procedures which are to be used for maintenance work, routine surveillance testing, accomplishment of design changes, and in the perfonnance of special tests or studies.

Conclusion:

We conclude that the licensea hcs described plant administrative controls and procedures which meet the staff requirements for this item and which are acceptable.

4. Management Controls 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 followed. (Item 2.2.1.4) i l Evaluation:

6 The licensee's response to this item addresses the original preparation and

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verification of the station manual, the revision process, and the management j procedures and controls that cover the utilization of the station manual 1 (and all quality stnadards documents). The licensee states that an item is considered safety-related unless it is shown to be non-safety related.

Further, the licensee states that reviews and audits are perfonned on documentation packages for safety-related stmetures, systems and components.

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Conclusion:

We find this descripion of the licensee's program of management control i

meets the staff requirements and is acceptable.

5. Design Verification and Procurement Guideline: The licensee / applicant's response should document that past usage demonstrates that appropriate' design verification and qualification i testing is specified for the procurement of safety-related components and y parts. The specifications should include qualification testing for expected safety service conditions and provide support for licensee's receipt of testing documentation which supports the limits of life recommended by the  ;

supplier. If such documentation is not available,. confirmation that the present program meets these requirements should be provided. (Item 2.2.1.5) .

Evaluation:-

i The licensee's response shows that the procurement specifications require -

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suppliers to include explicit verification of design capability and the l evidence of testing specified in the procurement specifications. The licensee addresses surveillance activities and preventative maintenance that verifies that components do not exceed their service life. The

-f licensee states that replacement safety-related components and parts are l purchased as a direct replacement item, whether from the original or an l alternate vendor, or by use of an industry standard part number.

Conclusion:

We find this infonnation describes the licensee's program which meets staff requirements and is acceptable.

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6. "Important To Safety" Components b /I l g[f j

%,Videline: Generic Letter 83-28 states that licensee / applicant equipmenti j'

" classification programs should include (in addition to the safety-related

' components) a broader class of ,cosdenents}esignated as "Important to Safety." However,sincethegent#%letibrjdoes.notrequirelicenm/  ;

applicant to furnish this informai1on! as.part of their response,1 staff.,c ,.

l review of this sub-item will not be performed. (Item 2.2.1.6) 3 c -

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Guideline: Licensees / applicants should confirm that an' equipment classi-fication program exists which provides assurance that all safety-re%ted a t o> I j

components are designated as safety-related on plant'do'cupents such as ,

drawings, procedures,systemdescriptions,testrandmaih.enanceinstmctions,

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1 . n .- e 3 operating procedures, and infonnation handling 'syi,te 30thatpersonnelwho

, -l perfonn activities that affect such safety-relatey componend are aware that l they are working on safety-related components an'd are guidad(by safety-

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related procedures and constraints. (Item 2.2.1)

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i' Evaluation:

The licensee's response to these requirements was contained in submittals  !

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dated November 4,1983, February 1,1984 and March c30, )1981. These ,

submittals describe the licensee's program fu identifying and classifying 7 safety-related equipment and components whic'f meets the staff requirements  !

I [ t as indicated in the preceding sub-item evaluations. f i

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Conclusion:

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We conclude that the licensee's program addresses the staff concerns i regarding equipment and component classification and is acceptable.  !

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jyO Mr. Hl B.~ Tucker .

Duke Power Company i -McGuire Nuclear Station w

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m Mr. A.V. Carr, Esq. Dr. John M. Barry ~

r Duke Power Company Department of Environmental Health  !

P."0. Box 33189 Mecklenburg. County j 422 South Church Street 1200 Blythe Boulevard s Charlotte, North Carolina 28242 Charlotte, North Carolina 28203 County Manager of Mecklenburg County Mr. Dayne H. Brown, Chief 720 East Fourth Street- Radiation Protection Branch i Charlotte, North. Carolina 28202 Division of Facility Services Department of Human Resources 701 Barbour Drive i Mr. Robert Gill Raleigh, North Carolina 27603-2008 i Duke Power Company i Nuclear Production Department i

, P. O. Box 33189-p Charlotte, North Carolina 28242 l J. Michael McGarry, III, Esq.  !

Bishop, Libennan, . Cook, Purcell j and Reynolds 1200' Seventeenth Street, N.W.

- Washington, D. C. 20036

/[ Senior Resident Inspector c/o U.S. Nuclear Regulatory Commission

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• Route 4, Box 529-l/ ". - Hunterville, North Carolina 28078 -

g 1 Regional lisinistrator, Region II l yi U.S. Nuclear Regulatory Commission, )

101 Marit.itta Street, N.W. , Suite 2900 J Atlanta, Georgia 30323 I L. L. Williams l Area Manager, Mid-South Area  ;

ESSD Projects i Westinghouse Electric Corporation MNC West Tower - Bay 239

~}. P. 0. Box 355 Pittsburgh, Pennsylvania 15230 t ,

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