ML20236D538

Safety Evaluation Accepting Util 831107 Response to Generic Ltr 83-28,Item 2.2.1 Re Equipment Classification Programs for safety-related Components

ML20236D538
Person / Time
Site:	Brunswick
Issue date:	03/17/1989
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20236D536	List: ML20236D533 ML20236D538 ML20236D548
References
GL-83-28, NUDOCS 8903230150
Download: ML20236D538 (4)

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.q SAFETY'EVALVATION BY THE'0FFICE OF NUCLEAR REACTOR REGULATION-l BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1&2 DOCKET NOS. 50-324/325 REGARDING GENERIC LETTER 83-28, ITEM 2.2.1 EQUIPMENT CLASSIFICATION PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS

1.0 INTRODUCTION

Generic; Letter (GL). 83-28 was issued by 'the Nuclear Regulatory Commission (NRC) .on July 8,1983.to indicate actions:to be taken _ by. licensees and l; applicants based on the generic implications of the Salem ATWS events.

Item 2.2.1 of that letter states that licensees and' applicants shall ing all describe in considerable safety-related components otherdetail their than program Reactor for_ classify (RTS) components Trip' System 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 identify:these components as safety-related; (2) the information handling system which identifies l the components as safety-related; (3) the manner in which station l personnel use this information handling system to control activities l affecting these ' components; (4) management controls that 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 Brunswick Steam Electric Plant, Units 1 and 2,. 1 submitted a response to GL 83-28, Item 2.2.1, in a submittal dated l November 7,1983. We.have evaluated that response as follows.

2.0 EVALUATION

.l In the evaluations which follow, the licensee's' responses-to the program and each of five sub-items are individually evaluated against-guidelines l developed by the NRC staff. Conclusions'are made regarding their '

individual and collective acceptability.

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

(Item 2.2.1.1)

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t Evaluation:

{ The licensee's response included from Volume XI, Book 2 of the Plant Operating Manual, the criteria used to identify safety-related equipment and components.

Conclusion:

The criteria used is 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)

Evaluation:

The licensee's response indicates that the information handling system is the means by which the Q-list is maintained. The Q-list ..

identifies the portion of. systems, instruments, and the special components of systems that are safety-related.' The Q-list is part of the Plant Operating Manual, a controlled document, which was developed under the guidance of ANSI 52.1-1978 and the information contained in the Final Safety Analysis Report (FSAR). This system will continue to be used until a new detailed, computerized classification database is established and implemented.

Conclusion:

The licensee's response meets the staff requirements and is l

. a acceptable.

3. Use of Information Handling System Guideline:' The licensee response should confirm that their equipment class 1Heation program includes criteria and procedures which govern the use of the information handling system to determine that an activity. is safety-related and that safety-related procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10 CFR Part 50, Appendix B, are applied to safety-related components. (Item 2.2.1.3).

Evaluation:

l The licensee's response describes plant procedures which govern '

maintenance, modification, and procurement activities. These . .

procedures require that safety-related components be identified and l

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specific instructions for Q-listed components be included on Work Requests and Authorizations. Where no procedure exists governing an activity performed on a safety-related component, the Maintenance Engineer prepares safety-related instructions in accordance with approved plant procedures. Procurement procedures ensure that Q-listed parts and materials are appropriately identified, procured, and handled. Plant modification activities are controlled by an approved engineering procedure which requires that safety-related equipment be identified as Q-list and that the requirements of the corporate QA Manual and other applicable documents be implemented in the modification procedures.

Conclusion:

The licensee's response describes a program that is 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)

Evaluation:

The licensee's response states that procedures and instructions that affect Q-list (safety-related) components are controlled documents that receive certain management reviews and approvals prior to implementation of new or revised versions to assure technical correctness and conformance to applicable requirements. In addition, periodic QA surveillance and audits are performed to assure management that these documents are properly prepared, revised, and implemented in the plant.

Conclusion:

This description of the licensee's program of management controls 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 testing is specified for the procurement of safety-related components and 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 limit 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)

i Evaluation: l The licensees's response stated that procurement documentation for safety-related (Q-listed) replacement parts and components are given i two separate reviews by different plant groups to assure the i inclusion'of appropriate specifications, QA requirements, design l l review requirements, and qualification testing requirements in these l

documents. For safety-related parts, certification requirements and l 10 CFR Part 21 provisions are required to be included on the l procurement documents. l l

Conclusion:

This information describes the licensee's program which meets staff  ;

requirements and is acceptable.- )

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6. "Important To Safety" Components Guideline: GL 83-28 states that licensee / applicant equi) ment i classification programs should include (in addition to tie  !

safety-related components) a broader class of components designated .!

as "Important to Safety." 'However, since the generic letter does i not require licensce/ applicant to furnish this information as part {

of their response, our review of this sub-item will not be performed. 1 (Item 2.2.1.6)

7. Program Guideline:

Licensees / applicants should confirm that an equipment classification program exists which provides assurance that all safety-related components are designated as safety-related on plant documents such I as drawings, procedures, system descriptions, test and maintenance  ;

instructions, operating procedures, and information 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 included information that described their program for classification of safety-related equipment and components. This program contained all the features required to meet the staff concerns for this issue.

CONCLUSION:

The licensee's program classification of safety-related equipment and i components is acceptable.

Principal Contributor: N. Trehan Dated:

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