ML20244D803
| ML20244D803 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/13/1989 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GL-83-28, NUDOCS 8904240120 | |
| Download: ML20244D803 (9) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23o1 MARKET STREET P.or. BOX 8699 PHILADELPHIA PA.191o1 2is 8414ooo April 13, 1989 Docket Nos. 50-352 50-353 License No. NPF-39 Construction Permit No. CPPR-107 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Limerick Generating Station, Units 1 and 2 NRC Generic Letter 83-28, Items 2.1 and 2.2 Response to Request for Additional Information
Dear Sir:
NRC letter dated March 4, 1988, requested additional information regarding Philadelphia Electric Company's (PECo's) response to NRC Generic Letter 83-28.
The information requests and our responses are provided below.
Additionally, we would like to clarify information which has been previously submitted in response to Generic Letter 83-28, Item 2-2.2, regarding our Nuclear Steam System Supplier (NSSS) vendor interface program.
At this time, the ongoing Vendor Interface Program is no longer being coordinated by the Independent Safety Engineering Group (ISEG) as previously identified.
This function.is now incorporated into our Operating Experience Assessment Program (OEAP) and will be made part of the vendor manual program.
The maintenance of controlled vendor manuals will be covered by the issuance of a Nuclear Group Administrative Procedure (NGAP), rather than the Engineering and Research Department Procedure (ERDP) specified in our previous response.
Item 2.1 (Part 1) Equipment Classification f0 NRC Evaluation g
The first submittal stated that plant procedures were still in the development stage and that the developed documents 8904240120 890413 PDR ADOCK 05000352 p
PNV
Docum3nt Control Dark April 13, 1989 Page 2 would reflect the requirements of this item of the generic letter.
In subsequent submittals, the licensee / applicant confirmed that all systems which contribute to the reactor trip function had been identified in the current "Q-List" and that all components of the identified systems are subject to the quality assurance program unless specifically excluded by the plant safety evaluation program.
The submittals stated that the licensee / applicant's program requires that each item or service to be procured must be reviewed to determine if it is safety-related.
However, based on our review of the licensee's/ applicant's submittals, we found that the list of components required to trip the reactor have not been completed to the component level.
We also found that the submittals did not confirm that the licensee's/ applicant's program meets the requirements for identification of safety-related components on relevant plant documents.
The licensee / applicant needs to supplement his response to fully address these requirements,
Response
Although the Limerick Generating Station (LGS) Project Q-List does not provide a complete component level listing for all of the Reactor Trip System (RTS) components, all systems that contribute to the reactor trip function are in the current Q-List.
The boundaries of the LGS safety-related RTS were delineated on the Quality Assurance Drawings (QADs) as part of the original design.
Presently, all components that are part of the safety-related (i.e.,
Q-Listed) RTS are maintained and handled as safety-related in accordance with the LGS Quality Assurance Plan and as further described below.
Reclassification of Q-Listed components can only be accomplished by the preparation and approval of a safety evaluation.
Operations - Pertinent documents used in plant operations include Operational Verification Forms (OVF), permits, and system operating procedures.
OVFs and permits are used in conjunction with Maintenance Request Forms (MRFs) which clearly identify safety related RTS components.
System operating procedures used to control / operate plant equipment themselves do not directly indicate safety related classification.
However, the safety related classification of the RTS equipment to be operated can be found through the use of Administrative Procedure A-41, a
M:,'
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.Pago 3
" Procedure for Control of Plant Equipment," which' clearly-1 identifies safety related-RTS.
Testing --Relevant documents used in. testing RTS equipment
- include: Temporary Circuit Alteration (TCA) forms,
. Troubleshooting Control Forms (TCF), Instrument' Setting LChange Forms, Calibration Forms, and Testing Procedures.
LTCAs and-Calibration Forms identify-safety-related
= components.
When appropriate operational troubleshooting of safety-related (i.e., Q-Listed) equipment is E
accomplished.by the:use of TCFs, which are controlled by.
)
E Administrative Procedure A-41.1, " Troubleshooting. Safety-lz tRelatedsand Tech. Spec. Equipment."
Instrument Setting l
Change. Forms'and' applicable Testing Procedures are used in conjunction _with:MRFs which clearly identify safety related components.
j 1
l Procurement - All relevant-procurement documents properly
.]
identify safety-related RTS components.
This includes requisition-worksheets, requisitions, purchase: orders,.
suborders, and' stock transfer. documents.
Administrative Procedures (A-27 series) require the'use of the Q-List to properly identify and control the procurement of safety-related components using the above documents.
Maintenance - The MRF is the principal document used in the process of planning and conducting RTS maintenance activities.
Safety-related components are clearly identified as such on this form.
Administrative Procedure A-26, " Procedure for Plant Maintenance using the Maintenance Request Form," requires that plant staff investigation of requests to perform work and subsequent
. approvals, must be documented in Section 2 of a MRF where the safety classification of the equipment is clearly identified.
As required by Administrative Procedure A-26, this identification is carried out by the assigned Plant Maintenance Staff Engineers by conducting a review of a controlled copy of the Q-List, and/or original specifications / purchase orders, or other project documentation, as required.
" Work instructions," used in conjunction with MRFs, provide specific detailed guidance for a particular maintenance task.
All Maintenance Procedures written in accordance with Administrative Procedure A-19, " Preparation of Maintenance Procedures,"
are properly annotated if they involve safety-related components.
Docum3nt Control Dask April 13, 1989 Pcga 4 Modifications - All relevant RTS modification documents properly identify safety-related components.
This includes' the Modification Proposal Form and Modification Design Change Packages.
Administrative Procedures.(A-14 Series) control the modification of safety and nonsafety-related.
components.
All modifications are then performed in conjunction with a MRF.
PECo considers that the current LGS Project Q-List, together with the existing procedural controls and Quality Assurance Program governing its use, satisfy the requirements of Generic Letter 83-28, Item 2.1.
- However, PECo is proceeding with a program to expand the present LGS Project Q-List to include all safety related RTS components by the end of 1990.
We consider that this enhancement of our Q-List will increase the efficiency.of the classification, maintenance, control, and handling activities for safety-related (i.e., Q-Listed) RTS components.
Item 2.2 (Part 1) Program NRC Evaluation The licensee has provided a description of the equipment classification program and controls associated with the identification of safety-related activities for repair, maintenance, and procurement.
However, the response does not clearly address whether all components designated as safety-related in the Project Q-List are also properly,
designated on plant documents, procedures, and in the information handling systems.
Also, within the responses, the licensee provided dates when the programs would be fully implemented, but there has been no response indicating that the programs as described are, in fact, implemented and that no changes have been made in the described programs.
The licensee should provide additional information that address the above issues.
Response
Although the LGS Project Q-List does not provide a complete component level listing for all safety-related components, all safety-related systems are in the current Q-List.
The boundaries of the LGS safety-related systems were delineated on the QADs as part of the original design.
Presently, all components that are part of the safety-related (i.e., Q-Listed) systems are maintained and handled i
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l Docum3nt Control D; k April 13, 1989
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Pago 5 l
l as safety-related in accordance with the LGS Quality Assurance Plan and as further described below.
Reclassification of Q-Listed components can only be accomplished by the preparation and approval of a safety l
evaluation.
Operations - Pertinent documents used in plant operations include OVFs, permits, and system operating procedures.
OVFs and permits are used in conjunction with MRFs which clearly identify safety related components.
System operating procedures used to control / operate plant equipment themselves do not directly indicate safety related classification.
However, the safety related classification of the equipment to be operated can be found through the use of Administrative Procedure A-41, which clearly identifies safety related systems.
Testing - Relevant documents used in testing plant equipment include TCA forms, TCFs, Instrument Setting Change Forms, Calibration Forms, and Testing Procedures.
TCAs and Calibration Forms identify safety-related components.
When appropriate, operational troubleshooting of safety-related (i.e., Q-Listed) equipment is accomplished by the use of TCFs, which are controlled by Administrative Procedure A-41.1.
Instrument Setting Change Forms and applicable Testing Procedures are used in conjunction with MRFs which clearly identify safety related components.
Procurement - All relevant procurement documents properly identify safety-related components.
This includes requisitions worksheets, requisition, purchase orders, suborders, and stock transfer documents.
Administrative Procedures (A-27 series) require the use of the Q-List to properly identify and control the procurement of safety-related components using the above documents.
Maintenance - The MRF is the principal document used in the process of planning and conducting maintenance activities.
Safety-related components are clearly identified as such on this form.
Administrative Procedure A-26 requires that plant staff investigation of requests to perform work and subsequent approvals, must be documented in Section 2 of a MRF where the safety classification of the equipment is clearly identified.
As required by Administrative Procedure A-26 this identification is carried out by the assigned Plant Maintenance Staff Engineers by conducting a review of a controlled copy of the Q-List, and/or original
Li' Documsnt Control D3ak April 13, 1989 I'*
Page 6-V specifications / purchase orders, or other project documentation as required.
" Work instructions," used in conjunction with MRFs, provide specific detailed guidance for a particular maintenance task.
All Maintenance Procedures' written in accordance with Administrative Procedure A-19-are properly annotated if they involve
' safety-related components.
Modifications - All relevant modification documents properly identify safety-related components.
This includes the Modification Proposal Form and. Modification Design Change Packages.
Administrative Procedures (A-14 Series) control the modification of safety and nonsafety-related components.
All modifications are performed in conjunction with'a MRF.
With the exception of the following clarifications, the equipment classification and controls programs are as described in'our previously submitted responses to this item.
Information Handling Systems 1.
The Computerized History and Maintenance Planning System (CEAMPS) is the mechanism for generation of MRFs; however, the CHAMPS program does not automatically insert the Q-List status of the component into Section 2 of the MRF.
Under the MRF system, described in Administrative Procedure A-26, plant staff investigation of requests to perform work and subsequent approvals must be documented in Section 2 of a MRF where the Q-List status of the equipment is identified.
At the present time this identification is carried out by the assigned Plant Maintenance Staff Engineers by conducting a review of a controlled copy of the Project Q-List, and/or original specifications / purchase orders, or other project documentation as required.
PECo considers that the current LGS Project Q-List, together with the existing procedural controls and Quality Assurance Program governing its use, satisfies the requirements of Generic Letter 83-28, Item 2.2.
- However, PECo is proceeding with a program to expand the present LGS Project Q-List to include all safety-related components, by the end of 1990.
We consider that this enhancement of our
J Docum;nt Control. Desk April 13, 1989 I
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i Q-List will increase the efficiency of the class'ification, I
L maintenance, control, and handling activities for safety-L related (i.e., Q-Listed) components.
I J
Item 2.2.1.1 Identification Criteria NRC Evaluation The licensee's submittal provides the classification criteria used to determine whether a structure, system, or-component is safety-related.
This is consistent with the definition given in Item 2.2.1.
However, the licensee did not identify the procedures used to initiate.the identification of components as safety-related if no previous ~ classification existed.
The licensee should provide additional information that addresses this latter situation.
Response
Currently, there is no single procedure to initiate the identification of safety-related components for LGS if no previous classification exists.
The possibility of a situation where a component does not have a safety classification specified by the LGS Project Q-List, purchase specification, etc, is highly unlikely.
Should this situation arise, however, the PECo Nuclear Engineering Department would be requested to provide the safety classification of the component through a revision to the Q-List.
Furthermore, as of May, 1989, Administrative Procedure, A-129.2 entitled " Classification and Engineering Evaluation of Items and Off-Site Services," will be utilized to document the safety classification determination and procurement level of components previously not classified.
Item 2.2.1.3 Use of Equipment Classification Listing NRC Evaluation The licensee's response stated that safety-related activities are required by administrative maintenance procedures to be conducted under the MRF system.
This MRF system will be automated by the CHAMPS equipment data base management system.
The CHAMPS program will automatically insert the Q-List status of the component into the
Docum nt Control Dack April 13, 1989 Page 8 a
i computerized MRP thereby eliminating any human involvement in review of a hard copy of the Q-List.
The licensee stated that this system would be fully operational by January 1985.
I.! this system is at the present time fully operational and functions as described in the November 10, 1983 response, the concerns of the sub-items are addressed as far as maintenance is concerned.
However, it is not clear how the CHAKPS will be used in the accomplishment of other activities such as routine surveillance testing, design changes, engineering support work, setpoint changes, i
and performance of special tests or studies.
Also, it has not been addressed how station personnel use the MRF or other means to identify the appropriate plant instructions and procedures to be used for the accomplishment of other activities such as routine surveillance testing, design changes, engineering support work, setpoint changes, and performance of special tests or studies.
The licensee should address the staff concerns described above.
Response
As stated in our preceed'ing response to Item 2.2 (Part 1),
above, the CHAMPS program is not presently utilized as stated in our earlier renponse to Generic Letter 83-28.
However, under the MRF system described in Administrative Procedure A-26, plant staff investigation of requests to perform work and subsequent approvals must be documented in Section 2 of a MRF, where the Project Q-List status of the equipment is clearly identified.
At the present time, this identification is carried out by the assigned Plant Maintenance Staff Engineers by conducting a review of a controlled copy of the LGS Project Q-List and/or original specifications / purchase orders, or other Project documentation as required.
All surveillance tests for Q-Listed as well as non-O-Listed l
equipment are performed in accordance with safety-related I
Surveillance Procedures and do not utilize CHAMPS.
These procedures are governed by Administrative Procedure A-43,
" Surveillance Testing Program."
l Design changes and engineering support work utilize CHAMPS to the extent that such activities are performed in accordance with the Modification Program which must be implemented using MRFs (i.e., CHAMPS).
Special tests / studies use CHAMPS to the extent that they are most often performed in conjunction with a MRF.
Special tests / studies, when not considered modifications, are controlled by the safety-related Administrative Procedure
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Documant Control Dask~
April 13,'1989 i
t Page 9 A-41'and Administrative' Procedure A-23, " Generation of Special Procedures."
Setpoint changes are accomplished in' conjunction with a.MRF j
per Administrative Procedure A-32, " Procedure for the Control of Instrument Setting Changes."
As explained.previously, the' classification of the equipment affected by these activities is specified on the MRF.
Should you require any further information, please do not hesitate to contact us.
Very truly yours, 1
o G.
A.
Hunger, Jr.
Director Licensing Section Nuclear Support Division cc:
W. T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS 1
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