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Forwards Response to 870220 & 24 Requests for Addl Info Re Util Responses to Generic Ltr 83-28,Item 2.2 on Equipment Classification Concerning Generic Implications of ATWS Events
	ML20207S420
Person / Time
Site:	Haddam Neck
Issue date:	03/13/1987
From:	Mroczka E; CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
	A06176, A06384, A06385, A6176, A6384, A6385, B12375, GL-83-28, NUDOCS 8703190421
	Download: ML20207S420 (12)
	v • d • e

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s NORTHEAST UTILITIES o.nor.i onic.. . s.m.n street. Bornn. connecticut c

HARTFORD CONNECTICUT 06141-0270 L t Ta Z ' Z' C '%~J'

, (203) ses-sooo March 13,1987 Docket Nos. 50-213 50-245 50-336 A06176 A06384 A06385 B12375 Re: Generic Letter 83-28, Item 2.2 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Generic Letter 83-28, Item 2.2

" Equipment Classification" In a letter dated October 22, 1986,(1) the Staff requested additional information on Millstone Unit No. I's response to Generic Letter 83-28, item 2.2," Equipment Classification." Northeast Nuclear Energy Comggny (NNECO) responded to the Staff in a letter dated November 21, 1986 w stating that the additional information would be supplied to the Staff by February 27,1987.

Subsequently, throug verbal requests and letters dated February 20,(3) and February 24, 1987,(4 the NRC requested additional information on NNECO's Millstone Unit No. 2 and Connecticut Yankee Atomic Power Company's (CYAPCO's) Haddam Neck Plant responses to the same issue. In light of the additional requests, the NRC's Millstone Unit No.1 Project Manager was verbally informed that the response for Millstone Unit No. I would be delayed to allow for a comprehensive response to be prepared for the three plants.

(1) C. I. Grimes letter to 3. F. Opeka, " Request for Additional Information,"

dated October 22,1986.

(2) J. F. Opeka letter to C.1. Grimes, " Request for Additional Information -

Generic Letter 83-28, item 2.2 ' Equipment Classification,' " dated November 21, 1986.

(3) D. H. Jaffe letter to E. 3. Mroczka," Request for Additional Information

- Generic Letter 83-28," dated February 20,1987.

(4) F. M. Akstulewicz letter to E. J. Mroczka, " Request for Additional f ,g Information Concerning Responses to Generic Implications of Salem A0b' ATWS Events (Generic Letter 83-28)," dated February 24,1987. (

0703190421 870313 PDR ADOCK 05000213 P PDR

O.S. Nuclear Regulatory Commission

- B12375/Page 2 March 13,1987 Attachment I details the Staff's requests for each plant. In response to these requests, Attachment 2 provides the additional information requested by the Staff.

If you have any questions on this material, please feel free to call my staff.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY CONNECTICUT YANKEE ATOMIC POWER COMPANY

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Senior rice President cc: F. M. Akstulewicz, NRC Project Manager, Haddam Neck Plant D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 Dr. T. E. Murley, Region I Administrator T. Rebelowski, Resident inspector, Millstone Unit Nos. I and 2

3. 3. Shea, NRC Project Manager, Millstone Unit No.1 P. D. Swetland, Resident Inspector, Haddam Neck Plant

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Docket Nos. 50-213 50-245 50-336 B12375 Attachment 1 Haddam Neck Plant Millstone Unit No.1

, Millstone Unit No. 2 NRC Request for Additional Information on Generic Letter 83-28 March,1987

Att:chmtnt 1 B12375/Page 1 March 13,1987 Millstone Nuclear Power Station Unit No.1(1)

1) Item 2.2.1 - Program Guideline Licensees ano applicants should submit a program description that provides assurance that all safety-related components are designated as safety-related in all plant documents, drawings, procedures, and in information handling systems that are used in accomplishing safety-related activities such as work orders for repair, maintenance, and surveillance testing and orders for procurement of replacement parts.

Evaluation The licensee states that they are converting to a computer-based information handling system. The licensee has not stated that the scope of the computer-based system and the present system encompass all safety-related components or that the safety-related components are designated as safety-related on all plant documents, drawings, procedures, and in information handling systems that are used in accomplishing safety-related activities.

The licensee should confirm that all safety-related components are encompassed in the identification systems and are identified in the documentary material used in accomplishing all safety-related activities.

2) Item 2.2.1.2 - information Handling System Guideline The licensee's description of his information handling system for component classification should confirm that a listing of safety-related equipment detailed to the component level has been compiled that includes such components as switches, motors, relays, transmitters, pumps, pipes, fittings, tanks, and valves. The description should show (a) how the listing was originally prepared; (b) how new safety-related items are entered; (c) how changes in classification of listed items are made; (d) how listed items are verified; (e) how unauthorized changes to the listing are preveated; and (f) how the listing will be maintained and distributed to users as an official, single, consistent and unambiguous version.

Evaluation The licensee's submittal identifies the Category 1 Material, Equipment and Parts List (MEPL) as the information handling system that lists safety-related structures, systems, components and parts. The description included the methods used for its development; the process by which new safety-(1) C. I. Grimes letter to 3. F. Opeka, " Request for Additional Information,"

dated October 22,1986.

s Attachment 1 B12375/Page 2 March 13,1987 related items are entered; and how changes in the classification of listed items are made. The licensee is changing over to a computer-based system, the Production Maintenance Management System (PMMS) for which information was not supplied, however, it was noted that the PMMS is intended to replace the MEPL. Revisions to the PMMS are controlled by the MEPL engineer. The licensee's response does not describe how listed items are verified; and how unauthorized changes are prevented. Thus, it is not clear that the listing is maintained and distributed to users as an official, single, consistent and unambiguous version. The licensee snould provide additional information describing the new computerized version of the safety-related component listing and describing how the listing is maintained and controlled as an official, single, consistent and unambiguous version as indicated in guideline items (d), (e) and (f) above.

3) Item 2.2.1.5 - Design Verification and Procurement Guideline The licensee's submittals should show that the specifications for procurement of replacement of safety-related components and parts require that the supplier include in their documentation, verification of design capability and evidence of testing that qualifies the components and parts for service under the expected conditions over the service life.

Evaluation The licensee's submittals specify that Quality Assurance Program procedures QAP 4.0 and 7.0 satisfy the requirements of this guideline. Procedure GEC 2.01 (Generation Engineering and Construction Division) augments these procedures by stipulating testing requirements and acceptance criteria.

Procedure NEO 3.06 (Nuclear Engineering and Operations) also supplements the Quality Assurance program procedures by assuring that the purchase documents have the proper Quality Assurance documents attached to them.

However, the requirement to submit evidence of testing is not specifically addressed by the licensee. The licensee should show that the procurement specifications specifically require the supplier to include verification of design capability and evidence of testing that qualifies the components and parts for service under the expected conditions over the life of the component or part.

Attachment i B12375/Page 3

. March 13,1987 Haddam Neck Plant (2)

1) Item 2.2.1 -

The licensee's response does not confirm that the information handling system consists of a single, concise, unambiguous listing of all safety-related components and parts.

2) Item 2.2.1.2 The licensee's response has not confirmed that the new computerized information handling system includes a list of safety-related equipment and that procedures exist which govern its development and validation.

i (2) F. M. Akstulewicz letter to E. 3. Mroczka, " Request for Additional Information Concerning Responses to Generic Implications of Salem ATWS j Events (Generic Letter 83-23)," dated February 24, 1987.

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Attachment 1 B12375/Page 4 March 13,1987 1

Millstone Nuclear Power Station. Unit No. 2(3)

1) Item 2.2.1 The licensee's response does not confirm that the information handling system consists of a single, concise, unambiguous listing of all safety-related components and parts.

, 2) Item 2.2.1.2 The licensee's response has not confirmed that the information handling system includes a list of satety-related equipment and that procedures exist which govern its development and validation.

3) Item 2.2.1.3 The licensee's response has not confirmed that criteria and procedures exist l which govern the use of the information handling system to determine that an

) . activity is safety-related and what procedures for maintenance, surveillance, I parts replacement and other activities defined in the introduction to 10 CFR l 50, Appendix B, apply to safety-related components.

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(3) D. H. Jaffe letter to E. J. Mroczka, " Request for Additional Information -

Generic Letter 83-28," dated February 20,1987.

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Docket Nos. 50-213 50-245 50-336 B12375 Attachment 2 Haddam Neck Plant i Millstone Unit No.1 I Millstone Unit No. 2 l

Additional Information on Generic Letter 83-28, Item 2.2 l

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l March,1937

Attachment 2 B12375/Page1 March 13,1987 Response for item 2.2.1 " Program Guideline" The computer-based Production Maintenance Management System (PMMS) and the Material, Equipment, and Parts List (MEPL) together encompass most safety-related components. Use of the PMMS and MEPL are governed by Nuclear Engineering and Operations (NE&O) Procedures 6.10 and 6.01, respectively. By these procedures, NNECO and CYAPCO work conservatively when it is uncertain whether a specific component (in a safety-related system)is safety-related. In such cases, work on the component must be performed as if it is safety-related unless a formal evaluation proves differently.

Also, for components which are not included in the PMMS or MEPL (e.g., hangers), NNECO and CYAPCO work conservatively when it is uncertain whether a specific component (in a safety-related system) is safety-related. In such cases, work on the cornponent must be performed as if it is safety-related unless a formal evaluation per NEO 6.01 proves differently.

Work Orders are the basic method of controlling activities such as repair, maintenance and installation. PMMS is the information system used to generate such work orders. Therefore, as a practical matter, Millstone Unit No.1, Millstone Unit No. 2 and the Haddam Neck Plant control safety-related activities rather than designate specific safety-related components in every piece of plant documentation (files, drawings, procedures, etc.).

Surveillance testing is controlled by (PORC-approved) plant procedures which include safety-related components.

Procurement activities are controlled as described in the response for Item 2.2.1.5.

In addition, both Millstone Unit No.1, Millstone Unit No. 2 and the Haddam

. Neck Plant distinguish safety-related documentation as shown in the following examples:

1) Administrative Control Procedures (ACPs) which control safety-related work are designated "Q.A.";

2) Drawings are designated " safety-related" if any portion of the drawing contains safety-relged information; and

3) Purchase documents for safety-related equipment are designated "Q.A.".

Attachment 2 B12375/Page 2 March 13,1987 Response for Item 2.2.1.2 "Information Handling System Guideline" How listed items are verified:

NEO Procedure 6.10 provides the controls for PMMS Category 1 quality indicators. That is, if the PMMS quality indicator is a "U" (meaning undefined), a complete MEPL evaluation per NEO Procedure 6.01 is required to ascertain if the item is quality related. If the PMMS quality indicator is an "N" (meaning not quality-related), a MEPL evaluation must be referenced substantiating this determination. New items entered into PMMS require a "U" initially or a MEPL evaluation if the item is not listed in the MEPL.

How unauthorized changes to the listing are prevented:

Fields within this database which indicate the equipment's quality status are specifically protected by the mainframe computer security scheme. Plant management must specifically request authorization for individuals to be capable of changing these specifically treated fields. In addition, a report is available which lists all changes to the protected fields that have occurred within a specified date range. NEO 6.10 requires this listing to be checked once per core cycle to verify that changes have been correctly entered.

How the listing is maintained and distributed:

PMMS is " distributed" officially, consistently, and unambiguously to all users through on-line computer facilities. It is maintained in that fashion by use of the centrols described above.

The MEPL remains a hard-copy listing of safety-related items, including those not listed in PMMS. Currently, components may be listed in both the MEPL and PMMS, and the MEPL is identified as the governing document. NEO Procedure 6.01 controls how safety-related determinations are made and documented, and also how the MEPL is maintained. It is still intended to eventually replace the MEPL with PMMS.

s Attachment 2 B12375/Page 3 March 13,1987 Response for item 2.2.1.3 "Use of the Equipment Classification Listina" See responses for items 2.2.1 and 2.2.1.5.

Response for Item 2.2.1.5 "Deslan Verification and Procurement" The invoking of requirements in the procurement of. safety-telated components and parts is described principally in NEO Procedure 6.02,' " Preparation and Review of Quality-Related Purchase Requisitions" (superseding document to NEO Procedure 3.06), and NEO Procedure 5.04," Preparation, Review, Approval, Revision, and Control of Specifications."

NEO Procedure 6.02 requires the originator of the purchase requisition (PR) to specify the appropriate documentation requirements or, if applicable, the Contract Document Plan (CDP). This procedure also holds the PR Originator responsible for specifying the scope of work, technical requirements, and technicM adequacy, including adherence to original specification' requirements; i.e.,. Northeast Utilities Service Company (NUSCO), A/E, NSSS, or Origmal Equipment Manufacturer (OEM). - Here, it is also stated that spare or replacement Category 1 materials must be purchased to either the original specifications or their properly reviewed and approved revisions and codes or acceptsble substitute specifications and codes.

The responsibility for verifying and/or specifying required docum'entation and reviewing the PR to ensure technical adequacy is that of the various NNECO and CYAPCO Supervisors, Quality Assurance and Technical Reviewers (NEO Procedure 6.02). Overall responsibility for ensuring that QA documentation requirements are specified on the PR is assigned to the NUSCO/NNECO/CYAPCO Engineering and Construction Supervisors (NEO Procedure 6.02).

NEO Procedure 5.04 is the governing procedure for procurement specifications.

In it, the specification originator is advised as follows:

Stipulate the testing requirements, acceptance criteria, in excess of those in any reference documents to ensure that the components will meet performance requirements; and Stipulate the documentation requirements for the materials, design, fabrication, examination and testing of components, including that required by the applicable codes, standards, and regulatory documents. Included may be drawings, performance data, performance curves, etc.

Insofar as Environmental Equipment Qualification (EEQ) is concerned, NEO i Procedure 6.02 requires that prs for electrical, instrumentation, and control items be routed to the Generation Electrical Special Programs and Studies Section for EEQ review and approval.

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Attachm:nt 2 B12375/Page 4 March 13,1987 ,

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Generation Engineering and Construction Procedure 2.01, " Preparation Review, I Approval, Revision and Control of NUSCO Generation Engineering and l Construction Division Specifications," the implementing procedure for NEO 1 Procedure 5.04, requires the discipline engineer to consider the design input requirements of ANSI N45.2.ll, and to stipulate the testing requirements, acceptance criteria, in excess of those in any reference documents to ensure that the components will meet performance requirements.

Also, as part of the QA review, and in support of the qualification program, the following statement is used for the procurement of spare / replacement parts:

"The customer shall be informed of design and/or material deviations incorporated since placement of original or subsequent orders procuring material of this type. This shall include, but not be limited to, changes made to part number, design and material. This information is important to nuclear safety and is a mandatory requirement of this order."

The EEQ review and approval functions are described in NEO Procedure 2.21,

" Nuclear Plant Environmental Qualification Program," which requires this review to be performed prior to Quality Assurance (QA) approval of the PR, and to verify, as a minimum, the following:

1) Whether the material is an EQ Master List piece of equipment (requiring environmental qualification), or is a component or part thereof.

2) If the material falls within the scope of the EQ Program, to ensure that appropriate EQ specifications (including Certificates of Compliance and submittal of test plans and reports) are completely and correctly included.

3) Where EQ Equipment is specified, to ensure that vendor qualification documentation is adequate to demonstrate qualification to the plant-specific environmental parameters.

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s NORTHEAST UTILITIES o.nor.i onic.. . s.m.n street. Bornn. connecticut c

HARTFORD CONNECTICUT 06141-0270 L t Ta Z ' Z' C '%~J'