ML13308A979

Final Conformance to Generic Ltr 83-28,Item 2.2.1-- Equipment Classification for All Other Safety-Related Components:San Onofre 1, Informal Rept

ML13308A979
Person / Time
Site:	San Onofre
Issue date:	04/30/1987
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML13308A978	List: ML13308A977 ML13308A979
References
CON-FIN-D-6001 EGG-NTA-7396, GL-83-28, TAC-53713, NUDOCS 8706260161
Download: ML13308A979 (18)

Text

EGG-NTA-7396 April 1987 INFORMAL REPORT Idaho National CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1-Engineering EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY Laboratory RELATED COMPONENTS:

SAN ONOFRE-1 Managed by the U. SA Department Alan C. Udy of Energy Work performed under Prepared for the NDEContra0,,ct U.S.

NUCLEAR REGULATORY COMMISSION 87026061 870501f PD ADOCK 05000206.

-PDR

DISCLAIMER This book was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product or process disclosed, or represents that its use would not infringe privately owned rights. References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.

EGG-NTA-7396 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1-EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

SAN ONOFRE-1 Docket No. 50-206 Alan C. Udy Published April 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Under DOE Contract No. DE-ACO7-76I001670 FIN No. D6001

ABSTRACT This EG&G Idaho, Inc., report provides a review of the submittal from Unit No. 1 of the San Onofre Nuclear Generating Station for conformance to Generic Letter 83-28, Item 2.2.1.

Docket No. 50-206 TAC No. 53713 ii

FOREWORD This report is supplied as part of the program for evaluating licensee/applicant conformance to Generic Letter 83-28 "Required Actions Based on Generic Implications of Salem ATWS Events."

This work is being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Idaho, Inc., NRR and I&E Support Branch.

The U.S. Nuclear Regulatory Commission funded this work under the authorization B&R 20-19-10-11-3, FIN No. D6001.

Docket No. 50-206 TAC No. 53713 iii

CONTENTS ABSTRACT

.......................................................... 11 FOREWORD

......................................................... 111

1. INTRODUCTION................................................... 1

2. REVIEW CONTENT AND FORMAT....................................... 2

3.

ITEM 2.2.1 - PROGRAM............................................3 3.1 Guideline..................................................

3 3.2 Evaluation.................................................

3 3.3 Conclusion..................................................

3

4. ITEM 2.2.1.1 -

IDENTIFICATION CRITERIA........................... 4 4.1 Guideline................................................. 4 4.2 Evaluation................................................ 4 4.3 Conclusion.................................................

4

5. ITEM 2.2.1.2 -

INFORMATION HANDLING SYSTEM....................... 5 5.1 Guideline..................................................

5 5.2 Evaluation.................................................

5 5.3 Conclusion.................................................

5

6.

ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING...........

6 6.1 Guideline.................................................

6 6.2 Evaluation................................................

6 6.3 Conclusion.................................................

6

7.

ITEM 2.2.1.4 - MANAGEMENT CONTROLS.............................. 7 7.1 Guideline..................................................

7 7.2 Evaluation.................................................

7 7.3 Conclusion.................................................

7

8.

ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT............... 8 8.1 Guideline.................................................

8 8.2 Evaluation................................................

8 8.3 Conclusion.................................................

8

9.

ITEM 2.2.1.6 -

"IMPORTANT TO SAFETY" COMPONENTS..................

9 9.1 Guideline.................................................

9

10. CONCLUSION.................................................... 10

11.

REFERENCES....................................................11 iv

CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1-EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

SAN ONOFRE-1

1. INTRODUCTION On February 25, 1983, both of the scram circuit breakers at Unit 1 of the Salem Nuclear Power Plant failed to open upon an automatic reactor trip signal from the reactor protection system. This incident was terminated manually by the operator about 30 seconds after the initiation of the automatic trip signal.

The failure of the circuit breakers was determined to be related to the sticking of the undervoltage trip attachment.

Prior to this incident, on February 22, 1983, at Unit 1 of the Salem Nuclear Power Plant, an automatic trip signal was generated based on steam generator low-low level during plant startup. In this case, the reactor was tripped manually by the operator almost coincidentally with the automatic trip.

Following these incidents, on February 28, 1983, the NRC Executive Director for Operations (EDO), directed the NRC staff to investigate and report on the generic implications of these occurrences at Unit 1 of the Salem Nuclear Power Plant. The results of the staff's inquiry into the generic implications of the Salem incidents are reported in NUREG-1000, "Generic Implications of the ATWS Events at the Salem Nuclear Power Plant."

As a result of this investigation, the Commission (NRC) requested (by Generic Letter 83-28 dated July 8, 1983 1) all licensees of operating reactors, applicants for an operating license, and holders of construction permits to respond to the generic issues raised by the analyses of these two ATWS events.

This report is an evaluation of the response submitted by the Southern California Edison Company, the licensee for the San Onofre Nuclear Generating Station, for Item 2.2.1 of Generic Letter 83-28. The document reviewed as a part of this evaluation is listed in the references at the end of this report.

2. REVIEW CONTENT AND FORMAT Item 2.2.1 of Generic Letter 83-28 requests the licensee or applicant to submit, for the staff review, a description of their programs for safety-related equipment classification including supporting information, in considerable detail, as indicated in the guideline section for each sub-item within this report.

As previously indicated, each of the six sub-items of Item 2.2.1 is evaluated in a separate section in which the guideline is presented; an evaluation of the licensee's/applicant's response is made; and conclusions about the programs of the licensee or applicant for safety-related equipment classification are drawn.

2

3. Item 2.2.1 -

PROGRAM 3.1 Guideline Licensees and applicants should confirm that an equipment classification program exists which provides assurance that all safety-related components are designated as safety-related on all plant documents, drawings and procedures and in the information handling system that is used in accomplishing safety-related activities, such as work orders for repair, maintenance and surveillance testing and orders for replacement parts.

Licensee and applicant responses which address the features of this program are evaluated in the remainder of this report.

3.2 Evaluation The licensee for Unit No. 1 of the San Onofre Nuclear Generating Station responded to these requirements with a submittal dated November 28, 1983.2 This-submittal included information that describes their existing safety-related equipment classification program. In the review of the licensee's response to this item, it was assumed that the information and documentation supporting this program is available for audit upon request. The licensee states that the Q-list identifies safety-related components and is used to ensure that procedures governing safety-related activities are classified as safety-related and that these procedures have specific considerations for safety-related activities incorporated in them.

Thus, safety-related activities are identified as such.

3.3 Conclusion We have reviewed the licensee's information and, in general, find that the licensee's response is adequate.

3

4. ITEM 2.2.1.1 -

IDENTIFICATION CRITERIA 4.1 Guideline The applicant or licensee should confirm that their program used for equipment classification includes criteria used for identifying components as safety-related.

4.2 Evaluation The licensee states that components that are part of safety-related systems are classified as safety-related. Component and system function, interfaces, General Design Criteria 10 CFR 50, ANSI N18.2 and applicable regulatory guides are cited as additional basis for classification of a component as safety-related.

4.3 Conclusion We find that the licensee has confirmed that they have identified the criteria used in the identification of safety-related components, thus meeting the requirements of Item 2.2.1.1.

4

5. ITEM 2.2.1.2 -

INFORMATION HANDLING SYSTEM 5.1 Guideline The licensee or applicant should confirm that the program for equipment classification includes an information handling system that is used to identify safety-related components. The response should confirm that this information handling system includes a list of safety-related equipment and that procedures exist which govern its development and validation.

5.2 Evaluation The licensee's submittal identifies the Q-list as the information handling system that lists safety-related structures, systems, components and parts. The description states that the Q-list is developed, reviewed, approved and controlled in accordance with Quality Assurance Program procedures. The station manager maintains the Q-list. Changes to the Q-list are the responsibility of the managers of the Nuclear Engineering Department, the Safety Department, the Technical Department and the Project Manager.

5.3 Conclusion We find that the information contained in the licensee's submittals is sufficient for us to conclude that the licensee's information handling system for equipment classification meets the guideline requirements.

Therefore, the information provided by the licensee for this item is acceptable.

5

6. ITEM 2.2.1.3 -

USE OF EQUIPMENT CLASSIFICATION LISTING 6.1 Guideline The licensee's or applicant's description should confirm that their program for equipment classification includes criteria and procedures governing the use of the equipment classification 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.

6.2 Evaluation The licensee states that procedures are written in consultation with the Q-list to determine if an activity is safety-related. The procedure (and this is audited by the Quality Assurance Department) then is identified as safey-related or non-safety-related. The licensee describes how each station organization verifies that a given procedure is current.

6.3 Conclusion We find that the licensee's description of plant administrative controls and procedures meets the requirements of this item and is, therefore, acceptable.

6

7. ITEM 2.1.4 - MANAGEMENT CONTROLS 7.1 Guideline The applicant or licensee should confirm that the management controls used to verify that the procedures for preparation, validation and routine utilization of the information handling system have been followed.

7.2 Evaluation The licensee's response states that their Quality Assurance Program serves as the method of managerial control.

These controls identify management responsibilities and are stated to require strict adherence to procedures, applicable interdisciplinary reviews and control of documentation. Quality assurance reviews, surveillances and audits assure that the programs and their implementation are correct.

7.3 Conclusion We find that the management controls used by the licensee assure that the information handling system is maintained, is current and is used as intended. Therefore, the licensee's response for this item is acceptable.

7

8. ITEM 2.2.1.5 -

DESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline The applicant's or licensee's submittal 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 the applicant's/licensee's receipt of testing documentation to support 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.

8.2 Evaluation The licensee's submittal specifies that Material Control Procedures S0123-XI-1.0, 2.0 and 2.1 require the application of the proper technical and quality requirements.

Inspections and audits imposed by these procedures are used to assure the appropriate design and manufacture. The environmental qualification package must be completed, by remedial action if necessary, before an item is used in plant operation.

8.3 Conclusion The licensee's response for this item is considered to be complete.

The information provided addresses the concerns of this item and is acceptable.

8

9. ITEM 2.2.1.6 - "IMPORTANT TO SAFETY" COMPONENTS 9.1 Guideline Generic Letter 83-28 states that the licensee's equipment classification program should include (in addition to the safety-related components) a broader class of components designated as "Important to Safety."

However, since the generic letter does not require the licensee to furnish this information as part of their response, review of this item will not be performed.

9

10.

CONCLUSION Based on our review of the licensee's response to the specific requirements of Item 2.2.1, we find that the information provided by the licensee to resolve the concerns of Items 2.2.1.1, 2.2.1.2, 2.2.1.3, 2.2.1.4 and 2.2.1.5 meet the requirements of Generic Letter 83-28 and is acceptable. Item 2.2.1.6 was not reviewed as noted in Section 9.1.

10

11.

REFERENCES

1. NRC Letter, D. G. Eisenhut to all Licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits, "Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," July 8, 1983.

2. Letter, Southern California Edison Company (M. 0. Medford) to Director, Office of Nuclear Reactor Regulation, NRC (0. M. Crutchfield), "Generic Letter 83-28:

Required Actions Based on Generic Implications of Salem ATWS Events," November 28, 1983.

11

NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION

1. REPORT NUMB3ER (Auwpnadby TC. add Vol. No., ilrAnV 12-841 NRCM 1102, IEGNA79 32013202 BIBUOGRAPHIC DATA SHEET EGG-NTA-7396 SEE INSTRUCTIONS ON THE REVERSE

2. TITLE AND SUBTITLE 3 LEAVE BLANK CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1-EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED.

COMPONENTS:

SAN ON0FRE-1

4. DATE REPORT COMPLETED MONTH YEAR 5, AUTHORIS)

April 1987 Alan C. Udy

6. DATE REPORT ISSUED MONTH YEAR April 1987

7. PERFORMING ORGANIZATION NAME AND MAILING ADDRESS (includeZWCodeI

8. PROJECT/TASK/WORK UNIT NUMBER EG&G

Idaho, Inc.

P. 0. Box 1625 BIN OR GRANT NUMBER Idaho Falls, ID 83415 D6001

10. SPONSORING ORGANIZATION NAME AND MAILING ADDRESS (include Zip Code) li.. TYPE OF REPORT Division of PWR Licensing - A Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

b.

PERIOD COVERED nclusive Washington, DC 20555 12 SUPPLEMENTARY NOTES

13. ABSTRACT (200 ords orlssi This EG&G Idaho, Inc., report provides a review of the submittals from the Southern California Edison Company regarding conformance to Generic Letter 83-28, Item 2.2.1 for San Onofre-1.

14 DOCUMENT ANALYSIS a KEYWORDS/DESCRIPTORS

15. AVAILABILITY STATEMENT Unlimited Distribution

16. SECURITY CLASSIFICATION (This Oagel

b. IDENTIFIERS/OPEN-ENDED TERMS Unclassified (This recorri Unclassified

17. NUMBER OF PAGES 18, PRICE