ML18052B055
| ML18052B055 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/30/1987 |
| From: | Vanderbeek R EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML18052B053 | List: |
| References | |
| CON-FIN-D-6001 EGG-NTA-7439, GL-83-28, TAC-53699, NUDOCS 8706080007 | |
| Download: ML18052B055 (20) | |
Text
.. n n
- 1 Idaho National Engineering..
Laboratory,
Managed by the US.
Department of Energy 0
0 0
n
Work performed under DOE Contract
- No. [YE-AC07~761001570
- -~*--
- 8706080007 870417
,.1.
PDR ADOCK 05000255 I ;
P PDR 1-1 0
- :,O"j.*. -
EGG-NTA-7439 April 1987 INFORMAL REPORT CONFORMANCE TO' GENERIC LETTER 83.-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
PALISADES R. VanderBeek Prepared for the U.S. NUCLEAR REGULATORY COMMISSION
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 disclose~. 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-7439 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERit LETTER 83-28. ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR All OTHER SAFETY-RELATED COMPONENTS:
PALISADES Docket No. 50-255 1 R. VanderBeek Published April 1987 Idaho National Engineering Laboratory EG&G Idaho. Inc.
Idaho Falls. Idaho 83415 Prepared for the U.S. Nuclear Regulatory Convn1ss1on Washington. D.C.
20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. 06001
ABSTRACT This EG&G Idaho, Inc. report provides a review of the submittal for the Palisades Nuclear Plant for conformance to Generic Letter 83-28, Item 2.2.1.
Docket No. 50-255 TAC No. 53699 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 C9nmission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Idaho, Inc.
The U.S. Nuclear Regulatory Commission funded this work under the authorization B&R 20-19-10-11-3, FIN No. D6001
- Docket No. 50-255 TAC No. 53699 i; i
ABSTRACT FOREWORD CONTENTS
- 1.
INTRODUCTION......................................................
- 2.
REVIEW CONTENT ANO FORMAT........................................
- 3.
ITEM 2.2.1 - PROGRAM.............................................
- 3. 1 Gu 1de11 ne..................................................
3.2 Evaluat1on 3.3 Conclus1on
- 4.
ITEM 2. 2.1.1 - IOENTIF I CATION CRITERIA...........................
- 4. 1 Gu 1de11 ne..........................................*....*..
4.2 Evaluat1on 4.3 Conclus1on
- 5.
ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM.......................
5; 1 Guideline........**.....*...*...................... :.......
5.2 Eva luat1 on...,*...............................................
5.3 Conclusion
- 6. 'ITEM Z.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING...........
6.1 Gu1del ine........*.......*....*...*...................,...... -
6.2 6.3 Evaluation Conclusion
- 7.
ITEM 2.2.1.4 - MANAGEMENT CONTROLS...............................
7.1
- Guideline..................................................
7.2 7.3 Evaluation Conclusion
\\i
\\ii 1
2 3
3 3
4 5
5 5
5 6
6 6
6 7
7 7
7 8
8 8
8
~.*
- 8.
- 9.
- 10.
- 11.
ITEM 2. 2. 1
- 5 DESIGN VERIFICATION AND PROCUREMENT
- 8. 1 8.2 8.3 Guideline Evaluation Conclusion ITEM 2. 2. 1. 6 11 IMPORTANT TO SAFETY 11 COMPONENTS
- 9. 1 Guideline...................................................
CONCLUSION REFERENCES v
9 9
9 9
10 10 11 12
CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
PALISADES
- 1.
INTRODUCTION On February 25, 1983, both of the scram circuit breakers at Unit l of the Salem Nuclear Power Plant fa11ed to open upon an automatic reactor trip signal from the reactor protect1on system.
Th1s 1nc1dent was terminated manually by the operator about 30 seconds after the in1t1at1on of the automatic trip signal.
The fa11ure of the circu1t breakers was determ1ned to be related to the sticking of the undervoltage trip attachment.
Prior to th1s 1nc1dent, on February 22, 1983, at Un1t l of the Salem Nuclear Power Plant, an automat1c tr1p s1gnal was generated based on steam generator low-low level dur1ng plant startup.
In th1s case, the reactor was tripped manually by the operator almost co1ncidentally w1th the automat1c tr1p.
following these inc1dents, on February 28, 1983, the NRC Executive Director for Operations (EDO), d1rected the staff to investigate and report on the generic 1mp11cations of these occurrences at Un1t 1 of the Salem Nuclear Power Plant.
The results of the staff's 1nqu1ry into the gener1c 1mp11cat1ons of the Salem un1t 1nc1dents are reported in NUREG-1000, "Generic Implications of the ATWS Events at the Salem Nuclear Power Plant."
As a result of this 1nvest1gat1on, the Commission (NRC) requested (by Generic Letter 83-28, dated July 8, 19831) all 11censees of operat1ng reactors, applicants for an operating license, and holders of construct1on permits to respond to gener1c 1ssues raised by the analyses of these two ATWS events.
Th1s report 1s an evaluat1on of the response subm1tted by the Consumers Power Company for Pa11sades Nuclear Plant for Item 2.2.1 of Gener1c Letter 83-28.
The actual document rev1ewed as a part of this evaluation is listed in the references at the end of this report.
1
- 2.
REVIEW CONTENT;AND FORMAT Item 2.2. 1 of Generic Letter 83-28 requests the licensee/applicant to submit, for staff review, a description of their programs for classification of their safety-related equipment includes supporting information, in considerable detail, as indicated in the guidelines preceding.:t~e evaluation of each sub-Jtem.,
As*' previously stated~: 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 its acceptability are drawn.
2
- 3.
ITEM 2.2.1 - PROGRAM 3.1 Guideline licensee and applicants should confirm that an equipment classification program is in place which will provide assurance that all safety-related components are designated as safety-related on plant documentation* such as procedures, system descriptions, test and maintenance instructions and in information handling systems so that personnel performing act1v1ties 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.
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 Palisades Nuclear Plant provided a response to 2
Generic Letter 83-28 with a submittal dated November 9, 1983.
This submit ta.l included 1 nformat ion that describes their safety-re lated 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 has provided a description of the equipment classification program for the identification of safety-related activities for repair, maintenance, and procurement.
The response does not directly confirm that all components designated as safety-related in the Q-list are also properly designated on plant documents, procedures and in the information handling systems used for safety-related act1v1ties.
- However, the licensee's response to Items 2.2.1.2 and 2.2.1.3 indicate that the documents used to control safety-related activities from start to finish are marked as safety-related. This is discussed in detail in Sections 5.2 and 6.2 of this report.
We consider this to be acceptable.
3
3.3 Conclus1on.
We have rev1ewed the 11censee's 1nformat1on and, 1n general, f1nd that the 11censee's response 1s adequate.
4
- 4.
ITEM 2.2.l~l - IDENTIFICATION CRITERIA 4.1 Gu1de11ne The appl1cant or 11censee should conf1rm that the1r program used for equ1pment class1f1cat1on 1ncludes cr1ter1a used for 1dent1fy1ng components as safety-related.
4.2 Evaluat1on The 11censee's response states that safety-related structures, systems, components and related consumables are 1dent1fied in a Q-11st.
Th1s 11st was developed and is ma1ntained in accordance with the cr1ter1a of Regulatory Guide l.29 as clarif1ed by Item No. 20a, Append1x A, Part 2 of Topical Report C PC-2A.
4-.3 Conclusion The licensee's response to this item is cons1dered to be complete and is acceptable..
5
5._ ITEM 2~2.l.2 - INFORMATION HANDLING SYSTEM 5.1 Gu1del1ne The 11censee or appl1cant should conf1rm that the program for equ1pment class1f1cat1on 1ncludes an 1nformat1on handl1ng system that \\s used to 1dent1fy safety-related components.
The respons~ should cohf1rm that.~::th1s 1nformat1on handlin*g~,system 1ncludes a 11st of safety-related.
equ1pment and that procedures ex1st wh1ch govern \\ts development and val1dat1on.
5.2 Evaluat1on The 11censee response states the Pal\\sades Plant Q-L\\st 1s composed of the Equ1pment Data Base (EDB) and the Append1ces to Pal1sades Adm1n1strat1ve Procedure 10.08.
Plant structures. systems. components, chem1cals and consumables are class1f\\ed as safety-related or nonsafety-related 1n accordance wHh the requ\\rements of NODS-A21 and Consumers Power Company's Qual1ty Assurance Program.
When the Q status of an 1tem cannot be determ1ned from the Q-L1st. or an apparent d\\screpancy ex\\sts. a Q-Ust Interpretat1on Form 1s 1n1t1ated.
Th1s form, along wHh an EDS Data Fbrm 1f the 1tem 1s new. \\s forwarded to the Techn1cal Super1ntendent.
The Techn1cal Super\\ntendent ass\\gns an \\nd\\v\\dual to perform the \\riterpretat1on.
Upon complet1on, the 1nterpretat1on \\s g\\ven a techn1cal rev1ew by a knowledgable 1nd1v1dual, a rev1ew by QA-Nuclear Operat1ons (NO) and an adm1n1strat1ve rev1ew by the Techn1cal Super1ntendent.
5.3 Conclus1on The licensee's response to th1s 1tem 1s cons1dered to be complete and 1s acceptable.
6
- 6.
ITEM 2.2.l.3 - USE OF EQUIPMENT CLASSIFICATION LISTING 6.1 Gu1del1ne The 11censee's descr1pt1on should show how stat1on personnel use the equ1pment class1f1cat1on 1nformat1on handl1ng system to determ1ne:.
(a) when ari act1v1ty 1s safety-related, and (b) what procedures are to.be used for ma1ntenance work, routine su'rve1llance test1ng, accompl1shment of des1gn changes, and performance of spec1al tests or studies.
We should be able to ga1n conf1dence from our rev1ew'that there w111 be no confus1on about when act1v1ty 1s safety-related.
- 6. 2 Evaluation The 11censee's response 1dent1f1es the use of the Q-list, Nuclear Operat1ons Department Standards, Ha1ntenance Orders, and Adm1n1strative procedures 1n the dete~m1nat1on of safety-related activities 1n the areas of parts replacement, storage, ma1ntenance, mod1f1cat1on, test1ng, and surve1llance.
Collect1vely, these documents conta1n the controls to ensure that safety-related equ1pment 1s 1dent1f 1ed and handled 1n an appropr1ate manner.
6.3 Conclus1on The 11censee's response to th1s 1tem 1s considered to be complete and 1s acceptable.
7
- .1
1~
ITEM 2.2.1.4 ~MANA~EMENT CONTROLS.
7.1 Gu1del1nes' The appl1cant or 11censee should conf1rm that the management controls used to ve~ify that the procedures for preparation, validat1on and rout1ne ut111zat1on.*of the 1nformation handT1ng,system have been followed.
7 ~ 2,. Eva 1 ua ti on.. *.
The 11censee's response states that by plant Adm1nistrative Procedures, all ma1ntenance o*rders, modH1cat1ons and contracts are subject to rev1ew/approval prior to implementation.
Period1c surveillances and audits of maintenance, procurement, and mod1f1cat1on procedures, c~nducted by the Qual1ty Assurance Department, v~r1fy that the Q-L1st informat1on 1s be1ng properly ut111zed in these activ1t1es.
7.3. Conclus1on The 11censee' s response to th1s Hem 1s c.ons1dered to be complete and 1s acceptable.
8
- 8.
ITEM' 2.2.1.5 DESIGN VERIFICATION AND PROCUREMENT
.8.1 Gu1del1ne The 11censee's subm1ttals shall show that the spec1f1cat1ons for procurement of replacement safety-re.lated components and parts requ1re that ver1f1cat1on of des1gn capab111ty and ev1dence of test1ng that ~ual1f1es the components and parts for serv1ce under the expected cond1t1ons for the serv1ce lHe spec1f1ed by the suppl1er 1s 1ncluded.
8.2 Evaluat1on The licensee's response states that Palisades adm1nistrative procedures 10.02, "Procurement Process-Genera 1, 11 and 10. 03, "Procurement o.f Materials, 11 establ1sh the requ1rements, respons1b111t1es and method of procurement for all stock and non-stock equ1pment, mater1als and suppl1es.
These procedures provide 1nstruct1ons for prepar1ng the Mater1al Request/Authorization to Purchase (MR/ATP) Form.
These procedures 1nclude deta1led stat~ments for 1nclus1on w1th the MR/ATP spec1fy1ng design, manufacturer test1ng, shipment, and storage requ1rements.
The MR/ATP Form and associated documentat1on receive techn1cal, QA and Adm1n1strat1ve re~iews to ensure the adequacy of technical/quality requ1rements specified by the originator of the MR/ATP Form.
8.3 Conclusion The licensee's response for. this Hem is considered to be,complete and is acceptable.
9
- 9.
ITEM 2.2.J.6 _.,,... IMPORTANT TO' SAFETY" COMPONENTS 9.1 Gu1del1ne The Gener1c letter 83-28 states that the 11censee's equ1pment class1f1cat1on program.should 1nclude (1n add1t1on to the safety-related components) a broader class of components des1gnated as "Important to Safety."
Howeyer"'~*.,,sthce tb~ GeQer1c,Let:ter do.e.s:.7.,not.requJre the app11cant/11cens~e to furn1sh th1s 1nformaJ.1on a~ par.t of the1r re~ponse, re.v.\\ew_~of,. th ts Hem w1ll not be pet:formed *.
10
.l
e e
- 10.
CONC_LUSION Based on our rev1ew of the* 11censee's response to the spec1f1c requ1rements of Item 2.2.1, we f1nd that the 1nformat1on prov1ded by the 11censee to resolve the concerns of Item 2.2.1 of Gener1c Letter 83-28 1s acceptable.
Item 2.2.1.6 was not rev1ewed as noted 1n Sect1on 9 of th1s report.
11 I
- 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 Implication of Salem ATWS Events (Generic Letter 83-28)," July 8, 1983.
- 2.
Consummers Power Company letter, D. J. VandeWalle to D. G. Eisenhut, NRC, Novenber 9, 1983.
38492 12
NAC FOAM 3311 12*8'1 U.I. NUCLIAA AIQULATOAY COMMllSION
- 1. REPORT NUMBER IAuip<<lby TIOC. *dd Vol. No.* lf*n~I NRCM 1102.
3201, 3202 BIBLIOGRAPHIC DATA SHEET EGG-NTA-7439 SEE INSTRUCTIONS ON THE REVERSE
- 2. TITLE ANO SUBTITLE CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
PALISADES J. LIAVE BLANK
- 4. DATE REPORT COMPLETED MONTH YEAR
- 5. AUTHORISI Apri 1 1987
~
R. VanderBeek
P. O. Box 1625 Idaho Falls, ID 83415
- 10. SPONSORING ORGANIZATION NAME ANO MAILING AODRESS llnt:lu<*Zip Co<*I Division of PWR Licensing - A Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
- 12. SUPPLEMENTARY NOTES
- 13. ABSTRACT 1200 won/1 01 !011J
&. DATE REPORT ISSUED MONTH YEAR Apri 1 1987
- 8. PROJECT/TASK/WORK UNIT NUMBER
- b. PERIOD COVERED (lnclu1iw datwl This EG&G Idaho, Inc., report provides a review of the submittal from the Consumers Power Company regard.i ng conformance to Generic Letter 83-28, Item.2. 2. 1 for the Pa 1 i sades Nuclear Plant.
I* DOCUM~NT ANALYSIS
- l(E,WOROStOESCR1PTORS
- b. IOENTIF IE RS/OPEN.ENDED TERMS 15 AVAILABILITY STATEMENT Unlimited Distribution 1 &. SECURITY CLASSIFICATION *-
/Tlti1 f>>PJ Unclassified (T1ti1,_,,o,,J Unclassified
- 17. NUMBER OF PAGES
- 18. PRICE