ML18095B023
| ML18095B023 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 08/18/1989 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Fernandez W POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| References | |
| IEIN-81-26, NUDOCS 8908310230 | |
| Download: ML18095B023 (21) | |
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.National Engineering Laboratory Managed bv the U.S.
Department of Energv n
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~GC..G Idaho Work performed under DOE Contract No. DE-AC07-76/D07570
' i EGG-NTA-7392 June 1989 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
SALEH-1/-2 Alan C. Udy Prc,:::red for the U.S. NUCLEAR REGULATORY COMMISSION
NOTICE This report was prepared as an account of work sponsored by an agency of.
the United States Government. Neither the United Sates Government nor any agency thereof, nor any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility forjllY third party's use, or the results of such use, of any. information, apparatus, product or proc-ess disclosed in this report, or represents that its use by such third pany would not infringe p~'*'~tely owned rights.
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EGG-NTA-7392 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2. 1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
SALEM-1 /-2 Docket Nos. 50-272/50-311 A 1 an. C. Udy Published June 1989 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-AC07-76ID01570 FIN No. D6001 TAC Nos. 53711/53712
SUMMARY
This EG&G Idaho, Inc., report provides a review of the submittals from the Salem Generating Station for conformance to Generic Letter 83-28, Item 2.2. 1.
Item 2.2. 1 of Generic Letter 83-28 requires licensees and applicants to submit a detailed description of their programs for safety-related equipment classification for staff review. - It also describes guidelines that the licensee 1s or applicant 1s programs should encompass.
This review concludes that the licensee complies with the requirements of this item.
FIN No. 06001 B&R No. 10-19-11-3 Docket Nos. 50-272/50-311 TAC Nos. 53711/53712 i i
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PREFACE This report is supplied as part of the program for evaluating licensee/applicant conformance to Generic_ Letter 83-28 11Required Actions Based on Generic Implications of Salem ATWS Events.
11 This work is being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Engineering and Syste~ Technology, by EG&G Idaho, Inc., Regulatory and Technical Assistance Unit.
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CONTENTS
SUMMARY
PREFACE...............................................................
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- 5.
- 6.
- 7.
- 8.
- 9.
lo.
- 11.
INTRODUCTION.....................................................
REVIEW CONTENT AND FORMAT........................................
ITEM 2.2.1 - PROGRAM.............................................
- 3. 1 3.2 3.3 Guideline Evaluation Conclusion
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- m * * * * * * * * * * * * * * * * * * * * * * * * * * *
- ITEM 2.2.1. l IDENTIFICATION CRITERIA
- 4. 1 4.2 4.3 Guideline Evaluation Conclusion ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM.......................
- 5. 1 5.2 5.3 G"uide 1 i ne Evaluation Conclusion ITEM 2.2.l.3 - USE OF THE EQUIPMENT CLASSIFICATION LISTING
- 6. 1 6.2 6.3 Guideline Evaluation Conclusion ITEM 2.2. 1.4 - MANAGEMENT CONTROLS...............................
- 7. 1 7.2 7.3 Guideline Evaluation Conclusion ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT
- 8. 1 8.2 8.3 Guideline Evaluation Conclusion ITEM 2.2.1.6 - "IMPORTANT TO SAFETY" COMPONENTS
- 9. 1 Guideline..................................................
CONCLUSION...................
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REFERENCES.......................................................
iv ii iii 2
3 3
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5 5
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10 10 10 10 11 11 12 13
CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
SALEM-1/-2
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INTRODUCTION On February 25, 1983, both of the scram circuit breakers at Unit l of the Salem Generating Station 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 l of the Salem Generating Station, a~ 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 Febr~ary 28, 1983, th~ NRC Executive Director for Operations (EDO), directed the NRC staff to investigate and report on the generic implications of these occurrences at Unit l of the Salem Generating Station.
The. r~sults of the staff's inquiry irito the generic implications of the Salem Unit l incidents are reported in NUREG-1000, "Generic Implications of the ATWS Events at the Salem Nuclear Power Plant.
11 As a result of this investigation, the Commission {NRC) requested {by Generic Letter 83-28 dated July 8, 19831) 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 responses submitted by the Public Service Electric and Gas Company, the licensee for the Salem Generating Station, for Item 2.2. l of Generic Letter 83-28.
The documents reviewed as a part of this evaluation are listed in the References (Section 11) at the end of this report.
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REVIEW CONTENT AND FORMAT Item 2.2.1 of Generic Letter 83-28 requests the licensee to submit a description of their programs for safety-related equipment classification for staff review.
Detailed supporting information should also be included in the description, as indicated in the guideline section for each item within this report.
As previously indicated, each of the six items of Item 2.2.1 is evaluated in a separate section in which the guideline is presented; an evaluation of the licensee's response is made; and conclusions about the programs of the licensee for safety-related equipment classification are drawn.
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ITEM 2.2.1 - PROGRAM 3.1 Guideline Licensee should confirm that an equipment classification program is in place that wi 11 provide assurance that safety-re 1 ated components are designated as safety-related on plant documentation.
The program should provide assurance that the equipment classification information handling system is used so that activities that may_affect safety-related components are designated safety-related.
By using the information handling system, personnel are made aware that they are working on safety-related components and are directed to, and are guided by, safety-related procedures and constraints. Licensee responses that address the features of this program are evaluated in the remainder of this report.
3.2 Evaluation The licensee for the Salem Generating Station responded to the generic letter with a submittal dated July 22, 1983. 2 This response referred to five previous submittals that address the concerns of Item 2.2. 1 (References 3 through 7). These submittals describe the then existing safety-related equipment classification program.
Additional information was provided on September 20, 19858 and April 17, 1989.9 The licensee describes the Master Equipment Lists (MEL), stating that each MEL (referring to one for each unit) was developed from source documents such as the Final Safety Analysis Report, system descriptions, equipment specifications, and engineering drawings.
The MEL has been replaced by the Managed Maintenance Information System (MMIS).
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.
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3.3 Conclusion We have reviewed the licensee's submittals and, in general, find that the licensee's responses are acceptable.
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ITEM 2.2.l.l - IDENTIFICATION CRITERIA
- 4. l Guideline The licensee should confirm that their program used for equipment classification includes the criteria used for identifying components as safety-related
- 4.2 Evaluation The licensee's response for this item identifies 10 CFR 100, Appendix A, ANSI Nl8.2 and IEEE Std 308-1971 as the criteria used in classifying components as safety-related. These sources encompass the criteria given in the footnote to Section 2.2. 1 of the generic letter.
4.3 Conclusion The licensee's responses to this item are complete and address the staff's concern.
Therefore, we find the licensee's responses for this item acceptable.
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ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM 5.1 Guideline The licensee 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 to govern its development and validation.
5.2 Evaluation The licensee's submittals identify the Managed Maintenance Information System (MMIS) as the information handling system containing the listings of safety-related structures~ systems, components, and parts referred to. The description states that the Master Equipment List (MEL) was developed from the construction program document Project Directive No. 7(PD-7) and compiled from source documents such as the Final Safety Analysis Report, system descriptions, equipment specifications, and drawings.
The MEL has since been updated, reviewed and issued as a controlled document, and the information contained therein transcribed to the MMIS.
The MMIS contains a component classification database that is accessed in the preparation of work orders and preventive maintenance data.
The MMIS database management group has the responsibility for database changes.
Password security prevents unauthorized changes to the database.
The licensee states that there are approved procedures that define the MMIS work control process and control changes to the database.
The MMIS database group is also responsible for the classification of new components, as well as assigning individual component identification numbers for new components installed in the plant. These activities use approved Nuclear Department procedures in their accomplishment.
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5.3 Conclusion The licensee*s responses describe a system that meets the recommendations of this item.
Therefore, we find the licensee 1s responses for this -item acceptable.
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ITEM 2.2. 1.3 - USE OF THE EQUIPMENT CLASSIFICATION LISTING 6.1 Guideline The licensee's description should confirm that the program for equipment classification includes criteria and procedures that govern how station personnel use the equipment classification information handling system to determine that an activity is safety-related.
The description should also include the procedures for maintenance, surveillance, parts replacement, and other activities defined in the introduction to 10 CFR 50, Appendix B.
6.2 Evaluation Plant maintenance activities are under the control of work orders.
The MMIS prepares work orders, accessing the component classification database in th~ process.
The component classification printed on the work order is verified by the engineering department.
The classification cannot be changed without a design change package to document the change.
The component classification database can only be changed by the MMIS database management group.
The work performed is done in accordance with station initiated and approved administrative procedures.
These procedures control the work processes, and, the licensee states, adherence to the approved procedures is required.
6.3 Conclusion We find that the licensee's description of plant administrative controls and procedures meets the requirements of this item.
Therefore, we find the licensee's responses for this item acceptable.
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ITEM 2.2. 1.4 - MANAGEMENT CONTROLS 7.1 Guideline The licensee should briefly describe the management controls that are used to verify that the procedures for preparation, validation, and routine utilization of the information handling system have been, and are being, followed.
- 7. 2 Eva 1 uat ion The licensee states that formal procedures control the use of, the review of, and the updating of the MEL.
The licensee also states that a formal engineering verification has been performed.
This verification involved an independent review by separate personnel using approved procedures.
The licensee has replaced the MEL with the computerized MMIS.*
The description of the MMIS discusses similar procedures and verifications.
Validation is on a continuing basis, with the component classification for each work order being verified by the engineering department.
The MMIS prepares the work orders and accesses the component classification database automatically.
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, we find the licensee 1s responses for this item acceptable.
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ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline The licensee's submittals should document that past usage demonstrates that appropriate design verification and qualification testing are specified for the procurement of safety-related components and parts. The specification should include qualification testing for expected safety service conditions and provide support for the 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 states that a revised procurement program provides administrative and management controls that provide for safety-related classification by the nuclear engineering personnel with independent verification by quality assurance personnel.
Personnel training is required in the use of the procurement procedures.
The licensee indicates that both the original and the revised procurement programs contain-procedures that address supplier requirements, such as component qualification and documentation to be supplied by the vendor, including qualification testing;_ Quality Assurance audits verify both the proper component classification and the use of the proper procedures.
8.3 Conclusion We conclude that the licensee has addressed the concerns of this item.
Therefore, we find the licensee's responses for this item acceptable.
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ITEM 2. 2. 1. 6 -
11 IMPORTANT TO SAFETY 11 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 fo Safety." However, since the generic letter does not require the licensee to furnish this information as part of their response, this item will not be reviewed.
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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 these concerns meets the requirements of Generic Letter 83-28 and is acceptable.
Item 2.2. 1.6 was not reviewed as noted in Section 9. 1.
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REFERENCES
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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.
Public Service Electric and Gas Company (PSE&G) letter, E. A. Liden to Director of Nuclear Regulatory Regulation, NRC, "Response to Generic Letter 83-28," July 22, 1983.
- 3.
Letter, PSE&G (R. A. Uderitz) to NRC Region l (R. W. Starostecki),
"Reactor Trip Breaker Failure," March 8, 1983.
- 4.
Letter, PSE&G (R. A. Uderitz) to NRC, "Corrective Action Program Related to Reactor Trip Breaker Failures," March 14, 1983.
- 5.
Letter, PSE&G (R. A. Uderitz) to NRC Region l (R. W. Starostecki),
"Vendor Manual Program," March 23, 1983.
- 6.
Letter, PSE&G (R. A. Uderitz) to NRC (D. G. Eisenhut), "Corrective Action Program Related to Reactor Trip Breaker Failures," April 7, 1983.
- 7.
Letter, PSE&G (R. A. Uderitz) to NRC (D. G. Eisenhut), "Supplement to Corrective Action Program Reactor Trip Breaker Failures," April 8, "1983.
- 8.
Letter, PSE&G (C. A. McNeill, Jr.) to NRC (S. A. Varga), "Request for Additional Information Following Preliminary Staff Review of Licensee Response to Generic Letter 83-28," September 20, 1985.
- 9.
Letter, PSE&G (S. E. Mittenburger) to NRC, "Response to Request for Additional Information, Generic Letter 83-28, Item 2.2.1,"
April 17, 1989, NLR-N89072.
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NRC FORM 335 12-89)
NRCM 1102, 3201, 3202
- 2. TITLE AND SUBTITLE U.S. NUCLEAR REGULATORY COMMISSION BIBLIOGRAPHIC DATA SHEET (SIM instructions on rhe reverse)
CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
SALEM-1/-2
- 5. AUTHOR(SI Alan C. Udy
- 1. REPORT NUMBER
- 3.
(Aalgned by NRC. Add Val., SUpp,, Rov.,
ll'ld Addendum Numbers, if any. I EGG-NTA-7392 DATE REPORT PUBLISHED MONTH June I
YEAR 1989
- 6. TYPE OF REPORT Technical Evaluation Report
- 7. PERIOD COVERED llnclusive Oates/
- 8. PERFORM I NG 0 RGAN IZA TION ~ NAME AND ADDA ESS !If NRC, provide Division, Office or R~lon. U.S. Nucl*ar R"91Jlatorv Commission, and mailing Mid~ss: if contractor. provide n-* and mai/inp Midmss.)
EG&G Idaho, Inc.
P. 0. Box 1625
- Idaho Falls, ID 83415
- 9. SPONSO A I NG 0 RGANI ZA TION - NAME AND ADDRESS !If NRC. type "S*me as abovo": if cont1Xtor. provido NRC Oivilion. Offict1 or R&11ian. U.S. Nucloar R&gulatorv CommiSlion.
and mailing addraa.J Division of Engineering and System Technology Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
- 10. SUPPLEMENTARY NOTES
- 11. ABSTRACT (200 words or less/
This EG&G Idaho, Inc., report provides a review of the submittals from the Salem Generating Station regarding conformance to Generic Letter 83-28, Item 2.2.1. The review concludes that the licensee complies with the requirments of this item.
- 12. KEY WO R DS/D ESCR I PT ORS !List words or ph~* that will assist res*arch*rs in locating the"'"°"* I NRC FORM 335 (2-891
- 13. A\\IAILABILITY STATEMENT Unlimited
- ilic:trihution
- 14. SECURITY CLASSIFICATION IThlsP"!l"i Unclassified (This Repart)
Unclassified
- 15. NUMBER OF PAGES
- 16. PRICE
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