ML19327A674

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Conformance to Generic Ltr 83-28,Item 2.2-1, `Equipment Classification for All Other Safety-Related Components: Clinton,' Technical Evaluation Rept
ML19327A674
Person / Time
Site: Clinton Constellation icon.png
Issue date: 05/30/1989
From: Udy A
EG&G IDAHO, INC.
To:
NRC
Shared Package
ML19327A675 List:
References
CON-FIN-D-6002 EGG-NTA-7216, GL-83-28, NUDOCS 8909140269
Download: ML19327A674 (16)
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EGG-NTA-7216 TECHNICAL EVA!.UATION REPORT i CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1-- ,

EQUIPMENT CLASSIFICATION CLINTON FOR ALL OTHER SAFETY-RELATED l

1 Docket No. 50-461 -

Alan C. Udy n

h Published May 1989 Idaho National Engineering Laboratory EGbG Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-761001570 FIN No. D6002 TAC No. 63077 se=- -

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SUMMARY

r This EG&G Idaho, Inc., report provides a review cf the licensee's f

submittals for the Clinton Power Station for conformance to Generic Letter 83-28, Item 2.2.1. l Item 2.2.3 of Generic Letter 83-28 requires licensees l

and applicants to submit a detailed description of their programs for ,

i safety-related equipment classification for staff review. It also describes guidelines that the licensee's or applicant's programs should

-encompass.

The review concludes that the licensee complies with the requirements of this item.  !

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FIN No. D6002 i B&R No. 20-19-40-41-3  ;

Docket No. 50-461 i

! TAC No. 63077 I

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PREFACE This report is supplied as part of the program for evaluating licensee /appitcant 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 Engineering and System Technology, by EG&G Idaho, Ir.c., Regulatory and Technical Assistance Unit.

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c CONTENTS

SUMMARY

............................................................... 11 ,

PREFACE ............................................................... 111 i i

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INTRODUCTION ..................................................... 1 2.

R Ev! E( CONTENT AND FO RMAT . . . . . . . . . . . . . . . . . . .2 . . . . . . . . '

3. ,

ITEM 2.2.1 - PROGRAM ............................................. 3 f

i 3.1 3.2 Guideline ..................................................

Evaluation ................ 3 s

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

................................ 3

4. .

ITEM 2.2.1.1 - IDENTIFICATION CRITERIA ........................... 4 '

4.1 4.2 Guideline ..................................................

Evaluation ............... 4  ;

4.3 Conclusion ............... ................................. 4 i

................................. 4

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ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM ....................... 5 5.1 5.2 Guideline ..................................................

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

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6.

ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLASSIFICATION LISTING 6 ...

6.1 6.2 Guideline ..................................................

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

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7.

ITEM 2.2.1.4 - MANAGEMENT CONTROLS ...............................7 7.1 7.2 Guideline ..................................................

Evaluation .................. 7 -

1.3 Conclusion .................. ..............................

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8. l ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ............... 8 8.1 8.2 Guideline ..................................................

Evaluation ................... 8

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8.3 Conclusion .................................................

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9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS .................. 9  !

9.1 Guideline ..................................................

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CONCLUSION ....................................................... 10 i 11.

REFERENCES ....................................................... 11 1

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., CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1-- ,

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMI CLINTON '

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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 teminated i 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.

l 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 Unit 1 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 I ) all licensees of '

operating reactors, applicants for an operating license, and holders of construction permits to l'espond to the generic issues raised by the i analyses of these two ATWS events.

This report is an evaluation of the responses submitted by the Illinois Power Company, the licensee for the C1tnton Power Station, for Item 2.2.1 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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,, 2. -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.I 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  ;

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drawn. '

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3. ITEM 2.2.1 - PROGRAM  !

3.1 Guideline i i

t Licensees should confirm that an equipment classification program is in place that will provide assurance that safety-related components are i designated as safety-related on plant documentation. The program shcold provide assurance that the equipment classification information handling f

system is used so that activities that may affect safety-relatec components l

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 guided by, safety-related procedures and constraints.

Licensee responses that address the features of this program j are evaluated in the remainder of- this report.

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3.2 Evaluation The licensee for the Clinton Power Station responded to these requirements with submittals dated October 1, 19842 and May 27, 1988.3 '

These submittals describe the licensee's 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 is developing a computerized Master Equipment List '

(MEL). The MEL consolidates the original General Electric Master Parts List, Sargent & Lundy component listings and design documentation, and the Final Safety Analysis Report (FSAR). The above documents have been controlled through procedures by the responsible organization. The l Itcensee describes an interim system of consulting both the MEL and the originating documentation should the MEL not have the component in question in the database.

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

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ITEM 2.2.1.1 - IDENTIFICATION CRITERIA '

- I 4.1 Guideline +

' The licensee should confirm that the program used for equipment '

classification includes criteria used for identifying components as safet) related.  ;

i 4.2 Evaluation The licensee states that the criteria for identifying safety-related equipment and components are given in Section 3.2 of the Clinton Power Station FSAR. The licensee has three safety classifications identified in

  • Section 3.2.3 of the FSAR. These classifications encompass the staff position footnoted in Section 2.2 of the generic letter. The criteria are i used as part cf the component classification review performed by the '

nuclear station engineering department. Component classifications are '

reviewed by the quality assurance department. '

4.3 Conclusion '

The licensee's response to this item is complete and addresses the '

staff's concerns. Therefore, we find the licensee's responses for this '

item acceptable.

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,. ITEM 2.2.I.2 - INFORMATIDN HANDLIhG 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 states that the GE Master Parts List and the Sargent & Lundy component listings werel e'ectronically transferred into the MEL database.

The licensee states that procedures were, and are beir.g .

followed in the develcpment of the MEL database. Validation will be by physical system walkdowns, documentation searches, and component classification design document research. Changes to the reference documents in the MEL database flag the MEL of the change via the Design System Status database.

This electronic notification allows the MEL group ,

to review the revised document and to update the MEL database if necessary.

The licensee also states that database security is provided to prevent unauthorized entry of data into the MEL. '

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The licensee's responses describe a system that meets the recommendation's of this item. Therefore, we find the licensee's 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 detemine that an activity is safety-related. The description should also include the procedures for maintenance, surveillance, parts replacement, and other activities applicable to safety-related components, as defined in the introduction to 10 CFR 50, Appendix 8.

6.2 Evaluation The licensee states that procedures, maintenance work requests, and spare parts procurement are classified as safety-related or

  • nonsafety-related. Plant and engineering department staff review the classification to detcrmine the acceptability of the classification according to procedures. The MEL database, as part of the Power Plant 1

Maintenance Planning System (PPMPS), is used in the generation of  !

maintenance work requests (MWRs) that automatically provide the safety-related classification of components on the MWR.

t 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 licensea's response 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 '

use of the information handling system have been, and are being, followed.

7.2 Evaluation The licensee describes the managerial controls that are applied to assure that the MEL database has been properly prepared, that its contents have been validated, that it is being maintained current, and that it is (

i being used to determine equipment classification as intended. These ,

controls include electronic notification of modifications by the Design .

Status System database, security over the database to prevent unauthorized changes, system walkdowns and documentation searches, and internal and external audits. These audits are reviewed by the quality assurance department and management reviews. The MEL database.is used by the PPMPS '

.in the preparation of MWRs, which control all plant maintenance and repair activities. ,

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's response for this item acceptable, i

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ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline The 11c'ensee's submittals should document that past usage demonstrate that appropriate design verification and qualification testing are specified for procurement of safety-related components and parts. The specification should include qualification testing for the expected safety-service conditions and shculd provide support for the licensee 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 response states that auditable documentation exists in support of the licensee's procurement, design verification, and qualification testing specifications.

8.3 Conclusion f

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We conclude that the licensee has addressed the concerns of this Therefore, we find the licensee's response for this item acceptable.

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,, 9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS 9.1 Guideline Generic Letter 63-28 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 sa fe ty. " 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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10. CONCLUSION I 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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11. REFERENCES q

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Letter, NRC (O. G. Eisenhut) to all Licensees of Operating Reactors,

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Applicants for Operating License and Holders of Construction Permits. l

" Required Actions Based on Generic Implications of Salem ATW$ Events I

(Generic Letter 83-28)," July 8,1983.

2. i Letter,1111nois Power Company (F. A. Spangenberg, III) to NRC, "NRC Generic Letter 83+28, salem ATWS Events," October 1, 1984. U-0743, i

N85-84(10-01)L,1A.120.

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Letter Illinois Power Company (F. A. Spangenberg, III) to NRC,

" Request for Additional Information - Generic Letter 83-28," May 27, 1988,U-601200,L30-88(05-27)-LP,1A.120. '

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EG4G Idaho. Inc.

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Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington DC 20555 10 sv8PLewsNtaRY worts i t. aest R AC T tMs e . a ,

f This EG4G Idaho. Inc.. report provides a review of the submittals from the Clinton Power Station regarding conformance to Generic Letter 83-28. Item 2.2.1. i The item.

review concludes that the licensee complies with the requirements of this '

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