ML19327A676

Conformance to Generic Ltr 83-28,Item 2.2.1-Equipment Classification for All Other Safety-Related Components: Cooper, Technical Evaluation Rept

ML19327A676
Person / Time
Site:	Cooper
Issue date:	05/31/1989
From:	Udy A EG&G IDAHO, INC.
To:	NRC
Shared Package
ML19327A677	List: ML19327A676
References
CON-FIN-D-6001 EGG-NTA-7254, GL-83-28, TAC-53663, NUDOCS 8909150139
Download: ML19327A676 (17)

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ATTACHMENT i i

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TECHNICAL EVALVATION REPORT l

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

COOPER I Docket No. 50-298 l

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i Alan C. Udy i

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Published May 1989 Idaho National Engineering Laboratory  !

EG8,G Idaho, Inc. i Idaho Falls, Idaho 8341 5  !

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Prepared for the l U.S. Nuclear Regulator UnderWashington DOE ContractD ho..C.y Comission 20555 DE- AC07-761001570 FIN No. 06001 TAC No. 53663 ,

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SUMMARY

This EG&G Idaho, Inc., report provides a review of the licensee's submittals for the Cooper Nuclear Station regarding conformance to Generic j Letter 83-28, item 2.2.1. Item 2.2.1 of Generic Letter 83 28 recuires l licensees to sebmit a detailed description of their programs for  !

safety-related equipment classificaticn for staff review. It also '

cescribes the guidelines that the licensee's programs should encompass.  ;

This review concludes that the licensee complies with the requirements of this item. l i

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. . FIN No. 06001 ,

B&R 20-19-10-11-3  !

, Docket No. 50-298 TAC No. 53663 11

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[ PREFACE l This report is supplied as part of the program for evaluating I' licensee / applicant conformance to G6neric Letter 83-28, " Required Actions Based on Generic Implications of Salem ATW5 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, Inc., Regulatory and Technical Assistance Unit.

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CONTE NT S

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SUMMARY

............................................................... ii PREFACE ...............................'................................ iii

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

2. R E VI EW CONI E N T AND F ORMAT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2. .

3. I T EN 2 . 2 .1 P R O GR AM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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. I TEM 2. 2.1. 2 - I NF ORMAT ION HANDL I NG S YS TEM . . . . . . . . . . . . . . . . . . . . . . . 5 5.1 Guideline .................................................. 5 5.2 Evaluation ................................................. 5 5.3 Conclusion ................................................. 5

6. ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLAS$1FICAT10N LISTING ....... 6 6.1 Guideline .................................................. 6 6.2 Evaluation ................................ ................ 6 6.3 Conclusion ................................................. 6

7. I TEM 2. 2.1. 4 - M ANAGEMENT CONTROLS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 7.1 Guideline .................................................. 7 7.2 Evaluation .............................................. 7 7.3 Conclusion .............................................. .. .. 7

8. ITEM 2. 2.1.S - DES IGN VER IFICATION AND PROCUREMENT . . . . . . . . . . . . . . . 8 8.1 Guideline .................................................. 8 8.2 Evaluation ................................................. 8

8. 3 Conclusion ................................................. 8

9. ITEM 2. 2.1. 6 "JMPORTANT TO S AFETY" COMPONENTS . . . . . . . . . . . . . . . . . . 9 9.1 Guideline .................................................. 9

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

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

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMP 0hENTS:

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, COOPER

, 1. INTRODUCTION On Februcry 25, 1983, both of the scram circuit breakers at Unit I of the Salem Nuclear Po er Plant f ailed 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 f ailure of the circuit breakers was detemined 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 I of the Salem Nuclear Power Plant. The results of the staff's inquiry into the generic implications of the Salem Unit I 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)

I requested (by Generic Letter 83-28 dated July 8,1983 ) 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 Nebraska Public Power. District, the licensee for the Cooper Nuclear Station, for item 2.2.1 of Generic Letter 83-28. The documents reviewed as a part of this evaluation'is listed in the References (Section 11) at the end of this report.

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2. REVIEW CONTENT AND FORMAT  !

ltem 2.2.1 of Generic Letter 83 28 requests the licensee to submit a ,

description of their programs for safety-related equipment classification i f or staf f review. Detailed supporting information should also be incluceo in the cescription, 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 i 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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3. ITEM 2.2.1 - PROGRAM 3.1 Guideline Licensees should confirm that an equipment classification program is in place that will provide assurance that safety-rclated components art-designated as safety-related on plant documentaticq. The program shculd provide assurance that the equipment classification information handling system is used so that activities that may affect safety-related compor.ents 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 are evaluated in the remainder of this repot't.

3.2 Evaluation l The licensee for the Cooper Nuclear Station responded to these '

2 requirements with submittals dated November 4,1963 and December 28, >

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 are available for audit upon request. '

The licensee states that they are using the equipment data file (EDF) {

as the computerized information handling system referred to. The licensee states that components are designated as essential (safety-related components) or as nonessential within the EDF.

3.3 Conclusion ,

We have reviewed,the, licensee's submittals and find that, in general, the licensee's responses are acceptable. '

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• 4 ITEM 2.2.1.1 - IDENTIFICATION CRITERI A

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b 4.1 Guideline f I i The licensee should confirm that the program used for equipment i classification includes the criteria used for identifying components as

, safety-rclated.

4.2 Evaluation  !

The licensee's response identified the criteria for determining the j safety-related status of components. The criteria are contained in the licensee's Quality Assurance Instruction QAl-9, " Guidelines for Establishing Quality Classifications of Components and Materials." The criteria are also stated in the licensee's Administrative Procedure 1.11

" Requisitioning, Receiving, and Storage of Essential Parts and Components," ,

and in Engineering Procedure 3.13. " Equipment Classification." The criteria are consistent with the staff position footnoted in Section 2.2 of

• the generic letter. '

4.3 Conclusion The licensee's responses to this item are complete and address the I staf f's concerns. Therefore, we find the licenste's responses for this 'f item acceptable.

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5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM l l

5.1 Guiceline l The licensee should confirm that the program for equipment  ;

classification includes an informPtion handling system that is used to  ;

identify safety-related components. The response should confirm tha'. 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 EDF as the computeri2ed index '

that identifies safety-related components. The EDF is one portion of the plant equipment management system that is used in the operation and i

maintenance of plant equipment and in the procurement of spare parts. The description includes the methods used for the rievelopment and validation of the EDF; the process by which new safety-related items are entered into the  ;

EDF; how changes in classification of listed items are made; and how listed items are verified. The licensee stater that the EDF is electronically accefasible by other portions of the plant equipment management system, and thus is a single, official, consistent, and unambiguous document.

5.3 Conclusion i

The licensee's responses describe a system that meets the recomendations of this item. Therefore, we find the licensee's responses  ;

for this item acceptable.

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g 6. ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLAS5!FICATION LISTING

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6.1 Guideline -

ine licer,see's cescription should confirm that the program f or I equipment classification incluces criteria and procedures that govern how station personnel use the equipment classification information handling ~!

system to cetermine that an activity is safety-related. The description should also i.iclude 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 B.

l 6.2 Evaluation The licensee states that the plant equipment management system, which uses the EDF as its database, generates the forms needed for the above activities. Reviews and approvals of these forms refer to the EDF for  ;

equipment classification as part of the review process. Thus, this list is i consulted before any maintenance, testing, design changes, engineering support, setpoint changes, or special tests or studies are initiated.

6.1 Conclusion '

We find that the licensee's description of plant administrative controls and procedures meets tre requirements of this item. Therefore, we find the licensee's responses fo- this item acceptable.

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROL S f i

7.1 Guideline 1

The licensee should briefly describe the management controls that are uset to verify that the procedures for preparation, validation, and the  !

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

l 7.2 Evaluation The licensee states that the EDF was developed using Procedure QAl-9 t

and Administrative Procedure 1.11, and that it is updated in accordance '

with Aaministrative Procedure 1.13. These procedures provide management controls for these activities. The EDF is a part of the plant equipment management system; therefore, the EDF is used routinely in the preparation

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of maintenance work requests and work item tracking forms, spare parts t

inventory, and purchase orders.

i Review and approval of these forms by maintenance, operations, quality !

control, and engineering assure that the EDF is being maintained current,  !

contains valid data, and is being used as intended. .

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7. 3 Conc lusion .

i We find that the manegement controls used by the licensee assure that the information handling system is maintained, is current, and is used as I intended. Therefore, we find the licensee's responses for this item i acceptable. '

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

The licensee's submittals should document that past usage demonstrates c 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 reconenended 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 di$ cusses Plant Services Procedure 1.4, " Requisitioning,"

in Reference 3 This procedure specifies the requirements for the procurement of parts. The licensee states that this procedure imposes the requirements of 10 CFR 50, Appendix B, and ANSI N45.2 on the supplier. The  !

procedure is also said to detail the documentation required to precede or i to accompany the shipment. In addition, the licensee audits vendor test programs and f acilities.

8.3 Conc lusion .

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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9. ITEM 2.2.1.6 "lMPORTANT TO SAFETY" COMPONENTS

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9.1 Guideline  :

Generk Letter 83 28 states thtt the licensee's equipment [

[ classification program shonld include (in addition to the safety-related .

l. components) a broacer class of components designated as "!mportant to l I^

$4fety." However, since the generic letter does not require the licensee l to furnish this information as part of their response, this item will not {

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4 lesed on our review of the licensee's response to the specific I F, - requirements.uf ltem,2.2.1, we find that the information provideo by the l t' licensee to resolve these concerns meets the requirements of Generic Letter 83 28 and is acceptable. ltem 2.2.1.6 was not' reviewed. As noted in

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11. REFERENCES

• i l 1. Letter, NRC (D. G. Eisenhut) to all Licensees of Operating Reactors.

i Applicants for Operating License, ano Holders of Construction Permits,

" Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83 28)," July 8, 1983.

2. Letter', Nebraska Public Power District (L. G. Kunal) to NRC (D. G. Eisenhut), " Response to Generic Letter 83-28," Required Actions Based on Generic Implications of Setem ATWS Events," November 4,1983, f

3. Letter, Nebraska Public Power District (G. A. Trevers) to NRC, L

" Generic Letter 83 28, Item 2.2," December 28, 1988, CNS$886447 L e

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