ML19332B580

Conformance to Generic Ltr 83-28,Item 2.2.1,Equipment Classification for All Other Safety-Related Components: La Salle-1/-2, Technical Evaluation Rept

ML19332B580
Person / Time
Site:	LaSalle
Issue date:	09/30/1989
From:	Udy A, Uudy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML19332B581	List: ML19332B580
References
CON-FIN-D-6001 EGG-NTA-7267, GL-83-28, TAC-53684, TAC-53685, NUDOCS 8909260201
Download: ML19332B580 (16)

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EGG-NTA 7267.

L TECHNICAL EVALUATION REPORT r

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COM LA SALLE-1/-2 '

Docket Nos. 50-3.'3/50-374 Alan C. Udy Published September 1989 Idaho Natior,al 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. 06001 i TAC No. 53684/53685  !

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SW9tARY This EG&G. Idaho,.Inc., report provides a review of the submittals from

Unit Nos. I and 2 of the LaSalle County 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 programs.should encompass. This review concludes'that the licenseeLcomplies with-the requirements of this item.

FIN No. D6001 B&R No. 10-19-10-11-3 Docket Nos. 50-373/50-374 TAC Nos. 53684/53685 ii 7'

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i L PREFACE

'l This report _is supplied as part of the program for evaluating licensee applicant conformance to Generic Letter 83-28 " Required Actions l

Based on Generic Implications of Salem ATWS Events." This work is being 4

' - conducted: for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Systems Technology, by EG&G Idaho, Inc.,

Regulatory and Technical Assistance Unit.

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SUMMARY

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-PREFACE .................................................... .......... .

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INTRODUCTION ..................................................... I 2.

REVIEW CONTENT AND FORMAT ........................................ 2 3.

. ITEM 2.2.1 - PROGRAM ............................................. 3 3.1 3.2 .Evaluation Guideline...................

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

3.3 Conclusion .................................................

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

4. - ITEM 2.2.1.1

IDENTIFICATION CRITERIA ........................... 4 4.1. Evaluation 4.2 -Guideline...............

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

4.3 Conclusion ............... .................................

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

Evaluation ................. 5

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

............................... 5 6.-

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

6. l' Guideline ....................

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

6.3 Conclusion .................... ............................

............................ 6 7.

ITEM 2.2.I.4 - MANAGEMENT CONTROLS ............................... 7

~7.1 7.2' Guideline ..................................................

Evaluation .................... 7' 7,3 ......................... 7 Conclusion .................... .... ............................ 8 8.

i ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ............... 9 L 8.1 L 8.2 Guideline ..................................................

Evaluation .................... 9 8.3' 9 E

i Conclusion .................... ............................

............................ 9

-9. ITEM 2. 2.1.6 L

1 "IMPORTANT TO SAFETY" COMPONENTS . . . . . . . . . . . . 10 ......

9.1 Guideline .................................................. 10

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CONCLUSION ....................................................... 11 11.

REFERENCES .......................................................

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

[ EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONE .

LA SALLE-1/-2  ?

1. INTRODUCTION On February 25, 1983, both of the scram circuit breakers at Unit 1 of the Salen Generating Station failed to open upon an automatic reactor trip signal ~ from the reactor protection system. This incident was terminat'ed 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 Sales Generating.

' Station, 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 Generating Station. The results of the staff's inquiry into the h

generic-implications of the Salem-1 incidents are reported in NUREG-1000,

[ Generic Implications of the ATWS Events at the Salem Nuclear Power Plant."

l As a result of this investigation, the Commission (NRC) requested (by 1

Generic Letter 83-28 dated' July 8,1983 ) that all licensees of operating reactors, applicants for an operating license, and holders of construction permits respond to the generic issues raised by the analyses of these two ATWS events.

This' report is an evaluation of the responses submitted by Commonwealth Edison, the licensee for the LaSalle County Station, for Item 2.2.1 of L 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 shoulci 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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3. ITEM 2.2.l'- PROGRAM 3

3.1 Guideline L

' Licensees should confirm that an equipment classification program is in.

L place that will provide assurance that safety-related components are

-designated as safety-related on plant documentation. The program should provide assurance that the equipment classification information handl.ing system is used so that activities that may affect safety-related componerits p

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 L

p are evaluated in the remainder of this report.

3.2 Evaluation The licensee for the LaSalle County Station responded to these requirsments with submittals dated November 5, 1983,2 February 29, 1984,3 June 29, 1989,4 and August 9, 1989.5 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.

L p 3.3 Conclusion We'have reviewed the licensee's information and, in eeneral, find that the licensee's-responses are acceptable.

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a ITEM 2.2.1.1 - IDENTIFICATION CRITERIA j 1

4.1 Guideline l

' The licensee should confirm that their program used for equipment classification includes the criteria used for identifying components as safety-related.

T 4.2. Evaluation L

L The licensee states that'the criteria used to classify structures, systems, components, and parts are contained in the Station Nuclear Engineering Department's quality procedure Q.12, exhibits B and C, in station administrative procedures, and in engineering procedure manuals.

l 4.3 Conclusion ,

The licensee's responses to this item are complete and address the L staff's concern. Therefore, we find the licensee's responses for this item

acceptable.

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i S. ITEM 2.2.1.2

,* INFORMATION HANDLING SYSTEM ,

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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 information handling system (Q-list) consists of listings that are made using computer programs and techniques.

The licenses states that vendor input is used extensively, and that detailed parts lists are generated by computer. These lists are maintained current by Sargent and Lundy in a program under the control of the BWR System Design Section of the Nuclear Engineering Department using Quality Assurance >

procedures.

These procedures are Q.P. 2-53, " Classification of Structures, i

System and Components," Q.P. 3 3, " Classification of System, Components, Parts and Material," Q.P. 3-51, " Design Control for Operations - Plant Modification," and Engineering Procedure Q.12.3, " Control and Maintenance of the Q-list for LaSalle County Station." These procedures require personnel to consult the information handling system to determine if the components are safety-related.

The determination of the classification of parts or materials within components is made by de Technical Staff Supervisor using procedures developed by the Station Noctear En'gineering Department.

L 5.3 Onclusion The licensee's responses describe a system that meets the l recommendations of this item. Therefore, we find the licensee's responses L for: this item acceptable.

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ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLASSIFICATION LISTING l

e 6.1 Guideline

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1 The licensee's description should confim that the program for equipment classification includes criteria and procedures that govern how station personnel use the equipment classification infomation handling l

system to determine that an activity is safety-related. The description a

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 Operating engineers are directed by LaSalle Administrative Procedure LAP-1300-1, " Work Requests," to classify maintenance activities as safety related or nonsafety-related. This same procedure directs work analysts to verify the safety-related classification. The corporate Quality

' Assurance Manual, Quality Procedure 2-53, " Quality Assurance Programs for Operations Classification of Structures, Systems and Components," directs supervisory personnel to the information handling system for the classification of work requests and procurement activities.

Safety-related work requests are said to ensure that safety-related procedures, cautions, and constraints are used, with additional levels of approval and review required. The infomation handling system is said to be used in the development of detailed work instructions.

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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7. ITm 2.2.1.4 MmmT CONTES 7.1 Guideline The' licensee should briefly describe the management controls that are <

7 used to verify that the procedures for the preparation, validation, and routine utilization of the information handling system have been and are being, followed. i i

7.2 Evaluation-The licensee's response to this item states that safety-related work requests receive quality control and quality assurance review and, additionally, that modifications have on-site reviews. The licensee also describes other reviews and audits concerning work being done that verify the utilization of the information handling system.

The following Comonwealth Edison procedures are used in the preparation, maintenance, and validation of the Q-list.

Q.12.3 " Control and Maintenance of the Q-list for LaSalle County i Station"

.Q.P.2-53 " Classification of Structures, System and Components" Q.P.3-3 " Classification of System, Components, Parts and Material" Q P.3-51 " Design Control for Operations - Plant Modification" l!

These procedures provide for audits and inspections whose results L - inform management of the status and performance of the equipment L classification system.

The following Sargent and Lundy instructions and procedures are used in the preparation, maintenance, and validation of the Q-list.

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i1 PI-LSNS-16.

• Processing of Drawing Change Reauests (DCRs)" ,

t PI-LSNS " Preparation and Maintenance of Q-list PI-LSNS-44 l GQ-3.07 "Sargent and Lundy Drawings" The licensee describes how the Q-list is maintained current as plant modifications are made. The above listed procedures are part of the given description that shows how system changes are reflected in the Q-list. .

N 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 responses for this item acceptable.

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' 8. . ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline The licensee's submittals should document that past usage demonstrates l that appropriate design verification and qualification testing are specified  !

for the procurement of safety-related components and parts. The j specification should include qualification testing for expected safety'  !

' service conditior.s and provide support for the licensee's rectipt of testing l

documentation *.o support the limits of life. recommended by the supplier. If such documer.tation is not available, confirmation that the present program meets these requirements should be provided, (

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8.2 Evaluation t

The licensee states that the design criteria of the station nuclear engineering department assure that design verification and qualification  !

tasting is'specified for the procurement of safety-related equipment and components. The licensee states that service conditions and the requirement  !

to identify maintenance schedules to achieve the expected component or part life _are specifled.

i 8.3 Conclusion I 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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• 1 L . ,' , 9. ~ ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS i

9.1 Guideline  ;

1 L Generic Letter 83-28 states that the licensee's equipment l- classification program should include (in addition to the safety-related E

components) a broader class-of components designated as "Important to Sa fety. " 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! )n Based'on our review of the-licensee's response to the specific 1 requirements of-Item 2.2.1, we find that-the information provided by the

' licenses to resolve these-concerns meets the requirements of Generic 3

Letter 83 28 and is acceptable. l Item 2.2.1.6 was not reviewed as noted in i

'Section 9.1.

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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, Commonwealth Edison Company (P. L. Barnes) to NRC (H. R. Denten), " Response-to Generic Letter No. 83-28,"

November 5, 1983.

3. Letter, Commonwealth Edison Company.(P. L. Barnes) to NRC (H. R. Denton), " Response to Generic Letter Nc. 83-28,"

February 29, 1984.

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Letter, commonwealth Edison Company (W. E. Morgan) to NRC, " Response to Request for Additional Information for Item 2.2 (Part 1) of Generic Letter 83-28," June 29, 1989.  !

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Letter, Commonwealth Edison Company (W. E. Morgan) to NRC, " Response to Request for Additional Information for Item 2.2 (Part 1) of Generic letter 83-28," August 9, 1989.

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