ML19332B584

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Conformance to Generic Ltr 83-28,Item 2.2.1-Equipment Classification for All Other Safety-Related Components: Harris, Technical Evaluation Rept
ML19332B584
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 09/30/1989
From: Udy A
EG&G IDAHO, INC.
To:
NRC
Shared Package
ML18009A280 List:
References
CON-FIN-D-6001 EGG-NTA-7360, GL-83-28, TAC-64510, NUDOCS 8910060010
Download: ML19332B584 (19)
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TECHNICAL EVALVATION REPORT CONFORMANCE TO GENERIC LETTER 83 28, ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

HARRIS Docket No. 50 400 '

i Alan C. Udy Published September 1989 l

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-AC07-761001570 FIN No. D6001 TAC No. 64510 empaR#4

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SUMMARY

This EG1G Idaho, Inc., report provides a review of the submittals from

![ the Shearon Harris Nuclear Power Plant for the 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 licensee complies with the requirements of this item.

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FIN No. 06001 B&R 20-19-10 11-3 Docket No. 50 400 TAC No. 64510 ii

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PREFACE i

This report is supplied as part of the program for evaluatiag licensee / applicant conformance to Generic Letter 83 28. " Required Actions

Based on' Generic Implications of Salem ATWS Events." This work is being l
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, l'

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CONTENTS L

SUMMARY

.............................................................., 11 PREFACE ............................................................... iii l 1,

l INTRODUCTION ..................................................... 1

[ 2. REVIEW CONTENT AND FORMAT ....................................... 2 i 3. ITEM 2.2.1 PROGRAM ............................................. 3

! 3.1 Guideline .................................................. 3

! 3.2 Evaluation............................................ 3 l

g 3,3 Conclusion ...................................................... 3 i

j. 4 ITEM 2.2.1.1 IDENTIFICATION CRITERIA ........................... 4 4.1 Guideline .................................................. 4 4.2 Evaluation ............................................ 4 4.3 Conclusion ............................................ .... .... 4
5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM ....................... 5 5.1 Guideline .................................................. 5 5.2 Evaluation ............................................ 5 5.3 Conclasion ............................................ .... .... 6 6.- ITEM 2.2.1.3 USE OF THE EQUIPMENT CLASSIFICATION LISTING ....... 7 6.1 Guideline .................................................. 7 6,2 Evaluation ................................................. 7 6.3 Conclusion ................................................. 7
7. ITEM 2.2.1.4 MANAGEMENT CONTROLS ............................... 8 7.1 Guideline .................................................. 8 7.2 Evaluation ................................................. 8 7.3 Conclusion ................................................. 8
8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ............... 9 8.1 Guideline .................................................. 9 8.2 Evaluation ................................................. 9 8,3 Conclusion ................................................. 9
9. ITEM 2.2.1.6 "lMPORTANT TO SAFETY" COMPONENTS .................. 10  ;

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

10. CONCLUSION ....................................................... 11
11. REFERENCES ....................................................... 12  ;

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

E0VIPMENT CLASSIFICATION FOR ALL OTHER SAFETY RELATED COMPONENTS:

l HARRIS

1. INTRODUCTION On February 25, 1983, both of the scram circuit breakers at Unit I 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 af ter 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 Generating r -

Station, an automatic trip signal was generated based on steam generator low low level during plant startup.- In this case, the reactur was tripped manually by the operator almost coincidentally with the automatic trip.

Following these incidents, on February 29, 1983, the NRC Executive Director for Operations (ED0) 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 generic implications of the-Salem 1 incidents are reported in NUREG 1000,

" Generic !mplications 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 ) 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 Carolina Power and Light Company, the licensee for the Shearon Harris Nuclear Power Plant, for item 2.2.1 of Generic Letter 83 28. The documents reviewed as a f

, 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 classif.ication -

-for staff review. . Detailed supporting information should also be included U in the description, as indicated in the guideline section for each-item C

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-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 V drawn.

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ITEM 2.2.1 - PROGRAM

[ 3.1 Guideline p

Licensees should confirm that an equipment classification program is in f

place that will provide assurance that safety related components are designated as safety related on plant documentation. The program should.

f. provide. assurance that the equipment classification information handling 6

l system is used so that activities that may affect safety-related components e<

o are designated safety-related. By using the information handling system, L personnel are made aware that they are working on safety-related components

, and are directed to, and are guided by, safety-related procedures and It constraints. -Licensee responses that address the features of this program.

E are' evaluated in the remainder of this report.

3.2 Evaluation The licensee for the Shearon Harris Nuclear Power Plant responded to

~these requirements with submittals dated' November 7, 19832, May 31, 198T,3 and August 24, 1989.4 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 auditLupon. request.

3.3 Conclusion We have reviewed the licensee's submittals and find that the licensee's program is. acceptable, as indicated in the following sections.

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4. ITEM 2.2.1.1 - IDENTIFICATION CRITERIA 4.1 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 ANSI N18.2-1973,

" Nuclear Safety criteria for the Design of Stationary Pressurized Water Reactor Plants," and ANSI N18.2a-1975, " Revision and Addendum to Nuclear L

Safety Critaria for the Design of Stationary Pressurized Water Reactor ,

~ Plants," 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.

i 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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5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM L

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 i information handling system includes a list of safety-related equipment and

'that. procedures exist to govern its development and validation.

I 5.2 Evaluation The licensee describes the Equipment Data Base System (EDBS) as the information handling system referred to. The Nuclear Engineering Department (NED) has the responsibility for implementing'and maintaining the safety-related component. status in the EDBS ouality classification field.

This responsibility is designated by Plant Program PLP-602, " Equipment Data Base," and is discharged in accordance with Nuclear Engineering Department g Guideline E 22, "NED Preparation and Control of Component Level Q-List."

The licensee describes how the component quality classification is determined.in'accordance with NED Guideline E-22. The licensee states that the, classification determination is verified prior to its entry into the EDBS; Further, the-licensee states that E-22 is being revised to procedurally provide for the verification of the data base entries as

,e required by PLP-602.

E Access to the quality classification field is controlled by use of the corporate data security system to permit only authorized individuals to enter or alter the classification data. The licensee states that any data entry produces an auditable trail that provides a mechanism to aid in the

. verification of data entry.

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The EDBS is accessed by the Automated Maintenance Management System (AMMS)- for use by maintenance personnel and by the Corporate Material Management System for component procurement.

5.3 Conclusion Th'e_ licensee's responses describe a system that meets the recommendations of this item. Therefore, we find the licensee's responses -

for this item acceptable.

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

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 i

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.- i 6.2 Evaluation The licensee states-that Work Requests and Authorizations (WR&A) are the controlling mechanism for planning and implementing maintenance, surveillance, and testing activities. The WR&A is prepared by the Automated Maintenance Management System (AMMS). The AMMS is linked to the EDBS, which automatically inserts the safety-related. status of the equipment onto the WR&A'.

Personnel can also-query the EDBS for engineering reviews or for component replacements. This access is controlled by the corporate data security system, so that only personnel whose work requires access to the EDBS are able to1 access the information.

6.3 Conclusion

. We find that. the licensee's descr.iption of plant administrative controls and procedures meets the requirements of this item. Therefore, we l'

find the licensee's responses for this item acceptable.

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS' I ,

P 7.1 Guideline  ;

F The licensee should briefly describe the management controls that are used to verify that the procedures for the preparation, validation, and routine utilization of the information handling system have been, and are being. followed.-

7.2 Evaluation The licensee uses programmatic and procedural requirements as the management controls for this item. The licensee states that a auditable  ;

data trail is generated when safety-related data is entered into the Quality Classification field of the'E0BS.- WR&A forms automatically use the EDBS information when prepared, and are approved by management. Quality Assurance audits and surveillance also-inform management of the status and performance of the equipment classification program.

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  ;

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8.1 Guidelin,3

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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 compon'ents and parts. The '

specification should include qualification testing for the 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's procurement of safety-related components and parts is controlled by Procedure PMC-001, 4rocurement and Cataloging of Parts,

'M'aterials, Equipment, and Services:," The Engineering Technical Support

, -Group determines the technical and quality assurance requirements in accordance with Procedure.TMM 104, " Determination cf Technical and QA-Requirements for Procurement Documents." Engineering reviews are conducted  !

in a. systematic manner to' include testing and test document requirements.  ;

The EDBS is also coordinated with the Corporate Material Management System ,

to aid in-the preparation of procurement documents.

l< 8.3 Conclusion L

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 "!MPORTANT TO. SAFETY" 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 to 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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10. CONCLUSION

- Based on our review of the' licensee's response to the specific l requirements ~of Item 2.2.1, we find that the information provided by the 111censee to' resolve these con'cerns 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 1, Letter, NRC (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,-Carolina Power & Light Company (A. B. Cutter) to NRC ,,

(D. G. Eisenhut), " Generic Implications of Salem ATWS Events, November 7, 1983, Serial LAP-83-516,

3. - -Letter, Carolina Power.& Light Company (S. R. Zimmerman) to NRC (H. R. Denton), " Generic Letter 83-28. Request for Additional Information Responses," May 31, 1985, Serial NLS 85-186.
4. Letter, Carolina Power & Light Company (L. I. Loflin)'to NRC, " Generic Letter 83 28 Item 2.2.1," August 25, 1989, Serial NLS-89-227. ,

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