ML19332B614

Conformance to Generic Ltr 83-28,Item 2.2.1--Equipment Classification for All Other Safety-Related Components:Quad Cities 1 & 2, Final Technical Evaluation Rept

ML19332B614
Person / Time
Site:	Quad Cities, 05000000
Issue date:	10/31/1989
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML17202G712	List: ML19332B614 ML19332B615
References
CON-FIN-D-6001 EGG-NTA-7299, GL-83-28, TAC-53707, TAC-53708, NUDOCS 8911080309
Download: ML19332B614 (18)

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.4 - ENCLOSURE 3 i o* ,

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EGG NTA 7299 I

TECHNICAL EVALUATION REPORT CONFORMANCE TO CENERIC LETTER 83-28, ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY RELATED COMPONENTS:  :

QUAD CITIES 1/ 2 Docket Nos. 50 254/50 265 i

Alan C. Udy i

Published October 1989 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Under DOE Contract No. DE AC07-761001570 FIN No. D6001 TAC Nos. 53707/53708

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i SUttiARY .

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

the Quad Cities Station, Unit Nos. I and 2, for conformance to Generic Letter 83-28, Item 2.2.1. Item 2.2.1 of Generic Letter 83 28 requires l 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.

FIN No. 06001 B&R 20 19 10 11 3 Docket Nos. 50 254/50-265 TAC Nos. 53707/53708 ii

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PREFACE This report is supplied as part of the program for evaluating ,

licensee / applicant conformance to Generic Letter 83 28 " Required Actions  :

Based on Generic Implications of Salem ATWS Events." This work was ,

conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Systems Technology, by EG1G Idaho, Inc.,

Regulatory and Technical Assistance Unit.

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CONTENTS

SUMMARY

............................................................... 11 PREFACE ............................................................... iii

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

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

3. ITEM 2.2.1 - PROGRAM ............................................. 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. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM ....................... 5 5.1 Guideline .................................................. 5 5.2 Evaluation................................................. 5 5.3 Conclusion ......,.......................................... 5

6. ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLASSIFICATION LISTING ....... 6 6.1 Guideline .....'............................................. 6 6.2 Evaluation ................................................. 6 6.3 Conclusion ................................................. 6

7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS ............................... 7 7.1 Guideline .................................................. 7 7.2 Evaluation ................................................. 7 7.3 Conclusion ................................................. 7

8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ............... 8 8.1 Guideline .................................................. 8 8.2 Evaluation ................................................. 8 8.3 Conclusion ................................................. 8

9. ITEM 2.2.1.6 'IMPORTANT TO SAFETY" COMPONENTS .................. 9 9.1 Guideline .................................................. 9

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

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

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CONFORMANCE TO GENERIC LETTER 83 28. ITEM 2.2.1 -

E0VIPMENT CLASSIFICATION FOR ALL OTHER SAFETY RELATED COMPONENTS:

00AD CITIES 1/-2 l

1. INTRODUCTION On February 25, 1983, both of the scram circuit breakers at Unit 1 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 1 of the Salem 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 Dircctor 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 Staticn. The results of the staff's inquiry into the generic implications of the Salem 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 1

) 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 the Commonwealth Edison Company, the licensee for the Quad Cities Station, Unit Nos. I and 2, 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 the 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  !

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for staff review. Detailed supporting inforination should also be included in the description, as indicated in the guideline section for each item l within this report.  !

l 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 l evaluation of the licensee's response is made; and conclusions about the i programs of the licensee for safety related equipment classification are l 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 related 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 infomation 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 Quad Cities Station, Unit Nos. I and 2, responded to these requirements with submittals dated November 5, 1983,2 February 29, 1984,3 April 3, 1989,4 and October 4, 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.

3.3 C.g.nclusion l 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 l 4.1 Guideline I The licensoe should confirs that their program used for equipment classification includes the criteria used for identifying components as safety related.

4.2 Evaluation The licensee's response states that the criteria used to classify structures, systems, and components as safety related are contained in the Station Nuclear Engineering Department Quality Procedure Q 12,

" Classification and Listing of Safety related Items and ASME Section III Components," exhibits 8 and C. This classifies as safety related any part ,

or component that assures the safety function of a safety related system.

The introduction to the Safety-related Classification List (SRCL) defines safety-related equipment as the equipment required to maintain the primary )

containment pressure boundary, perform a function necessary for safe shutdown, or to conform with 10 CFR 100 guidelines. These sources encompass j the criteria given in the footnote to Section 2.2.1 of the generic letter.

d 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 )

I 5.1 Guideline l

The licensee should confirm that the program for equipment ]

classification includes an information handling system that is used to l identify safety-related components. The response should confirm that this )

information handling system includes a list of safety related equipment and I that procedures exist to govern its development and validation.

5.2 Evaluation The licensee's response states that the SRCL is prepared, validated, maintained, and distributed by the BWR System Design Group of the Nuclear Engineering Department. The SRCL is a computerized database that can only be viewed or printed when an authorized password is used. A single person  !

is responsible for updating the SRCL; the ability to update the SRCL database is controlled by a separate computer password. BWR System Design Group procedures are followed to assure the accuracy of the updated SRCL, which is distributed quarterly.

5.3 Conclusion 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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, 6. ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLASSIFICATION LISTING l

6.1 Guinaline The licensee's description should confirm that the program for equipment classification includes criteria and procedures that govern how  !

station perscnnel use the equipment classification information handling l system to determine that an activity it safety related. The description f should also include the procedures for maintenance, surveillance, parts l replacement, and other activities defined in the introduction to 10 CFR 50,  !

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l 6.2 Evaluation The work request system governs all activities at the Quad Cities Station. Commonwealth Edison's Corporate Quality Assurance Program and station administrative procedures govern the work request system. l Safety related work is classified as such on the work request after consulting the SRCL. If the ivork request is safety-related, Quality Control and Quality Assurance personnel review and approve the work request and its classification prior to the work being started.

r 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 ites acceptable.

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS l I

7.1 Guideline The licensee should briefly describe the management controls that are used to verify that the procedures for the preparation, validation, and

'i routine use of the information handling system have been, and are being, followed, j i

7.2 Evaluation  !

The licensee states that the responsibility for the preparation,  ;

validation, maintenance, and periodic distribution of the Safety related Classification List (SRCL) is assigned to the BWR Systems Design Group.

Quality Assurance audits verify the proper classification of components listed on the SRCL. Quality Assurance also provides surveillance that audits the use of the SRCL in the preparation of work requests and l modification packages. Quality Assurance procedures provide for audits and inspections whose results 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 response for this item acceptable.

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8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT 4.1 Guideline l

I The licensee's submittals should document that past usage demonstrates I 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 the expected safety )

service conditions and provide support for the licensee's receipt of testing i documentation to support the limits of life recommended by the supplier. If j such documentation is not available, confirmation that the present program meets these requirements should be provided.

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8.2 Evaluation )

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The licensee's response specifies that the station nuclear engineering design criteria have been established to ensure that design verification and qualification testing are specified for procured parts and equipment. The l service conditions for which such equipment must be qualified and the requirement to identify maintenance schedules for life-limiting components or parts are also specified in the responses.

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. l l

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9. ITEM 2.2.1.6 'IMPORTANT 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 requirements of Item 2.2.1, we find that the infomation provided by the licensee to resolve these concerns meets the requirements of Generic Letter 83 28 and is ac.ceptable. Item 2.2.1.6, as noted in Section 9.1, was not reviewed.

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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, Connonwealth Edison (P. L. 8arnes) to NRC (H. R. Denton),

" Response to Generic Letter 83 28,' November 5, 1983.

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3. Letter, Commonwealth Edison (P. L. 8arnes) to NRC (H. R. Denton),

" Response to Generic Letter 83 28,* February 29, 1984.

4. Letter, Commonwealth Edison (R. Stols) to NRC (T. E. Murley), " Request  !

for Additional Information on Generic Letter 83 28," April 3,1989. ,

5. Letter, Commonwealth Edison (R. Stols) to NRC (T. E. Murley), " Request for Additional Information on Generic Letter 83-28," October 4,1989, 1

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