ML19332B617

Conformance to Generic Ltr 83-28,Item 2.2.1--Equipment Classification for All Other Safety-Related Components: South Texas-1/2.

ML19332B617
Person / Time
Site:	South Texas
Issue date:	11/30/1989
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML19332B618	List: ML19332B617
References
CON-FIN-D-6002 EGG-NTA-7395, GL-83-28, TAC-63486, NUDOCS 8911090039
Download: ML19332B617 (17)

Text

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i EGG-NTA-7395 November 1989 TECHNICAL EVALUATION REPORT g

CONFORi%NCE TO GENERIC LETTER 83-28,

/daho ITEll 2.2.1--EQUIPMENT CLASSIFICATION FOR ALL Nat/onal OTHER SAFETY-RELATED COMPONENTS: SOUTH TEXAS-1/-2 Engineering Laboratory Managed Alan C. Udy by the U.S.

Department ofEnergy d

Prepared for the l4EGnB~ U.S. NUCLEAR REGULATORY COMMISSION W

No. M AC07 MID01570 t

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EGG NTA 7395

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY RELATED COMPONENTS:

SOUTH TEXAS 1/-2 ,

Docket Nos. 50-498/50-499 Alan C. Udy Published November 1.989 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 AC07-761 DOI 570 FIN No. D6002 TAC No. 63486

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SUMMARY

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This EG&G Idaho, Inc., report provides a review of the submittals from i the South Texas Project Electric Generating 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 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. D6002 8&R No. 20-19-40-41-3 Docket Nos. 50 498 and 50-499 TAC No. 63486 11-

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i 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 is being 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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i CONTENTS

SUMMARY

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iii e PREFACE ............................................................... ,

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1. INTRODUCTION ..................................................... I 1

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

3. ITEM 2.2.1 - PROGRAM ............................................. 3 )

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. 3.1 G u i d el i n e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3 i 3.2 Evaluation ..................................................

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

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

4 4.1 G u i d el i n e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4 4.2 Evaluation ..................................................

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

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5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM ....................... 1 5

5.1 Guideline ...................................................

5 5.2 Evaluation ..................................................

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

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

6 6.1 G u i d el i n e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

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

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS ................................

7 l 7.1 G u i d el i n e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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!. 7.2 Evaluation..................................................

7 7.3 Conclusion..................................................

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8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ............... .

8 8.1 Guideline ...................................................

8 8.2 Evaluation ..................................................

8 8.3 Conclusion ..................................................

9 l 9. ITEM 2.2.1.6 "IMPORTANT-TO SAFETY" COMPONENTS ..................

9 l 9.1 Guideline ...................................................

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10. C ON C L U S I ON . . . . . . . . . . . . . . . . . . . . . . . . ' ' " " ' ' '

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

EOUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY RELATED COMPON ENTSi SOUTH TEXAS-1/-2  !

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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.  ;

I Following these incidents, on February 28,.1983, the NRC Execu'tive Director for Operations (EDO) directed the NRC staff to investigate and l report on the generic implications of these occurrences at Unit 1 of the l i

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

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

j Generic Letter 835 28, dated July 8,1983I ) that all licensees of operating

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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 Houston Lighting and Power Company, the licensee for the South Texas Project s Electric Generating 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 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 2.2.1 is evaluated in a separate section in which the guideline is presented, an evaluation of licensee's response is made; and conclusions about the programs df 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-related components are designated 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 information handling system, l personnel are made aware that they are working on safety-related components L and are directed to, and are guided by, safety related procedures and constraints. Licensee responses that address the features of this program f are evaluated in the remainder of this report. ,

1 3.2 Evaluation The licensee for the South Texas Project Electric Generating Station, Unit Nos. I and 2, responded to these requirements with submittals dated June 28, 1985,2 November 4, 1986,3 and October 26, 1989.4 These submittals describe the safety-related equipment classification program. In the review of the licensee's response to this item, it was assumed that the l

L information and documentation supporting this program is available for audit .

upon request.

3.3 Conclusion 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 ,

4.1 Guideline The licensee should confirm that their program used for equipment

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i classification includes the criteria used for ide.ntifying components as safety-related.

4.2 Evaluation The licensee's response states that the classification criteria used to -

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determine whether a structure, system, or component is safety-related are contained in ANSI N18.2a-1975. This is stated to be compatibit with the requirements of Regulatory Guide 1.26. The classification criteria for all other non-mechanical components are found in the Final Safety Analysis i Report-(FSAR), Section 3.2. These sources encompass the criteria given in  ;

the footnote to Section 2.2.1 of the generic letter.

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 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 I

l The licensee states that the Total Plant Numbering System (TPNS) identifies the safety (quality) class of plant equipment. The TPNS number j is uniquely assigned to each safety-related component. The TPNS number and the associated equipment are identified in the Material Labor Control System (MLCS) database. The TPNS is controlled by the Support Engineering Department, as established by South Texas Project Electric Generating Station (STPEGS) specification 9A010GS1001, and implemented by support i

engineering procedures.

The MLCS database is electronically linked to the Master Equipment Database (MED). The MED is updated from the MLCS database and is ,

5 essentially a subdocument database to the MLCS database. The MED is used for maintenance planning; the unique TPNS number has a unique identifier that identifies the safety class of the component.

The licensee states that a Master Parts List (MPL) is under development aid will be implemented in 1992. Procedure IP-3.23Q, " Master Parts List,"

governs the development and validation of the MPL.

5.3 conclusion The licensee's responses describe a system that meets the requirements 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 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 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.

6.2 Evaluation The licensee states that written instructions are required for plant activities, and procedures provide instructions to plant personnel for assigning a safety classification to maintenance work requests and operating, maintenance, and surveillance procedures. Preventive maintenance and maintenance work requests utilize the MED along with the TPNS to determine if a component is quality-related. All safety-related components are quality-related. The plant personnel using the work instruction are aware of the significance of the TPNS number designation. Procedures OPGP03-ZM-0002, " Preventive Maintenance Frogram," and OPGP03, " Work Process I Program," govern the activities of the plant staff. The requestor of

..- contractor work must identify the safety class of the components in the -

Contractor Work Request (CWR) form, as required by procedure OPGP03-ZE-0034,

" Contractor Work Request Program."

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. ITEM 2.2.1.4 - MANAGEMENT CONTROLS 1

7.1 Guideline i

The licensee should briefly describe the management controls that are l used t'o verify that the procedures for the preparation, validation, and i routine utilization of the information handling system have been, and are )

being, followed.

7.2 Evaluation The licensee's response states that procedures regarding equipment ,

classification tnd related documentation are subject to regular audits. Any deficiencies noted during these audits require corrective action and are ,

identified to appropriate levels of management.

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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- . l 8.- ITEM 2'.2.1.5 - DESIGN VERIFICATION AND FROCUREMENT l 8.1 ' Guideline l

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 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 ' response states that technical requirements, including appropriate casign verification and qualification testing, are specified for the procurement of safety-related components. Any new equipment, spare parts, mater'al, c" services are required to have quality requirements greater than rt a al to the original. The licensee has established an Equipment Qualir '<rtion Program to assure that safety related electrical and mechanical equipment and replacement equipment are environmentally and seismically qualified for the specified safety-service conditions and functions in accordance with NRC guidelines.

,3 8.3 Conclusi2A We conclude that the licensee has addressed the concerns of this item.

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 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. CONCLL'310N Based on our review of tha licensee's response to the specifi c

-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, 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 Rehetors, 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, Houston Lighting and Power Company (J. H. Goldberg) to NRC (H. L. Thompson, Jr.), " Response to NRC Generic Letter 83-28, ' Required Actions Based on Generic Implications of Salem ATWS Events',"

- June 28, 1985, ST-HL-AE-1274, File No: G3.8. l

3. Letter, Houston Lighting and Power Company (J. H._Goldberg) to NRC (H. L. Thompson, Jr.), " Revised Response to Generic Letter 83-28,

' Required Actions Based on Generic Implications of Salem ATWS Events' y (Section 2.2.1.2 only)," November 4,1986, ST-HL-AE-1776, File No.: G3.8. l l

o 4. Letter, Houston Lighting and Power Company (S. L. Rosen) to NRC, "NRC I Generic Letter 83-28, Action Item 2.2.1, ' Equipment Classification and l Vendor Interface (Programs for all Safety-Related Components)',"

! October 26, 1989, ST-HL-AC-3187, File No.: G03.06.

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