ML20058K103

Conformance to Generic Ltr 83-28,Item 2.2-1 - Equipment Classification for All Other Safety-Related Components, Turkey Point-3/-4, Technical Evaluation Rept

ML20058K103
Person / Time
Site:	Turkey Point
Issue date:	05/30/1989
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML17348A492	List: ML20058K103
References
CON-FIN-D-6001 EGG-NTA-7411, GL-83-28, TAC-53726, TAC-53727, NUDOCS 8909140274
Download: ML20058K103 (15)

Text

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ENCLOSURE 2 EGG-NTA-7411 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28 ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMP TURKEY POINT-3/-4 Docket Nos. 50-250/50-251 Alan C. Udy Published May 1989 i

Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 l

Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under 00E Contract No. DE-AC07-761001570 FIN No. 06001 TAC Nos. 53726/53727 p .

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SUMMARY

This EG&G Idaho, Inc., report provides a review of the licensee's ' I submittals for Turkey Point, Unit Nos. 3 and 4. regarding conformance to Generic Letter 33-28, Item 2.2.1, and finds them acceptablo for this item, l

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B&R No. 20-19-10-11-3 FIN No. 06001 Docket Nos. 50-250/50-251 TAC Nos. 53726/53727 11 4.

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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 is being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear i Reactor' Regulation, Division of Engineering and System Technology, by '

EG&G Idaho, Inc., Regulatory and Technical Assistance Unit. I l

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CONTENTS '

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SUMMARY

............................................................... 11 PREFACE ............................................................... 111 -

1.

INTRODUCTION ..................................................... 1 2.

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

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3, .

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

Evaluation .................. 3 3.3 Conclusion .................. ..............................

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4.

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

4.1' 4.2 Guideline ..................................................

Evaluation .............. 4 -

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

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

Evaluation .............. 5 l 5.3 Conclusion .............. .................................. 5 t

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ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLASSIFICATION 6LISTING .

6.1 6.2 Guideline ..................................................

Evaluation .............. 6 l 6.3 Conclusion ,,,........... .................................. 6

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ITEM 2.2.1.4 - MANAGEMENT CONTROLS ............................... 7 7.1 7.2 Guideline ..................................................

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

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

8.1 8.2 Guideline ..................................................

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

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

10. -CONCLUSION ....................................................... 10 11.

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

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

EQUIPMENT CLAS$1FICATION FOR ALL OTHER SAFETY-RELATED COMP!

' TURKEY POINT-3/-4

1. INTRODUCTION I On February 25, 1983, both of the scram circe. breakers at Unit 1 of the Salem Nuclear Power Plant 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 (

aute.matie trip signal.

The failure of the circuit breakers was determined to be reisted to the sticking of the undervoltage trip attachment. Prior i 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.

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Following these incidents, on February 28, 1983, the NRC Executive Director for Operations (EDO), directed the NRC staff to investigate and j

report on the generic implications of these occurrences at Unit 1 of the '

3 Salem Nuclear Power Plant. The results of the staff's inquiry into the generic implications of the Salem Unit 1 incidents are reported in i

NUREG-1000, " Generic Implications of the ATWS Events at the Salem Nuclear Power Plant."

I As a result of this investigation, the Commission (NRC) requested (by Generic Letter 83-28 dated July 8,1983 1

) 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 Florida Power & Light Company, the licensee for Turkey Point, Unit Nos. 3 and 4, for Item 2.2.1 of Generic Letter 83-28. The document reviewed as a part.of 4

this evaluation is 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 pteviously 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 2.2.1 - PROGRAM 3.1 Guideline i i

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 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 report.

l 3.2 Evaluation The licensee for Turkey Point, Unit Nos. 3 and 4, responded to these requirements with submittals dat=6 November 8, 19832 and April 17, 1987.3 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 is available for audit upon request.

The plant Final Safety Analysis Report (FSAR),' power Plant Engineering Quality Instructions, and the QList are used for the identification of safety-related components in accordance with Administrative Procedure 0190.19, 3.3 Conclusion '

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

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4. _ ITEM 2.2.1.1 - IDENTIFICATION CRITERIA i

4.1 Guideline i

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

l 4.2 Evaluation The licensee's response states the criteria that are used for identifying safety-related equipment and components. A component is safety-related it it is required to assure: (a) the integrity of the reactor coolant system pressure boundary, (b) the capability to achieve and maintain a safe shutdown or (c) the capability to prevent or to mitigate

.he consequences of an. accident which could result in potential offsite u dXposures.

Oraft guidelines that expand on these criteria were included '

l with the licensee's (Reference 2) submittal.

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4.3 Conclusion The licensee's responses to this item are complete, address the staff's concerns, and are, therefore, 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-1 The licensee has developed a computerized Total Equipment Data Base -

(TEDB) that is accessed by the Nuclear Job Planning System (NJPS). The NJPS prepares and. tracks Plant Work Orders (PW0s). The computer printout-PWO includes the safety-related classification of t'he involved components. ,

Administrative Procedure 0-ADM-701, " Plant Work Order Preparation,"

requires the job planner to verify the safety related classification by comparison to the QList.

The classification is also verified by a _ quality l control inspector.

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The TEDB is maintained by the review of revisions to.various plant documents, including the QList, and by feedback from plant personnel' .

Verification and validation of the TED8 is accomplished each time a PWO is issued by two independent comparisons with the QList.

i S.3 Conclusion The licensee's responses describe a-system that meets the recommendations of this item. Therefore, the licensee's responses for this 4 item are acceptable, 4

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ITEM 2.2.1.3'- USE OF THE EQUIPMENT CLASSIFICATION LISTING 6.1 Guideline The'11censee's description should confirm that the program for I equipment classification = includes criteria and procedures that govern how i

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 *

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replacement.. and other activities applicable to safety-related components \ I as defined in the introduction to.10 CFR 50, Appendix 8.

L I o 6.2 Evaluation The. licensee st0tes that job plannersfand quality control inspectors are directed by Admiristrative Procedure 0-ADP-701 to consult the QList to determine that the information handling system (the TEDB/NJPS) has classified components and activities correctly on the PWO, The PWO is printed by the NJPS computer. system, which calls up the safety-related '

classification automatically from the TEDB.

The licensee states.that quality assurance procedures are followed-for maintenance work, surveillance testing, parts replacement, and other maintenance and testing -

activities. ,

6.3 _Concl usion l We find that the licensee's description of plant administrative controls and procedures meets the requirements of this item. Therefore, the licensee's responses for this item are acceptable.

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS 7.1 Guideline The licensee should briefly describe the management controls that are j

used to verify that the procedures for preparation, validation, and the t

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

1 7.2 Evaluation The licensee states that the management controls over the preparation, s validation, and routine use of the QList are the quality assurance programs I and audits. ,

i 7.3 Conclusion l

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, the licensee's response for this item is acceptable. '

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ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT l J

8.1 Guideline

.i 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 components and parts. The specification should include qualification testing'for expected safety service conditions and provide support for the licensee's receipt'of j

testing documentation to support the limits'of life recommended by the supplier.

' If such documentation is not available, confirmation that the i present program meets these requirements should be provided. -

8.2 Evaluation 1

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The licensee's submittals includes Quality ~ Procedure 4.1, which is stated to be the procedure that assures that appropriate technical and quality requirements are specified. Administrative Procedure AP-0190-4, ,

" Procurement Document Control," controls procurement documents to ensure that the appropriate design verification,and qualification testing requirements are specified.

a 8.3 Conclusion item.

We conclude that the licensee has addressed the concerns of this q Therefore, the licensee's_ responses for this item are acceptable, a

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9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS 9.1- Guideline i i

i Generic Letter 83-28 states that the licensee's equipment i

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 information provided by.the licensee to resolve these concerns meets the requirements of Genei'ic Letter 83-28 and is acceptable.

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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.

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Letter, Florida Power & Light Company (J. W. Williams, Jr.) to Office i of Nuclear Reactor Regulation, NRC (D. G. Eisenhut), " Generic Letter 83-28," November 8, 1983,-L-83-555, 3.

Letter, Florida Power & Light Company (C. O. Woody) to NRC, " Generic-Letter 83-28, Request for Additional Information," April 17, 1987, L-87-174.

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