ML20116D955
| ML20116D955 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/28/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20116D885 | List:
|
| References | |
| FOIA-96-237 GL-83-28, NUDOCS 9608050026 | |
| Download: ML20116D955 (7) | |
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION wAsHWGTON, D. C. 20666
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SAFETY EVALUATION REPORT CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1&2 DOCKET NOS. 50-317/318 GENERIC LETTI." 02 a3. ITEM 2.2.I EQUIPMENT CLASSIFICATION PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS l
1.0 INTRODUCTION
Generic Letter 83-28 was issued by the NRC on July 8,1983 to indicate actions
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to be taken by licensees and applicants based on the generic 1sp11 cations of l
the Salem ATWS events.
Item 2.2.1 of that letter states that licensees and
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applicants shall describe in considerable detail their program for classifying l
all safety-related components other than RTS components as safety-related on j
plant documents.and in information handling systems that a're used to control j,
plant activities that may affect these components. Specifically, the licensee /
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applicant's submittal was required to contain information describing (1) The l,
criteria used to identify these components as ' safety-related; (2) the~
j information handling system which identifies the components as safety-related; (3) the manner in which station personnel use this information handing system l
to control activities affecting these components; (4) management contrels that i
are used to verify that the informat1on handling gystem is prepared, maintained,
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l ka11 dated,andusedinaccordancewithapprovedprocedures;and(5) design
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verification and qualification testing requirements that are part of the
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t specifications for procurement of safety-related components.
The licensee for the Calvert Cliffs Nuclear Power Plant, Units 1&2 submitted responses to Generic Letter 83-28, Item 2.2.1 in submittals dated November 5 1983, February 29, 1984, and April 6, 1987. 'We have evaluated these responses and find them to be acceptable.
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'v Evaluation In these sections the licensee's responses to the program and each of five sub-items are individually evaluated against guidelines developed by the staff and conclusions are drawn regarding their individual and collective acceptability.
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Identification Criteria
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1 Guideline: The licensee's response should describe the criteria used to identify safety-related equipment and components.
(Item 2.2.1.1) i Evaluation:
The licensee's response stated that equipment and instrumentation were designated safety-related if they met these criteria: Were needed to assure (a) the integrity of the RCS pressure boundary, (b)thecapabilitytoachieveandmaintainasafereactorshutdown, (c) the capability to prevent or mitigate the consequences of an accident which coulo result in potential offsite exposures, or (d) items that the Nuclear Engineering Services Dept. specifies to j
receive the same level of QA as necessary for classes (a), (b), and (c)above.
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Conclusion:==
We find these stated criteria meet the requirements and are acceptable.
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Information Handling S_ystem
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Guideline: The licensee's response should confirm that the equipment classification program incibdes an information handling
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components. Approved procedures which govern its development, maintenance, and validation should exist.
(Item 2.2.1.2) i j
Evaluation:
The licensee stated in their response that the Q-List and it's
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attachments are the coeponent listing. The 11 sting's development.
1 verification, and changes are governed by Quality Assurance Procedure (QAP)-28bytheQ-Listcommittee. This procedure is implemented by the Electric Engineering Dept. Procedure (EEDP)-4 which covers activities affecting the Q-List.
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Conclusion:==
r We find that the information contained in the licensee's submittals shows that their information handling system meets the requirements for this ites and is acceptable.
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Use of Information Handling System Guideline: The licensee response should confirm that their equipment classification program includes criteria and procedures which govern the use of the information handling system to determine i
that an activity is safety-related and that safety-related procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10CFR50, Appendix B, are applied to safety related components.
(Item 2.2.1.3)
Evaluation:
The licensee, in their submittals, describe certain administrative procedures which require personnel to consult the Q-List to determine
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whether affected components and the activity affecting them are safety-related. These administrative procedures are followed when preparing for and performing maintenance work, surveillance testing, l
parts replacement, and other maintenance and testing activities.
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Conclusion:==
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We find the licensee's description of the administrative procedures governing the use of the Q-List and their implementation acceptable.
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Management Controls Guideline: The licensee / applicant should confirm that management controls used to verify that the procedures for preparation, validation, and routine utilization of the information handling system have been and are being followed.
(Item 2.2.1.4)
Evaluation:'
The licensee, in their submittals, describe management review and approval controls that are applied to the preparation, validation, maintenance and routine use of the Q-List.
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Conclus1on:
We find the licensee's description of their management controls to be acceptable for this item.
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Design Verification and Procurement Guideline: The licensee / applicant's response should document that I
past usage demonstrates that appropriate design verification and qualification testing is specified for the procurement of-safety-related components and parts. The specifications should include l
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qualification testing for expected safety service conditions and i
J provide support for licensee's receipt of testing documentation which supports the limits of life recommended by the supplier. If l
such documentation is not available, confirmation that the present i
program meets these requirements should be provided. (Item 2.2.1.5) 1 Evaluation:
l The licensee stated, in their submittal, that Quality Assurance j
procedures and the " Procurement and Storage Manual" specify the 3
verification and testing for replacement safety-related components l
and parts. A description of the information contained in a l
specification package, how the package is developed, and how the package is used in procurement actions was included.
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Conclusion:==
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i We find the licensee's response described acceptable procedures for
!j procurement of replacement safety-related components and is dCCeptable.
6.
"lo ortant To Safet.y" Components f
Guideline: Generic Letter 83-28 states that licensee / applicant equipmentclassificationprogramsshouldinclude(inadditionto thesafety-relatedcomponents)abroaderclassofcomponents designated as "Important to Safety." However, since the generic letter does not require licensee / applicant to furnish this information as part of their response, staff review of this sub-itam will not be performed. (Item 2.2.1.6)
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Program Guideline:
Licensees / applicants should confirm that an ecof r
.lassifi-cation program exists which provides assuranct i safety-j related components are designated as safety-rel.
on plant i
documents such as drawings, procedures, system descriptions, test and maintenance instructions, operating procedures, and l
infonnation handling systems so that personnel who perform activities that affect such safety-related components are aware that they are working on safety-related components and are guided by safety-related procedures and constraints.
(Item 2.2.1)
Evaluation:
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l The licensee's response to these requirements was contained j
in submittals dated November 5,1983, February 29, 1984, and i
April 6, 1987. These submittals included information that describes their progren for classification of safety-related i
s.omponents and equipment.
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Conclusion:==
We find the licensee's program as described in the submittals to be acceptable.
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3 ENCLOSURE 2 l
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ICS8/ DEST SALP INPUT PLANT: Calvert Cliffs Nuclear Power Plant, Units 1&2 D0CKET NO: 50-317/318 SER
SUBJECT:
Review of Generic Letter 83-28. Item 2.2.1 PERFORMANCE PARAMETERS:
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Management Involvement in Assuring Quality I
J Approach to Resolution of Technical Issues From a Safety Standpoint
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Response to NRC Initiatives I
I Staffing (IncludingManagement)
.i ll Reporting and Analysis of Reportable Events Training and Qualification Effectiveness i
)i Any Other SALP Functional Area PERF0fMANCE NARRATIVE DESCRIPTION OF CATEGORY /
PARAMETER APPLICANT / LICENSEE'S PERF0lMANCE RATING 1
No basis for assessment.
N/A s
2 Approach was dimet and enabled 1
verification of the acceptability of the licensee's progree.
3 Licensee described his program I
which met the requirements for.this item.
4 thru 7 No basis for assessment.
N/A OVERALL APPLICANT / LICENSEE PERFORMANCE RATING 1
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EGG-NTA-7427 c
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CONFORNUICE TO GENERIC LETTER 83-28. ' ITEM 2.2.1--
EQUIPE NT CLASSIFICATION FOR'ALL OTHER SAFETY-j RELATED COPPONENTS: CALVERT CLIFFS-1 AND -2 l
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by the U.8; Alan C. Udy Depam mt,$.'
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Prepared for the 1
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l DISCLAIMER l
The book wee propered as an account of work sponsomd by an agency of the Unned l
Steese Govemment. fenhor the Urvied States Govemment nor any agency themot.
nor any of ther empeoveen. makes any warranty, comme or imated. or soeumes any ingel intehty or responeneiny for the accuracy. comedsomene, or usehdness of any l
adormenon, apperetus, product or procese encioned, or reemeense that me use would not inennes pmmedy owned nghts. neeerences heen to any spemac essmamos product, process, or sorwoe by trade nome, tredamerk, menulacewer. or sehenaus, does not necessardy consenute or unply ate endorsement. recommemseelen, er lavonng by the Uruted Steses Govemment or any agency themot. The woes and esonene of authoie somosed hoon do not neceanenly stees or renset those of the Uniend Steese Govemment or any agency thereof.
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EGG-NTA-7427 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
CALVERT CLIFFS-1 AND -2 1
Docket Nos. 50-317/50-318 Alan C. Udy 1,
l Published May 1987 l
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Idaho Nat. tonal Engineering Laboratory
- i EG&G Idaho, Inc.
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U.S. Nuclear Regulatory Commission
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Under DOE Contract No. DE-AC07-76ID01570 FIN No. D6001 4
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ABSTRACT This EG&G Idaho, Inc., report provides a review of the submittals from the Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, regarding conformance to Generic Letter 83-28, Item 2.2.1.
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i Docket Nos. 59-317/50-318 TAC Nos. 53659/53660 l
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I" FOREWORO This report is supplied as part of the progras'for evaluating-Itcensee/ applicant conformance to Generic Letter 83-28, " Required Actions Based on Generic Implications of Sales ATWS Events." This work is being conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Idaho, Inc., NRR, and I&E Support Branch.
The U.S. Nuclear Regulatory Commission funded this work under the authorization B&R No. 20-19-10-11-3, FIN No. D6001.
f Docket Nos. 50-317/50-318 TAC Nos. 53659/53660
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ABSTRACT..............................................................
11 FOREWORD..............................................................
111 1.. ! INTRODUCTION.....................................................
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REVIEW CONTENT AND FORMAT........................................
2 3.
ITEM 2.2.1 - PROGRAM.............................................
3 3.1 Guideline..................................................
3 3.2 Evaluation.................................................
3 3.3 Conclusion.................................................
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ITEM 2.2.1.1 - IDENTIFICATION CRITERIA...........................
4 4.1 Guideline..................................................
4 4.2 Evaluation.................................................
4 4.3 Conclusion.................................................
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ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM.......................
5 5.1 Guide 11ae..................................................
5 5.2 Evaluation.................................................
5 5.3 Conclusion.................................................
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ITEM 2.2.1.3 '- USE OF EQUIPMENT CLASSIFICATION LISTING...........
6 6.1 Guideline..................................................
6 6.2 Evaluation.................................................
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6.3 Conclusion.................................................
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ITEM 2. 2.1. 4 - MANAGEMENT CONTROLS...............................
7 7.1 Guideline..................................................
7 7.2 Evaluation.................................................
7 7.3 Conclusion.................................................
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ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT...............
8 8.1 Guideline..................................................
8 8.2 Evaluation.................................................
8 8.3 Conclusion..................................'...............
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ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS..................
9 9.1 Guideline..................................................
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- 10. CONCLUSION.......................................................
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- 11. REFERENCES.......................................................
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CONFOR E TO GENERIC LETTER 83-28. ITE
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EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
l CALVERT CLIFFS-1 AND -2 l
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INTRODUCTION
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On February 25, 1983, both of the scram circuit breakers.at Uni _t 1 of the Sales Nuclear Power Plant failed to open upon an automatic reactor trip i
signal from the reactor protection system. This incident was 'erni manuallybytheoperatorabout30.secondsafterthe-initiatioNofh.nated t
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automatic trip signal. The failure of the circuit breakers was determined u.
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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 Nuclear Power Plant, an automati : trip signal was generated based on steam generator low-low level during plant startup.
In this case, the reactor 4
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was tripped manually by the operator almost coincidentally with the j
automatic trip.
i Following these incidents, on February 28, 1983, the NRC Executive Director for Operations (EDO), directed the NRC staff to investigate and
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report on the generic implications of these occurrences at Unit 1 of the
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Sales Nuclear Power Plant. The results of the staff's inquiry into the generic implications of the Sales unit 'ncidents are reported in NUREG-1000, " Generic Implications of the ATWS Events at the Sales Nuclear Power P1.nt."
As a result of this investigation, the Commission (NRC)_
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requested (by Generic Letter 83-28 dated July 8,1983 ) all licensees of operating reactors,' a~pplicants for an operating license, and holders of construction permits to respond to the generic issues raised by thO analyses of these two ATWS evants.
J This report is an evaluation of the responses submitted by the Baltimore Gas and Electric Company, the licensee for Unit Nos. I and 2 of the Calvert Cliffs Nuclear Power Plant, for Item 2.2.1 of Generic Letter 83-28. The documents reviewed as a part of this evaluation are listed in the references at the end of this report.
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REVIEW CONTENT AND FORMAT Item 2.2.1 of Generic Letter 83 28 requests the ifcensee or. app 1tcant to submit, for the staff review, a description of their programs for safety-related equipment classification including supporting information, in considerable detail, as indicated in the guideline section for each sub-ften within this report.
As preyfously indicated, each of the six sub-f tens of Item 2.2.1 ts evaluated in a separate section in which the guideline is presented'; an evaluation of the Itcensee's/ applicant's response is made; and conclusions about the programs of the Itcensee or applicant for safety-related equipment classification are drawn.
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ITEM 2.2.1 - PROGRAM i
3.1 Guideline I
.-Licensees and app 1tcants should confirm that an equipment classification program exists which provides assurance that all safety-related components are designated as safety-related on all plant documents, drawings and procedures and in the information~ handling s'ystem
'thatisusedinaccomplishingsafety-relatedactivities,suchaswod-orders.for repair, maintenance and surveillance testing and onders for replacement parts.
Licensee and applicant responses which address the features of this program are evaluated in the remainder of this report.
e 3.2 Evaluation The licensee for the Calvert Cliffs Nuclear Power Plant responded to these requirements with submittals dated November 5, 1983,2 February 29, 3
1984 and April 6, 1987.4 These submittals include information that describes their safety-related equipment classification program (Q-list).
We have reviewed thfs information and note that the licensee states that i
all safety-related components are designated as such on the Q-list, and identified as such on plant documents, drawings, and procedures. The Itcensee states that the Q-list includes red-lined piping and instrumentation diagrams and a computerized list of safety-related systems, equipment and components.
3.3 Conclusion We have reviewed the licensee's submittals and, in general, find that the licensee's response is adequate.
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ITEM 2.2.1.1 - IDENTIFICATION CRITERIA
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4.1 Guideline l
The applicant or licensee should confirm that their program 'used.for equipment classification includes criteria used for identifying coqponents
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4 4.2 Evaluation The licensee's response gives the criteria used for identifying safety-related equipment and components.
Instruments and equipment are considered safety-related if required to assure: (a) the integrity of the reactor coolant system pressure boundary, (b) the capability to achieve and maintain a safe shutdown of the reactor, (c) the capability to prevent or to mitigate the consequences of an accident which could result in potential offsite exposures or (d) items that the Nuclear Engineering Services Department specifies to receive the same level of quality assurance as necessary for items (a), (b), and (c) above. Guidelines that expand on these criteria were included with the licensee's submittal.
4.3 Conclusion We find that the criteria used in the identification of safety-related components meets the requirements of Item 2.2.1.1 and are acceptable, i
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ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM
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5.1 Guideline The licensee or applicant should confirm that'the program ~for.
equipment classification includes an information handling system thatL is used to identify safety-related components. The response should confirm that this information handling system includes a list' of safety-related equ'ipment and that procedures exist which govern its developeent'and' validation.
l 5.2 Evaluation The licensee states that the Q-list and its attachments are the component listing referred to. Quality Assurance Procedure (QAP)-28 is the governing procedure for the Q-list committee's development, verification and validation of and changes to the Q-list. QAP-28 is implemented by the j
Electric Engineering Department's Procedure (EEDP)-4, which covers the preparation, approval, issue, revision and interpretation of the Q-list.
iI 5.3 Conclusion We find that the information contained in the licensee's submittal is sufficient for us to conclude that the licensee's information handling system for equipment classification meets the guideline requirements.
Therefore, the information provided by the licensee for this item is acceptable.
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ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION
- LISTING 6.1 Guideline
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The licensee's or applicant's description;should confirm tNtf their
.o programforequipmentclassificationincludescriteriaand'proce$$s'which govern how station personnel use the equipment classiffcation inf5rsation handlingsystemtodeterminethatanactivityis; safety-related,andNat
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n,; 9, procedures for maintenance, surveillance, parts replacement and other-act1yitiesdeffned1atheintroduction'to10CFR50, Appendix $,{ apply.to safety-related components.
6.2 Evaluation The licensee describes QAP-14 and 15 and Calyert Cliffs Instructions (CCI)-126, 200, 201'and 211 which are administrative procedures that require personnel to consult the Q-11st to determine when a component or activity is safety-related. The licensee states that QAPs are followed for maintenance teork, survet11ance testing, parts replacement and other maintenance and testing activities.
6.3 Conclusion
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The information provided by the ifcensee addresses the concerns of i
this item. We find that the' licensee's description of plant administrative controls and procedures is adequate for this item.
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ITEM-2.2.1.4 - MANAGEMENT CONTROLS 7.1 Guideline
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i Managerf a1' controls that will be used by the Itcensee to verify that
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the information handling system for equipment classification has 'been' l
prepared according to the approved procedures,- that its contents have been valtdated, that it is being,maintatned current, and that it fs.being.used to determine eq'ufpment classiffcation as(fntended s'hal'1 be deserib O.i The
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description of these controls shall be in?. sufficient detaf1' for de staff '
to determine that they are in place and are workable.
7.2 Evaluation The Itcensee has described che management controls over the preparation, validation, maintenance and routine use of the Q-list in sufficient detail.
7.3 Conclusion We find that the management controls used by the Itcensee 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 ?.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline The licensee's submittals shall show that the specifications for procurement of replacement safe'y-related components and parts require that verification of design capability and evidence of testing that qualifies the components and parts for service under the expected conditions. for the service life specified by the suppiter is included.
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l 8.2 Evaluation l
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l The licensee's submittal indicates that QAP-2 " Procurement and Storage" and the licensee's " Procurement and Storage Manual" specify the verification and testing for replacement safety-related components and i
parts. The licensee included a description of what is included in a specification package, how the package is developed and how the specified requirements ~are implemented into a specification package.
l 8.3 Conclusion The licensee's response for this item is considered to be complete.
.The information provided addresses the concerns of this ites and is acceptable.
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ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS 9.1 Guideline Generic Letter 83-28 states that the Itcensee'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.1feensee to furnish this information as part of their response, reiffew of tNf slf tes j
will not be performed.
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- 10. CONCLUSION j
Based on our review of the licenscs's resporse to the specific requirements'of Item 2.2.1, we find that. the information;provided by.~the i
If eensee to resolve the concerns of Items 2.2.1.1,-2.2.1.2, 2'.2.1.3,'
2.2.1.4 and 2.2.1.5 meet the requirements of Generic Letter 83-28 add is acceptable.
Item 2.2.I'.6 was not reviewd as noted in Section 9.1.
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- 11. REFERENCES 1
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NRC Letter, D. G. Eisenhut to all Licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits, i
~" Required Actions Based on Generic Implications of. Sales AlVS. Events j
.(Generic Letter 83-28)," July 8, 1983.
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Letter, Baltimore Gas and Electric Company'(A. E. Lundvall, Jr.) to
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NRC (D. G. Eisenhut), " Generic Letter 83-28; Required Actions Based on i
J Generic Impiteations of Salem ATWS Events," November 5,' 1983.
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d Letter, Baltimore Gas ' nd Electric Company' (A. E. Lundvall, Jr.).to -
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NRC (O. G. Eisenhut), " Generic Letter 83-28. " Required l Actions Based on Generic Implications of Salem ATW5 Events," February 29,-1984.
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Letter, Baltimore Gas and Electric Company (J. A. Tiernan) to NRC,
. " Request for Additional Information Concerning BG&E Responses to Generic Letter 83-28," April 6, 1987.
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EGG-NTA-7427 e r.rse m.sws.rse CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1--
EQUIPENT. CLASSIFICATION FOR ALL OTHER SAFETY-RELATED C090NENTS: CALVERT CLIFFS-1 AND -2
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Alan C. Udy May V 1987
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Idaho Falls 10 83415 06001
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Division of PWR Licensing - A Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission e au'===='=s - a=*
Washington, DC 20555 3
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i This EG&G Idaho. Inc., report provides a review of the subaittals from the Baltimore Gas and Electric Company regarding confonnance to Generic Letter 83-28. Item 2.2.1 for i
Calvert Cliffs-1 and -2.
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