ML20151B569

SER Accepting Util Proposal Re Item 2.2.1 of Generic Ltr 83-28 Concerning Equipment Classification Programs for All safety-related Components

ML20151B569
Person / Time
Site:	Waterford
Issue date:	03/30/1988
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20151B566	List: ML20151B563 ML20151B569
References
GL-83-28, NUDOCS 8804110004
Download: ML20151B569 (6)

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\...../ SAFETY EVALUATION REPORT WATERFORD STEAM ELECTRIC STATION UNIT NO. 3 DOCKET NO. 50-382 GENERIC LETTER 83-28, ITEM 2.2.1 EQUIPMENT CLASSIFICATION PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS ,

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1.0 INTRODUCTION

Generic Letter 83-28 was issued by the NRC on July 8, 1983 to indicate actions I

to be taken by licensees and applicants based on the generic implications of the Salem ATWS events. Item 2.2.1 of that letter states that licensees and applicants shall describe in considerable detail their program for classifying all safety-related components other than RTS components as safety-related on plant documents and in information handling systems that are used to control plant activities that may affect these components. Specifically, the licensee /

applicant's submittal was required to contain information describing (1) The criteria used to identify these components as safety-related; (2) the information handling system which identified the components as safety-related; (3) the manner in which station personnel use this information handing system to control activities affecting these components; (4) management controls that are used to verify that the information handling system is prepared, maintained, validated, and used in accordance with approved procedures; and (5) design verification and qualification testing requirements that are part of the specifications for procurement of safety-related components.

The licensee for the Water Steam Electric Station, Unit No. 3 submitted responses to Generic Letter 83-28, Item 2.2.1 in submittals dated November 4, 1983 and November 15, 1985. We have evaluated these responses ad find them to be acceptable, 8804110o04 DR 080330 ADOCK 05000302 PDR l l

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Evaluation <

In these sections the licensee's responses to the program and each of five sub-itens are individually evaluated against guidelines developed by the staff and conclusions are drawn regarding their individual and collective acceptability.  !

1. Identification Criteria Guideline: The licensee's response should describe the criteria used to identify safety-related equipment and components.

(Item 2.2.1.1)

Evaluation ,

The licensee's response states that safety-related equipment is identified as safety-related based on the criteria specified in the project management procedure PMP-321, "Determination of safety /Q-Level Components for the MEL/Q-List".

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Conclusion The licensee's response, for this item, meets staff requirements and is acceptable, i

2. Information Handling System Guideline: The licensee's response should confirm that the equipment classification program includes an infonnation handling system that is used to identify safety-related equipment and components. Approved procedures which govern its development, maintenance, and validation should exist. (Item 2.2.1.2)

i Evaluation The licensee's response states that the 0-List is maintained by a dedicated staff whose activities are governed by project management procedure PFP-321.

The Q-List information for components in the plant is entered in the data base and validated in accordance with project management procedure PHP-3?O.

Conclusion The licensee's submittal meets the staff requirments for this item and is acceptable.

3. Use of Information Handling System Guideline: The licensee responsa should confirm that their equipment classification program includes criteria and procedures which govern the use of the information handling system to determine 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. (Iten. 2.2.1.3)

Evaluation The licensee's response identifies the use of the Q-List, and Administrative procedures in the determination of safety-related activities in the areas of parts replacement, storage, maintenance, modification, testing, and surveillance. Collectively, these documents contain the controls to i

ensure that safety-related equipment is identified and handled in the proper manner.

Conclusion The licensee's response meets the staff requirements for this item and is acceptable.

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4-4 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 nave been and are being followed. (Item 2.2.1.4)

Evaluation The licensee's response states that the management controls established for activities related to the development, validation and maintenance of the Q-List are covered by procedures and instructions which are prepared, l t

reviewed, and approved in accordance with project management procedure PHP-001. Administrative procedures UNT-1-002 and QP-5-001 establishes ,l I

management controls related to the routine utilization of the Q-List.

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The licensee's submittal meets the staff requirements and is acceptable, for this item. -

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5. Design Verification and Procurement Guideline: The licensee / applicant's response should document that 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 qualification testing for ]

I expected safety service conditions and provide support for licensee's receipt of testing documentation which supports the limits of life recommended by the supplier. If such documentation is not available, confinnation that the present program meets these requirements should be provided. (Item 2.2.1.5) j i

4 Evaluation The licensee's submittal references Standard Clauses in UNT-8-001 which are used to ensure that technical and quality requirements are specified consistently for safety-related equipment orders.

Conclusion The licensee's submittal meets the stcff requirements for this item and i

is acceptable.

6. "Important To Safety" Components Guideline: Generic Letter 83-28 states that licensee / applicant equipment .

classification programs should include (in addition to the safety-related components) a broader class of components designated as "Important to i

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-item will not be performed. (Item 2.2.1.6)

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7. Program Guideline:

Licensees / applicants should confirm that an equipment classification program exists which provides assurance that a'l safety-related components are designated as safety-related on plant documents such as drawings, procedures, system descriptions, test and maintenance instructions, operating procedures, and information 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)

t 6-Evaluation The licensee's response to these requirements was contained in the submittals of November 4, 1983 and November 15, 1985. These submittals describe the licensee's program for identifying and classifying safety-related equipment and components which meet the staff requirements as indicated in the preceding sub-item evaluations.

I Conclusion We conclude that the licensee's program addresses the staff concerns regarding equipment and component classification, and is acceptable.

3.0 REFERENCES

1. NRC Letter, D. G. Eisenhut to all Licensees cf Operating Reactors, Applicants for Operating License, and Holders of Construction Perrnits , "Required Actions Based on Generic Implication of Salem

..NS Events (Generic Letter 83-28)," July 8,1983.

2. Louisiana Power and Light letter, K. W. Cook to D. G. Eisenhut, NRC, November 4, 1983, W3P83-3911, 4-3-A20.02, 3-A1.01.04, L.02.

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3. Louisiana Power and Light letter, K. W. Cook to G. W. Knighton, NRC, l l

November 15, 1985, W3P85-3158, A4.05 NQA.

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INFORMAL REPORT Idaho Nations / . .w CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

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o DISCLAIMER This eoo= wee orecerod u en account of wort soorared by en egency of the umed States Gomt. Netner the Uruted States Gowrnment nor any agency thereof, nor any of ther empoyees makes any worrenty,6spress or imphed, W assumes arty ,

egal kaoshty or responsitehty for the eCCuracy Competences, or usefulness of any eformatron, 40ceratus, product or process " acoeed, or repromonte thet its use would not etnnge smatney owned rf ts. References heren to any spoofic CoM prodvCt. process, or service by trade name, tradomert, manufacturer, or otherwes, does not necessenN corwttute or m its endorsement, recommendoson, or favonng by the United States Govemment or any agency thereof. The m and opreone of authors empressed hereen oo not necessenty state or refkCt thoes of the Umted Stems GoverWt or any SQency thereof.

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TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 8.1-28. ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR Ali 0THER 3ATETY-RELATED COMPONENTS:

WAT' .4F ORD-3 Docket No. 50-382 i

,. i R. VanderBeek Published /.pril 1987 Idaho Kation41 Engineering Laboratoiy l E G&G Idaho, I:'.c . l Idaho Falls, Idaho 83415 i I  !

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Prepared for the U.S. Nuclear Regulatcry Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-761001570

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A8STRACT i l

l This EG&G Idaho, Inc. report provides a review of the submittals for ,

t the Waterford Steam Electric Station, Unit No. 3 for conformance to Generic t Letter 83-28 Item 2.2.1. j i

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Docket No. 50-382 TAC No. 57705 11 1

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FOREWORD This report is supplied as part of the program for evaluating licensee / applicant conformance to Generic Letter 83-28 ' Required Actions Basect on Generic Implications of Salem ATWS Events." This work is being conducted for the U.S. Nuclear Regulatory Conssission, Of fice of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Idaho, Inc.

The U.S. Nuclear Regulatory Comission funded this work under the authorization B&R 20-19-10-11-3, FIN No. 06001.

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Docket No. 50-38)

TAC No. 57705 J

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CONTENTS ABSTRACT .............................................................. 11 FOREWORD .............................................................. 1))

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 ................................................. 4 4

4. ITEM 2.2.1.1 - IDENTIFICATION CRITERIA ........................... 5 ,

1 4.1 Guideline .................................................. 5 4.2 Evaluation ................................................. 5 4.3 Conclusion ................................................. 5

5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM ....................... 6 5.1 Guideline .................................................. 6 5.2 Evaluation ................................................. 6 5.3 Conclusion ................................................. 6 l 6. ITEM 2.2.1.3 - USE 0F EQUIPMENT CLASSIFICATION LISTING ........... 7 6.1 Guideline .................................................. 7 l 6.2 Evaluation ................................................. 7 6.3 Conclusion ................................................. 7

7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS ............................... 8 7.1 Guideline .................................................. 8

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7.2 Evaluation ................................................. 8 7.3 Conclusion ................................................. 8 ,

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8. IT'EM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ............... 9

• 8.1 Guideline .................................................. 9

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8.3 Conclusion ................................................. 9  !

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! 9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS .................. 10  !

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Guideline .................................................. 10 i i

10. CONCLUSION ....................................................... 11 l

11. REFERENCES ....................................................... - 12  !,

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

- E0VIPdENT CL ASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

WATERFORO-3

1. INTRODUCTION On February 25, 1983, both of the scram circuit 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 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 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. .

Following these incidents, on February 28, 1983, the NRC Executive Director for Operations (E00), directed the staff to investigate and report on the generic implications of these occurrences at Unit 1 of the Salem Nuclear Power Plant. The results of the staff's inquiry into the generic implications of the Salem unit 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 I

(by Generic Letter 83-28 dated July 8, 1983 ) all licensees of operating reactors, applicants for an operating license, and holders of construction permits to respond to generic issues raised by the analyses of these two ATWS events.

This report is an evaluation of the' responses submitted by Louisiana Power and Light for Waterford Steam Electric Station, Unit No. 3 for Item 2.2.1 of Generic Letter 83-28. The actual documents reviewed as a part of this evaluation are listed in the references 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 / applicant to submit, for staff review, a description of their programs for classification of their safety-related equipment includes supporting information, in considerable detail, as indicated in the guidelinr.s preceding the evaluation of each sub-item.

As previously stated, each of the six sub-items of Item 2.2.1 is evaluated in a separate section in which the guideline is presented; an evaluation of the licensee's/ applicant's response is made; and conclusions about its acceptability are drawn.

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3. ITEM 2.2.1 - PROGRAM 3.1 Guideline Licensees and applicants 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 system that is used in accomplishing safety-related activities, such as work orders for repair, maintenance and surveillance testing and orders for replacement parts. Licensee and applicant responses which address the features of this program are evaluated in the remainder of this report.

3.2 Evaluation The licensee for Waterford Steam Electric Station, Unit No. 3 provided a response to Generic Letter 83-28 with submittals dated November 4, ,983 -

and November 15, 1985. These submittals included information that describes their 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 licensee has provided a description of the equipment classification program for the identification of safety-related activities for repair, maintenance, and procurement. However, the response does not directly confirm that all components designated as safety-related in the MEL/Q-list are also properly designated on plant documents, procedures and in the information handling systems used for safety-related activities.

However, the licensee's response to Items 2.2.1.2 and 2.2.1.3 indicate that the documents used to control safety-related activities from start to

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fintsn are approprt'ately marked as safety-related. This is discussed in Sections 5.2 and 6.2. We consider this to be acceptable.

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We have reviewed the licensee's inf ormation and, in general, find that the licensee's response is adequate.

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4. ITEM 2.2.1.1 - IDENTIFICATION CRITLRIA ,

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• 4.1 Guideline The applicant or licensee should confirm that their program used for equipnent classification includes criteria used for identifying components as safety-related. ,

) i 4.2 Evaluation The licensee's response states that safety-related structures, systems, and components are identified as safety-related based on the

! criteria specified in the project management procedure PMP-321, ,

"Determination of Safety /Q-Level Components for the MEL/Q-List'. The procedure was not included in the response; however, review of Section 3.2 of the FSAR identified these criteria. ,

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The licensee's response to this item is considered to be complete and is acceptable.

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5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM 5.1 Guideline The licensee or applicant should confirm that the program for equipment classification includes an information handling system that is i

used to identify safety-related components. The response should confirm that this inf ormation handling system includes a list of saf ety-related l equipment and that procedures exist which govern its development and validation.

5.2 Evaluation l

The licensee's response states that the Q-list is maintained current 1 l by a dedicated staff whose activities are governed by project management '

! procedure PMP-321. This procedures is being updated to include requirements for Q-List maintenance activities. The Q-List information for components in the plant is entered in the data base and validated in accordance with project management procedure PMP-320.

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5.3 Conclusion The licensee's response to this item is considered to be complete and is acceptable.

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6. ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING 6.1 Guideline The licensee's or applicant's description should confirm that their program for equipment classification includes criteria and procedures which govern how station personnel use the equipment classification information handling system to determine that an activity is safety-related and what procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10 CFR 50, Appendix B, apply to safety-related components.

6.2 Evaluation The licensee's response identifies the use of the Q-list, and Administrative procedures in the determination of safety-related activities in the areas of parts replacement, storage, maintenance, modification, '

testing, and surveillance. Collectively, these documents contain the controls to ensure that safety-related equipment is identified and handled in an appropriate manner. ,

6.3 Conclusion I

The licensee's response to this item is considered to be complete and is acceptable.

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS 7.1 Guidelines The applicant or licensee should confirm that the management controls used to verify that the procedures for preparation, validation and routine utilization of the information handling system have been followed.

7.2 Evaluation The licensee's response states that the management controls established for activities related to the development, validation and maintenance of the Q-List are covered by procedures and instructions which are prepared, reviewed, and approved in accordance with project management procedure PMP-001, Preparation and Revision of Project Management Procedure / Instructions". The management controls established for activities related to the routine utilization of the Q-List are governed by Administrative procedure UNT-1-002 and QP-5-001, "Instructions, Procedures and Drawings."

7.3 Conclusion The licensee's response to this item is considered to be complete and is acceptable.

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8. ITEM 2.2.1.5 OESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline The applicant's or licensee's submittal should document that 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 qualification testing for expected safety service conditions and provide support for the applicant's/ licensee's receipt of testing documentation to support the limits of life reconnended 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 specifications imposed upon the vendor are referenced on the Purchase Order Requisition based on either previous orders for the same equipment or specifications supplied by Engineering. Standard Clauses in UNT-8-001 are used to ensure that I technical and quality requirements are specified consistently for safety and quality related equipment orders.

8.3 Conclusion i l The licensee's response for this item is considered to be complete and is acceptable.

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9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY' COMPONENTS ,

9.1 Guideline i

The 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 applicant / licensee to furnish this information as part of their response, review of this item will not be performed.

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10. CONCLUSION i i I i

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. requirements of Item 2.2.1, we find that the information provided by the f I licensee to resolve the concerns of Items 2.2.1 of Generic Letter 83-28 is  !

1 acceptable. Item 2.2.1.6 was not reviewed as noted in Section 9 of this I a  ?

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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 Implication of Salem ATWS Events (Generic Letter 83-28),' July 8, 1983.

2. Louisiana Power and Light letter, K. W. Cook to 0. G. Eisenhut, NRC, November 4, 1983, W3P83-3911, 4-3-A20.02.02, 3-A1.01.04, L.02.

3. Loutstana Power and Light letter, K. W. Cook to G. W. Knighton, NRC, November 15, 1985, W3P85-3153, A4.05,NQA.

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

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This EG&G Idaho. Inc., report provides a review of the submittals from Louisiana Power and Light reg 2rding conformance to Generic Letter 83-28. Item 2.2.1 for the Waterford Steam Electric Station. Unit No. 3.

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