ML20154D443
| ML20154D443 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/10/1988 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20154D401 | List: |
| References | |
| GL-83-28, NUDOCS 8805190199 | |
| Download: ML20154D443 (6) | |
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SAFETY EVALUAT!ON
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r0RT CALHOUN NUCLEAR POWER STATION, UNIT 1 DOCKET NO. 50-285 GEENRIC LETTER 83-28, ITEM 2.2.1 EQUIPMENT CLASSIFICATION PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS
1.0 INTRODUCTION
Generic Letter 83-28 was issued by the NRC on July 8, 1983 to indicate actions to be taken by licensees and applicants based on the generic implications of the Salem ATWS events.
Iter. 2,2.1 of that letter states that licensees and applicants shall describe in considerabie detail their program for classifying all safety-related components other than RTS components as safety-related on plant documents and in infomation handling systems that are used to control plant activities that may affect these components. Specifically, the J
licensee / applicant's submittal was recuired to contain infomation describing (1) The criteria used to identify these components as safety-related; (2) the infomation handling system which identifies the components as safety-related; (3) the manner in which station personnel use this infomation handling system l
to control activities affecting these components; (4) management controls that are used to verify that the infor1 ration handing sytem is prepared, maintained, validated, and used in accordance with approved procedures; and (5) design i
verification and qualification testing requirements that are part of the specifications for procurement of safety-related components.
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The licensee for the Fort Calhoun huclear Power Station, Unit 1 submitted a response to Generic Letter 83-28. Item 2.2.1 in a submittal dated November 4, 1983. We have evaluated snis response and find it acceptable.
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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.
1.
Identification Criteria Guideline:
The licensee's response should describe the criteria used to ideatify safety-related equipment and components. (Item 2.2.1.1)
Evaluation The licensee's response provides a description and supporting information on the criteria used to determine whether a structure, system, or corrponent is safety-related.
For the electrical and instrumentation equipment, the response specifies that the criteria used is based on the station FSAR, station QA manual, station diagrams and IEEE standards.
For mechanical criteria, the response identifies a special class which corresponds to a safety-class 3 in ANSI NI8.2 and other components under ASME Section III code.
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Conclusion:==
The licensee's respanse meets the staff requirements for this item and is acceptable.
2.
Infomation Handling System
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Guideline: The licensee's response should confinn that the l'
equipment classification program includes an information 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)
Evaluation:
The licensee states that the present method for identifying safety-related components is by using the interim electrical CQE list, the station piping and instrumentation diagrams, station structural drawings, technical specifications and updated SAR. The licensee also stated that they are in the process of implementing a prcgram to provide a computerized maintenance centrol and equipment history.
@nclusion: The licensee's response on this item meets staff requirements and is acceptable.
3.
Use of Information Handlino System Guideline: The licensee response should confim that their equipment classification program includes criteria and procedures which gcvern the use of the information handling system to determine that an activity is safety-related and the safety-related procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10FR50, Appendix B, are applied to safety related components.
(Item 2.2.1.3)
Evaluation: The licensee states that station perscnnel utilize the CQE list, station diagrams and drawings, Technical Specifications, and updated Safety Analysis Report as required by procedure orders, Operating Manual, QA Manual, Purchase Manual, Generating Station Engineering Manual, and Technical Service Manuals. Collectively, these documents define programs, record handling systems, administrative controls and procedures used to control activities relating to safety-related equipment.
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.4 CInclusion: The licensee's response meets staff requirements for this item and is acceptable.
4.
Manacement Controls Guideline: The licensee / applicant should confim that management controls used to verify that the procedures for preparation, validation, and routine utilization of the infomation handling system have been and are being followed.
(Item 2.2.1.4)
Evaluation:
The licensee's response states that management controls to verify the proper preparation, validation, and use of the CQE list are on two levels. These levels are direct management interaction with the day-to-day procedures and independent audits to verify compliance with the various governing. documents. The licensee states that procedures controlling maintenance, surveillance testing, modification and purchasing are reviewed by supervisory and management personnel.
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Conclusion:==
The licensee's response to this item, meets the staff requirements and is acceptable.
5.
Design Verification and Procurement Guideline: The licensee / applicant's response should document that past usage demonstrates that appropriate design verification and qualfication 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 licensee's receipt of testing
i 5-dccumentation which supports the limits of life recomended by the supplier.
If such documentation is not available, confimation that the present program meets these requirements should be provided.
l (Item 2.2.1.5)
Evaluation:
The licensee states that all purchasing is dene in accordance with their purchasing manual. They further state that the individual initiating the purchase order is responsible for identifying the qualification recuirements necessary. These purchase documents are reviewed by QA and appropriate super /isory and management personnel.
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Conclusion:==
The licensee's submittal for this item, neets staff requirements and is acceptable.
6.
"Important To Safety" Components Guideline: Generic Letter 83-28 states that licensee /apolicant equipment classification programs should include (in addition to the safety-related ccmponents) a broader class of components 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-item will not be perfonted.
(Item 2.2.1.6) 7.
plogram Guideline:
Licensee / applicants should confirm that an equipment classification program exists which provides assurance that all safety-related components are designated as safety-rela +.ed on plant documents such as drawings, procedures, system descriptions, test and naintenance instructions, operating procedures, and information handling systems so that personnel who perform activities that affect
6-t such safety-related components are aware that they are working on
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safety-related components and are guided by safety-related i
e procedures and constraints.
(Item 2.2.1)
Evaluation:
The licensee's response to these requirements was j
contained in a submittal dated November 4, 1983. This submittal describes the licensee's program for identifying and classifying i
safety-related equipment which meets the staff's requirements as indicated in the preceding sub-item evaluations.
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Conclusion:==
We conclude that the licensee's program addresses the staff concerns regarding equipment classificatton and is acceptable.
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References l
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 ATW3 Events (Generic Letter 83-28),"
l July 8, 1983.
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Omaha Public Power District letter, W.C. Jones, to D.G.
Eisenhut, NRC, November 4, 1983, LIC-83-267.
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EGG-NTA-7425 l
TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC Lf fTER 83-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL
.HER SAFETY-RELATED COMPONENTS:
FORT CALHOUN-l Docket No. 50-285 R. Vander8eek Published April 1987
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Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 63415 Prepared for the U.S. Nuclear Regulatory Comission Washington 0.C.
20555 Under DOE Contract No. DE-AC07-761001570 FIN No. 06001
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ABSTRACT This EG&G Idaho, Inc. report provides a review of the submittal for the Fort Calhoun' Nuclear Station for conformance to Generic Letter 83-28, Item 2.2.1.
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1 Docket No. 50-285 TAC No. 53673 11
i FOREWORD 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 PWR Licensing-A, by EG&G Idaho, Inc.
The U.S. Nuclear Regulatory Commission funded this work under the authorization B&R 20-19-10-11-3, FIN No. D6001, Occket No. 50-285 TAC No. 53673 tii
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CONTENTS ABSTRACT..............................................................
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FOREWORD..............................................................
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1.
INTRODUCTION.....................................................
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2.
REVIEW CONTENT AND FORMAT........................................
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1 3.
ITEM 2.2.1 - PROGRAM.............................................
3 3.1 Guideline..................................................
3 1.2 Evaluation.................................................
3 3.3 Conclusion.................................................
4 4.
ITEM 2.2.1.1 - IDENTIFICATION CRITERIA...........................
5 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 6.
ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING...........
7 6.1 Guideline..................................................
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l 6.2 Evaluation.................................................
7 6.3 Conclusion.................................................
7 7.
ITEM 2.2.1.4 - MANAGEMENT CONTROLS...............................
8 7.1 Guideline..................................................
8 7.2 Evaluation.................................................
8 7.3 Conclusion.................................................
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ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT...............
10 8.1 Guideline..................................................
10 8.2 Evaluation.................................................
10 8.3 Conclusion..................................................
10 9.
ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS..................
11 9.1 Guideline..................................................
11 10.
CONCLUSION.......................................................
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- 11. REFERENCES.......................................................
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CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1--
E0VIPMENT CLASSIFICATION FOR ALL OTHER SAFETY.RELATED COMPONENTS:
FORT CALHOUN-1 1.
INTRODUCTION On February 25, 1983, both of the scram circuit breakers at Unit 1 of i
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 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 t, 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 ine CAlem 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 (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 response submitted by the Omaha Pubite Power District for Fort Calhoun Nuclear Station for Item 2.2.1 of Generic Letter 83-28.
The actual document reviewed as a part af this evaluation is listed in the references at the end of this report.
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2.
REVIEW CONTENT AND FORMAT i
Item 2.2.1 of Generic Letter 83-28 requests the licensee / applicant to submit, for staff review, a description of their programs for f
classification of their safety-related equipnent including supporting information, in considerable detail, as indicated in the guidelines preceding the evaluation of each item.
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As previously stated, 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 l
the licensee's/ applicant's response is made; and conclusions about its acceptability are drawn, f
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3.
ITEM 2.2.1 - PROGRAM i
3.1 Guideline
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Licensee and applicants should confirm that an equipment classification program is in place which will provide assurance that all j
safety-related components are designated as safety-related on plant documentation such as procedures, system descriptions, test and maintenance instructions and in information handling systems so that personnel performing 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.
Licensee and applicant
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responses which address the f eatures of this program are evaluated in the remainder of this report.
3.2 Evaluation The licensee for fort Calhoun Nuclear Station provided a response to Generic Letter 83-28 on November 4, 1983.
This submittal included information that describes their saf ety-related equipmer.t 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 components and activities for repair, maintenance, and procurement.
However, the response does not directly confirm that all components dMignated as safety-related in the 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 Item 2.2.1.2 and 2.2.1.3 indicate that the documents used to control safety-related activities from start to finish are marked as safety-related.
This is discussed in Sections 5.2 and 6.2 of this report.
We consider this to be acceptable.
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3.3 Conclusion We have reviewed the licensee's information and, in general, find that l
the licensee's response is adequate.
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ITEM 2.2.1.1 - IDENTIFICATION CRITERIA 4.1 Guideline The applicant or licensee should confirm that their program used for equipment classification includes criteria used for identifying components as safety-related.
4.2 Evaluation The licensee's response provides a description and supporting information on the criteria used to determine whether a structure, system, or component is safety-related.
For the electrical and instrumentation equipment, the response specifies that the criteria used are based on (1) the station FSAR, (2) the station QA Manual, (3) the station piping and instrumentation diagrams, elementary diagrams, loop diagrams and logic diagrams, and (4) IEEE Standards IEEE-Std-279, 308, 328, 344, 379, 384, and 420.
For the mechanical equipment and component criteria, the response indicates that the ASME Section III code applies.
The response also states that the ASME Section III code is in transition from a component concept to a system concept.
For the mechanical criteria, the response identifies a special safety class which corresponds to a safety-class 3 in ANSI N18.2 for items which do not fall within the guidelines of the ASME Section III code.
4.3 Conclusion The licensee's response to this item is considered to be complete and is acceptable.
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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 used to identify safety-related components.
The rasponse should confirm that this information handling system includes a list of safety-related equipment and that procedures exist which govern its development and validation.
5.2 Fvaluation The licensee response states that the Omaha Public Power District's present methods for identifying safety-related components involve the proper utilization and application of five documents. These are (1) the interim electrical CQE list, (2) the station piping and instrumentation diagrams, (3) tne station structural drawings, (4) the Fort Calhoun Station Unit No. i Technical Specifications, and (5) the Fort Calhoun Station Unit I updated Safety Analysis Report.
Item 1, 2, and 3 are controlled by the statica engineering procedure A-9, "Document Control".
The licensee's response states that the Omaha Public Power District is in the process of implementing a program to provide a computerized maintenance control and equipment history.
5.3 Conclusion The licensee's response to this item is considered to be complete and is acceptable.
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ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING 6.1 Guideline The licensee's description should show how station personnel use the equipment classification information handling system to determine:
(a) when an activity is safety-related, and (b) what procedures are to be f
used for maintenance work, routine surveillance testing, accomplishment of design changes, and performance of special tests or studies.
We should be able to gain confidence from our review that there will be no confusion about when activity is safety-related.
6.2 Evaluation The licensee's response states that Omaha Public Power district personnel utilize (1) the interim electrical CQE list, (2) the station piping and instrumentation diagrams, (3) the station structural drawings, (4) the Fort Calhoun Station Unit No. 1 Technical Specifications, and (5) the Fort Calhoun Station Unit No. I updated Safety Analysis Report as i
required by procedures, Station Standing Orders, Fort Calhoun Station Operating Manual, Quality Assurance Department Manual, Purchasing Manual, Generating Station Engineering Manual, and Technical Services Manual.
Collectively, these documents define programs, record handling systems, administrative controls and procedures to permit District personnel to perform necessary plant functions and maintain a high level of quality at all tires.
Included in these functions are maintenance, preventive maintenance, testing, modifications, purchasing, records, requirements, audits, equipment storage, reviews, and approvals.
Collectively, these processes contain controls to ensure that safety-related equipment is identified as such and handled in an appropriate manner.
6.3 Conclusion The licensee's response to this item is considered to be complete and is acceptable, 7
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ITEM 2.2.1.4 - MANAGEMENT CONTROLS 7.1 Guidelines Managerial controls that will be used by the licensee to verify that the information handling system for equipment classification has been prepared according to the approved procedures, that its contents have been validated, that it is being maintained current, and that it is being used to determine equipment classification as intended shall be described. The description of these controls shall be in sufficient detail for the staff to determine that they are in place and are workable.
7.2 Evaluation The licensee's response states that the management controls to verify the proper preparation, validation, and use of the CQE list are on two levels.
These two levels are (1) direct management interaction with the day-to-day procedures and (2) independent audits to verify compliance with the various District-governing documents.
The four areas of maintenance, surveillance testing, station modification, and purchasing are adequately controlled.
Each of these areas has included in the governing procedures required involvement of District supervi.ory and management personnel in the review cycle to ensure compliance. New surveillance test procedures are reviewed by the Plant Review Comittee (PRC) and approval by the Plant Manager. Modification Requests require both Generating Station Engineering 1
(GSE) management and plant staff review.
Purchasing requires quality review and management approval.
Independent audits serve to reinforce the management controls. Audits are performed by QA, the SARC (Saf ety Audit and Review Comittee), INPO, American Nuclear Insurers and the NRC.
These provide management with information to judge compliance with controlling documents and proper application of these documents.
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7.3 Conclusion I
The licensee's response for this item is considered to be complete and is acceptable.
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ITEM 2.2.1.5 DESIGN 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 qualificaticn 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 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 the District has defined requirements for purchasing in the Purcnasing Manual.
The individual initiating the purchase order is responsible for identifying the quality (qualification requirements) data necessary.
These purchasing documents are reviewed by QA and appropriate supervisory and management personnel.
Appropriate specifications are included with the purchasing document (s).
For electrical equipment located in a harsh environment the District is complying with 10 CFR 50.49 by the guidelines outlined in Standing Order G-17A. As part of this work, the District will also implement a qualified life program by December 1, 1983 for harsh environment electrical equipment.
8.3 Conclusion.
We consider the licensee's response for this item to be complete 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 licensee's or applicant'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 or applicant to furnish this information as part of their response, review of this item will not be performed.
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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 the concerns of Item 2.2.1 meets the requirements of Generic Letter 83-28 and is acceptable.
Item 2.2.1.6 was not reviewed by the staff as noted in Section 9 of this report.
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REFERENCES 1.
NRC Letter, D. G. Eisenhut to all Licensees of Operating Reactors.
Applicants for Opeiating License, and Holders of Construction Permits, "Required Actions 8ased on Generic Implication of Salem ATWS Events (Generic Letter 83-28)," July 8, 1983.
2.
Omaha Public Power District letter, W. C. Jones, to D. G. Eisenhut, NRC, November 4, 1983, LIC-83-267.
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