ML20196D431
| ML20196D431 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/06/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20196D428 | List: |
| References | |
| GL-83-28, NUDOCS 8812090093 | |
| Download: ML20196D431 (3) | |
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- UNITE 3 STATE 8 NUCLEAR REGULATORY COMMISSION '
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! AAaHING704. D. C. 200a6 l 4 . . . . . s.
i SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION l i
THE CLEVELAND ELECTRIC ILLUMINATING COMPANY ET AL. ,
PERRY NUCLEAR POWER PL ANT. UNIT N05.1 AND 2 DOCKET NOS 50-440 AND 50-441 GENERIC LETTER 83-28 ! TEM 2.2 PART 1
1.0 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 after the initiation of the autoratic trip signal. The failure of the circuit breakers was determined to be related to the sticking of the undervoltage trip attachment. Prior te this incident, on February 22, 1983 at Unit 1 of the Salem Nuclear Power Plant, an autoraatic trip signal was generated based on steam generator low-low level during the plant startup. In this case the reactor was tripped
. manually by the operator almost coincidentally with the automatic trip.
Following these incidents, on February 23, 1983, the NRC Executive Director for Operations directed the NRC staff to invest)gete rnd report on the generic inplications of these occurrences et Unit 1 of the Salem Nuclear Power Plant. The results of the staff's inquiry into the generic implica-tions of the Salem unit incidents are reported in NUREG-1000. "Generic Implications of the ATW5 Events at the Salem Nuclear Power Plant." As a result of this investigation, the NRC requested by Generic Letter (G.L.)
83-28 dated July 8,1983, that all licensees of operating reactors, applicants for an operating license, and holders of construction permits respond to the generic issues rat.ed by the analyses of these two ATWS events.
The Cleveland Electric illuminating Company, et al., licensees for the Perry Nuclear Power Plant, responded to G.L. E3-28 by letter dated April 6, 1984. The NRC staff and their contractor, EG6G of Idaho, have reviewed the licensees' responses. The purpose of this safety evaluation is to cocument the staff's review of item 2.2. Part 1 of G.L. 83-28. The contractor's Technical Evaluation Report (TER) is attached.
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. 2.0 EVALUATION G.L. 83-28 Item 2.2 requires, in part, that licensees and applicants submit for staff review, a description of their programs for safety-related* equip-ment classification as described below:
For equipment classification, licensees and applicants were required to !
describe their programs for ensuring that all components of safety-related systems necessary for accomplishing required safety functions are identif ttd as safety-related on documents, procedures, and information handling systems used in the plant to control safety-related activities, including mainte-nance, work orders and replacement parts. This description was to include:
- 1. The criteria for identifying components as safety-related within systems currently classifie' as safety-related. This was not ,
interpreted to require changes in safety classification at the systems level.
- 2. A description of the infomation handling system used to identify I safety-related Components (e.g. Computerized equipment lists) ?rd !
the roethods used for its development and validation. '
- 3. A des'.ription of the process by which station personnel use this !
inforination handling system to determine that an activity is safety-rela;ec and what p=ocedures for maintenance, surveillance, parts re-placement and other activities defined in the introduction to 10 CFR 50, Appe ndix B, apply to safety-related components.
4 A de scription of the tranagement control utilized to verify that the i procedures for preparation, validation and routine utilization of the information handling system have been followed. i
- 5. A demonstration that appropriate design verification and qualification testing is specified for procurement of saSty-related components. The specifications were to include qualification testing for expected safety service conditions and p
- ovide support for the licensees' receipt of testing docurrentation to support the limits of life reconmended by the +
i supplier.
Licensees and applicants were also directed to includu toe broatier class of '
structures, syste:ns, and components important to safety required by GDC-1
- (defined in 10 CFR Part 50, Appendix A "General Design Criteria, Introduc- !
i 'itn") in their equipment classification program.
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- Safety-related structures, systems, and components are those that are relied upon to rcnoin functional during and following design basis ,
t events to ensure: (1) the integrity of the reactor coolant boundary. (
, (2) the capability to shut down the reactor and maintain it in a safe i shutdown condition, and (3) the capability to prevent or mitigate the !
consequences of accidents that could result in potential offsite ex- '
posures comparable to the gutcelines of 10 CFR Part 100.
The licen;ees' response to item 2.2 provided details concernina their method for equipment classification at the Perry Nuclear Power Plant including discussions of the Q-list review program, Perry Material Management System, work order process, Perry Plant Maintenance Information System, parts procurement procedures, audits, and the Equipment Qualification Pro 9 ram.
Our contractor, EG&G o' Idaho, evaluated the licensees' submittal for conformance with each of the positions listed above. The dr. tails of their review are contained in the attached TER.
3.0 CONCLUSION
Based upon our review of the. licensees' submittal and the attached TER prepared by our contractori EG&G of Idaho, the staff concludes that the licensees adequately meet the provisions of G.L. 83-23 Item 2.2 Part 1 for the Perry Nuclear Power Plant, Units 1 and 2.
Attachment:
Technical Evaluation Report Principal contributor: T.G. Colburn Date:
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Attacluent EGG-NTA-7236 4.
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/ TECHNICAL EVALUATICN REPORT CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED CCMPONENTS PERRY-1/-2 Docket Nos. 50-440/50-441 Alan C. Udy 4
- Published January 1988 Idaho National Engineering Laboratory EG&G Idano, Inc.
I Precared for the U.S. Nuclear Regulatory Commission i Wasnington, D.C. 20555 i Uncer COE Contract No. OE-AC07-76IC01570 FIN N6 06C01
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4 ABSTRACT This EG&G Idaho, Inc., report provides a review ~of the submittal from the Perry Nuclear Power Plant on conformance to Generic Letter 83-28, Item 2.2.1.
l Cocket Nos. 50-440/50-441 7;c Mc. O l ? 5 /o 11
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 Engineering and System Technology, by EG&G Idaho, Inc., Electrical, Instrumeltation and Control Systems Evaluation Unit. ,
The U.S. Nuclear Regulatory Commission funded this work under the authori:ation E&R 20-19-10-11-3, .:IN No. 06001.
4 Oceket Nos. 50-440/50-441 tii
CONTENTS
. ABSTRACT............................................................... 11 FOREWORD ............./................................................ 111
- 1. INTR 0cuCir0N ........'............................................. 1
- 2. REVIEWCONTyNTANDFORMAT................ . ..................... 2
- 3. ITEM 2.2.1 - PROGRAM ............................................. 3 3.1 Guieetine ........................ ....................'..... 3 3.2 Evaluation ...................... .......................... 3 3.3 Conclusion ................................................. 4
- 4. ITEM 2.2.1.1 - IDENTIFICATICN CRITERIA ........................... 5 4.1 Guidelino .................................................. 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 CLASSIFICATICN LISTING . . . . . . . . . . . 7 6.1 Guideline .................................................. 7 6.2 Evaluation ............. ................................... 7 6.3 Conclusion ............................. ................... 7
- 7. ITEM 2.2.1.4 - MANAGEMENT CCNTROLS ............................... 3 7.1 Guideitne .................................................. 8 7.2 Evaluation ................................................. 8 7.3 Conclusion ...............'.................................. 8
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- 8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ........... . 9 J
8.1 Guideline .................................................. 9
- 8.2 Evaluation ................................................. 9 8.3 Conclusion ................................................. 9
- 9. ITEM 2.2.1.6 "IMPORTANT-TO-SAFETY" CCMPONENTS .................. 10 9.1 Guideline .................................................. 10
- 10. CONCLUSICN ....................................................... 11
- 11. REFERENCES ....................................................... 12 iv i
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,' CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETV-RELATED CCMPONENIS2 PERRY-1/-2
- 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 after the initiation of the automatic trip signal. The failure of the circuit breakers was deterT.ined to be related to the sticking of the undervoltage trip attachment. Pater to this incident, on February 22, 1983, at Unit 1 of the Salem Nuclear Po,rer Plant, an automatic trip signal was generated based on stear generator low-low level during plant startto. In this ca*e, the *egttor was tripped manually by the operator almost coincidentally with the automatic trip.
Following these incidents, on February 23, 1983, the NRC Executive Director for Operations (ECO), directad the NRC staff to investigate and recort on the generic imolications 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 recorted in NUREG-1000, "Generic Implications of the AT'WS Events at the Salem Nuclear Power Plant." As a result of this investigation, the Cenmission (NRC) 1 l requested (by Generic Letter 83-23 dated July 8,1983 ) all licensees of ope *ating reactors, applicar*.s for ?n operating license, and holders of construction permits t o respond to the generf: issues raised by the analyses of these two Ards events.
i This report is an evaluation of the response setnitted by the Cleveland Electric Illuminating Company, the licensee for tne Perry-1, for Item 2.2.1 of Generic Letter 33-28. The document reviewed as a part of -
this evaluation is listad in the references at the end of this recort, and l
1s apolicable also to the postooned Unit LJ. 2.
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- 2. REVIEW CONTENT AND FORMAT
'<em 2.2.1 of Gene'ric L6tter 83-28 requests the licensee or applicant fOr the staf.f review, a description of their programs for
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... ,3d equippent classification including supporting information, able detail, as indicated in the guideline section for each
< within this report.
As previously steted, each of the six subitems of Item 2.2.1 is evaluated in a separate sectier,in which the guideline is presented, an evaluation of the licensee's/ applicant's response is made, and conclusions concerning the acceptability of the program of the licensee or applicant
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are drawn.
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- 3. ITEM 2.2.1 - PROGRAM
. 3.1 Guideline Licensee and applicants should confirm that an equipment classification progra'm is in place that wili provide assurance that all safety-related components are designtted as safety-related on plant documentation and in information handling systems that control activities that may affect safety related components. The purpose of this program is to ensure that personnel performing activities that affect such safety-related components are aware that they are -orking on safety-related components and are guided by safety-related procedures and conttraints.
Licensee and applicant responses which address tne features of this program are evaluated in the remainder of this report.
J.2 Evaluation The licensee for the Percy Nuclear Power Plant responded to these requirem-ats with a submittal dated April 6, 1984.2 This submittal included information that cescribes the Perry safety-related equipment classification program. In the review of the licensee's resoonse to tnis item, it was assumed that the information and documentation supporting this program is available for audit upon request. We have reviewed this '
information and note :he following general concerns.
The licensee states that they are using the computeri:ed Perry Matertal Management System (PMMS) as the information handling system referred to, which has, as part of its data base, the 0-list. The 0-list is a listing of components and parts that nave been cetermined to me safety-related. The PMMS prints out work orders (for any maintenance, surveillasce, inspections or tes?,ing) that cesi? nates automatically wnether the activity is safety-related. Additionally, parts procurement procedures require the determination of the safety-re1Ated status of the materihl cedered.
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3.3 M elusion We have reviewed the licensee's submittal and find that the licensee's response is adequate.
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- 4. ! TEM 2.2.1.1 - 80ENTZFfCAT80N CR8TER8A 4.1 Guideline The applicant or licensee should confirm that the program used for '
equipment classification includes criteria used for identifying components as safety-related. -
4.2 Evaluation .
The licensee states that a component is determined to be safety-related if it is needed to function in order to ensure (a) the integrity of the reactor coolant pressure boundary, (b) the capability to shut down the reactor and to maintain it in a safe shutdown condition, and (c) the capability to prevent or to mitigate the consequences of an accident that could result in offsite releases.
4.3 Conclusion We find that the criteria used in the identification of safety-related comconents meets the requiremer,ts of Item 2.2.1.1 and are 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 -
used to identify safety-related ecmponents. The response should egnfirm that this information handling system includes a list of safety-related equipment and that procedures exist which govern its development and validation.
5.2 Evaluation .
The licensee states that the original 0-list was prepared according to written procedures by a consultant The preparation was audited by the licensee to ensure that the Q-list was prepared according to the written procedures. The Q-list information has been entered into the PriS (computer) data base under controls and verification procedures. An auditable record of all input data ensures that the approved data is entered. Unauthori:ed changes to the data base are controlled by the use of log-on orocecures and cassword comoinations that are controlled by the General Supervisor of the Perry Plant Department Maintenance Section.
Contr?lled (protected) data fields have sof tware logic to prevent inadvertent changes.
5.3 Conclusion .
We find that the information contained in the licensee's su mittal is sufficient for us to conclude that the licensee's information nandling system for equipment classification meets the guideline recuirements.
Therefore, the information provided by the licensee for this item is acceptable.
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- 6. ITEM 2.2.1.3 - USC 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. The description should also include the procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10 CFR 50, Appendix B, that apply to these safety-related components.
6.2 Evaluation The licensee's computeri:ed Perry Plant Maintenance Information System (PPMIS) is used to determine what work activities are safety-related. The PPMIS automatically consults the data base Q-list to determine the safety related status of the work activity. The work order printout is then verified manually. Work requests, work orders, corrective maintenance, procurement, tecnnical specification sarveillance, inservice inspections and testing, and preventative maintect.. e are included in this process.
6.3 Conclusion We find that the licensee's description of plant administrative controls and procedures meets the requirements of this item and is, tnerefore, acceptable.
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- 7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS 7.1 Guideline 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 submittal describes the managerial controls that are applied to assure that the equipment classification information handling
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system has been properly prepared, that its contents have been validated, that it is being maintained current, and that it is being used to determine equipment classification as intended. These controls include audits by the Perry Plant Department and the Nuclear Engineering Department during the preparation of the Q-list. These audits verify compliance with approved procedures and the validation of tne Q-list contents. The use of the 0-list is verified during Quality Assurance audits, during surveillances, and during the review of work orders, procurement documents, and other documents. Periodic evaluations of the Q-list are used to initiate changes to ensure that the Q-list is maintained current.
7.3 Conclusion We find that the licensee's description eeets the recuirements of this
! item and is, therefore, acceptable.
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- 8. ! TEM 2.2.1.5 - DESfGN VERTFICAT10N AND PROCUREM2NT l
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. 8.1 Guideline ;
The applicant's or licensee's submittal should document that past
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usage demonstrates that appropriate design verification and qualification testing is specified for the procurement of sa, ty-related components and parts. The specifications should include qualification testing for expected safety service conditions and should 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 Q-list is the central data base used for procurement requirements. The licensee states that safety-related components are qualified, by the use of the Q-list, with documentation to ensure that the ecuiement will perform its design function in normal, abnormal, accident, and post-accident environments for its service life. The licensee states that the cualification documentation is reviewed to show the qualified life of the component or part. 4 8.3 Conclusion Tne licensee's response for this ' item is considered to be complete.
The information provided accresses the concerns of this item and is ,
acceptable.
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- 9. ITEM 2.2.1.6 "IMPORTANT-TO-SAFETY" CCMPONENTS 9.1 Guideline Generic Letter 83-28 states that the licensee's or applicant's equipment, classificatior, program should include (in addition to the safety-related components) a broader class of components designate'd 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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. 10. CONCLUSION Based on cur 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 Items 2.2.1.1, 2.2.1.2, 2.2.1.3.
2.2.1.4 and 2.2.1.5 meets the requirements of Generic letter 83-28 and is acceptable. Item'2.2.1.6 was not reviewed, as noted in Section 9.1.
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- 11. REFERENCES
- 1. NRC Letter, D. G. Eisenhut to all Licenseas of Operating' Reactors, Applicants for Operating License and Holders of Construction Permits, "Required Ac~tions Based on Generic Implications of Salem ATWS Events (Generic Letter 82-28)," July 8, 1983. .
- 2. Cleveland Electric Illuminating Company letter, M. R. Edelman to
- 0. G. Eisehut NRC, "Response to Generic Letter 83-28," April 6,1984, PY-CEI/NRR-0100 L.
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.. . .. ., .w ,... o, r-e .e s . .e CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-REl.ATED ' . :.r o m. :: . .i i.
COMPONENTS: PERRY-1/-2 , , , -
January 1988
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Alan C. Udy g January 1988
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P. O. Box 1625 Idaho Falls ID 83415 06001
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Division of Engineering and System Technology Office of Nuclear Reactor Regulation *'**'*"--.--
U.S. Nuc1 ear Regulatory Comission Washington, DC 20555 ..
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This EG&G Idaho, Inc., report provides a review of the submittal from tne Perry Nuclear Power Plant regarding conformance to Generic Letter 83-28 Item 2.2.1.
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