ML20196G908

SER Re Util 831104 & 850208 Responses to Generic Ltr 83-28, Item 2.2.1, Equipment Classification (Program for All Safety-Related Components. Responses Acceptable

ML20196G908
Person / Time
Site:	North Anna
Issue date:	03/04/1988
From:	NRC
To:
Shared Package
ML20196G904	List: ML20196G900 ML20196G908
References
GL-83-28, NUDOCS 8803100024
Download: ML20196G908 (7)

Text

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SAFETY EVALUATION REPORT NORTH ANNA POWER STATION UNIT 5 1 AND 2 000V.ET NO. 50-338/339 GENEDIC LETTER 83-?8. ITEM 2.2.1 EOUIPMENT CLASSIFICATION PROGRAMS FOR Al.l SAFETY-RELATED COMPONENTS

1.0 INTRODUCTION

Generic letter 83-28 was issued by the NRC on July 8,1983 to indicated actions to be taken by licensees and applicants based on the generic imolications of the Salem ATWS events. Item 2.2.1 of that letter states that licersees and applicants shall describe in considerable detail their procram for classifying all safety-related components other than RTS components as safety-related on plant docurents and in information handling systems that are used to control plant activities that may affect these components. Specifically, the licensee'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 identifies the components as safety-related; (3) the manner in which station personnel use this information handling system to control activi-ties 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 North Anna Power Station, Units 1&2, submitted responses to Generic letter 83-28. Item 2.2.1 in submittals dated November 4,1983 and February 8,1985. We have evaluated these responses and find them to be acceptable.

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. 2.0 EVALUATION AND CONCLUSIONS In these sections, the licensee's responses to the program and each of five sub-items are incividually 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 the criteria utilized for classification of safety-related structures, systems, and components are consistent with the definition and requirements stated in 10 CFR 100. Appendix A, Paragraph !!!(c).

Conclusion:

The licensec's criteria meets the requirements of this item of Generic Letter 83-28 and are acceptable.

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

. _ Evaluation:

The licensee's response states that the infortr.ation nandling system consists of Station Administrativo Procedurc A0M2.1, which contains a listing of safety-related structures, systems, and components. The listing containe? in the procedure does not provide a detailed listing of every component of safety-relateo systems but provides a general breakdown by system and rajor component parts. Subcomponents of safety-related systems are considered to be safety-related. The procedure containing the list is a controlled station document and requires the review and approval of the Station Nuclear Safety and Operating Connittee (SNSOC). Where questions arise during classification of specific structures, systems or components, requests are forwarded to the station

, engineering staff for resolution. Appropriate reviews are required prior to the removal from or addition to the list.

The licensee indicates that oevelopment of a new and more complete listing of safety-related components is in planning but no specific date for completion has been set.

Conclusion:

We conclude that this response and the licensee's program satisfies the staff's concern and is, t5erefore, acceptable. The licensee should provide a schedule for completion of the new listing and confirm its implementation.

3. Use of Information Handling System Guideline: The licensee's resoonse 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

4 introduction to 10 CFit 30. Appendix B, are applied to safety-r: lated components. (Item 2.2.1.3)

Evaluation:

The licensee's responsu indicates that responsible station personnel use the equipment listing and corporate proceoures to designate the safety classification of the equipment and the procedures required to perfonn the work. The safety classification and procedures are indicated on the work activity forms used for all repair and modification work perfonned at the plant. If anyone within the plant is unsure of the classification of a component, the procedures require that he check with the station engineering staff.

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Conclusion:

We conclude that the licensee has described plant administrative controls and procedures which meet the stafi requirements for this item and are acceptable.

4 Management Controls Guideline: The licensee / applicant should confim that management controls used to verify that the procedures for preparation, validation, and routine utilization of the infonnation handling system have been and l are being followed. (Item 2.2.1.4)

Evaluation:

l i The licensee's response states that changes in the approved classifica- l tion listing must be approved by the SN50C, and the Quality Assurance l Department perfoms audits of activities covered by the plant instructions and procedures. Thus, the audit program provides verification of the r routine utilization of the infonnation handling system.

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Conclusion:

We find this description of the licensee's program of manag went controls meets the staff requirements and is acceptable. "

5. Design Verif1 cation and Procurement

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Guideline: The licensee /applicent's response should document that p' dst usage oemonstrates 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 licensee's

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receipt of testing documentation which supports the 11mfts of life reconenenced by the supplier. If such documentation is not available, ,

confirmation that the present program meets these requirements shoulo be 1 provided. (Item 2.2.1.5)

Evaluation:

The licensee's response states that the guideline and policy for procurenent of equipment for use at each station is contained in Section 4 and Section 7 of the, Nuclear power Station Quality Assurance Manual (NP5QAM) and related station adctinistrative procedures. These documents provide direction regarding review of purchase documents, requirements for standard tests or inspections and supporting Quality Assurance documentation, requirements for review when "cocinercial grade" materials or components or substitute materials or components are used in lieu of those originally specified. General guidance is also provided regarding the use of "Engineering Specifications" for new caterials or components added during plant design changes.

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Nonnal % placement pa.ts and mainte.iince items are procured through

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4 ' purchase requis1tions whic.h contain the required infomation referenced

f in the Np50AM and stattop administrative procedures. The infomation and detail is included iN tht purchase document and are nonnally standard

,1 nuclear industry requirements. Special items may be procured using fonnal specification documents and the specifications include such considerations as environmental and testing conditions.

Material and equipraent for plar.t mos:fications are procured through methods similar to those described above. The same governing documents apply to this procurement cycle. The difference is primarily in the area of approval for monetary comitments and expenditures.

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We find the licensee's procedures meet the staff requirements for this item and are acceptable.

6. "Important To Safety" Comqone m Guideline: Generic Letter 83-28 st4tus that licensee / applicant equipment classification programs should include (in addition to the safety-related components)abroaderclassofcomponentsdesignatedas"Importantto Safety." However, since the generic letter does not require licensee /

applicant to furnish this information as part of their response, staf f review of this sub-item will not be performed. (Item 2.2.1.6)

7. Program j Guideline:

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Licensees / applicants should confinn that an equipment classification program exists which provides assurance that all safety-related components -

are designated as safety-related on plant documents such as drawings,

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procedures, system descriptions, fest and maintenance in'structions, operating procedures, and informatiod 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 ana constrafrits. (Item 2.2.1)

Evaluation:

The licensee's response to these requirements was contained in submittals

< ,; dated November 4,1983 and February 8,1985. These submittals describe the license,'s, proyram for identifying and classifying safety-related equipment and i:otepw-ents which meets, the staff requirement as indicated in the preceding sub-item evaluations.

Conclusion:

We conclude that the licensee's program addresses the staff concerns regardingequipmentandcomponentclassifica'tfcnandisacceptabid.

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3.0 REFERENCES

1. NRC Letter, D. G. Eisenhut to all Licenseec of Operating

,4eactors, Applicants for Operating License and Holders of s

r Construction Permits, "Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28),"

. July 8, 1983. ,

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2. Virginia Electric and Power Company Letter, W. L. Stewart to H. R. Denton, NRC, November 4,1983, Serial Number 617,

3. Virginia Electric and Power Companj ' Letter, W. L. Stewart to H. R. Denton, NRC, February 8,1985, Serial Number 85-063.

Dated: .tarch.4, 1933

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EGG-NTA-7379 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

NORTH ANNA-1 AND -2 Docket Nos. 50-338 and 50-339 R. Vander8eek Published April 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.

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Prepared for the U.S. Nuclear Regulatory Commission Washington, D.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 submittals from North Anna Power Station, Unit Nos. I and 2 for conforraance to Generic Letter 83-28, Item 2.2.1.

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i l Docket Nos. 50-338 and 50-339 l

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FOREWORD This report is suppiled as part of the orogram for evaluating licensee / applicant conformance to Generic Letter 83-28 ' Required Ar.tions Based on Generic Implications of Salem ATWS Events." This work is being conducted for the 11.S. Nuclear Regulatory Commission, Of fice 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. 06001.

t Docket Nos. 50-338 and 50-339 TAC Nos. 53693 and 53694

CONTENTS ABSTRACT .....................<........................................ 11 FOREWORD .............................................................. iii 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 .................................................. 3

4. ITEM 2.2.1.1--IDENTIFICATION CRITERIA ............................ 4 4.1 Guideline ................................................... 4 4.2 Evaluation .................................................. 4 4.3 Conclusion .................................................. 4

5. ITEM 2.2.1.2--INFORMATION HANDLING SYSTEM ........................ 5 5.1 Guideline ................................................... 5

-5.2 Evaluation .................................................. 5 5.3 Conclusion .................................................. 5

6. ITEM 2.2.1.3--USE OF EQUIPMENT CLASSIFICATION LISTING ............ 6 6.1 Guideline ................................................... 6 6.2 Evaluation .................................................. 6 6.3 Conclusion .................................................. 6

7. ITEM 2.2.1.4--MANAGEMENT CONTROLS ................................ 7 7.1 Guideline ................................................... 7 7.2 Esaluation .................................................. 7 7.3 Conclusion .................................................. 7

8. ITEM 2.2.1.5--DESIGN VERIFICATION AND PROCUREXENT ................ 8 8.1 Guideline ................................................... 8 8.2 Evaluation .................................................. 8 8.3 Conclusion .................................................. 9

9. ITEM 2.2.1.6- "IMPORTANT TO SAFETY" COMPONENTS ................... 10 9.1 Guideline .. ................................................ 10

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

11. REFERENCES ....................................................... 12 iv i

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

E0VIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

NORTH ANNA-1 AND -2

1. I.1TRODUCTION On February 25, 1983, both of the scram circuit breakers at Unit 1 of the Salem Nuclear Power Plant failed to open upon an autematic reactor trip i 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 1 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 NRC 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 Comission (NRC)

I 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 the generic issues raised by the analyses of these two ATWS events.

l This report is an evaluation of the responses submitted by Virginia l Electric and Power Company, the licensee for the North Anna Power Station, Unit Nos. I and 2 for Item 2.2.1 of Generic Letter 83-28. The document reviewed as a part of this evaluation is listed in the references at the end of this report.

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3. ITEM 2.2.1--PROGRAM 3.1 Guideline j l

Licensees and applicants should confirm that an equipment classification program exists which provides assurance that all j 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 the North Anna Power Station, Unit Nos.1 and 2, responded to these requirements with submittals dated November 4, 1983 and February 8, 1985.3 These submittals include information that describes their existing 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. We have reviewed this information and note that the licensee's response does not directly confirm hat all components designated as safety-related in the equipment listing are also properly designated on documents, procedures, and in information handling systems used for safety-related activities. However, the licensee's response to Items 2.2.1.2 and 2.2.1.3 indicates that the documents used to control safety-related activities from start to finish are appropriately marked as safety related. This is discussed in Sections 5.2 and 6.2. 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 I the licensee's response is adequate.

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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 response 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 Evaluation The licensee's response states that the information handling system consists of station administrative Procedure ADM2.1 which contains a listing of safety-related structures, systems, and components. The listing contained in the procedure does not provide a detailed listing of every component of safety-related systems but provides a general breakdown by system and major component parts. Subcomponents of safety-related systems are considered to be safety-related. The procedure containing the list is a controlled station document and requires the review and approval of the Station Nuclear Safety and Operating Committee (SNSOC). Where questions arise during classification of specific structures, systems or components, requests are forwarded to the station engineering staff for resolution.

Appropriate reviews are required prior to the removal from or addition to the list.

The licensee indicates that development of a new and more complete listing of safety-related components is in planning but no specific date for completion has been set.

5.3 Conclusion 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 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 response states that the Quality Assurance Department performs audits of activities covered by the plant instructions and procedures. Thus, the audit program provides verification of the routine utilization of the information handling system.

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

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I apply te this procurement cycle. The difference is primarily in the area of approval for monetary comitments and expenditures.

8.3 Conclusion We consider the licensee's response to be complete and is acceptable.

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10. CONCLUSION Based on our review of the licensee's response to the specific requirements of Item 2.2.1, Equipment Classification Program for All Other Safety-Related Components, 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 as noted in Section 9 of this report.

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This EG&G Idaho, Inc., report provides a review of the submittals from the Virginia Electric and Power Company regarding conformance to Generic Letter 83-28 Item 2.2.1 for the North Anna Power Station.

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