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l SAFETY EVALUATION REPORT GENERIC 1.ETTER 83-28. ITEM 2.1 (PART 11 l
EQUIPMENT CLAS5IFICATION (RT5 COMPONENT 5)
PILGRIM NUCLEAR POWER STATION f
j DOCVET N05. 50-293 INTRODUCTION AND SU W RY 1
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On February 25, 1983, both of the scram circuit breakers at Unit 1 of the Salem f
l Nuclear Power Plant failed tu open upon an automatic reactor trip signal from I
the reactor protection system.
Tnts incident was terminated manually by the q
l operator about 30 seconds after the initiation of the at,tomatic trip signal..
The failure of the circuit breakers was detemined to be related to the sticking f
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of the undervoltage trip attachment.
Prior to this incident, on February 22, 1983, at Unit 1 of the Sa1.m Nuclear Power Plant, an automatic trip signal was' j
generated based on steam generator low low level during plant start-up.
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l this case, the reactor was tripped manually by the operator almost coin-
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cidentally with the automatic trip.
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1 Following these incidents, on February 28, 1983, the NRC Executive Director for I
Operations (E00), directed the staff to investigate and report on the generic j
implications of these occurrences at Unit 1 of the Salem Nuclear Power Plant.
I The results of the staff's inquiry into the generic implications of the Salem unit incidents are reported in NUREG-1000. "Generic Ip911 cations of the ATWS Events at the Salem Nuclear Power Plant." As a result of this investigation.
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the Cocmission (NRC) requested (by Generic Letter 83 28 dated July 8,1963 )
all licensees of oHrating reactors, applicants for an operating license, and i
j holders of construction pemits to respond to generic issues raised by the analyses of these two ATWS events.
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This report is an evaluation of the response submitted by Boston Edison Company, the licensee for the Pilgrim Nuclear Power Station, for Item 2.1 (Part 1) of Generic Letter 83-28. The actual documents reviewed as part of l
this evalcation are listed in the references at the end of the report.
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Item ?.1 (Part 1) requires the licensee to confim that all Reactor isin -
System components are identified, classified and treated as safety reisted f
as indicated in the following statement:
i Lice 9 sees and applicants shall confim that all components whose
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functioning is required to trip the reactor are identified as f
safety-related on documents, procedures, and information handling systems used in the plant to control safety related activities, in-f I
cluding maintenance, work orders, and parts replacement.
l EVALUATION The licensee for the Pilgrim Nuclear l'ower Station responded to the requirements l
ofItem2.1(Part1)withsubmittalsdatedNovember7,1983 and June 28, 1985.
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I The licensev stated in thw *ubmittals that all components that are required to perfom the reactor tr,7 we rtan were reviewed to verify that these components l
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are classified as safety-W.ed equipewnt in the plant Q list." The lit.ensee l
f further confirred that documents used to control activitias associated with this equipntat are identified as "Q" which designates the use of safety related procedures.
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. CONCLUSION Based on our review of these responses, we find the licensee's statements confirm that a program exists for identifying, classifying and treating-components that are required for performance of the reactor trip function as safety related. This program meets the requirements of Item 2.1 (Part 1) of the Generic Letter 83-28, and is therefore acceptable.
REFERENCES 1.
NRC Letter D. G. Eisenhut to all Licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits, "Required Accions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," July 8,1983, 2.
Letter, W. D. Harrington, Boston Edison Co., to D. B. Vassallo, NRC, November 7, 1983.
3.
Letter, W. D. Harrington, Boston Edison Co., to D. B. Vassallo, NRC, June 28, 1985.
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ENCLUbUKt IC5BSALPIHPLIT PLMT.
Pilgrim Nuclear Power Station
SUBJECT:
Review of G.L. 33-28 Item 2.1 (Part 1)
PERFORf1ANCE BASIS EVALUATION CATEGORY CRITERIA N/A No basis for assessment.
Management I:.volvement l
1 Appr ach was diract. and enabled ready verification of the acceptability of App M to their program.
Resolution of.
i Technical Issues
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The licensee described his program and confirmed its completion.
- . Responsiveness i
N/A No basis for assessment.
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,, g,,,c _ t History
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N/A I
No basis for assessment.
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Reportable Events y
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Staffing N/A No basis for assessment.
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N/A No basis for assessment.
7.-Training
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EGG-NTA -7188 Revised Draft CONFORMANCE TO GENERIC LETTER 83-28 I(!M 2.1 (PART 1) EQUIPMENT CLASSIFICATION (RT3 COMPONENTS)
SELECTED GENERAL ELECTRIC BOILING WATER REACTOR PLANTS HOPE CREEK PEACH BOTTOM 2 AND 3 PERRY l AND 2 PILGRIM 1 R. HAROLOSEN 1
Published September 1986 L
1 EG&G Idaho, Inc.
l Prepared for the U.S. Nuclear Regulatory Commission I
Washington, D. C. 20555 Under 00E Contract No. DE-AC07-761001570 FIN Nos. 06001 and 06002
ABSTRACT This EG&G Idaho, Inc. report provides a review of the submittals from selected operating and applicant Boiling Water Reactor (BWR) plants for conformance to Generic Letter 83-28, Item 2.1 (Part 1).
The following plants are included in this review.
plant J me Docket Number TAC Number Hope Creek 50-354 OL Peach Bottom 2 50-277 52865 Peach Bottom 3 50-278 52866 Perry 1 50-440 61705 Perry 2 50-441 OL Pilgrim 1 50-293 52867 L
FOREWORD This report is supplied as part of the program for evaluating licensee /appitcant conformance to Generic Let'ger 83-28, "Required Actions Based on Generic Implications cf Salem ATWS Events." This work is being conducted for the U. S. Nuclear Regulatory Comission, Office of Nuclear Regulation, Division of PWR Licensing-A, by the EG&G Idaho, Inc.
The U. S. Nuclear Regulatory Commission funded this work uder the authorization B&R 20-19-10-11-3 and 20-19-40-41-3, FIN Nos. 06001 and 06002.
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CONTENTS ABSTRACT..............................................................
11 FOREWORD..............................................................
11 1.
INTRODUCTION AND
SUMMARY
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PLANT RESPONSE EVALUATIONS......................................
3 2.1 Hope Creek.................................................
3 2.2 Conclusion.................................................
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2.3 Peach Bottom 2 and 3.......................................
5 2.4 Conclusion.................................................
5 2.5 Perry 1 and 2..............................................
6 2.6 Conclusion.................................................
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2.7 Pilgrim 1..................................................
7 2.8 Conclusion.................................................
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GENERIC REFERENCES.....'..........................................
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1 1.
INTRODUCTION AND
SUMMARY
On f ebru.iry 25, 1983, both of the scram circuit breakers at Unit 1 or' the Salem Nuclear Power Plant failed to cpeq upon an auto #aatic react,r trip signal from the reacto protectioir ayttem.
This incident was terr anated manually by the operator about 30 sece..os a'fieT ~the initiation of the automatic trip signal.
The failure of the circuit breakers Y, M at, ermined to be related to the sticking of the t:ndervoltage trip attachment. Priir" ~- %
to this incident, on February 22, 1983, an automatic trip signal was generated at Unit I of the Salem Nuclear Power Plant 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 implicattors of the occurrences at Unit 1 of the Salem niuclear Power Plant.
The results of the staff's inquiry into the generic implications of the Salem Unit 1 incidents are reported in NUREG-1000,
' Generic Inplications of the ATWS Events at the Salem Nuclear Power Plant.
- As a result of this investigation, the Cemis,sion (NRC) requested (by Generic Letter 83-20, dated July 8, 1983') all licensees of operating reacters, applicants for an operating license, and nciders of construction permits to respond to generic issues raised by the analyses of these two ATWS events %
This report is an evaluation of she forponses submitted from a selected group of Boiling Water Ret.; tors (BWRs) for Item 2.1 (Pa7t 1) of Generic Letter 83-28.
The results of the review of four individual plant responses ar4 combined and reported on in this document to el.tince review efficiency.
The specific plants reviewed in this report were selected based on the i
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colivraience of review.
Tne actual documents which were reviewed for each evaluation are listed at the end of each plant evaluation.
The generic documents referenced.in this report are listed at the end of the report.
Part 1 of item 2.1 of Generic Letter 83-28 requires the licensee or applicant to confirra that all reactor trip system components are identified, classified, and treated 4: safety-related, as indicated in the following statement:
- %.%, Licensees and applicants shall confirm that all components whose rt.?i % ';;o,is required to trip the reactor are identified as safety-relaGJ'hp4uments, procedures, and information handling I
d systems used in the pIEMuco,[ trol safety-related activities, including maintenance, work ordo s W.S prLs replacement.
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PLANT RESPONSE EVALUATIONS 2.1 Hope treek 50-354 (OL)
The appitcant for Hope Creek (Public Service Electric and Gas Company) provided responses to the requirements of Item 2.1 (Part 1) of Generic Letter 83-28 in submittals dated Marcr. 30, 1984, December 17, 1984 and May 21, 1985.
In the first submittal the applicant described their plan to develop a Master Equip-ent List (MEL) which would identify the components required to initiate reactor trip and designate these components as saf ety-related.
The MEL imposes quality assurance requirements for the safety-related components and is the controlling document for safety-related activit).').
The applicant stated intentions to be in compliance with Item 2.1 (Part 1) prior to September 1984.
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The second submittal reviewed progress to December 17, 1984 and
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outlined 4.cvised program which would meet the requirements of Item 2.1 (Fort 1) prior to March 1985.. The appiteant confirmed in th61r May 21, 1985 submittal that review of the reactor trip system had been completed and that reactor trip system components were verified to be classified safety-related on appropriate design documents, however, the MEL had not been completed for all components of the reactor trip system.
The applicant stated that this effort would be completed by September 30, 1985.
2.2 Cor.c lu s ion Based on a review of the applicant's submittals, we find that the applicant's responses confirm that components required to trip the reactor have been designated safety-related and that the MEL is used to control all activities relating to safety-related components. We, therefore, find that the applicant's responses meet the requirements of item 2.1 (Part 1) of Generic Letter 83-28, and are acceptable.
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I REFERENCES 1.
Letter, R.L. Mitti, Public Service Electric and Gas Co., to A.
Schwancer, NRC, Harch 30, 1984.
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Letter, R.L. Mitti, Public Service Electric and Gas Co., to A.
Schwencer, NRC, Decen.ber 17, 1984.
3.
Letter, R.L. Mitti, Public Service Electric and Gas Co., to W. Butler, NRC, ' Jay 21, 1985.
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2.3 Peach Bottom 2 50-277 TAC NO. 52865 Peuch Bottom 3 50-278 TAC NO. 52866 The licensee for Peach Bottom 2 and 3 (Philadelphia Electric Co.)
provided responses to the requirements of Item 2.1 (Part 1) cf Generic letter 83-28 in submittals dated November 4, 1983, April 23. 1984 and May 29, 1985.
The responses state that all systems that contribute to the reactor trip function have been identifie as safety-related in the current "Q"
d 11st and that all compnnents of safety-related systems are safety-related unless specifically excluded by safety evaluation.
The "Q' list is used to identify the applicable cudes, standards and procedures to be used for activities relating to the safety-related components.
Each item or seivice to be procured is reviewed to determine if it is safety-related.
Tha review is performed by a congnizant member of the plan i
staff or the EngineerTng and.R(;earch Department.
l 2.4 Conclusion Item 2.1 (Part 1) requires licenjees to confirm that all components whose functioning is required to trip the reactor are identified as l
I safety-related on documents, procedures, and information handling systems used in the plant te control safety-related activities, including maintenance, work erders, and parts replacement.
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Based on the lictntee's submittal we find that the list of components required to trip the reactor is incomplete. We also find that the licensee's program does not identify safety-related components on relevant plant documents. The response, therefore, does not meet the requirements of Item 2.1 (Part 1) of Generic Letter 83-28 and is unacceptable.
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REFERENCES 1
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Letter, S.L. Daltrof f, Philadelphia Electr ic Co., to D.G. Eisenhut, NRC, November 4, 1983.
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Letter, S.L. Daltroff, Philadelphia Electric Co., to 0.G. Eisenhut, NRC, April 23, 1984.
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Letter, S.L. Daltroff, Philadelphia Electric Co., to J.F. Stolz, NRC May 29, 1985.
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1.5 Perry 1 50-440 (OL) and Perry 2 50-441 (0L1 i
l The applicant for Perry 1 and 2 (Cleveland Electric Illuminating Co.)
provided responses to the requirements of Item 2.1 (Part 1) of Generic Letter 83-28 in submittals dated April 6, 1984 and August 28, 1985.
The applicant reported in the first submitt31 that the "Q'-Itst for the plants was undergoing review to verify the correct classification of safety-related components.
The "Q'-list is to be used to determine i'
classification for maintenance, work orders and procurement activities.
l The second submittal reported that the "Q'-list evaluation had been -
completed and that all numbered components from the 5 systems that contribute to the "factor trip function had been reviewed and classified as sarety-rniated or nonsafety-related.
The "Q'-list is the safety-related subset of the Perry Equipment Master Files System (PEMS) useo to determine the classification for work vrdsrs, maintenance and parts procurement.
2.6 Conclusion t
Based on the review of the applicant's submittals, we find that the applicant has verified th&t the components necessary to perform reactor 1
trip are classified as safety-related and that this classificatien program imposes safety-related procedures on work orders, maintenance, and procurement activitie:. We, therefore, find that the applicant's response meet the requirements of Item 2.1 (Part 1) of Generic Letter 83-28 and are acceptable.
REFERENCES I
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Letter P.R. Edelman, Cleveland Elet.tric Illuminating Co. to D.G.
Eisenhut, NRC, April 6, 1984.
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Letter, M.R. Edelman, Cleveland Electric Illuminating Co., to 8.J.
Youngblood, August 28, 1935.
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2.7 Pilaris 1. 50-293. TAC NJ. 52867 The licensee for Pilgrim 1 (Boston Edison Co.) provided responses to the requirements of Item 2.1 (Part 1) of Generic Letter 83-28 in submittals dated November 7, 1983 and June 28, 1985.
In the submittals the licensee I
confirmed that the components required to function for reactor trip ars identified in the plant "Q"-list and are controlled at a quality level which reflects the safety-related functions.
Documents (Purchase Orders, Maintenance Requests) used to control activities associated with the "Q' listed equipment are identified as "Q' which designates the use of safety-related procedures.
2.8 Conclusion Based on the review of the licensee's submittals, we find that the licensee has verified that the components necessary to perform reactor trip are classified as safety-related and that the classification program imposes safety-related procedures on maintenance and procurement activities relating to the components. We, therefore, find that the licensee's l
response meet the requirements of Items 2.1 (Part 1) of Generic Letter 83-28 and are acceptable.
REFERENCES t
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Letter, W.D. Harrington, Boston Edison Co., to 0.8. Vassallo, NRC, November 7, 1983.
2.
Letter, W.D. Harrington, Boston Edison Co., to 0.8. Vassallo, NRC, June 28, 1985.
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GENERIC REFERENCES 1.
Generic Imolications of ATWS Events at the Salem Nuclear Power Plant.
NUREG-1000, Volume 1, April 1983; Volume 2, July 1983, 2.
NRC Letter D.G. Eisenhut to all Licensees of Opet2 ting Reactors, Applicants for Operating License, and Holders of Construction Permits,
' Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," July 3, 1983.
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