ML20214G408

Conformance to Generic Ltr 83-28,Item 2.1 (Part 1), Equipment Classification (Reactor Trip Sys Components), Selected GE BWR Plants (Cooper,Dresden 2 & 3,Fermi 2 & Fitzpatrick)

ML20214G408
Person / Time
Site:	Dresden, Fermi, Cooper, FitzPatrick, 05000000
Issue date:	03/31/1986
From:	Haroldsen R EG&G IDAHO, INC.
To:	NRC
Shared Package
ML20214G411	List: ML20214G408 ML20215D982 ML20215E006
References
CON-FIN-D-6001 EGG-NTA-7178, GL-83-28, TAC-52829, TAC-52834, TAC-52835, TAC-52838, NUDOCS 8605220072
Download: ML20214G408 (12)

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1 EGG-NTA-7178 I

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CONFORMANCE TO GENERIC. TETTER 83-28 ITEM 2.1 (PART 1) EQUIPMENT CLASSIFICATION (RTS COMP 0NENTS)

SELECTED GENERAL ELECTRIC BOILING WATER REACTOR PLANTS i

T COOPER DRESDEN 2 ANO 3

. FERMI 2 FITZPATRICK R. Haroldsen I

- Published March 1986 EG&G Idaho, Inc.

Idaho falls. Idaho 83415 I

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Prepared for the

! U.S. Nuclear Regulatory Comission j Washington 0.C. 20555

• Under 00E Contract NO. OE-AC07-761001570 FIN Nos. 06001 and 06002 sc , , .' O y n

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ABSTRACT

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This EG66 Idaho, Inc. report provides'a review of the submittals from selected operating and applicant Boiling Water Reactor (SWR) plants for conformance to Generic Letter 83-28 Item 2.1 (Part 1). The following plants are included in this review.

I Plant Name Docket Number Tac Number

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7 50 298 52829 Cooper -

Dresden 2

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50 237 52834 ,

Oresden 3 50 249 52835 Fermi 2 50 341 --

FitzPatrick 50 333 52838 4

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FOREWORD 7

This report is supplied as part,of the program for evaluating licensee / applicant conformance to Generic Letter 83-28, ' Required Actions

, Sased on Generic Implications of Salem ATWS Events." This work is being e

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conducted for the U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation. Division'of PWR Licensing-A, by the EG6G Idaho, Inc.

4 The U.S. Nuclear Regulatory Commission funded this work under the authorization B&R 10-19-19-11-3, FIN Nos. 06001 and D6002.

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CONTENTS

, A85 TRACT .............................................................. 11 FOREWARD .............................................................. 111

1. INTRODUCTION AND

SUMMARY

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2. PL ANT RE SPONSE E VALUATI 0NS' . . . . . . . . . . . . . .". . . . . . . . . . . . . . . . . . . . . . . . . 3 0

2.1 Cooper ..................................................... 3 2.2 Conclusior ................................................. 3

. . 2.3 Oresden 2 sad 3 ............................................ 4 2.4 C onc l u s i c.n . . . . . . . . . . . . . . . . . . . . '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2.5 Ferst .................'..................................... 5 2.6 Conclusion ................................................. 5 T

- 2.7 Fit Patrick ........../...'.................................. 6 2.8 Conclusion ..............,.................................. 6

3. : GENERIC REFERENCES ...............................................

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1. INTRODUCTION AND SUMNARY On February 25, 1983, both of the scram circuit breakers at Unit 1 of the Sales 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, an automatic trip signal was generated at Unit 1 of the Sales 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

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Directive Director for Operations (EDO), directed the staff to inve'stigate and report on the generic implications of the occurrences at Unit 1 of the Sales Nuclear Power Plant. The resuits of the staff's inquiry into the i

generic implications of the Salem Unit 1 incirlents are reported in I

NUREG-1000, " Generic Implications of the ATWS Events at the Sales Nuclear Power Plant. " As a result of this investigation, the Commission (NRC) requested (by Generic Letter 83-28, dated .luly 8, 1983 ) all licensees of f

I operating reactors, applicants for an operating license, and holders of construction permits to respond to generic issues raisediby the analyses of these two ATWS events.

l This report is an evaluation of the responses submitted from a j selected group of Boiling Water Reactors (BWRs) for Item 2.1 (Part 1) of Generic Letter 83-28.

l The results of the review of four individual plant responses are combined and reported on in this document to enhance review efficiency.

Th'e specific plants reviewed in this report were selected based on the convenience of review. The actual documents which were reviewed for each 1

C' evaluation are listed at the end of each plant evaluation. The generic s -

documentsreferenced'1Nthisreportarelistedattheendofthereport. '

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,2, Part 1 of Item 2.1 of Generic Letter 83-28 requires the licensee or a/ , applicant to con' firm that all reactor trip system components are vf6 identified, classified, and treated as safety-related, as indicated in the I , following statement:

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t s Licensees and applicants shall confirm that all components whose

?_ " functioning is required to trip the reactor are identified as

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safety-related on documents, procedures, and information handling I'"4 '

- systems used in the plant to control safety-related activities,

,,\ including maintenance, work orders, and parts replacement.

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2. PLANT RESPONSE EVALUATIONS 2.1 Cooper 298 TAC No. 528?9 The licensee for the Cooper Nuclear Plant (Nebraska Public Power District) responded to the requirements of Item 2.1 (Part 1) of Generic iletter 83-28 in a submittal dated July 1, 1985. The licensee confirmed

that the Equipment Data File (EDF) had been reviewed and verified that all reactor system components were classified as safety-related. The licensee stated that the Equipment Data File (EDF) is the system generally used to control maintenance, work orders, and parts replacement. Essentially the

. same procedures are used to control station procedures, drawings, and vendors manuals, with no differences in procedure for safety-related or non-safety related systems.

T 2.2 Conclusions Based on a review of the license'e's submittal, we find that the

- -- licensee's response confirms that the components required to trip the reactor have been designated safety-related. However, we are unable to verify that documents and procedures relating to components required for reactor trip conform to the requirements of safety related procedures. We, i' therefore, find that the licensee's response does not meet the requirements t

of Item 2.1 (Part 1) of Generic Letter 83-28, and is unacceptable.

The Licensee shall ccnfirm that all components whose functioning is

,5 required to trip the reactor are identified as safety-related on documents, procedures, and information handling systems used in the plant to control safety-related activities, including maintenance, work orders, and parts replacement.

REFERENCE

1. Letter, J. M. P11 ant, Nebraska PUblic Power District, to -

D. 8. Vassallo, NRC, July 1, 1985.

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s 2.3 Dresden Units 2 and 3 -- 50-237 and 50-249 TAC Nos. 51234 and C2835 The licensee for Dresden Units 2 and 3 (Commonwealth Edison Co.)

responded to the requirements of Item 2.1 (Part 1) with submittals dated November 5, 1983, and July 26, 1985. The licensee emphasized that the components whose functioning is required to trip the reactor do not include all reactor trip components (e.g., some turbine trip components). However, the licensee confirmed that those components which must function to trip the reactor are classified in the licensing-basis documentation as safety-related. The licensee also confirmed that the safety-related components are identified in applicable documents, procedures, and information handling systems. -

2.4 Conclusion Based on the review of the licensee's submittals, we find that the 4

licensee's responses state thatla system has been implemented to verify that those components that are necessary to perform a reactor trip are classified as safety-related and that such components are verified as safety-related in all relevant plant documentation. These responses.-

therefore, meet the requirements of Item 2.1 (Part 1) of Generic

Letter 83-28, and are acceptable.

REFERENCES

1. Letter, P. L. Barnes, Commonwealth Edison Co., to H. R. Denton, NRC, November 5, 1983.

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2. Letter g.L. Alexander,CommonwealthEdisonCo.,toH.R.Denton, NRC, a ... . .- 26, 1985.

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2.5 Feret Unit 2--50-341 (0L1 The applicant for the Enrico Fermi, Unit 2. Nuclear Plant (Detroit Edison Company) provided an initial response to Item 2.1 (Part 1) in a submittal' dated November 3, 1983. In this response, the applicant stated that all active components that function to implement a reactor scram had been identified and that the documents and procedures used to control safety-related activities, including maintenance, work orders, and parts replacement, were being reviewed to ensure that these components are appropriately identified as safety-related. The applicant also stated their intention to complete the review and correct any deficiencies. The  ;

licensee estimated this task would be completed by April 1, 1984. l In a subsequent submittal, dated Julu 5,1985, the applicant confirmed that the review had been completed and that the results indicated that I ~

their component classification system, administrative controls, and'

' procedural practices meet the requirements of Item 2.1 (Part 1).

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2.6 Conclusion Based on the review of the applicant's submittals, we find that the applicant's responses confirm that the components required to trip the reactor have been identified as safety-related and that the components are

' designated as safety-related in all relevant documents. These responses, i therefore, meet the requirements of Item 2.1 (Part 1) of Generic Letter 83-28, and are acceptable.

l REFERENCES

1. Letter, W. H. Jens Detroit Edison Co., to B. J. Youngblood, NRC, i November 3, 1983.

2. L t er, W. H. Jens, Detroit Edison Co., to B. J. Youngblood, NRC, 5, 1965. .

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2.7 FitrPatrick -- 50-333 TAC No. 52838 The licensee for the James A. FitzPatrick Nuclear Plant (New York Power Authority) provided responses to the requirements of Item 2.1 (Part 1) in three submittals dated November 9, 1983 June 29, 1984, and s July 2, 1985. The initial submittal pr'ovided the results of a preliminary i

ravlev of the items of concern. In subsequent submittals, the licensee stated that til components of the reactor protection system are classified is QA Category 1 (safety-related), except for the motor generator sets.

Other systL?s which have components that form part of the reactor trip

. systm.4 were also reviewed to verify that the components of concern were classified as QA Category 1. The licensee determined that all reactor trip function components are classified-as QA Category 1.

The licensee performed a review of the documents, procedures, and jr - Informatter handling systems used to control safety-related activities in

- 4 the plant. These activities include saintenance, work requests, pa'r ts

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replacement, and plant modifications.'

The program implemented by the licensee does not require a classification of safety-related for documents such as vendor manuals and 4

drawings, nor does is require explicit identification of safety-related components on these documents. The program does, however, include extensive administrative control which requires identification of all documentation relating to safety-related activities.

1 2.8 Conclusion Based on the review of the licensee's submittals, we find that the licensee's responses confirm that the components required to trip the reactor have been designated safety-related. While the licensee's program does not require identification of safety-related components on all documents, we find that the administrative control requiring all

! safety-related activities to be identified is acceptabe. These responses, therefore, meet the requirements of Item 2.1 (Part 1) of Generic -

Letter 83-28, and cre acceptable.

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c REFERENCES

1. Letter, J. P. Bayne, New York Power Authority, to D. B. Vassallo, NRC, November 9, 1983.

2. Letter, J. P. Bayne, New York Power Authority, to 0. B. Vassallo NRC, June 29, 1984.

3. Letter, J. P. Bayne, New York Power Authority, to D. B. Vassallo NRC, July 2, 1985.

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3. GENERIC REFERENCES

1. Generic Implications of ATWS Events at the Sales Nuclear Power Plant, NUREG-1000 Volume 1. April 1983; Volume 2. July 1983.

2. NRC Letter. D. S. Eisenhut,to all Licensees of Operating Reactors.

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Applicants for Operating License, and Nolders of Construction Permits.

" Required Actions Based on Generic Implications of Salem ATWS Events l (Generic Letter 83-28)." July 8,1983.

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