ML20214Q749

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Conformance to Generic Ltr 83-28,Item 2.2.1 - Equipment Classification for All Other Safety-Related Components: Rancho Seco Unit 1, Informal Technical Evaluation Rept
ML20214Q749
Person / Time
Site: Rancho Seco
Issue date: 04/30/1987
From: Vanderbeek R
EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:
NRC
Shared Package
ML20214Q726 List:
References
CON-FIN-D-6001 EGG-NTA-7321, GL-83-28, NUDOCS 8706050149
Download: ML20214Q749 (19)


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'- I EGG-NTA-7321 Jj April 1987

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  • CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

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. Engineering cf EQUIP!1ENT CLASSIFICATION FOR ALL OTHER SAFETY-i.'

RELATED COMPONENTS: RANCHO SECO-1 Laboratory 1 a

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U.S. NUCLEAR REGULATORY COMMISSION No. DE-AC07-MID01570 .:

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ssp DISCLAIMER This book was prepared as an account of work sponsored by an ageK:y of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or imolied, or assumes any legal hability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus. product or process disclosed, or represents that its use would not infnnge pnvately owned nghts. References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessanly constitute or imply its endorsement, recommendat on, or favonng by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessanly state or reflect those of the Uruted States Govemment or any agency thereof.

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EGG-NTA-7321 TECHNICAL EVALUATION REPORT l CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

RANCHO SECO-1 Docket No. 50-312 R. Vander8eek l

Published April 1987 l

Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415  !

Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 under DOE Contract No. DE-AC07-76ID01570 FIN No. D6001 1

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ABSTRACT This EG&G Idaho, Inc. report provides a review of the submittals for the Rancho Seco Nuclear Generating Station, Unit No. 1 for conformance to Generic Letter 83-28, Item 2.2.1.

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- Docket No. 50-312 TAC No. 53709 11

e 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.

- Docket No. 50-312 TAC No. 53709 tii

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 .................................................  ?
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 Evaluation ................................................. 7 7.3 Conclusion ................................................. 7 iv
8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ............... 8 8.1 Guideline .................................................. 8 6.2 Evaluation ................................................. 8 8.3 Conclusion ................................................. 8

. 9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS .................. 9 9.1 Guideline .................................................. 9 b

10. CONCLUSION ....................................................... 10
11. REFERENCES ....................................................... 11 d

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

RANCHO SECO-1

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 determined to be related to the sticking of the undervoltage trip attachment. Prior i 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 J 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 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 Commission (NRC) requested I '

(by Generic Letter 83-28 dated July 8, 1983 ) all licensees of operating reactors, applicants for an operating license, and holders of construction l permits to respond to generic issues raised by the analyses of these two 3 ATWS events.

, This report is an evaluation of the responses submitted by the Sacramento Municipal Utility District for Rancho Seco Nuclear Generating Station, Unit No. 1 for Item 2.2.1 of Generic Letter 83-28. The actual documents reviewed as a part of this evaluation are listed in the references at the end of this report.

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2. REVIEW CONTENT AND FORMAT Item 2.2.1 of Generic Letter 83-28 requests the licensee / applicant to submit, for staff review, a description of their programs for classification of their safety-related equipment includes supporting information, in considerable detail, as indicated in the guidelines .

l preceding the evaluation of each sub-item.

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As previously stated, each of the six sub-items of Item 2.2.1 is evaluated in a separate section in which the guideline is presented; an evaluation of the licensee's/ applicant's response is made; and conclusions about its acceptability are drawn.

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3. ITEM 2.2.1 - PROGRAM 3.1 Guideline Licensee and applicants should confirm that an equipment classification program is in place which will provide assurance that all safety-related components are designated as safety-related on plant

. documentation such as procedures, system descriptions, test and maintenat.ce 1

instructions and in information handling systems so that personnel a

performing activities that affect such safety-related components are aware that they are working on safety-related components and are guided by l safety-related procedures and constraints. Licensee and applicant responses which address the features of this program are evaluated in the remainder of this report. I 3.2 Evaluation l

The licensee for Rancho Seco Nuclear Generating Station Unit No. 1 provided a response to Generic Letter 83-28 on November 4, 1983 , 2 May 23,19853 and December 3, 1986.* These submittals included information that describes their 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.

3.3 Conclusion The staff concludes that all the basic requirements of the equipment classification program are in place and address the concerns of the items of Item 2.2.1 of Generic Letter 83-28.

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4. ITEM 2.2.1.1 - IDENTIFICATION CRITERIA 4.1 Guideline The criteria for identifying components as safety-related should be presented. This should include a description of means for handling
  • sub-components or parts as well as procedures for initiating the identification of components as safety-related or non-safety related if no previous classification existed.

4.2' Evaluation The licensee's submittal provides the classification criteria used to determine whether a structure, system or component is safety related. This is consistent with the definition given in Item 2.2.1. The licensee identified the procedure used to initiate the identification of components as safety-related or nonsafety-related if no previous classification existed.

4.3 Conclusion The licensee's response to this item is complete and is 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 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 describes the information handling system used for identifying safety-related components as a computerized method of listing, tracking, and retrieving maintenance information on plant equipment. This system is known as the Maintenance Information Management System (MIMS).

The MIMS consists of the Master Equipment List (MEL), the Drawing Index, the Spare Parts System, the Work Request System, the Auxiliary Tables System, and the Veador List System. Administrative procedure AP.42 defines the MIMS content, the responsibility and authority for adding, changing, or deleting information and the method of making changes.

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

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6. 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 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 section 2.1 of Quality Assurance Procedure QAP3, " Quality Assurance Classification", establishes a procedure for classifying systems, structures, subassemblies, components and design characteristics so as to establish the degree of quality assurance activity related to their manufacture, erection, installation, maintenance, or in-service inspection. It also establishes that Nuclear Engineering determines the classification of systems and components. The MEL is used for this. In addition administrative procedure AP.3 requires 1) that a work request be submitted for documentation of maintenance, modifications, and other work items, and 2) the QA class of the item be recorded on the l l

work request. The cognizant engineer determines what procedures are required for the work based on the QA class specified on the work request.

The licensee states that all procedures are reviewed by the Plant Review  :

1 Committee (PRC).

6.3 Conclusion The licensee's response to this item is complete and is acceptable. ,

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7. 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 l

The licensee's response states that the Rancho Seco Technical l

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Specifications, Item 6.5.2.8.d require that the Management Safety Review Comittee audit the QA program. Quality Control Instruction QCI.2 l describes the Q4 audit program. The purpose of this program is to provide l for systematic, planned audits of nuclear safety-related aspects of operation, maintenance, inspection, testing, modification, administration and the nuclear operations, testing, modification, administration and the nuclear operations quality assurance program to verify that they are in accordance with their respective license requirements. The result of audits and corrective action are reported to management. The Nuclear Executive Director determines the effectiveness of the QA program based on this information.

7.3 Conclusion l

We find the licensee's response to this item complete and is

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8. 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 apprcpriate design verification and qualification -

testing is specified for the procurement of safety-related components and

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parts.. The specifications should include #qualificatien testing for expected safety service conditions and provide support for the applicant's/ licensee'sreceipt.oftestingdocumentationtosuhportthe 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 included within his response Quality Control Instruction QCI-4 which defines the method whereby quality class requirements are evaluated and documented. The procedure applies to QA Class 1 parts and materials.

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

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9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS 9.1 Guidel in,e, 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, sipce 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 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 meet 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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11. REFERENCES
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 ATWS Events (Generic Letter 83-28)," July 8, 1983.

- 2. Sacramento Municipal Utility District letter, R. J. Rodriguez to D. G. Eisenhut, NRC, November 4, 1983, RJR 83-725.

3. Sacramento Municipal Utility District letter, R. J. Rodriguez to H. L. Thompson, Jr. , NRC, May 23, 1985, RJR 85-269.
4. Sacramento Municipal Utility District letter, J. A. Ward to F. J. Miraglia, Jr., NRC, December 3, 1986, JEW 86-901.

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"o,"l# BIBUOGRAPHIC DATA SHEET sta sNSTmuCTIONS 08. THE REVER$t 2TITLtANOSuSTTLE J LEAwaOLANE CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED

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- April 1987 7 PG A,OmassNG onGami2ATION Naut ANO MA8UNG ADDatSS isacerarle Cass# 8 PROJECTITasavuuOmn uMIT NuesSEA EG8G Idaho, Inc.

P. O. Box 1625 .

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Washington, DC 20555 12 $UPPLtutNTany NOTil IJ ASSTRACT t10D weres er eses This EG&G Idaho, Inc., report provides a review of the submittals from the Sacramento Municipal Utility District regarding conformance to Generic Letter 83-28, Item 2.2.1 for the Rancho Seco Nuclear Generating Station, Unit No. 1.

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