ML20214Q850

Conformance to Generic Ltr 83-28,Item 2.2.1--Equipment Classification for All Other Safety Related Components:Fort Calhoun-1, Final Informal Rept

ML20214Q850
Person / Time
Site:	Fort Calhoun
Issue date:	04/30/1987
From:	Vanderbeek R EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20214Q834	List: ML20214Q831 ML20214Q850
References
CON-FIN-D-6001 EGG-NTA-7425, GL-83-28, TAC-53673, NUDOCS 8706050225
Download: ML20214Q850 (21)

Text

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. EGG-NTA-7425 i April 1987 4

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Idaho ,

~ National CONFORMANCE TO GENERIC LETTER 83-28 ITEM 2.2.1--

EngineerinF EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY Laboratory  ; RELATED COMPONENTS: FORT CALHOUN-1  !

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DISCLAIMER This book was prepared as an account of work sponsored by an agency of the United States Government. Neitner the United States Government nor any agency thereof.

nor any of theer employees, makes any warranty, express or imphed, or assumes any legal habihty or responsibihty 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 commeretal product, process, or service by trade name, trademark, tranufacturer, or otherwise, does not necessanly constitute or imply its endorsement, recommendation, 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 United States Government or any agency thereof.

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EGG-NTA-7425 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

FORT CALHOUN-l Docket No. 50-285 R. VanderBeek Published April 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415

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Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. 06001

ABSTRACT This EG&G Idaho, Inc. report provides a review of the submittal for the Fort Calhoun Nuclear Station for conformance to Generic Letter 83-28, Item 2.2.1.

4 Docket No. 50-285 TAC No. 53673 11 1

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O FOREWORD This report is supplied as part of the program for evaluating licensee / applicant conformance to Generic Letter 83-28 " Required Actions 8ased on Generic Implications of Salem ATWS Events." This work is being conducted for the U.S. Nuclear Regulatory Comission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Idaho, Inc.

The U.S. Nuclear Regulatory Comission funded this work under the authorization B&R 20-19-10-11-3, FIN No. 06001.

Docket No. 50-285 TAC No. 53673 iii

CONTENTS ABSTRACT .............................................................. 11 FOREWORD .............................................................. iii o 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

4. ITEM 2.2.1.1 - IDENTIFICATION CRITERIA ........................... 5 4.1 Guideline ..................................................

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 CLASSIFICATION LISTING ........... 7 6.1 Guideline .................................................. 7 6.2 Evaluation ................................................. 7 l

t 6.3 Conclusion ................................................. 7 1

7. ITEM 2.2.1.4 . MANAGEMENT CONTROLS ............................... 8 l

7.1 Guideline .................................................. 8 o

7.2 Evaluation ................................................. 8 l ,

l 7.3 Conclusion ................................................. 9 l

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8. -ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ............... 10 8.1 Guideline .................................................. 10 8.2 - Evaluation ................................................. 10 8.3 Conclusion ................................................. 10

9. . ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS .................. 11

. 9.1 Guideline .................................................. 11

10. CONCLUSION ....................................................... 12

11. REFERENCES ....................................................... 13 1

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

FORT CALHOUN-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 attachnent. 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 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 (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 generic issues raised by the analyses of these two ATWS events.

This report is an evaluation of the response submitted by the Omaha Public Power District for Fort Calhoun Nuclear Station for Item 2.2.1 of Generic Letter 83-28. The actual document reviewed as a part of this evaluation is 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 including supporting

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information, in considerable detail, as indicated in the guidelines preceding the evaluation of each item. ,

As previously stated, each of the six 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.' - 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 maintenance instructions and in information handling systems so that personnel performing activities that affect such safety-related components are aware that they are working on safety-related components and are guided by safety-related procedures and constraints. 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 Fort Calhoun Nuclear Station provided a response to Generic Letter 83-28 on November 4, 1983. This submittal included information that describes their safety-related equipment classification program. In the review of the licensee's response to this item, it was l assumed that the information and documentation supporting this program is available for audit upon request.

The licensee has provided a description of the equipment l

classification program for the identification of safety-related components and activities for repair, maintenance, and procurement. However, the response does not directly confirm that all components designated as safety-related in the Q-list are also properly designated on plant l documents, procedures and in the information handling systems used for

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safety-related activities. However, the licensee's response to Item 2.2.1.2 and 2.2.1.3 indicate that the documents used to control safety-related activities from start to finish are marked as l' safety-related. This is discussed in Sections 5.2 and 6.2 of this report.

We consider this to be acceptable.

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3.3 Conclusion l

We have reviewed the licensee's information and, in_ general, find that the licensee's response is adequate.

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4. ITEM 2.2.1.1 - IDENTIFICATION CRITERIA 4.1 Guideline The applicant or licensee should confirm that their program used for equipment classification includes criteria used for identifying components as safety-related.

4.2 Evaluation The licensee's response provides a description and supporting information on the criteria used to determine whether a structure, system, or component is safety-related. For the electrical and instrumentation equipment, the response specifies that the criteria used are based on (1) the station FSAR, (2) the station QA Manual, (3) the station piping and instrumentation diagrams, elementary diagrams, loop diagrams and logic diagrams, and (4) IEEE Standards IEEE-Std-279, 308, 328, 344, 379, 384, and 420.

For the mechanical equipment and component criteria, the response indicates that the ALAE Section III code applies. The response also states that the ASME Section III code is in transition from a component concept to a system concept. For the mechanical criteria, the response identifies a special safety class which corresponds to a safety-class 3 in ANSI N18.2 for items which do not fall within the guidelines of the ASME Section III code.

4.3 Conclusion The licensee's response to this item is considered to be 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 response states that the Omaha Public Power District's present methods for identifying safety-related components involve the proper utilization and application of five documents. These are (1) the interim electrical CQE list, (2) the station piping and instrumentation diagrams, (3) the station structural drawings, (4) the Fort Calhoun Station Unit No. 1 Technical Specifications, and (5) the Fort Calhoun Station Unit i updated Safety Analysis Report. Item 1, 2, and 3 are controlled by the station engineering procedure A-9, " Document Control".

The licensee's response states that the Omaha Public Power District is in the process of implementing a program to provide a computerized maintenance control and equipment history.

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

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6. ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING r 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 Omaha Public Power district personnel utilize (1) the interim electrical CQE list, (2) the station l' piping and instrumentation diagrams, (3) the station structural drawings, (4) the Fort Calhoun Station Unit No. 1 Technical Specifications, and (5) the Fort Calhoun Station Unit No. 1 updated Safety Analysis Report as required by procedures, Station Standing Orders, Fort Calhoun Station Operating Manual, Quality Assurance Department Manual. Purchasing Manual, Generating Station Engineering Manual, and Technical Services Manual.

Collectively, these documents define programs, record handling systems, administrative controls and procedures to permit District personnel to perform necessary plant functions and maintain a high level of quality at all times. Included in these functions are maintenance, preventive maintenance, testing, modifications, purchasing, records, requirements, audits, equipment storage, reviews, and approvals. Collectively, these

processes contain controls to ensure that safety-related equipment is

! identified as such and handled in an appropriate manner.

6.3 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 Guidelines Managerial controls that will be used by the licensee to verify that the information handling system for equ',pment 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 equi pment cl assif icat on i as intended s ah ll be described. The h 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 The licensee's response states that the management controls to verify

. the proper preparation, validation, and use of the CQE list are on two levels. These two levels are (1) direct sanagement interaction with the day-to-day procedures and (2) independent audits to verify compliance with f

the various District-governing documents. The four areas of maintenance, surveillance testing, station modification, and purchasing are adequately controlled. Each of these areas has included in the governing procedures required involvement of District supervisory and management personnel in the review cycle to ensure compliance. New surveillance test procedures are reviewed by the Plant Review Committee (PRC) and approval by the Plant Manager. Modification Requests require both Generating Station Engineering (GSE) sanagement and plant staff review. Purchasing requires quality review and management approval.

. Independent audits serve to reinforce the management controls. Audits are performed by QA, the SARC (Safety Audit and Review Committee), INP0, _

Ame. Nuclear Insurers and the NRC. These provide management with information to judge compliance with controlling documents and proper ,

application.of these documents.

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

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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 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 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 District has defined requirements for purchasing in the Purchasing Manual. The individual initiating the purchase order is responsible for identifying the quality (qualification requirements) data necessary. These purchasing documents L are reviewed by QA and appropriate supervisory and management personnel.

Appropriate specifications are included with the purchasing document (s).

For electrical equipment located in a harsh environment the District is-complying with 10 CFR 50.49 by the guidelines outlined in Standing Order G-17A. As part of this work, the District will also implement a qualified life program by December 1, 1983 for harsh environment electrical equipment.

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

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9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS 9.1 Guideline 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, 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 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 meets the requirements of Generic Letter 83-28 and is acceptable. Item 2.2.1.6 was not reviewed by the staff 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. Omaha Public Power District letter, W. C. Jones, to D. G. Eisenhut, NRC, November 4, 1983, LIC-83-267.

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Washington, DC 20555 12 Sur,Lipthf.M. NOTES

1) LOSTm.Cf tJ00 weres er vess This EG&G Idaho, Inc., report provides a review of the submittal from the Omaha Public Power District regarding conformance to Generic Letter 83-28 Item 2.2.1 for the Fort Calhoun Nuclear Station.

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