ML20214R206
| ML20214R206 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/30/1987 |
| From: | Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20214R199 | List: |
| References | |
| CON-FIN-D-6001 EGG-NTA-7330, GL-83-28, TAC-53665, NUDOCS 8706080020 | |
| Download: ML20214R206 (19) | |
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s EGG-NTA-7330 April 1987 INFORMAL REPORT I
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Idaho i
CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
Eng/neer/nf EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-Laboratory RELATED COMPONENTS:
DAVIS-BESSE l
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DISCLAIMER This boct was prepared as en account of work eponsored by en egency of the Uruted States Government, P4either the Uruted States Government not any agency thereof, nor any of their employas, makes any warranty, empress er implied, or enumes arrf legal 16ebsty or responsibaty for the accuracy, completenou, or usefulness of any information, apparatus product or procou d.sclosed, or represents that its use would not intnnge pnvetely owned rights. Refrences here+n to any specife commercel product, process, or serwce by trade name, trademark, manufacturer, or otherwise, does not necouanly constitute or imply its endorsement, recommendation, or favonng by the United States Government or any agency thereof. The vows entf opinions of authors espressed here+n do not eccessardy state or reflect those of the Urwted States Government or any agency thereof.
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EGG-NTA-7330.
TECHNICAL EVALUATION REPORT.
a CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
DAVIS-BESSE-1
>l Docket No. 50-346 Alan C. Udy Published Apr11 1987 Idaho National E ineering Laboratory EG&G I ho, Inc.
Idaho falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Under DOE Contract No. DE-AC07-761001570 i
FIN No. 06001
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A8STRACT This EG&G Idaho, Inc., report provides a review of the submittals from Unit No. 1 of the Davis-Besse Nuclear Power Station for conformance to Generic Letter 83-28, Item 2.2.1.
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TAC No. 53665 t1 2
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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., NRR and I&E Support Branch.
The U.S. Nuclear Regulatory Commission funded this work under the authorization B&R 20-19-10-11-3, FIN No. D6001.
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Docket No. 50-346 TAC No. 53665 111 l
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CONTENTS ABSTRACT..............................................................
11 FOREWORD..............................................................
111 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...........................
5 4.1 Guideline..................................................
5 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 6.3 Conclusion.................................................
7 7.
ITEM 2.2.1.4 - MANAGEMENT CONTROLS...............................
8 7.1 Guideline..................................................
8 7.2 Evaluation.................................................
8 7.3 Conclusion.................................................
8 8.
ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT...............
9 8.1 Guideline..................................................
9 8.2 Evaluation.................................................
9 8.3 Conclusion.................................................
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ITEM 2.2.1.6 "IMPORTANT-TO-SAFETY" COMPONENTS..................
-10 9.1 Guideline..................................................
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- 10. CONCLUSION.......................................................
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REFERENCES.......................................................
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l CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
DAVIS-BESSE-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 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 nunually 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 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 l
permits to respond to the generic issues raised by the analyses of these two ATWS events.
This report is an evaluation of the responses submitted by the Toledo Edison Company, the licensee for Unit No. 1 of the Davis-Besse Nuclear Power Station, for Item 2.2.1 of Generic Letter 83-28.
The documents reviewed as a part of this evaluation are listed in the references at the end of this report.
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REVIEW CONTENT AND FORMAT Item 2.2.1 of Generic Letter 83-28 requests the licensee or applicant to submit, for the staff review, a description of their programs for safety-related equipment classification including supporting information, in considerable detail, as indicated in the guideline section for each
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sub-item within this report.
As previously indicated, 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 the programs of the licensee or applicant for safety-related equipment classification are drawn.
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ITEM 2.2.1 - PROGRAM i
3.1 Guideline Licensees and applicants should confirm that an equipment classification program exists which provides assurance that all 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 Davis-Besse Station responded to these requirements with submittals dated December 9, 1983 and June 10, 1985.
These submittals include information that describes the licensee's 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.
2 The licensee states that their Q-list and Equipment Data Base is the information handling system referred to and are on the system and component level respectively. The licensee has stated that safety-related components are identified as such on supportive, approved plant documents, drawings and procedures.
3.3 Conclusion I
We find that the licensee's responses are in general, adequate. The licensee states that the equipment classification information handling system consists of a component and system level listing of safety-related 3
components and parts.. The licensee also states that safety-related parts-and components are listed as such on plant documents, drawings and procedures used for~ safety-related activities.
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ITEM 2.2.1.1 - IDEtlTIFICATION 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 gives the criteria for identifying safety-related cquipment and components. A component is considered safety-related if it is required to assure:
(a) the integrity of the reactor coolant. system pressure boundary, (b) the capability to achieve and maintain a safe shutdown or (c) the capability to prevent or to mitigate the consequences of an accident which could result in potential-offsite exposures.
4.3 Conclusion
'I We find that the criteria used in the identification of safety-related components meets the requirements of Item 2.2.1.1 and are acceptable.
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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 informattor, 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 states that the information handling system includes the use of the Q-list, supplemented by controlled drawings and other source l
documents.
It is being converted to the equipment data base, a part of the Davis-Besse usintenance management system. Further, the licensee states that the equipment data base is maintained and updated by procedures that are being deveioped. Data being entered is done in accordance to l
procedures. The entry data is compared against source documents and verified by a second individual.
5.3 Conclusion We find that the information contained in the licensee's submittals is sufficient for us to conclude that the licensee's information handling system for equipment classification meets the guideline requirements.
Therefore, the information provided by the licensee for this item is-acceptable.
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ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING 6.1 Guideline The licensee's or applicant's description should confirm that their program for equipment classification includes criteria and procedures which govern how station personnel use the equipment classification information handling system to determine that an activity is safety-related and what 4
procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10 CFR 50, Appendix B, apply to safety-related components.
1 6.2 Evaluation 1
The licensee's responses describe the utilization of the Q-list to determine when an activity is safety-related. The licensee states administrative procedure AD 1844.00 " Maintenance," requires the consultation of the Q-list or the computerized information handling system 1
(when fully developed) in determining if an activity is safety-related as part of the maintenance work order system.
This procedure is used in preparing any work requests for those activities identified by this sub-item. The reviews called out by AD 1844.00 insure that the proper j
procedures are used for maintenance work, routine surveillance testing, accomplishment of design changes, performance et engineering support work, accomplishment of setpoint changes and the performance of special tests and studies. Administrative procedure AD 1847.00, " Station tlaterials Control,"
is described as controlling safety-related materials.
Other procedures are listed that govern material receipt inspection and for evaluating a vendors capabilities.
6.3 Conclusion We find that the licensee's description of plant administrative controls and procedures meets the requirements of this item and is, therefore, acceptable.
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ITEM 2.2.1.4 - MANAGEMENT CONTROLS -
7.1 Guideline The applicant or licensee should confirm that the nunagement 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 their method of managerial control includes verifying procedural compliance in regard to the information handling system, and review and approval of any safety-related administrative procedures. The audit program of the Quality Assurance Department is also used to verify the preparation, validation and routine use of the information handling system and to assure that safety-related activities and their implementation are correct. Audit reports are
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approved and then distributed to cognizant personnel.
7.3 Conclusion We find that the management controls used by the licensee assure that the information handling system is maintained, is current and-is used as intended. Therefore, the licensee's response for this item is acceptable.
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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 i
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 states that the purchase orders for safety-related items contain design verification and qualification testing requirements for both replacement parts and new equipment. The required testing is identified by the. Facility Engineering Department and reviewed and approved by the Quality Engineering Department. The requirement for the vendor to submit evidence of testing is specifically addressed by the licensee, and requires qualification reports from the vendor.
8.3 Conclusion We consider the licensee's response for this item to be complete. The information provided addresses the concerns of this item and is acceptable.
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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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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 Items 2.2.1.1, 2.2.1.2, 2.2.1.3, 2.2.1.4 and 2.2.1.5 meet the requirements of Generic Letter 83-28 and is acceptable.
Item 2.2.1.6 was not reviewed as noted in Section 9.1.
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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 Implications of Salem ATWS Events (Generic Letter 83-28)," July 8, 1983.
2.
Toledo Edison Company, letter, R. P. Crouse to Director of Nuclear Reactor Regulation, NRC, December 9,1983, Serial No.1012.
3.
Toledo Edison Company, letter, R. P. Crouse to Director of Nuclear Reactor Regulation, NRC, June 10, 1985, Serial llo. 1158.
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CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS: DAVIS-BESSE
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This EG&G Idaho, Inc., report provides a review of the submittals from the Toledo Edison Company regardin.g conformance to Generic Letter 83-28, Item 2.2.1, for Davis-Besse.
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