ML20215H665

Conformance to Generic Ltr 83-28,Item 2.2.1, 'Equipment Classification for All Other Safety-Related Components,' Main Yankee, Technical Evaluation Rept

ML20215H665
Person / Time
Site:	Maine Yankee
Issue date:	04/30/1987
From:	Vanderbeek R EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20214Q451	List: ML20214Q447 ML20215H665
References
CON-FIN-D-6001 EGG-NTA-7436, GL-83-28, NUDOCS 8704280672
Download: ML20215H665 (18)

Text

y 1 1 .

EGG-NTA-7436 April 1987 2

INFORMAL REPORT

' idaho  ?

National '

TECHNICAL EVALUATION REPORT, CONFORftANCE TO Engineering 4 GENERIC LETTER 83-28 ITEM 2.2.1, -- EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED Laboratory COMPONENTS: MAINE YANKEE Managed E # '

R. VanderBeek Department ofEnergy sr

" EGEGu.r Presented for the

,,,.gfggg U.S. NUCLEAR REGULATORY COMMISSION

= _ - - - - - __

e DISCLAIMER This book was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or imphed, or assumes any legal liabihty or responsib*lity 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 commercal product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessanly constitute or irrply 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 these of the United States Government or any agency thereof.

1 l

st

. l l

l

E GG-NTA-7436 l 1

)

i k

TECHNICAL EVALUATION REPORT l CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1, --

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

MAINE YANKEE Docket No. 50-309 l

R. VanderBeek Published April 1987 I

i 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. 06001

.___ _ _ _ _ __ - _ _ _ _ __ __-_____________-__--_______-__.___-____-________-_-__---____-____J

-1 e

4'

~

j t

I i

1 A8STRACT 4

l This EG&G Idaho, Inc.. report provides a review of the submittal from l

Maine Yankee Atomic Power Plant for conformance to Generic Letter 83-28, Item 2.2.1.

]

l i

i i

1 i

f l Docket No. 50-309 4

i TAC No. 53686 1

l

- - . . . _ -,e ,.r._.----,,,,,.r,-- ..e, - - , -c-., - - . +,,- y

~9-w4-- , , . - , . , ,.-,m,-,, - - - - , - . - - . . - , - -

.-,-ve .,-- ,--ym-,---.,w-. . .%- - - - - - -

. - = - __ . .. _.

\

i

a 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 Comaission funded this work under the authorization B&R No. 20-19-10-11-3, FIN No. 06001. ,

I 1

Docket No. 50-309 i

TAC No. 53686 iii

CONTENTS ASSTRACT .............................................................. 11 FOREWORD .............................................................. 111

1. INTRODUCTION ..................................................... 1

2. REVIEW CONTENT AND FORMAT ........................................ 2 ~

i

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 ............................ 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 I 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 ................................................. 8

7. ITEM 2.2.1.4--MANAGEMENT CONTROLS ................................ 9 7.1 Guideline .................................................. 9 7.2 Evaluation ................................................. 9 7.3 Conclusion ................................................. 9

8. ITEM 2.2.1.5--DESIGN VERIFICATION AND PROCUREMENT ................ 10 8.1 Guideline .................................................. 10 4 8.2 Evaluation ................................................. 10

~

8.3 Conclusion ................................................. 11

9. ITEM 2.2.1.6- "IMPORTANT TO SAFETY" COMPONENTS ................... 12 .

9.1 Guideline .................................................. 12

10. CONCLUSION ....................................................... 13 i

11. REFERENCES ....................................................... 14 iv i

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

! EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS MAINE YANKEE

1. INTRODUCTION 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 l to be related to the sticking of the undervoltage trip attachment. Prior to this incident, on February 22, 1983, at l'ait 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 l 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 (EDO), 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 unit incidents are reported in NUREG-1U00,"GenericImplicationsoftheATWSEventsattheSalemNuclear s

) Power Plant." As a result of this investig5 tion, the Commission (NRC) requested (by Generic Letter 83-28 dated Jcly 8, 1983 I) all licensees of

~

. J operating reactors, applicants for an* operating licensk, and holders of constructionpermitstorEqpondtothegbericissuesraisedbythe.

analyses of these two AT,WS events. j .,

A i 3

This report is~an evaluation of the responses submitted by Maine

/ .

YankeeAtomicPowerCompany,thelicens'edfortheMaineYan,keeAtomicPower

~

Plant for Item 2.2.1 of Generic Letter 83-28. The docusiwnt reviewed as 'a; i

part z of this evaluation is listed in the references at thetend of this rehdr t'. / \ \

f g

7 k '4

. . -.u s - - - .  %. .1. -

2. 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 sub-item within this report. ,

As previously indicated, each of the six sub-items of Item 2.2.1 is i 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.

e e

O 2

3. ITEM 2.2.1--PROGRAM 3.1 Guideline Licensee and applicarts 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 Evalaution The licensee for the Maine Yankee Atomic Power Plant responded to these requirements with a submittal dated November 10, 1983. This submittal included information that describes their existing 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.

The licensee's response has not directly confirmed that all

]

safety-related components and parts are identified as safety-related on all relevant, plant documents and procedures used for 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 appropriately marked safety-related. This is discussed in detail in sections 5.2 and 6.2 of this report. We consider this to be acceptable.

3

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

?

S j =

l 4

4 1

4

-. .- - = . - . - - - -.. _ _ _ -. . _ - _ - -

4. ITEM 2.2.1.1--IDENTIFICATION CRITERIA 4.1 Guideline i

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 i

The licensee's response states that the criteria for determining safety-related structures, systems, and components are contained in ANSI j Standard N18.2 for mechanical systems components and structures and in IEEE Standard 279 and 308 for electrical systems and components.

4.3 Conclusion i

The licensee's response to this sub-item is considered to be complete and is acceptable.

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's response states that the information handling system used to identify safety related components is a designated subset of controlled plant drawings. These drawings show, in detail, the safety I

5 l , _ . . . - . _ , .,_ -

classification of all safety-related plant systems and components. Early in plant operation, Maine Yankee developed this subset of drawings for this purpose. Identification of safety classification was performed by Maine Yankee engineering personnel familiar with the details of plant design.

The safety classifications recorded on the drawings were based on the ,

classification criteria. The drawings were independently reviewed by the Nuclear Services Division (YNSD) of Yankee Atomic Electric Company. YNSD ,

had served as plant design coordinator throughout the entire plant design, construction, and licensing process and was intimately familiar with the plant design and safety analyses. Following this independent review, the drawings were issued as controlled documents for use in determining system and component safety classifications. These drawings are revised, reviewed and appro'ved in accordance with administrative controls as design changes are implemented, then reissued on controlled distribution to ensure access to current safety classification information. When a design change is being developed, administrative controls provide for coordination of information indicating that a change is in process prior to issuance of final revised drawings. This ensures that safety classification decisions using these drawings are based on the most current information.

. It appaars that the concerns of this sub-item are addressed in the licensee's existing program.

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

l p

i 1

\

l 1

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 an activity is safety-related.

4 6.2 Evaluation The licensee's response states that nonrepetitive activities, like plant repairs and design changes are governed by general safety class procedures. These procedures require a determination of the safety classification of systems and components being worked on in the intitial stages of carrying out the repair or change procedure for the specific task. When it is determined that safety class components are involved, this safety classification information is propagated forward through all subsequent activities, which are conducted in accordance with safety class i procedures based on the quality assurance plan.

Repetitive activities, like surveillance, are governed by  ;

activity-specific procedures which have been safety classified during the l process of development. Those repetitive activities which involve safety l class systems and components are safety class - those which do not involve  !

safety class systems and components are classified non-safety.

o In both cases, safety classification is based on the information handling system. For non-repetitive activities, the drawings are utilized in accordance with procedure 0-00-4; this procedure is used in conjunction with other procedures to determine the safety classification of'the activities. For repetitive activities, the drawings are used in accordance l

l l

7 1 \

with procedure 0-00-4, 0-06-1 and 0-06-2 to ensure the correct safety classification of the specific repetitive activity, i

6.3 Conclusion We consider the licensee's response to this sub-item to be complete and is acceptable. .

W

<t' e

8

7. ITEM 2.2.1.4--MANAGEMENT CONTROLS 7.1 Guideline The applicant or licensee should confirm that the management 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 the procedures which govern utilization, validation, and preparation of the information handling system provide for independent review and approval of the governed activities.

The review and approval process covers the full scope of safety-related actions including designation of safety classification. These reviews and approvals are conducted by engineering and/or quality assurance personnel depending on the specific task.

In addition to the engineering and quality assurance reviews mentioned above, Maine Yankee utilizes a three tiered system of audits, surveillances and inspections to monitor activities. Drawing control and updating is audited annually and portions may be covered in more than one audit.

Surveillance is performed on a random basis and includes drawing control.

Inspections of design changes include verifying as-built configurations to the job drawings. A final review of the design change documentation package is performed by quality assurance personnel. l 1

7.3 Conclusion l

The licensee's response to this item is considered to be complete and

- is acceptable. ,

9

8. ITEM 2.2.1.5--DESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline The licensee's submittals shall show that the specifications for 9

procurement of replacement safety-related components and parts require that verification of design capability and evidence of testing that qualifies ,

the components and parts for service under the expected conditions over the service life specified by the supplier is included.

8.2 Evaluation The licensee's response states that the procurement initiating documents used for all procurement indicates explicitly the safety class, seismic qualification, and environmental qualification levels for the items to be procurred. Processing of the procurement documents cannot be completed until this information is specified. The procurement procedure requires that the specific qualification criteria and standards for demonstrating satisfaction of the criteria be transmitted in writing to the vendor.

The procurement documents also require the vendor to provide written proof that demonstrates the criteria are met in accordance with the specified standards. The vendor's conformance with the qualification criteria is documented by qualification statements and reports which have been previously reviewed or are reviewed in receipt inspection by quality assurance personnel. Engineering personnel are consulted in the review of qualification documentation when requested.

Safety class components are purchased from vendors who have approved quality assurance programs which contain appropriate provisions for design verification. Maine Yankee audits these vendors for compliance with the quality assurance program. -

10

! Maine Yankee has its own safety class procedure for design

! verification which would be carried out prior to placing an order should Maine Yankee choose to conduct the design verification.

8.3 Conclusion W

We consider the licensee's response to be complete and is acceptable.

11

9. ITEM 2.2.1.6- "IMPORTANT TO SAFETY" C0FPONENTS 9.1 Guideline The Generic Letter 83-28 states that the licensee'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 applicant / licensee to furnish this information as part of their response, staff review of this sub-item will not be performed.

e 12

l i

10. CONCLUSION i l

1 Based on our review of the licensee's response to the specific l requirements of Item 2.2.1, Equipment Classification Program for All Other Safety-Related Components, we find that the information provided by the licensee to resolve the concerns of Items 2.2.1 of Generic Letter 83-28 is '

acceptable.

Item 2.2.1.6 was not reviewed as noted in section 9 of this report.

e l

l

)

13  :

. 3

s

11. REFERENCES i

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

deneric Letter 83-28)," July 8, 1983.

2. Maine Yankee Atomic Power Company letter, C. D. Frizzle to -

J. R. Miller, NRC, November 10, 1983, MN-83-232.

i l

2 14

8smC PCnes 338 UA 8sWCLtan meeULATom y --- __ i atPomi muassem (AssgesW Dy If0C, est Ved We,#f eart

, BIBLIOGRAPHIC DATA SHEET EGG-NTA-7436 Sig isesTauCTsONS ON Tiet mtytasa 3 TaTLt amo lueilTLE J Leavt Staseet

- TECHNICAL EVALUATION REPORT, CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1, -- EQUIPMENT CLASSIFICATION FOR

• o'" ""o" ' a"" a ALL OTHER SAFETY-RELATED COMPONENTS: MAINE YANKEE uo.s f. vtam l

, a tut omsi Apri1 1987 R. VanderBeek T., vtam

, April l 1987 7 PtopOnassesG OmGamizafiom maut aseo wasumG aODatSS isarawale Cases e PROJECTtTASE/vuOmn usesT muassen EG&G Idaho, Inc.

P. O. Box 1625 Idaho Falls, ID 83415 D6001

10. SromSOntNG OmGaNilaTION hanf t AND MalLING aDORESS tsarawarte Cams tle. TVPS 08 MEP0mf Division of Systems Integration Technical Evaluation Report Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission . Pa'a covalo u---,

Washington, DC 20555 e2 SurettMENTan? MOTES 13 atsimaCT #20D weest er'esad This EG&G Idaho, Inc. report provides a review of the submittals from Maine Yankee for conformance to Generic Letter 83-28 Item 2.1 (Part 1) Equipment Classification (RTS Components).

I l

1 e

14 DOCUutMT AN AL*Ss3 e E E

• womOS DESca+*T0*e5 il avantagiuf v

$TaTEMENT A

Un1imited i Distribution 16 SicymeTvCLaS$IFICATION IThe on.or

. .onfi..ws,o,e= ncio nnus Unclassified  ;

< r..e , ,

Unclassified I ir svueen os e*GrS j l

. is emict I

L