ML20215H670

Conformance to Generic Ltr 83-28,Item 2.2.1 - Equipment Classification for All Other Safety-Related Components, Prairie Island 1 & 2, Technical Evaluation Rept

ML20215H670
Person / Time
Site:	Prairie Island
Issue date:	04/30/1987
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20214Q481	List: ML20214Q477 ML20215H670
References
CON-FIN-D-6001 EGG-NTA-7422, GL-83-28, NUDOCS 8704300244
Download: ML20215H670 (16)

Text

- - - - - - -

5

, EGG-NTA-7422 April 1987 INFORMAL REPORT I

' idaho '

National' CONFORf1ANCE TO GENERIC LETTER 83-28, ITE!1 2.2.1--

. Engineering -) EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMP 0NENTS: PRAIRIE ISLAND-1 AND -2 Laboratory Managed

'"I ## Alan C. Udy Department '

ofEnergy 3

?

O EBsGn.

p Prepared for the Work performed under -

oorC=uea U.S. NUCLEAR REGULATORY COMMISSION No. DE-AC07-76tD01520 l _. -

E--,.-

gro+'scomf xA

l c> , j l

l 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 implied, or assumes any legal liability or responsibility for the accuracy, comp 6eteness, or usefulness of any information, apparatus, product or process disclosed, or represents that its use would not intnnge pnvately owned rights. References herein to any speofic commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessanly constitute or imply its endorserrent, recommendation, or favonng by the United States Government or any agency thereof. The views and opinions of authocs expressed herein do not necessanly state or reflect those of the United States Government or any agency thereof.

i e

S e

l l

EGG-NTA-7422 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

PRAIRIE ISLAND-1 AND -2 Docket Nos. 50-282/50-306 Alan C. Udy Published April 1987

) Idaho National Engineering Laboratory EG&G Idaho, Inc.  ;

Idaho Falls, Idaho 83415 4

l e

Prepared for the U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 l Under DOE Contract No. DE-AC07-76ID01570 FIN No. D6001 g-...e , , , - - - . - - . . . - _ . - - , - - , - - , - , , . ~ , - - - - , . -

2 N

ABSTRACT

~

This EG&G Idaho, Inc., report provides a review of the submittals from the Prairie Island Nuclear Generating Plant, Unit Nos. I and 2, regarding conformance to Generic Letter 83-28, Item 2.2.1.

1

.i l

4 l

'i l

Docket Nos. 50-282/50-306 TAC Nos. 53705/53706 11

- . . - - p , _y - - ,--- +

7-- -y ,- - - , y.- -r- , , ,- 7 7 y ,,-- ., - , g,7

1 i

a , FOREWORD 1

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 lof 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 No. 20-19-10-11-3, FIN No. 06001.

i 1

Docket Nos. 50-282/50-306 TAC Nos. 537051/53706 fii

CONTENTS -

,i ABSTRACT .............................................................. 11-FOREWORD .............................................................. i ii

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

2. REVI EW CONTENT AND FO RMAT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 ........................... 4 4.1 Guideline .................................................. 4 4.2 Evaluation ................................................. 4 4.3 Conclusion ................................................. 4 l 1

5. ITEM 2.2.1.2'- INFORMATION HANDLING SYSTEM ....................... 5 5.1 Guideline .................................................. 5 5.2 Evaluation ................................................. 5 I

5.3 Conclusion ................................................. 5 l J

J

6. ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING . . . . . . . . . . . 6 6.1 Guideline .................................................. 6 6.2 Evaluation ................................................. 6 6.3 Conclusion ................................................. 6 ,

i 7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS ............................... 7 7.1 Guideline .................................................. 7 7.2 Evaluation ................................................. 7 l 7.3 Conclusion ................................................. 7 1

8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ............... 8 )

i 1

8.1 Guideline .................................................. 8 8.2 Evaluation ................................................. 8 8.3 Conclusion ................................................. 8

9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS .................. 9 0

9.1 Guideline .................................................. 9

~

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

11. REFERENCES ....................................................... 11 l iv 1

1 I

h 9

, _ . , - . , , _ . . . m. . - . .- . , - . , _ _ . - -- .-__

__..-_,.__m. _ , , ,, __ _%, _

,.__7_.___.., - 4 .m

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-PELATED COMPONENTS:

PRAIRIE ISLAND-1 AND -2

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 manually by the operator almost coincidentally with the autematic trip.

Following these incidents, on February 28, 1983, the NRC Executive Director for Operations (EDO), directed the NRC staff to investigate and i 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) 1 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 the generic issues raised by the analyses of these two ATWS events.

This report is an evaluation of the responses submitted by the Northern States Power Company, the licensee for the Prairie Island Nuclear

. Generating Plant, 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.

1

l l

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 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.

4 e

f #

=

l t

I l 2 l

l

l

3. ITEM 2.2.1 - PROGRAM 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 Prairie Island Nuclear Generating Plant responded to these requirements with a submittal dated November 4, 1983.2 Additional information was provided on March 31, 1987.* These responses referred to internal documentation, procedures and work instructions that had been submitted separately. These submittals include information that describe the licensee's safety-related equipment classification program (Q-list). 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. We have reviewed the licensee's submittals. The Plant Component Data Files (Q-list extension) is the control element that identifies safety-related structures, systems and components. Procedure SACD 2.1, " Quality Assurance Program Boundry,"

requires the use of this data base in the performance of plant activities, modifications and maintenance.

3.3 Conclusion

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

3

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 gives the criteria used for identifying safety-related equipment and components in Administrative Control Directive (ACD) 5ACD 2.1. A component is considered safety-related (Class I) 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.

Additionally, the licensee has identified other considerations and guidance that are used in determining the safety-related-status for structures, systems and components.

4.3 Conclusion 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.

i f

h j

l H

4 l r

. . . , - - - - - - ~ , - , - - . . , - -

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 submittals address how the Q-list and extensions were originally prepared and verified, how revisions to the Q-list and extensions are made and how new safety-related items are entered.

Additionally, procedure SACD 4.5 states, in Section 6.3.3, that only authorized users may enter, delete or request processing of the transaction file cata.

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.

a 5 x

_ ~ - _ _ _ _ . . _ . -. __ _ - _ _ _ _ _ _ _ _ .

l

6. ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING 6.1 Guideline i

) 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 i

handling system to determine that an activity is safety related and what -

- procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10 CFR 50, Appendix B, apply to safety-related components.

6.2 Evaluation j The licensee's response lists ACDs that regulate safety-related work.

~

The N1AWI 6.1.x series procedures, " Uniform Nuclear Procurement Process,"

are stated to be the controlling procedures. They require that the list of i safety-related components be consulted before any maintenance, testing,

design changes, engineering support, cetpoint changes or special tests or -

studies are initiated. This ensures that safety-related equipment receives i the proper treatment during maintenance and operation.

l 6.3 Conclusion We find that the licensee's description of plart administrative l controls and procedures meets the requirements of'this item and is, therefore, acceptable.

i l

4 i

i i

I i

) 6

. s , v.

t}

s-7 j

7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS ,

t 't

! 1 i 7.1 Guideline r ,

i t i $

The appYicant er jice!see should confirm that the management controls used to verify that the prpcoduces for preparation, validation and routine utilization of the (oformatien.ha.ndling system have been followed'.

y ( ,e . .

l'i , 7.2 Evaluation ,

Thelicensee(sresponsetothksitemreferstoSACD2.2," Internal

k. Audits." This dir' ctis'a e

addresses the' management procedures and controls

,\ that verify complianc.e with, thE other administrative control directives.

l,. .

\;

<t ' 7.3 Conclusion

'f' We find that the management. controls used by the licensee assure that s the information handling system is maintained, is current and is used as

/ intended.

a h

l e

l 7

l l

l I

8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline The applict.nt'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 submittal refers to 5ACD 7.1 and it, in turn, calls out five Power Production Directives and Instructions regarding procurement activities. The Q-list and Q-list extensions are called out to verify the safety-related status of the item being procured. These instructions require receipt inspection to assure that any specified testing was done as required. N1AWI 6.1.5, " Requisition Contents," specifically requires that the verification of design capability (environmental qualification) and evidence of testing (that qualifies the safety-related components and parts for service under the expected conditions for its service life) be specified as part of purchase requisitiens.

8.3 Conclusion The licensee's response for this item is considered complete. The information provided addresses the concerns of this item and is acceptable. ,

i i

I 8

l 9

i

9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS 9.1 Guideline Generic Letter 83-28 states that the licensee's equipment i I

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 to furnish this information as part of their response ~, review of this item will not be performed.

9

- -_. __ _ _ - . _ - _ ._ - .._.__ . . _ _ . - . . . . . ~ .

10. CONCLUSION 1

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.

1 4

5 r

0 e

10

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 Implications of Salem ATWS Events (Generic Letter 83-28)," July 8, 1983.

2. Letter, Northern States Power Company (D. M. Musolf) to NRC, " Generic

. Implications of Salem ATWS Events (Generic Letter 83-28)," November 4, 1983.

3. Letter, Northern States Power Company (D. Musolf) to NRC, " Response to NRC Request for Further Information on NSP Response to Generic Letter 83-28, Items 2.2.1 and 2.2.2," March 31, 1987.

a

• 11

,,,,-..,r,,,, . - - - , ,, , , , - , ,-, ,.,7 .

U.S. NUCLEAR AtOULAfon y - _ -- i mtPORT NuMetR #Amyierer TiOC. ear ver No., rears 8eAC POntI 238 _

' EGG-NTA-7422 hh3$'- BIBUOGRAPHIC DATA SHEET StE INSTRUCTIONS ON Two mtvenst 3 76TLE ANO suet TLE J Ltavt BLANE CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED a cATE atPOaT COMPuito COMPONENTS: PRAIRIE ISLAND-1 AND -2 ,tA.

MO TN l '

. . AuT eO.,s, April 1987

. oATE =tPOaf .ssuto Alan C. Udy vtaa MONT April l 1987 a

, Pt APORMiNG ORGANi2ATION NAME A8eo MaeLING ADORiSS ffarmemte Gesed a PROJSCTITAsaruv0mE useti Nuuetm EG&G Idaho, Inc.

P. O. Box 1625 . pin Oa GaA,.i Nu ta Idaho Falls, ID 83415 D6001 14 SPONSORING ORGANi2 ATION NAME AND M4sLsNG ADDRESS fiarmeen,Je Cepps iia TYPtOFREPORT Division of PWR Licensing - A Office of Nuclear Reactor Regulation """'***'"'*"*"'~~~""

U. S. Nuclear Regulatory Commission Washington, DC 20555 12 $UPPLEMtNT ARY peOTES 13 ALSTR ACT (Jap -ores er >esas This EG&G Idaho, Inc., report provides a review of the submittals from the Northern States Power Company regarding conformance to Generic Letter 83-28, Item 2.2.1 for the Prairie Island Nuclear Generating Plant. l l

1 l

l 1

l ie DOCUMENT AN ALvsis . utvwomcs otscmierons it Ava As Lif v Unlimited Distribution 16 SECup.Tv CLAS$r88 CATION r.,o >

, ,ot T,,,t s,On, vect o n Ms Unclassified e rn., mem Unclassified i,Nuo.l.O. , AGE.

i Pa.cl l