ML20215L522

Final Conformance to Generic Ltr 83-28,Item 2.2.1 - Equipment Classification for All Other Safety-Related Components,Catawba Units 1 & 2, Informal Rept

ML20215L522
Person / Time
Site:	Catawba
Issue date:	05/31/1987
From:	Vanderbeek R EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20215L500	List: ML20215L498 ML20215L522
References
CON-FIN-D-6001, CON-FIN-D-6002 EGG-NTA-7327, GL-83-28, TAC-57742, NUDOCS 8706260083
Download: ML20215L522 (19)

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Waf/OD , 3 CONFORMANCE TO GENERIC LETTER 83-28 ITEM 2.2.1--

' EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY l

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i DISCLAIMER

,l 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 resportsibility for the accuracy, completeness, or usefulness of any information, apparatus, product or process disclosed, or represents that its use would not infnnge privately 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, recommendation, or favoring by the United States Governmant or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.

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EGG-NTA-7327' 1

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

CATAWBA-1 AND -2 R. VanderBeek Docket Nos. 50-413 and 50-414

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Published May 1987 )

l Idaho National Engineering Laboratory ,

EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 -!

1 Prepared for the U.S. Nuclear Regulatory Commission  :!

Washington, D.C. 20555 .

Under DOE Contract No. DE-AC07-761001570-FIN Nos. D6001 and'06002

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l ABSTRACT I

This EG&G Idaho, Inc., report provides a review of the submittals from )

1 Catawba Nuclear Station, Unit Nos. 1 and 2 for conformance to Generic j i

Letter 83-28, Item 2.2.1.

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1 Docket Nos. 50-413 and 50-414 i TAC No. 57742 I

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~f) REWORD 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,10ffice 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 Nos._ 20-19-10-11-3'and 20-19-40-41-3, FIN Nos. D6001~

and 06002.

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Docket Nos. 50-413'and 50-414 TAC No. 57742

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

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

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

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3. ITEM 2.2.1--PROGRAM .............................................. 3  !

3.1 Guiceline .................................................. 3 3.2 Evaluation ................................................. 3 .

3.3 Conclusion .................................................. 3 <

4. ITFM 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- j iv l 4 1

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

8 8.1 Guideline .................................................. 8 1 l l l

8.2 Evaluation ................................................. 8 8.3- Conclusion ............................. .................. 8~

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9. ITEM 2.2.1.6- "IMPORTANT TO SAFE TY" COMPONENTS . . . . . . . . . . . . . . . . . . . 9

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

10. CONCLUSION ....................................................... 10

11. REFERENCES ....................................................... 11 ,

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

E0VIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

CATAWBA-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 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-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 the generic issues raised by the analyses of these two ATWS events.

This report is an evaluation of the responses submitted by Duke Power Company, the licensee for the Catawba Nuclear Station, Unit Nos. 1 and 2 for Item 2.2.1 of Generic Letter 83-28. The 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 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 item within this report. .

As previously indicated, 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 conformance of the licensee or applicant is made; and conclusions about the programs of the licensee or applicant for safety-related equipment classification are drawn.

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) 3. ITEM 2.2.1--PROGRAM l

3.1 Guideline ]

Licensees and applicants should confirm that an equipment classification program exists which provides assurance that all l safety-related components are designated as safety-related on all plant documents, drawings and procedures and in the information handling system j that is used in accomplishing safety-related activities, such as work orders for repair, maintenance and surveillance testing and orders for j replacement parts. Licensee and applicant responses which address the  !

features of this program are evaluated in the remainder of this report. l 3.2 Evaluation The licensee for the Catawba Nuclear Station, Unit Nos. 1 and 2 I responded to these requirements with submittals dated November 4, 1983,'

February 2, 1984, and March 30, 1987. These submittals include i a

information that describes their existing safety-reiated equipment I classification program. In the review of the licensee's response to this item, it was assumed that the information and'dacumentation sunporting this program is available for audit uport request-The response states that the safety-related components are identified during the design phase and are desigr.ated as safety-related on applicable specifications, drawings, flow diagrams, purchase requisitions, and system descriptions. In addition, the licensee's work request system icientifies the classification of the system or component prior to any work being done. We consider this to be acceptable.

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

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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 the means for handling sub-components or parts, as well as procedures for initiating the ,

identification of components as safety-related or non-safety-re'tated if no previous classification existed.

4.2 Evaluation The itcensee's response states that the criteria for determining safety-related struc' ares, systems, and components are contained in the Catawba Nuclear Station Quality Standards Manual for Structures, Systems and Components. The criteria were included in the response and conform with the definition within Item 2.2.1 of Generic Letter 83-28.

4.3 Conclusion The licensee's response for 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 i equipment and that procedures exist which govern its development and validation.

5.2 Evaluation '

I The licensee states that the draft Station Manual received an interdepartmental review to ensure completeness and to serify accuracy.

l The licensee also defines.the process used in revising the Station Manual. l l

i The licensee has stated that the listing was originally prepared during the station's design phase. Changes to the station design are controlled to ensure that new safety-related items are identified with the same quality assurance program that identified these items in the original

,. station design. The procedure for revising the component lists is contained in the Quality Standards Manual.

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 1

1 The licensee's or applicant's description should confirm that their

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program for equipment classification includes criteria and' procedures which 3 govern how station personnel use the equipment classification information ,

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

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

l 6.2 Evaluation The licensee's. response provided a description of the station personnel's use of the Catawba Nuclear Station Quality Standards Manual for -!

Structures, Systems and Components. This manual contains the equipment I classification listings or makes reference to supplemental component lists. The procedures for preparing a work request (a prerequisite for maintenance activities) requires the use of the equipment classification information handling system to determine the safety classification of the equipment involved and the identification of the plant instructions and '!

procedures which are to be used for maintenance work, routine surveillance testing, accomplishment of design changes, and performance of special tests or studies.

6.3 Conclusion l

The licensee resporse for this item is considered to be complete and l is acceptable.

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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 l

l The licensee's response states that' management procedures and controls 1 cover the utilization of the quality standards documents at each station.

The Administrative Policy Manual for IJuclear Stations contains requirements .

for determining _the safety-related status of an affected item. 'Each '

-activity requires the determination and documentation of the safety status of the affected item and appropriate management approval is received in the

. documentation package. All documentation packages for activities affecting a safety-related structure, system, or component receive an 4

interdisciplinary station review including the_ Quality Assurance Department.

I 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 l

The applicant's er 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 l applicant's/ licensee's receipt of testing documentation to support the limits of life reconmended by 'the supplier. If such documentation is not available, confirmation that the present program meets these requirements should be provided. 4 l

8.2 Evaluation The licensee's response shows that the procurement specifications 1 f

require-the supplier to include verification of design capability and j evidence of testing by specified qualification testing requirements. The l licensee addresses surveillance activities and preventative maintenance that verifies that components do not exceed their service life. The licensee states that replacement safety-related components and parts are purchased as a direct replacement item, whether from the original or an I I

alternate vendor, or by use of an industry standard part number. i 8.3 Conclusion 1 1 The licensee's response for this item is considered to be complete and.

is acceptable, i

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9. ITEM 2.2.1.6- "IMPORTANT TO SAFETY" COMPONENTS I 9.1 Guideline ,

Generic tetter 83-28 states that the licensee's or applicant's equipment classification program should include (in addition to the 'I 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 j response, review of this item will not be performed. I i

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10. CONCLUSION Based on our. review of the licensee's response to the specific l requirements of Item 2.2.1, we find that.the-information provided by the j licensee to resolve these concerns meets the requirements of Generic  !

i Letter 83-28 and is acceptable. Item 2.2.1.6 was not reviewed as noted in i Section 9.1. .

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11. REFERENCES' u

1. NRC Letter, D. G. Eisenhut to all Licensees of Operating Reactors, j 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. Duke Power Company-letter, H. B. Tucker to D. G. Eisenhut, NRC,  ;

November 4.'1983. ]

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3. Duke Power Company letter, H. B. Tucker to D. G. Eisenhut, NRC, i 1

February'2, 1984. l l

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4. Duke Power Company letter, H. 8. Tucker.to NRC, March'30, 1987. i i

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l Catawba Nuclear Station, Unit Nos.1 and 2. i

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