ML20235M574

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Final Conformance to Generic Ltr 83-28,Item 2.2.1 - Equipment Classification for All Other Safety-Related Components:Big Rock Point, Informal Rept
ML20235M574
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 06/30/1987
From: Udy A
EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:
NRC
Shared Package
ML20235M547 List:
References
CON-FIN-D-6001 EGG-NTA-7210, GL-83-28, TAC-53653, NUDOCS 8707170241
Download: ML20235M574 (18)


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INFORMAL REPORT o

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

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RELATED COMPONENTS:

BIG ROCK POINT

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Alan C. Udy

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N gfEGEGw.no Prepared for the U.S. NUCLEAR REGULATORY COMMISSION

' Work performed under DOE Contract.

No. DE-AC07 76/D01570

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~ DISCLAIMEf1 j

This book was prepared as, an account of work sponsored by an agency of the United l

States Government. Neither the United States Government nor any agency thereof, nor any of fneir employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product or process disclosed, or r= presents that its use would not infringe pnvately owned nghts. References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, dow not necessarily constitute or imply its endorsement, recommendation, or favoring by the linited States Government or any agency thereof. The v'ews and opinions of i

l authors expressed herein do not necessanly state or reflect those of the United States l

Government or any agency thereof.

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

'l EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

BIG ROCK POINT j

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I Docket No. 50-155 A. C. Udy

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Published June 1987 l

Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission

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Washington, D.C.

20556 Under DOE Contract NO. DE-AC07-76ID01570 FIN No. 06001

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ABSTRACT l

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This EG&G Idaho, Inc., report provides a review of the submittals from the Big Rock Point Plant regarding conformance to Generic Letter 83-28, l

Item 2.2.1.

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Docket No. 50-155 1

1 TAC No. 53653 i

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I 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 l

Reactor Regulation,. Division of Engineering and System Technology, 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 10-19-11-3, FIN No. D6001.

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Docket No. 50-155 TAC No. 53653 iii i

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CONTENTS

. ABSTRACT............................................................

di FOREWORD lii 1.

INTRODUCTION................

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

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ITEM 2.2.1 - PROGRAM............................................

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3.1 Guideline..........

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3.2 Evaluation.

3 3.3 Conclusion...

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ITEM 2. 2.1.1 - IDENTI FICATION CRITERI A..........................

4 4.1 Guideline.................

4 4.2 Evaluation......

4 4.3 Co.iclusion....

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ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM....................

5 5.1 Guideline....

5 5.2 Evaluation....................

5 5.3 Conclusion...

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ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING..

6 6.1 Guideline....

6 6.2 Evaluation.......

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6.3 Conclusion 6

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ITEM 2.2.1.4 - MANAGEMENT CONTROLS.................

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7.1 Guideline...

7 7.2 Evaluation.........

7 7.3 Conclusion.......

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

8 8.1 Guideline.....

B 8.2 Evaluation...

8 E.3 Conclusion.............

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ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS 9

9.1 Guideline.

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CCNCLUSION........

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REFERENCES............

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

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BIG ROCK POINT l

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INTRODUCTION l

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 j

j 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 tne circuit breakers was determined to be related to the sticking of the undervoltage trip attachment.

Prior to this incident, on February 22, '.983, at Unit 1 of the Salem Nuclear Power Plant, an. automatic trip sigjal was generated based on steam generator low-low level during plu t startup.

In this case, the reactor was tripped manually by the operttor 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 staf f's inquiry into the generic imp'ications of the Salem unit incidents are reported in NUREG-1000, " Generic 1 implications of the ATWS Events at the Salem Nuclear Power Plant." As a result of this investigation, the Commission (NRC) 1 requested (by Generic '.etter 83-28 cated July 8,1983 ) all licensees of operating reactors,

_ N icant. Vor 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 Consumers Power Company, the licensee for the Big Rock Point Plant, regarding Item 2.2.1 of Generic Letter 83-23. The actual 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 83-23 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 stated, 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 conformance 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 3.1 Guideline Licensees and applicants should confirm that an equipment classification program exists that provides assurance that all 1

i safety-related components are designated as safety-related on all plant I

documents, drawings and procedures and in the information handling system O

1 that is used in accomplishing safety related activities, such as work orders for repair, maintenance and surveillance testing and orders for I

replacement parts.

Features of this program are evaluated in the remainder of this report.

I 3.2 Evaluation The licensee for the Big Rock Point Plant responded to these requirements with submittals dated Novemoer 7, 1983,2 August 16, 1985 3 and April 22, 1987.4 These submittals include information that describes their 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 " Safety-related Systems Classifications Quality List" (Q-list) provides a listing of safety-related structures, systems and components.

It is used to determine what components and ac.tivities are safety-related.

Maintenance Orders, Facility Change Forms and procurement documents are designated as safety-related or as non-safety-related, providing the appropriate controls over the work done.

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

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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.

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4.2 Evaluation The licensee states that the Nuclear Operation Department Standard (NODS) A21 provides a list of systems, components and supports that are to be included in the Q-list as safety-related.

This list is provided, and is based on the criteria of Regulatory Guide 1.29.

4.3 Conclusion We find that the criteria used in the identification of safety-related components meets the requireme.1ts 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 information handling system that is

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used to identify safety-related compnnents.

The response should confirm that this information handling system includes a list of safety-related eauipment and that' procedures exist which govern its development and validation.

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5.2 Evaluation The licensee states that the Q-list is the information handling system

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referred to and that it identifies' safety-related structures, systems, components, chemicals and consumables in accordance with the licensee's quality asvurance (QA) program.

The licensee states that the plant technical superintendent is responsible for maintaining the Q-list, with review and approvals required of the plant review committee, the QA department and the plant superintendent.

5.3 Conclusion We find that the information contained in the licensee's submittal 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

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

6.2 Evaluation The licensee has described plant administrative procedures that govern maintenance, modifications and procurement activities.

These procedures provide the criteria regarding Q-listed components or systems before any maintenance, testing, design changes, engineering support, setpoint changes or special tests or studies are initiated.

6.3 Conclusion We find that the licensee's administrative procedures meet the requirements of this item and therefore, the response is acceptable.

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ITEM 2.2.1.4 - MANAGEMENT CONTROLS 7.1 Guideline The applicant or licensee should confirm that the management controls used to "erify that the procedures for preparation, validation and routine utilization of the information handling system have been followed, j

i 7.2 Evaluation The licensee states that all plant maintenance and surveillance procedures receive technical and administrative reviews.

Additionally, those safety-related items identified in the Q-list receive plant review J

committee and quality assurance reviews and plant superintendent approval.

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The quality assurance department conducts periodic audits and surveillance l

to verify the proper use of the 0-list and.the proper use of the procedures l

that describe the development and use of the Q-list.

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 i

8.1 Guideline l

The applicant's or licensee's submittal should document that past j

usage demonstrates that appropriate design ' verification and qualification l

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.

l 8.2 Evaluation i

The licensee's " Controlled Procedures Manual - Materials and Services," governs the requirements for verification of design and testing-that is to be provided with the purchase of any stock or non-stock spare parts, equipment, materials or supplies.

The procedures assist in the preparation of the purchase specification, " Material Request / Authorization to Purchase" form, that receives technical and quality assurance reviews to insure adequate specifications concerning design verification and qualification testing.

S.3 Conclusion The licensee's response for this item is considered 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 SAFEliY" COMPONENTS 9.1 Guideline Generic Letter 83-28 states that the licensee'.s equipment 4

classification program should include (in addition t.o the safety-related l

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

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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, 1

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 i

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NRC Letter, D. 'G. Eisenhut to all Licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits, j

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

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Consumers Power Company letter, D. J. VandeWalle to D. G. Eisenhut,

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NRC, " Response to Generic Letter 83-28, Required Actions Based on Generic Implications of Salem ATWS Events," November 7,1983.

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Consumers Power Company letter, R. R. Frisch to Director, Nuclear Reactor Regulation, NRC,." Response to Requests for Additional Information on Generic Letter 83-28," August 16, 1985.

4 Consumers Power Company letter, R. R. Frisch to NRC, " Generic Letter 83-28 Request for Additional Information Response,"

April 22, 1987.

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EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMP 0NENTS:

BIG ROCK POINT

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MoNr June 7 PtmoomMtNo omoANi2Af ton NAME AND WAaLiNo Aoomiss ssei,mte Caos e PaoJECTITamspomat unit NUM64R EG&G Idaho, Inc.

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U.S. Nuclear Regulatory Commission ioo Covgato,,

Washington, DC 20555~

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This EG&G Idaho, Inc., report provides a review of the submittals from.the Consumers Power Company regarding conformance to Generic Letter 83-28,. Item 2.2.1-for

' Big Rock Point.

1 is DOCvutNT AN Akissa e a t inomos'ot &Ca PToMS 16 AvaikAlitaT V STAftMENT Unlimited Distribution to StCumif v CLAssisiCAfloN

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