ML20235M832

Conformance to Generic Ltr 83-28,Item 2.2.1 - Equipment Classification for All Other Safety-Related Components:Fort St Vrain, Final Informal Rept

ML20235M832
Person / Time
Site:	Fort Saint Vrain
Issue date:	06/30/1987
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20235M813	List: ML20235M812 ML20235M832
References
CON-FIN-D-6001 EGG-NTA-7437, GL-83-28, TAC-53674, NUDOCS 8707170341
Download: ML20235M832 (18)

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EGG-NTA-7437 June 1987 i l

INFORMAL REPORT

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

Idaho EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-National ' RELATED COMPONENTS: FORT ST. VRAIN Engineering ,

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by the U.S; '

Department .

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U E G r G =.s. Prepared for the pg U.S. NUCLEAR REGULATORY COMMISSION Work performed under

. DOE Contract

' No. DE AC07-76/D01570 8707170341 870612 PDR ADUCK 05000267 P PDR

DISCLAIMER This book was prepared as an account of work sponsored hy 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 hability or resoonsibriity for the accuracy, completeness, or usefulness of any information, acoaratus, product or process disclosed, or represents that its use would not infnnge pnvately owned rights References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessarily constitute or imply its endorsement, recommendation, or favonng .

by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United Statras Government or any agency thereof.

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EGG-NTA-7437 1 I

TECHNICAL EVALUATION REPORT i

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

FORT ST. VRAIN  :

i Docket No. 50-267 Alan C. Udy 1

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Published June 1987 I

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1 Idaho National Engineering Laboratory I l EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 l

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l Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-761D01570 FIN No. D6001 ,

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i ABSTRACT l \

This EG&G Idaho, Inc., report provides a review of the submittal from 1 the Fort St. Vrain Nuclear Generating Station regarding conformance to Generic Letter 83-28, Item 2.2.1. I i

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. i Docket No. 50-267 TAC No. 53674 l

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I; FOREWORD i

This report is supplied as part of the program for evaluating I licensee / applicant conformance to Generic Letter 83-28 " Required Actions Based on Generic Implications of Salem ATWS Events." This work is being l conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, Division of Engineering and System Technology, by EG&G j Idaho, Inc., NRR and I&E Support Branch. I l

The U.S. Nuclear Regulatory Commission funded this work under the l

authorization B&R No. 20-19-10-11-3, FIN No. 06001.

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Docket No. 50-267 TAC No. 53674 l

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CONTENTS ABSTRACT .............................................................. ii FOREWORD .............................................................. iii

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 ........................... 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

8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ............... 8 8.1 Guideline .................................................. 8 8.2 Evaluation ................................................. 8 8.3 Conclusion ................................................. 8

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

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

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

11. REFERENCES ....................................................... 11 iv

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

FORT ST. VRAIN

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1. INTRODUCTION

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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 j to.be related to the sticking of the undervoltage trip attachment. Prior l I

l 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 l 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 (ED0), 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 Comission (NRC)

I requested (by Generic Letter 83-28 dated July 8,1983 ) all licensees of l

I operating reactors, applicants for an operating license, and holders of  !

construction permits to respond to the gener'ic issues raised by the analyses of these two ATWS events.

. This report is an evaluation of the responses submitted by the Public  ;

Service Company of Colorado, the licensee.for the Fort St. Vrain Nuclear ]

Generating Station, for Item 2.2.1 of Generic Letter 83-28. The documents reviewed as a part of this evalu'ition are 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 ,

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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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.

l 3.2 Evaluation l The licensee for the Fort St. Vrain Nuclear Generating Station l responded to these requirements with submittals dated November 4, 1983,2 5

June 12, 1985,3 October 31, 1986,4 December 19, 1986 and April 1, 1987.0 These submittals include information that describes their existing safety-related ecuipment classification program. In the review of the licensee's response to this item, it was assumed that the information and j documentation supporting this program is available for audit upon request.

The licensee has had a maintenance procedure rewrite program. This, in i

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conjunction with the station service request, identifies safety-related equipment before maintenance activities begin. Thus, drawings and procedures have safety-related components identified. ,

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3.3 Conclusion i

We have reviewed the licensee's information, and in general, find that

. the licensee's response is. adequate.

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4. ITEM 2.2,1.1 - IDENTIFICATION CRITERIA 4.1 Guideline The appli_ cant 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 states that the definition for safety-related items is taken from Administrative Procedure G-1, " Definitions." It defines -

as safety-related:

j those plant systems, structures, equipment, and components which are )

identified in the FSAR and as detailed and supplemented by applicable -

P&I, IB and IC diagrams, E and E-1203 schematic diagrams, the Cable Tab and SR-6-2 and SR-6-8 lists to include the following:

a) Class I per the updated FSAR, Table 1.4-1.

b) Safe shutdown components per the updated FSAR, Table 1.4-2.

c) Alternate cooling method (ACM) equipment.

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The licensee oescribes this definition, comparing the high temperature gas. )

l reactor equipment with the definition found in Generic Letter 83-28. The FSAR states that the equipment, structures, systems, and components that are included in the above classifications are used to perform the ,

safety-related functions outlined in the generic letter.

4.3 Conclusion i We find that the licensee has identified the criteria used in the ~

identification of s'afety-related components. These criteria have been i shown to be comparable'to the criteria defined by the generic-letter. ,

Thus, we find that the licensee has met the requirements of item 2.2.1.1.. ,

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5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM i i

5.1 Guideline The licensee or applicant should confirm that the program for equipment classification includes an information handling system that is j 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 consists of a computerized data base that is available by printout or by on-line display terminals throughout the stat un, the nuclear engineering division and l company offices that may have need for this information. The licensee has engineering procedures that control revisions to the computer data base, )

and a description of these procedures is included in their submittals. The description includes information on how new safety-related items and changes in the classification of listed items are made, how entered items are verified and how the listing is maintained and distributed to users as an official, single, consistent and unambiguous version.

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 i system for equipment classification meets the guideline requirements.

Therefore, the information provided by the licensee for this item is  :

- acceptable.

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6. 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 ,

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 The licensee's submittal included administrative procedures that show that the above activities are determined to be safety or non-safety related. Maintenance procedures are approved for use by an equipment-specific station service request (SSR). The SSR, before approval, has a determination of the safety-related status of the equipment involved, and the maintenance procedures used. Procedure P-7 specifies the planning, preparation, approval and inspection of work done under an SSR. A similar I

procedure G-9 applies administrative controls to all modification work and j selected non-routine maintenance work. )

l 6.3 Conclusion We find that the licensee's description of plant administration controls and procedures meet the requirements of this item and is, 1 therefore, 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 The licensee's response to this item lists procedures that control and monitor the updating and validation of the computerized data base. Change notices, which control field changes and also initiate changes to the data base, are reviewed and approved by management. The data base is verified correct by an independent person by comparison of the data base to the change notice. Management is aware of these activities because of their review and approval of the change notices.

7.3 Conclusion We find that the management controls used by the licensee assure that the eqaipment classification 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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8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline l

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 )

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 suppert 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. .

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l 8.2 Evaluation The licensee provided procurement procedures that address this item.

Administrative procedure Q-4 includes a review of physical characteristics, l material specifications, design performance parameters, seismic and environmental qualification, applicable codes and standards, drawings and manuals. This procedure calls for appropriate documentation for seismic and environmental qualification to support limits of life and performance under the expected service conditions, i

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.

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

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Generic Letter 83-28~ states that the licensee's equipment classification program should include (in addition to the safety-related ]

components)abroaderclassofcomponentsdesignatedas"Importantto 3

. Safety." However, since the generic letter does-not require the licensee. l to furnish this information as part of their response, review of this item l will not be performed. )

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10. 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 Sec' ion 9.1.

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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, Public Service Company of Colorado (O. R. Lee) to NRC

. (D. G. Eisenhut), " Response to Generic Letter 83-28," November 4, 1983, P-83359.

3. Letter, Public Service Canpany of Colorado (J. W. Gahm) to NRC (E. H. Johnson), " Response to Generic Letter 83-28," June 12, 1985, P-85204 1

4. Letter, Public Service Company of Colorado (J. W. Gahm) to NRC (H. N. Berkow), " Generic Letter 83-28, Action Item 2.1,"

October 31, 1986, P-86610. ,

5. Letter, Public Service Company of Colorado (H. L. Brey) to NRC  ;

(H. N. Berkow), Generic Letter 83-28, Action Item 2.1,"

December 19, 1986, P-86676.  ;

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6. Letter, Public Service Company of Colorado (H. L. Brey) to NRC i (H. N. Berkow), Generic Letter 83-28, Action Item 2.2," April 1, 1987, P-87118.

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P. 0. Box 1625 . . = oa oa =T avMesa Idaho Falls. ID 83415 l D6001 I to. sponsonimo oacanization maMe amo Manu=o acome se naen,arie Cases p Tvos o, aspont Division of Engineering and System Technology Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 i 12 $UPPLEMENTaRV Norts tJ apSTAaCT #2(N7 eeres ariesse This EG&G Idaho, Inc., report provides a review of the submittals from the Public Service Company of Colorado, Inc., regarding conformance to Generic Letter. 83-28 Item 2.2.I for Fort St. Vrain. j

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