ML20236R300

Safety Evaluation Supporting Util Responses to Generic Ltr 83-28,Item 2.2.1 Re Equipment Classification Programs for All safety-related Components

ML20236R300
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/13/1987
From:	NRC
To:
Shared Package
ML20236R286	List: ML20236R285 ML20236R300
References
GL-83-28, NUDOCS 8711230211
Download: ML20236R300 (6)

Text

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SAFETY EVALUATION REPORT FORT ST. VRAIN DOCKET NO. 50-267 GENERIC LETTER 83-28, ITEM 2.2.1 EQUIPMENT CLASSIFICATION PROGRAMS FOR ALL SAFETY-RELATED COMPONENTS l

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1.0 INTRODUCTION

Generic Letter 83-28 was issued by the NRC on July 8, 1983 to indicate actions to be taken by licensees and applicants based on the generic implications of the Salem ATWS events. Item 2.2.1 of that letter states that licensees and l

applicants shall describe in considerable detail their program for classifying all safety-related components other than RTS components as safety-related on i

l plant documents and in information handling systems that are used to control l

plant activities that may affect these components. Specifically, the licensee /

l applicant's submittal was required to contain information describing (1) the criteria used to identify these components as safety-related; (2) the information handling system which identifies the components as safety-related; (3) the manner in which station personnel use this information handling system to control activities affecting these components; (4) management controls that are used to verify that the information handling system is prepared, maintained, validated, and used in accordance with approved procedures; and (5) design

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verification and qualification testing requirements that are part of the i

specifications for procurement of safety-related components.

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The licensee for Fort St. Vrain submitted responses to Generic Letter 83-28, I

Item 2.2.1 in submittals dated November 4, 1983; June 12, 1985; October 31, 1986; December 19, 1986 and April 1, 1987. We have evaluated these responses and find them to be acceptable.

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2.0 EVALUATIONS AND CONCLUSIONS In these sections the licensee's responses to the program and each of five sub-1 items are individually evaluated against guidelines developed by the staff and conclusions are drawn regarding their individual and collective acceptability.

1.

Identification Criteria l

i Guideline: The licensee's response should describe the criteria used to identify safety-related equipment and components.

(Item 2.2.1.1) l Evaluation:

The licensee's response defines safety-related equipment and components'for Fort St. Vrain by comparing the high temperature gas reactor equipment with the definition found in Generic Letter 83-28.

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Conclusion:==

I We find the stated criteria meets the staff's requirements and is acceptable.

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Information Handling System Guideline: The licensee's response should confirm that the equipment classification program includes an information handling system that is used to identify safety-related equipment and components. Approved procedures which govern its development, maintenance, and validation should exist.

(Item 2.2.1.2) 1 l

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Evaluation:

The licensee's response describes an information handling system consisting of a computerized database. The licensee has engineering-procedures that control the database.. The submittal contains information on how new safety related items and changes in classification are made.

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Conclusion:==

We conclude that this description of the licensee's information handling system shows compliance with staff requirements and is acceptable.

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3.

Use of Information Handling System:

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Guidelines: The licensee response should confirm that their equipment l

l classification program includes criteria and procedures which govern the I

l use of the information handling system to. determine that an activity is safety-related and that safety-related procedures for maintenance, surveillance, parts replacement and other activities defined in the introduction to 10CFR50, Appendix B, are applied to safety related components.

(Item 2.2.1.3)

I Evaluation:

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The licensee's submittal included administrative procedures that are used l

to govern the use of licensee's information system in determining whether l

equipment is safety-related and also what maintenance is required.

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Conclusion:==

We conclude that this description of the licensee's information handling system shows that it meets the staff requirements and is acceptable.

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Management Controls Guideline:

The licensee / applicant.should confirm that management controls used to verify that the procedures for preparation, validation, and

'l routine utilization of the information handling system have been and are being followed.

(Item 2.2.1.4)

Evaluation:

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The licensee's response to this item lists procedures that control and monitor the updating and validation of the computerized database.

Management is required to review and approve change notices and changes to the database, making management in control of the information handling system.

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Conclusion:==

We conclude that the licensee has described an acceptable means by which 1

their management is informed of the correct use of the information

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handling system.

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Design Verification and Procurement Guideline: The licensee / applicant's response 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 licensee's receipt of testing documentation which supports the limits of life recomended by the supplier.

If such documentation is not available, confirmation that the present program meets these requirements should be provided.

(Item 2.2.1.5)

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Evaluation:

The licensee provided procurement procedures that include reviews of physical characteristics, material specifications, design performance parameters, seismic and environmental. qualification, applicable' codes.and

. standards, drawings and manuals. The procedure also required appropriate documentation for seismic and environmental qualification to' support limits of life and performance under expected service conditions.

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Conclusion:==

We find that the licensee's procedures meet the staff requirements for this item and are acceptable.

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6.

"Important To Safety" Comments I

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.j Guideline: Generic Letter 83-28 states that licensee / applicant equipment

-j classification programs 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 licensee /

applicant to furnish this information as part of their. response, staff review of this sub-item will not'be performed.

(Item 2.2.1.6).

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Program Guideline:

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Licensees / applicants should confirm that an equipment classification program exists which provides assurance that all safety-related components are l

designated as safety-related on plant documents such as drawings, procedures, i

system descriptions, test and maintenance instructions, operating procedures, and information handling systems so that personnel who perform activities that affect such safety-related components are aware that they are working j

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i on safety-related components and are guided by safety-related procedures and constraints.

(Item 2.2.1)

Evaluation:

1 The licensee's submittals dated November 4, 1983; June 12, 1985; I

October 31, 1986; December 19, 1986 and April 1, 1987 provided responses to the above requirements. These submittals described the licensee's program for identifying and classifying safety-related equipment and components which meets the staff requirements as indicated in the preceding sub-item evaluation.

Conclusion.

j We conclude that the licensee's program addresses the staff concerns regarding equipment and component classification and is acceptable.

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3.0 REFERENCES

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NRC Letter, D. G. Eisenhut to all Licensees of Operating Reactors, Applicants fer Operating License, and Holders of Construction Permits, " Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," July 8, 1983.

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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.

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

4.

Letter, Public Service Company of Colorado (J. W. Gahm) to NRC (H. H. 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,"

l December 19, 1986, P-86676 i

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Letter, Public Service Company of Colorado (H. L. Brey) to NRC (H. N. Berkow), " Generic Letter 83-28, Action Item 2.2,"

April 1, 1987, P-87118.

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ENCLOSURE 2' EGG-NTA-7437-

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

FORT ST. VRAIN a

Docket No. 50-267

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Alan C. Udy Published June 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc.

Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Comission Washington, D.C.

20555 Under DOE Contract No. DE-AC07-761001570 FIN No. 06001 M S7.l-}h5h5

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

the Fort St. Vrain Nuclear Generating Station regarding conformance to, / a d.

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Generic 1.etter 83-28, Item 2.2.1.

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FOREWORD

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i This report is supplied as part of the program for evaluating licensee / applicant conformance to Generic Letter 83-28 " Required Actions.

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Dased on Generic linplications of Salem ATWS Events." This work is being j

conducted for the U.S. Nuclear Regulatory Conmission. 0ffice of Nuclear

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keactor Regulation, Division of Engineer fag and System Technology, by EG&G.

i Idaho, Inc., NRR and 1&E Support Bra:ich.

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authoriv* ion B.TR No. 20-19-10-11-3, FIN No.'06001.

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ITEM 2,2.h 1 - IDENTIFICATION CR ITERIA.. J.....d..................

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4.1 Guideline..................................................

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ITEM 2.2.1.2'- INFORMATION HANDLING SYSTEM....................... ' ?5 i

5,1 Guideline..,................i.......................'.'.....,;!5" 5.2 Enluatim................./.............................

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ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING...........

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ITEM 2. 2.1. 4 - MANAGEMENT CMTROLS...............................

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. Guideline.................................................

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ITEM 2.2.1.5 - DESIGN. VERIFICATION AND PROCURC$ENT...............

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9., ITEW 2. 2.1.6 J' IMPORTANT TO SAFETY" COMPONENTS.'.................

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

FORT ST. VRAIN L

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INTRODUCTION l

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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 i

signal from the reactor-protection system. This incident was terminated l

manually by the operator about 30 seconds after the initiation of the

'I 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

'i was tripped manually by the operator almost coincidentally with the sutomatic trip.

Following these incidents, on February 28, 1983, the NRC Executive N

Director for Operations (EDO), directed the NRC staff to investigate and report on the generic implications of these occurrences at Unit 1 of tihe Salem Nuclear Power Plant. The results of the staff's inquiry into the generic implications of the Salem unit incidents are reported in NUREGiOOO,"GenericImplicationsoftheATWSEventsattheSalemNuclear Power Plant." As a result of this investigation, the Comission (NRC) l I

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

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' operating reactors, applicants for an operating license, and holders of l

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 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 evaluation are listed in the references at the end of this report, i

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REVIEW CONTENT AND FORMAT.

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Item 2.2.1 of Generic Letter 83-28 requests the licensee or applicant j

to submit, for the staff review, a description of their programs for

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1 safety-related equipment classification including supporting information, i

in considerable datail, 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 1

I 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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ITEM 2.2.1 - PROGRAM

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s 3.1 Guideline Licensees and applicants should confirm that an equipment j

classification program exists which provides assurance that all

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safety-related components are designated as safety-related on al1 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 replacement parts. Licensee and applicant responses which address the features of this program are evaluated in the remainder of this report.

i 3.2 Evaluation j

The licensee for the Fort St. Vrain Nuclear Generating Station responded to these requirements with submittals dated November 4, 1983,2 June 12, 1985,3 October 31, 1986,4 December 19, 1986 and April 1, 1987.6 5

These submittals include 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 has had a maintenance procedure rewrite program. This, in conjunction with the station service request, identifies safety-related equipment before maintenance activities begin. Thus, drawings and procedures have safety-related components identified.

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

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ITEM 2.2,1,1 - IDENTIFICATION CRITERIA j

l 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 states that the definition for safety-related items is taken from Administrative Procedure G-1, " Definitions." It defines as safety-related:

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

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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:

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

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

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Alternate cooling method ( ACM) equipment.

The licensee describes this definition, comparing the high temperature gas 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 We find that the licensee has identified the criteria used in the identification of safety-related components. These criteria have been 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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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.-

1 5.2 Evaluation i

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 station, the nuclear engineering division and 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 l

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

6.3 Conclusion We find that the licensee's description of plant administration controls and procedures meet the requirements of this item and is, i

therefore, acceptable.

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ITEM 2.2.1'.4 - MANAGEMENT CONTROLS

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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 l

l review and approval of the change notices.

1 7.3 Conclusion We find that the management controls used,by the licensee assure that the equipment classification information handling system is maintained,- is' current and is used as intended. Therefore, the licensee's response for l

this item is acceptable.

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ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline The applicant's or licensee's submittal should document that past

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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 reconnended by the supplier.

If such docenentation is not

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available, confirmation that the present program meets these requirements should be provided.

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

l Administrative procedure Q-4 includes a review of physical characteristics, material specifications, design performance parameters, seismic and i

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.

8.3 Conclusion The licensee's response for this item is considered comp 1ete.

The information provided addresses the concerns of this item and is acceptable.

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ITEM 2.2.1.6 "IMPORTANT TO SAFETY"-COMPONENTS 9.1 Guideline Generic letter 83-28 states that the licensee's equipment classification program should include (in addition to the safety-related j

components) a broader class of canponents designated as "Important to Safety." However, since the generic letter does not require the licensee -

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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 I

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.

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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.

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Letter, Public Service Company of Colorado (O. R. Lee) to NRC (O. G. Eisenhut), " Response to Generic Letter 83-28," November 4, 1983, P-83359.

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Letter,PublicServiceCompanyofColorado(J.W.Gahm)toNRC (E. H. Johnson), " Response to Generic Letter 83-28," June 12, 1985,-

1 P-85204.

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Letter, Public Service Company of Colorado (J. W. Gahm) to NRC l

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

i October 31, 1986, P-86610.

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

l (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 (H. N. Berkow), Generic Letter 83-28, Action Item 2.2," April 1, 1987, P-87118.

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