ML20246L829
| ML20246L829 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/08/1989 |
| From: | Fairtile M Office of Nuclear Reactor Regulation |
| To: | Papanic G YANKEE ATOMIC ELECTRIC CO. |
| References | |
| GL-83-28, TAC-53729, NUDOCS 8903240289 | |
| Download: ML20246L829 (3) | |
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Docket No.50-029 MAR 8 1989 Mr.s George Papanic, Jr.
i Senior _ Project Engineer - Licensing Yankee Atomic Electric Company 580 Main Street Bolton,' Massachusetts 01740-1398
Dear Mr. Papanic:
SUBJECT:
SAFETY EVALUATION FOR GENERIC LETTER 83-28, ITEM 2.2.1 (CLASSIFYING SAFETY.RELATED COMPONENTS) FOR YANKEE R0WE NUCLEAR POWER STATION (TAC N0. 53729)
-1 Generic Letter 83-28 required licensees and applicants'to describe in considerable detail their program for classifying all safety-related components other than reactor trip system components as safety-related on plant documentation and in information handling systems that are used to control activities performed on this safety-related equipment.
By letters dated November 5, 1983, January 13, 1984, and July 22, 1987, you submitted responses to Generic Letter 83-28, Item 2.2.1.
Our review of the responses as documented in the enclosed contractor's report (EG&G-NTA-7416) finds your responses to Generic Letter 83-28, Item 2.2.1 to be acceptable. We concur with our contractor's findings and issue the enclosed TER as our Safety Evaluation Report.
i On this basis, we consider Item 2.2.1 of Generic Letter 83-28 to be closed by this action. TAC No. 53729 is not closed but remains open pending the resolution of Itr' 2.2.2.
Sincerely, i
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Morton B. Fairtile, Project Manager Project Directorate I-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosure:
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' l/ AR 8 1989 Docket No.50-029 Mr. George Papanic, Jr.
Senior Project Engineer
. Licensing Yankee Atomic Electric Company 580 Main Street Bolton, Massachusetts 01740-1398
Dear Mr. Papanic:
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SUBJECT:
SAFETY EVALUATION FOR GENERIC LETTER 83-28. ITEM 2.2.1 (CLASSIFYING SAFETY-RELATED COMPONENTS) FOR YANKEE R0WE NUCLEAR POWER STATION (TAC NO. 53729)
Generic Letter 83-28 required licensees and applicants to describe ir considerable
' detail their progran for classifying all safety-related components other than reactor trip system components as safety-related on plant documentation and in information. handling systens that are used to control activities performed on this i
safety-related equipment.
By letters dated November 5, 1983, January 13, 1984, and July 22, 1987, you submitted responns to Generic Letter 83-28, Item 2.2.1.
Our review of the responses as documented in the enclosed contractor's report (EG&G-NTA-7416) finds your responses to Generic Letter 83-28, Item 2.2.1 to be acceptable. We concur with our contractor's findings and issue the enclosed TER as our Safety Evaluation Report.
On this basis, we consider Item 2.2.1 of Generic Letter 83-28 to be closed by this action. TAC No. 53729 is not closed but remains open pending the resolution of Iten 2.2.2.
Sincerely,
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Morton B. Fairtile, Project Manager Project Directorate I-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosure:
EGT.G TER cc w/ encl.: See next page L
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Mr. George Papanic, Jr.
Yankee Atomic. Electric Company Yankee Nuclear Power Station i
cc:
Dr. Andrew C. Kadak, President and Chief Operating Officer Mr. George Papanic, Jr.
Yankee Atomic Electric Company Senior Project Engineer-Licensing 580 Main Street Yankee Atomic Electric Company i
Bolton, Massachusetts 01740-1398 580 Main Street Bolton, Massachusetts 01740-1398 Thomas Dignan, Esquire Ropes and Gray Mr. George Sterzinger, 225 Franklin Street Commissioner Boston, Massachusetts 02110 Vermont Department of Public Service Mr. N. N. St. Laurent 120 State Street, 3rd Floor Plant Superintendent Montpelier, Vermont 05602 Yarkee Atomic Electric Company Star Route Rowe, Massachusetts 01367 i
Chairman Board of Selectmen Town of Rowe Rowe, Massachusetts 01367 Pesident Inspector Yankee Nucleer Power Station c/o ll.S. NRC Post Office Box 28 Monroe Bridge, Massachusetts 01350 Regional Administrator, Region ?
U.S. Nuclear Regulatory Connission 475 Allendale Road King.of Prussia, Pennsylveriia 19406 Robert M. "allisey, Director Radiatfor Lontrol Prceram Massachusetts Department of Public Health 150 Trenont Street, 7th Floor Boston, Massachusetts 02111 1
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'T EGG-NTA-7416 L'
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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:
YANKEE R0WE.
Docket No. 50-29
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Alan C. Udy Published January 1989 Idaho National Engineering Laboratory EG&G Idaho, Inc.
Idaho Falls, Idaho 83415 Prepared for the U.:. Nuclear Regulatory Commission Washington, D.C.
20555 Under 00E Contract No. DE-AC07-761001570 FIN No. 06001 1
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l ABSTRACT This EG&G Idaho, Inc., report provides a review of the submittals from the Yankee Nuclear Power Station regarding conformance to Generic Letter 83-28, Item 2.2.1.
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Docket No. 50-29 TAC No. 53729 ii
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l FOREWORD l
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 Reactor Regulation, Division of Engineering and System Technology, by EG&G Idaho, Inc., Regulatory and Technical Assistance Unit.
The U.S. Nuclear Regulatory Comtaission funded this work under the authorization 8&R No. 20-19-10-11-3, FIN No. D6001.
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l Oocket No. 50-29 TAC No. 53729 tii l
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f CONTENTS i ;
L A B S T RA C T............................................................
11 FOREWORD..............................................................
i ii 1.
INTRODUCTION.....................................................
1 2.
REVIEW CONTENT AND FORMAT.........................................
2 3.
ITEM 2.2.1 - PR0 GRAM..............................................
3 3.1 Guideline..................................................
~3, 3.2 Evaluation.................................................
3 3.3 Conclusion.................................................
4 4.
ITEh 2.2.1.1 - IDENTIFICATION CRITERIA...........................
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. 4.1' Guideline..................................................
5 4.2 Evaluation................................................
5 4.3 Conclusion........................................
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ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM.......................
6-5.1 Guideline................................................
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5.2-Evaluation..............................................
5.3 Conclusion.......................
7 6.
ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLASSIFICATION LISTING.......
8 6.1 Guideline.....
8 6.2 Evaluation 8
8 6.3 Conclusion............................................
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ITEM 2.2.1.4 - MANAGEMENT CONTROLS.............................
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l 7.1 Guideline................................................
9 7.2 Evaluation..........................
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7.3 Conclusion.................................................
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ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT...............
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8.1 Guideline.................................................
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8.2 Evaluation..............................................
10 8.3 Conclusion.................................................
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ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS 11 l
i 11 9.1 Guideline..............
10.
CONCLUSION..
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REFERENCES................
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CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
I EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:
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YANKEE ROWE j
1.
INTRODUCTION i
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
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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 a'utomatic 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.
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i Following these incidents,-on February 28, 1983, the NRC Executive i
Director for Operations (E00) 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 i
Power Plant." As a result of this investigation, the Commission (NRC) f 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 Yankee Atomic Electric Company, the licensee for the Yankee Nuclear Power Station, for Item 2.2.1. of Generic Letter 83-28.
The documents reviewed as a part I
i of this evaluation are listed in the References (Section 11) at the end of this report.
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REVIEW CONTENT AND FORMAT Item 2.2.1 of Generic Letter 83-28 requests the licensee or applicant to submit a detailed description of their programs for safety-related equipment classification for staff review. Detailed supporting information should also be included in the description, as indicated in the guideline section for each sub-item within this report.
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l l-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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ITEM 2.2.1 - PROGRAM 3.1 Guideline I
1 Licensees and applicants should confirm that_an equipment
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I cl' ossification program is in place which will provide assurance that all safety-related components are designated as safety-related on plant documentation. The program should also assure that information handling
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systems which control. activities that may affect safety-related components are designated safety-related so that personnel are aware that they are L
working on safety-re' lated compenents and are guided by safety-related procedures and constraints. 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 Yankee Rowe responded to these requirements with submittals dated November 5, 1983,2 January 13, 1984,3 and July 22, 1987.4 In the review of the licensee's response to this item, it' was assumed t, t the information and documentation supporting this program are available for audit-upon request. These submittals describe the licensee's existing safety-related equipment classification program. We have reviewed this information and have the following general comment.
Appendix 0 of the " Yankee Operational Quality Assurance Program Manual" (YOQAP.-1-A) is identified as the information handling system.
However, the licensee also mentioned the plant's " Safety Classification of Systems Manual" and the procedure entitled " Safety Classification of Systems, Components and Structures." Our concern was that these three sources were not integrated and did not function together to form a consistent, single, and unambiguous source of classification information.
In the July 22, 1987 submittal, the licensee showed how these three documents work together to comprise a single, concise, and unambiguous source of classification information for all safety-related components and parts.
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1 3.3 Conclusion We have reviewed the licensee's submittals and find, in general, that the licensee's response is adequate.
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4 ITEM 2.2.1.1 - IDENTIFICATION CRITERIA 4.1 Guideline l
The applicant or licensee should confirm that the program used for equipment classification includes the criteria used for identifying components as safety-related.
4.2 Evaluation ANSI N18.2, " Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants," is cited as the basis for the safety classification of systems, components, and structures. The criteria in ANSI N18.2 includes the criteria listed in the footnote to Item 2.2.1 of Generic Letter 83-28. The licensee also gives three exclusion criteria which would permit a component of a safety-related electrical or instrumentation system to be classified as nonsafety-related.
4.3 Conclusion The licensee's response'to this item is considered to be complete.
Therefore, the licensee's response for this item is acceptable.
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ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM 5.1 Guideline 1
The licensee or applicant should confirm that the program for l
equipment classification includes an information handling system that is used to identify safety-related components.
The response shovid confirm that this information handling system includes a list of safety-related
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I equipment and that procedures exist to govern its development and validation.
.I 5.2 Evaluation The licensee states that safety-related, components are identified as
,such in the procedure entitled, " Safety Classification of Systems, 7: Components and Structures," in Appendix 0 to the " Yankee Operational Quality' Assurance Manual," and in the manual entitled " Safety i
Classification of Systems Manual." The licensee described these procedures in Reference 4,..as discussed b& low.
Appendix 0 of the quality assurance topical report is stated to include a~ list of all safety-related systems, components, and structures.
The " Safety Classification of Systems Manual" is a compilation of l
1 controlled drawings, sketches, and lists that detail the boundaries of safety-related component classification. The licensee uses the design change process to periodically revise this manual. The design change j
process is used to control any changes to the equipment classification, and prevents unauthorized changes to the documents. The licensee states that the accuracy of the original preparation and all subsequent revisions of this manual is assured by an extensive review process.
The licensee states that the " Safety Classification of Systems, Components and Structures" procedure contains criteria for personnel use of the above manual. The licensee updates this prncedure biennially using the design change process.
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5.3 Conclusion The licensee's response is considered to be complete. Therefore, the licensee's response for this item is acceptable.
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ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLASSIFICATION LISTING 6.1 Guideline The licensee's or applicant's description should confirm that the program for equipment classification includes criteria and procedures that govern how station personnel use the equipment classification information handling system to determine that an activity is safety-related. The description should also include the procedures for maintenance, surveillance, parts replacement, and other activities defined in the introduction to 10 CFR 50, Appendix B, that apply to safety-related components.
6.2 Evaluation i
The licensee states that maintenance requests are determined to be safety-related or nonsafety-related by consulting the " Safety Classification of Systems Manual." Any modification to plant systems, components, or structures requires the consultation of this manual, which is identified as the information handling system referred to by the NRC.
The procedure " Safety Classification of Systems, Components and Structures" directs the use of the " Safety Classification of Systems Manual" for any of the activities mentioned above. The licensee states that reviews, audits, and approvals are used to assure that proper procedures and equipment classifications are used, thus assuring that safety-related activities utilize safety-related procedures.
6.3 Conclusion We find that the licensee's description of plant administrative controls and procedures meets the requirements of this item.
Therefore, the licensee's response for this item is acceptable.
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ITEM 2.2 1.4 - MANAGEMENT CONTROLS l
7.1 Guideline l
The applicant or licer.see should briefly describe the management controls that are used to verify that the procedures for preparation, validation, and routine use of the information handling system have been, and are being, followed.
I 7.2 Evaluation l
The licensee states that their management controls utilized to satisfy this item consist of management operations; plant and quality assurance review and concurrence; and quality assurance audits, insr>ections, and surveillance. These reviews are interdisciplinary in nature.
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 8.1 Guideline The licensee's submittals should document that past usage demonstrates l
that appropriate design verification and qualification testing are specified for the procurement of safety-related components and parts. The specification should include qualification testing for the expected safety-service conditions and should provide support for the licensee's l
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 addresses design verification for safety-related components.
Specifications call out qualification testing and analysis for the environmental conditions, as required by the safety-related classification of the component involved. Procurement procedures ensure that the procurement specifications for safety-related components and parts specify the expected service conditions, design verification requirements, qualification testing requirements, and reporting requirements that document these requirements.
8.3 Conclusion We conclude that the licensee has addressed the concerns of this item.
Therefore, the licensee's response for this item is acceptable.
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ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS 9.1 Guideline L
l 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 components designated as "Important to Safety." However, since the generic letter does not require the licensee l
to furnish this information as part of their response, this item will not j
I be reviewed.
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- 10. CONCLUSION Based on our review of the licensee's response to the specific j
requirements of' Item 2.2.1, we find that the information provided by the licensee to resolve these concerns meets 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
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Letter, NRC (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, Yankee Atomic Electric Company (L. H. Heider) to NRC (D. G. Eisenhut), " Response to Generic Letter 83-28,"
November 5, 1983, FYR 83-94, 2.C2.1.
3.
Letter, Yankee Atomic Electric Company (J. A. Kay) to NRC (D. M. Crutchfield), " Additional Information in Response to Generic Letter 83-28;" January 13, 1984, 2.C.2.1, FYR 84-09.
4.
Letter, Yankee Atomic Electric Company (G. Papanic, Jr.) to NRC,
" Equipment Classification (GL 83-28, Items 2.2.1.2 and 2.2.1.3),"
July 22,1987, FYR 87-77.
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CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--
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4.ur..cr m This EG&G Idaho, Inc., report provides a review of the Yankee Rowe submittals l
regardi.ng conformance te Veneric Lctter 83-28, Item 2.2.1.
Based on the material examined, it is concluded that the licensee meets the requirements of this item.
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