ML19327B716

Conformance to Generic Ltr 83-28,Item 2.2.1-Equipment Classification for All Other Safety-Related Components: Fitzpatrick, Technical Evaluation Rept

ML19327B716
Person / Time
Site:	FitzPatrick
Issue date:	10/31/1989
From:	Udy A EG&G IDAHO, INC.
To:	NRC
Shared Package
ML19327B717	List: ML19327B716
References
CON-FIN-D-6001 EGG-NTA-7215, GL-83-28, TAC-53672, NUDOCS 8911070214
Download: ML19327B716 (17)

Text

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EGG-NTA-7215 October 1989 i

. TECHNICAL EVALUATION REPORT  ;

Idaho National CONFORMANCE TO GENERIC LETTER 83-28, Eng/neering ITEM 2.2.1--EQUIPl1ENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS: FITZPATRICK Laboratory Managed by the U.S. A1an C. Udy Department ofEnergy l

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=> 1 EGG-NTA-7215 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

FITZPATRICK Docket No 50-333 b

Alan. C. Udy Published October 1989 Idaho National Engineering Laboratory EG&G Idaho, Inc. l Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-761001570 FIN No. D6001

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SUMMARY

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

the James A. FitzPatrick Nuclear Power Plant for conformance to Generic

!. - Letter 83-28, Item 2.2.1. Item 2.2.1 of Generic Letter 83-28 requires

, licensees and applicants to submit a detailed description of their programs for safety-related equipment-classification for staff review. It also r describes guidelines that the licensee's or applicant's programs should l' encompass. This review concludes that,the licensee does comply with all the requirements of this item. -

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B&R No. 20-19-10-11-3 Docket No. 50-333 1 TAC No. 53672 l

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PREFACE 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.

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i Docket No. 50-333 r TAC No. 53672 111 1

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CONTENTS

SUMMARY

............................................................... 11 PREFACE ................................................................ iii

1. INTRODUCTION ..................................................... I 2.- REVIEW CONTE"I AND FORMAT ........................................ 2

3. ITEM 2.2.1 - PROGRAM ............................................. 3 3.l' 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 THE 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 r

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

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

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

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@NFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1--E0VIPMENT .

CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

FITZPATRICK

1. INTRODUCTION On February 25, 1983, both of the scram circuit breakers at Unit 1 of the Salem Generating Station 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 Generating Station, 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 (ED0) directed the NRC staff to investigate and report on the generic implications of these occurrences at Unit 1 of the Salem Generating Station. The results of the staff's inquiry into the generic implications of the Salem Unit 1 incidents are reported in NUREG-1000, " Generic Implications of the ATWS Events at the Salem Nuclear o Power Plant." As a result of this investigation, the Commission (NRC)

.reques et d (by Generic Letter 83-28 dated July 8,1983 1

) that all licensees of operating reactors, applicants for an operating license, and holders of I construction permits respond to the generic issues raised by the analyses of these two ATWS events.

L L This report is an evaluation of the responses submitted by the New York Power Authority, the licensee for the James A. FitzPatrick Nuclear Power Plant, for Item 2.2.1 of Generic Letter 83-28. The documents reviewed as a part of this evaluation are listed in the References (Section 11) at the end of this report.

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. t I 2. REVIEW CONTENT AND FORMAT Item.2.2.1 of Generic Letter 83-28 requests the licensee to submit a 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 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 licensee's response is made; and conclusions about the programs of the licensee for safety-related equipment classification are drawn.

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3. ITEM 2.2.1 - PROGRAM 3.1 Guideline Licensees should confirm that an equipment classification program is in

. place that will provide assurance that safety-related components are designated as safety-related on plant documentation. The program should provide assurance that the equipment classification information handling system is used so that activities that may affect safety-related components are designated safety-related. By using the information handling system, personnel are made aware that they are working on safety-related components and are directed to, and are guided by, safety-related procedures and constraints. Licensee responses that address the features of this program are evaluated in the remainder of this report.

3.2 Evaluation  !

The licensee for the James A. FitzPatrick Nuclear Power Plant responded to these requirements with submittals dated November 9, 1983,2 June 29, 1984,3 July 2, 1985,4 December 31, 1985,5 March 20, 1987,6 and October 16, 1989. These submittals describe the safety-related equipment classification program. In the review of the licensee's response to this item, it was assumed that the information and doc'u mentation supporting this program is available for audit upon request.

i 3.3 Conclusion l

We have reviewed the licensee's submittals and find that the licensee's l program is acceptable, as indicated in the following sections.

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. 4. ITEM 2.2.1.1 - IDENTIFICATION CRITERIA 4.1 Guideline

The licensee.should confirm that their program used for equipment classification includes the criteria used for identifying components as safety-related.

4.2 Evaluation The licensee's. responses provides.the criteria used for the identification of safety related components. The licensee states that these

. criteria are used in accordance with engineering design procedures. The licensee defines as safety related those structures, systems, and components that are necessary to assure a) the integrity of the reactor coolant system pressure boundary, b) the capability to shut down the reactor and to maintain 9

it in a safe shutdown condition, and c) the capability to prevent or to mitigate the consequences of accidents that could result in potential offsite exposures. The criteria encompass the criteria given in the footnote to Section 2.2.1 of the generic letter.

4.3 Conclusion The licensee's responses to this item are complete and address the staff's concern. Therefore, we find the licensee's responses for this item acceptable, i

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5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM s-5.1 Guideline The licensee 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 to govern its development and validation.

5.2 Evaluation l The licensee's submittals identify the Master Equipment List (MEL) as the information handling system that lists safety-related structures, systems, components, and parts. This computer database is accessible at plant and headquarter computer terminals. The licensee described the controls used in the development and validation of the MEL; the process by -

which new safety related items are entered; how changes in classification of listed items are made; how listed items are verified; and how unauthorized changes are prevented. FitzPatrick plant procedure WACP-10.1.18, " Control of the Master Equipment List," provides these controls and processes. The licensee is also replacing two associated procedures, EDP-12 and WACP 10.1.6, with MCM-6A, which lists the specific system safety functions, and MCM 3, which controls modifications and component changes. The licensee indicates that a l

single work group is responsible for the actual updating and verification of the MEL database information.

l' 5.3 Conclusion ,.

l l 'The licensee's responses describe a system that meets the L recommendations of this item. Therefore, we find the licensee's responses L for this item acceptable.

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6. ITEM 2.2.1.3 - USE OF THE EQVIPMENT CLASSIFICATION LISTING 6.1 Guideline The licensee's description shcald 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 8.

6.2 Evaluation The licensee has described plant administrative controls and procedures that govern maintenance, modification, and procurement activities. These controls require personnel to consult the MEL to determine the safety class of the equipment prior to initiating any maintenance, testing, design changes, engineering support, setpoint changes, or special tests or studies.

6.3 Conclusion We find that the licensee's description of plant administrative controls and procedures meets the requirements of this item. Therefore, we find the licensee's responses for this item acceptable. '

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS

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! 7.1 Guideline The licensee should briefly describe the management controls that are used to verify that the procedures for preparation, validation, and routine utilization of the information handling system have been, and are being, followed.

7.2 Evaluation The licensee's responses state that the managerial controls associated with the plant procedures that control activities affecting quality assurance classification; that list equipment; and that verify the preparation, validation, and routine use of the information handling system are followed. Quality assurance reviews and audits are specified as assurance that the programs and their implementation are correct.

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 l

intended. Therefore, we find the licensee's responses for this item acceptable.

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8. ITEM 2.2.1.5~- DESIGN VERIFICATION AND PROCUREMENT I

8.1 Guideline l

l The licensee's submittals should document that past usage demonstrates 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 expected safety l

service conditions and provide support for the licensee's receipt of testing l documentation to support the limits of life recommended by the supplier. If l such documentation is not available, confirmation should be provided that the present program meets these requirements'. I 8.2 Evaluation l l

The licensee's submittals state that Engineering Design Procedure (EDP)-16 satisfies the requirements of this guideline. This procedure has 4

checkoffs for environmental and seismic qualification being needed. This I procedure is being replaced with Work Activity Control Procedure l WACP 10.1.24, " Procedure for the Review of Procurement Documents for the Specification of Technical, Quality Assurance, and Documentation Requirements." The licensee states that this procedure requires the consultation of the MEL to determine the safety (QA) classification of the l item being procured. This procedure has controls on specifying the design, I

technical, operational, quality assurance, documentation, and test requirements on procurement documents. l l

8.3 Conclusion We conclude that the licensee has addressed the concerns of this item.

Therefore, we find the licensee's responses for this item acceptable.

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9. ITEM 2.2.1.6 "!MPORTANT 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 i 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, this item will not be reviewed.

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, , 10. CONCLUSION

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4 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 these concerns meets the requirements of Generic Letter 83-28 and'is acceptable. Item 2.2.1.6, as noted in Section 9.1, was not reviewed. -

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11. REFERENCES

1. Letter, NRC (D. G. Eisenhut) to all Licensees of Operating Reactors, Appiteants 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. I t

2. Letter, New York Power Authority (J. P. Bayne) to NRC, " Response to  !

Generic Implications of Salem ATWS Events (Generic Letter 83 28)," i November 9, 1983. JPN 83 92. '

3. Letter, New York Power Authority (J. P. Bayne) to NRC, " Required i

, Actions Based on Generic Implications of Salem ATWS Events,"  !

l June 29, 1984 JPN 84 42.

l l 4. Letter, New York Power Authority (J. C. Brons) to NRC, " Additional I Information Regarding Generic Letter 83 28. " Required Actions Based on Generic Implications of Salem ATWS Events," July 2,1985. JPN 85-55  :

5. Letter, New York Power Authority (J. C. Brons) to NRC (D. R. Muller),

, " Component Quality Assurance Category List," December 31, 1985, JPN 85-93.

6. Letter, New York Power Authority (J. C. Brons) to NRC, " Component Quality Assurance Category List," March 20, 1987, JPN 87 015. ,

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7. Letter, New York Power Authority (J. C. Brons) to NRC, Additional  !

Information Regarding item 2.2 (Part 1) of Generic Letter 83 28, ,

3 Equipment Classification Program " October 16, 1989 JPN 89 066.

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Washington DC 20555 io. supeumantaar worss

,,....,...,_ . , i This EG&G Idaho. Inc., report provides a review of the submittals from the '!

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