ML18150A122

Conformance to Generic Ltr 83-28,Item 2.2.1 -- Equipment Classification for All Other Safety-Related Components: Surry 1 & 2, Final Informal Rept

ML18150A122
Person / Time
Site:	Surry
Issue date:	04/30/1987
From:	VANDERBEEK R EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML18150A121	List: ML18150A120 ML18150A122
References
CON-FIN-D-6001 EGG-NTA-7378, GL-83-28, TAC-53721, TAC-53722, NUDOCS 8706080133
Download: ML18150A122 (19)

Text

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EGG-NTA-7378 April 1987 INFORMAL REPORT CONFORMANCE TO GENERIC LETTER 83-28, ITEM EQUIPMENT CLASSIFICATION FOR ALL OTHER RELATED COMPONENTS:

SURRY-I AND -2 R. VanderBeek Prepared for the U.S. NUCLEAR REGULATORY COMMISSION

. -DISCLAIMER This book was prepared as an account of work sponsored by 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 liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product or process disclosed, or represents that its use would not infringe privately 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 favoring 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 States Government or any agency thereof.

EGG-NTA-7378 TECHNICAL EVALUATION REPORT I CONFORMANCE TO GENERIC LETTER 83-28, ITEM EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

SURRY-1 AND -2 Docket Nos. 50-280 and 50-281 R. VanderBeek Published April 1987 Idaho National Engineering Laboratory EG&G Idaho, Inc. Idaho Falls, Idaho 83415 Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under DOE Contract No. DE-AC07-76ID01570 FIN No. D6001 I-I

• ABSTRACT Th1s EG&G Idaho, Inc .* report provides a review of the subm1ttals from Surry Power Station, Un1t Nos. 1 and 2 for conformance to Generic Letter 83-28, Item 2.2.1. Docket Nos. 50-280 and 50-281 TAC Nos. 53721 and 53722 ii 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 Co1M1ission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, 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 No~ 20-19-10-11-3, FIN No. 06001. Docket Nos. 50-280 and 50-281 TAC Nos. 53721 and 53722 iii

'J ABSTRACT FOREWORD CONTENTS D D D D D D D D D D D D D D

• D D D D D D D D

• D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D ................................................................

ii iii 1. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2. REVIEW CONTENT AND FORMAT........................................

2 . 3. ITEM 2.2.1--PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3.1 Guideline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3. 2 Eva 1 ua ti on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 Gui de 1 i ne . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 5.2 Evaluation..................................................

5 5.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 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 Cone 1 us ion . . . . . . . . . . . . . . . . . . . . . . . . . . . * . . . . . . . . . . . . . . . . . . . . . . 7 8. ITEM 2.2.1.5--DESIGN VERIFICATION AND PROCUREMENT

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

8 8.1 Guideline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 8.2 Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 8.3 Conclusion..................................................

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

10 9.1 Guideline . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 l O. CONCLUSION

11. REFERENCES

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

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

iv 11 12 CONFORMANCE TO GENERIC LETTER 83-28, ITEM EOUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

SURRY-1 AND -2 l. INTRODUCTION On February 25. 1983. both of the scram circuit breakers at Unit l 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 to be related to the sticking of the undervoltage trip attachment.

Prior to this incident.

on February 22. 1983. at Unit l 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 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 (EDO). directed the NRC staff to investigate and report on the generic implications of these occurrences at Unit l of the Salem Nuclear Power Plant. The results of the staff I s inquiry into the generic implications of the Salem unit incidents are reported in NUREG-1000. "Generic Implications of the ATWS Events at th~Salem Nuclear Power Plant." As a result of this investigation.

the Commission (NRC) requested (by Generic Letter 83-28 dated July 8. 1983 1) 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 Virginia Electric and Power Company. the licensee for the Surry Power Station. Unit Nos. land 2 for Item 2.2.l 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. 1

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 iri a separate section in which the guideline is pre~ented; 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. 2

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 survei 1 lance 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. The to these February 3.2 Evaluation licensee for the Surry Power Station, Unit Nos. 1 and 2, responded requirements with submittals dated November 4, 1983 2 and . 3 8, 1985. These submittals include information that describes their existing safety-related equipment classification program. In the review of the licensee's response to this item, H was assumed that the information and documentation supporting this program is* available for audit upon request. We have reviewed this information and note that the licensee's response does not directly confirm that all components designated as safety-related in the equipment ltsting are also properly designated on documents, procedures, and in information handling systems used for safety-related activities.

However, the licensee's response to Items.2.2.1.2 and 2.2~J.3 indicate that the documents used to control safety-related activities.

from start to finish are appropriately marked as safety-related.

This is discussed in Sections 5.2 and 6.2. We consider this to be acceptable.

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

3

4. ITEM 2.2.1.1--IDENTIFICATION CRITERIA 4.1 Guideline The criteria for identifying components as safety-related should be presented.

This should include a description of the means for handling sub-components or parts, as well as procedures for initiating the identification of components as safety-related or non-safety-related if no previous classification existed. 4.2 Evaluation The licensee's response states the criteria utilized for classification of safety-related structures, systems, and components are consistent with the definition and requirements stated in 10 CFR 100, Appendix A, Paragraph III.E. We find this acceptable.

4.3 Conclusion We find that the criteria used in the identification of safety-related components meets the requirements of Item 2.2.1.1 and are acceptable.

4

5. 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 thatthis 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's response states that the information handling system consists of Station Administrative Procedure ADM/73 which contains a listing of safety-related structures, systems, and components.

The listing contained in the procedure does not provide a detailed listing of every component of safety-related systems but provides a general breakdown by

• system and major component parts. Subcomponents of safety-related systems are considered to be safety-related; The procedure containing the list is ~~controlled

~tat1on document and requires the review and approval the Station Nuclear Safety and Operating Convnittee (SNSOC). Where questions arise during classification of specific structures, systems, or components, requests are forwarded to the station *engineering staff for resolution.

Appropriate reviews are required prior to the removal from or addition to the list. Th~ licensee indicates that development of a new and more complete listing of safety-related components is in planning but no specific date for completion has been set. 5.3 Conclusion The licensee's response to this item is considered to be complete and is acceptable.

5 ---,

6. ITEM 2.2.1.3--USE Of EQUIPMENT CLASSI~ICATION LISTING 6.1 Guideline The licensee*s description should show how station personnel use the equipment classification information handling system to determine: (a) when an activity-i~

safety-related, and (b) what procedures are to be,, used for maintenance .work, routine surveillance testing-~.

acc.omp l'l shmenLof:?'

design changes, and performance of special tests or studies. We should be able.to gain confidence from our review that there will be no confusion about when an activity is safety-related.

6.2 Evaluation The licensee's response indicates that responsible station personnel use the equipment listing and corporate procedures to designate the safety classification of the equipment and the procedures required to perform the work. The safety classification and procedures are indicated on the work actity forms used for all repair and modification work performed at the plant. If anyone within the plant is unsure of the classification of a component, he is required to check with the station engineering staff. 6.3 Conclusion We consider the licensee's response to this item to be complete and is acceptable.

6 '-

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 states that the Quality Assurance Department performs audits of activities covered by the plant instructions and procedures.

Thus, the audit program provides verification of the routine utilization of the information handling system. 7.3 Conclusion The licensee's response to this item is considered to be complete and is acceptable.

7

8. ITEM 2. 2, J. 5'.i;:-DESIGN VER IF I CATION AND PROCUREMENT

-' ' ** '-*. * ** '1, -*** 8.1 Guideline The licensee's submittals shall show that the specifications for procurement of r~placement*safety-related components and parts requ1re that verification of design~capability and evidence of testing that qualifies, the.components and parts for service und~r !he* expected conditibns~ove~th~,, service life specified by the supplier is included.

8.2 Evaluation The licensee's response states that the guideline and policy for procurement of equipment for use at each station is contained in Section 4 and Section 7 of the Nuclear Power Station Quality Assurance Manual (NPSQAM) and related station administrative procedures.

Direction is provided regarding review of purchase documents.

requirements for standard tests or inspections and supporting Quality Assurance documentation, requirements for review when 11 commercal grade 11 materials or components or,, substitute materials or components are used in lieu of those originally specified.

General guidance is also provided regarding the use of* 11 Engineering Specifications 11 for new materials or components added during plan design changes. , Normal replacement parts and maintenance items are procured through _ pruchase requisitions which contain the required information referenced in the NPSQAM and station administrative procedures.*

The information and. detail-is included in the purchase document and ar-e normally standard nuclear industry requirements.

Special items may be procured using formal specification documents and the specifications include unique requirements as necessary.

Specification guidelines include such considerations as environmentaly and testing conditions.

Material and equipment for plant modifications are procured through* methods similar to those described above. The same governing documents 8

apply to this procurement cycle. The difference is primarily in the area of approval for monetary commitments and expenditures.

8.3 Conclusion We consider the licensee's response to be complete and is acceptabT~:

9

9. ITEM 2,.2.1.6--"IMPORTANT TO:$AFETY" COMPONENT~.

9.1 Guideline Generic Letter 83-28 states that the licensee's or applicant's equipment classification program should include (1n addition to the safety-:-related components) a broader class of components.-designaJ~d**as

• • "Important to Safety.11* However, since thegeneric*letter:

doe.s;:nQJ,r¢qutre.

the licensee or applicant to furnlsh" this information a$*parct*of:

thetr resp.cmse, .. review of; this Hein will not be performed.

10

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 Item 2.2.l meets the requirements of Generic Letter 83-28 and is acceptable.

Item 2.2.1.6 was not reviewed as noted in Section 9 of this report. 11

11. REFERENCES

1. NRC Letter, D. G. Eisenhut to all licensees of Operating R~actors, 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. Virginia Electric and Power Company letter, W. L. Stewart to H. R. Denton, NRC, November 4, 1983, Serial Number 617. 3. Virginia Electric and Power Company letter, w. L. Stewart to H. R. Denton, NRC, February 8, 1985; Serial Number 85-063. * ...........

l .. . _ .. _. *-* ' -' .,.,.-,.,, 12 NRC FORM 335 '12-841 U.S. NUCLEAR AIGULATORY COMMISSION

1. REPORT NUMBER IAuign<<l.bv TIDC. *dd Vol. No., il*nv/ NRCM 1102, 3201, 3202 BIBLIOGRAPHIC DATA SHEET EGG-NTA-7378 SEE INSTRUCTIONS ON THE REVERSE 2. TITLE AND SUBTITLE CONFORMANCE TO GENERIC LETTER 83-28, ITEM EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

SURRY-l AND -2 5. AUTHORCSJ . IL VanderBeek

7. PERFORMING ORGANIZATION N'AME AND MAILING ADDRESS llnclu.t.Z,p Codi/ EG&G' Idaho, Inc. P. 0. Box 1625. Idaho Falls, Irr 83415 10. SPONSORING.ORGANIZATION NAME ANO MAILING ADDRESS (lnclu*Zip Cathi Division of PWR Licensing

-A Office of Nuclear Reactor Regulation U.S. Nuclear*Regulatory Commission Washington, DC 20555 12. SUPPLEMENTARY NOTES 1 J: ABSTRACT.

(200 word, or l*ul J. LEAVE BLANK 4. DATE REPORT COMPLETED MONTH . YEAR April 1987 6. DATE REPORT I_SSUED I YEAR 1987 MONTH April 8. PROJECT/TASK/WORK UNIT NUMBER 9. FIN OR GRANT NUMBER D6001 1 h. TYPE OF REPORT b. PERIOD COVERED /lnclu1i .. dam/ This EG&G Idaho, Inc., report provides a review of the submittals from the Virginia Electric and Power Company regarding conformance to Generic Letter 83-28, Item 2.2.1 for-the Surry Power Station, Unit Nos. 1 and 2. 14 DOCUMENT ANALYSIS

• KEYWORDS/DESCRIPTORS

b. IDENT*IFIERS/OPEN-ENDED TERMs*** 15. AVAILABILITY STATEMENT Unlimited Distribution

16. SECURITY CLASSIFICATION (Thi1 p~o/ Unclassified (Thi1 r.parrJ Unclassified

17. NUMBER OF PAGES 18. PRICE