ML19324A623

Conformance to Generic Ltr 83-28,Item 2.2.1 - Equipment Classification for All Other Safety-Related Components: Grand Gulf-1, Technical Evaluation Rept

ML19324A623
Person / Time
Site:	Grand Gulf
Issue date:	05/31/1989
From:	Udy A EG&G IDAHO, INC.
To:	NRC
Shared Package
ML19324A624	List: ML19324A623
References
CON-FIN-D-6001 EGG-NTA-7298, GL-83-28, TAC-53676, NUDOCS 8909150185
Download: ML19324A623 (15)

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

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

GRAND GULF-1 Docket No. 50-416 6

Alan C. Udy t

i Published May 1989 j

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

Idaho Falls Idaho 83415 i

t Prepared for the U.S. Nuclear Regulatory Commission

• Vashington 0.C. 20555 -

Under DOE Contract No. OE-AC07-76ID01570  :

FIN No. 06001 TAC No. 53676 .

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$UMMARY This EG6G Idaho, Inc., report provides a review of the licensee's

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submittals for Unit No.1 of the Grand Gulf Nuclear Station for conformance to Generic Letter 83-28. Item 2.2.1. Item 2.2.1 of Generic Letter 83-28 requires licensees to submit a detailed description of their programs for i safety-related equipment classification for staff review. It also .

describes the guidelines that the licensee's programs should encompass. '

This review concludes that the licensee complies with the requirements of this item. ~

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B&R No. 20-19-10-11-3 t FIN No. 06001 Docket No. 50-416 .

TAC No. 53676 L

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i PREFACE e

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 ATVS 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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" . CONTENTS t

Q-J' Lt ABSTRACT .............................................................. 11 r FOREWORD .................... ........ .............................. iii  !

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INTRODUCTION .............. .. ................................... 1 2.

REVIEW CCNTENT AND FORMAT ........................................ 2

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ITEM 2.2.1 - PROGRAM ............................................. 3 3.1 3.2 Guideline ..................................................

Evaluation .................. 3 ,

3 3.3 Conclusion .................. ..............................

.............................. 3 4

ITEM 2.2.1.1 - IDENTIFICATION CRITERIA ........................... 4 4.1 4.2 Guideline Evaluation ..................................................-

4-4 4.3 Conclusion ................................................. .......................... 4

5. 1 ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM ....................... -5 l 5.1 1

5.2 Guideline ..................................................

Evsluation ........................ 5 5

5.3 Conclusion ....................................,........... ........................ 5 6.

ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLASSIFICATION LISTING . . . . 6. . .

d.1 PJideline ........................... 6 6.2 Evasation.................................................

6.3 C o r. c l u s i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

...................... 6 7.

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

13. CONCLUSION ....................................................... 10 11.

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

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CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1-- i EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENT GRAND (mF-1 f b

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 (EDO) 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 imo'ications of the Salem Unit 1 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 Commission (NRC) t requested (by Generic Letter 83-28 dated July 8, 1983 1

) all licensees of 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.

l This report is an evaluation of the responses submitted by the licensee for the Grand Gulf Nuclear Station, for Item 2.2.1 of Generic Letter 83-28. The documents reviewed as a part of this evaluation is 1;,ted in the References (Section 11) at the end of this report.

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2. REVIEW CONTENT AND FORMAT Itts'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 th9 licensee's response is made;'and conclusions about the programs of the Itcensee 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 j designated safety-related an 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 i 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 Grand Gulf Nuclear Station responded to these requirements with submittals dated June 28, 19852 and June 17, 1988.3 i

These submittals describe the licensee's safety-related equipment classification program and the development of the Master Equipment List ,

(MEL). An administrative procedure, " Determination of Safety / Quality Classifications," was used before the MEL data base was complete to assure that any activity regarding safety-related components was identified as safety-related. The MEL data base willsbe replaced by the Component Data Base (COB) by the end of June 1989. The COB will be used in conjunction with the Station Information Management System (SIMS), an integrated work preparation and tracking system. In the review of the licensee's response j to this item, it was assumed that the information and documentation supporting this program is available for audit upon request.

s 3.3 Conclusion l

1 We have reviewed the licensee's submittals and find that, in general, the licensee's responses are acceptable. <

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[ ., 4. ITEM e 2.1.1 - IDENTIFICATION CRITERIA  !

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q 4.1 Guideline Thi licensee should confirm that the program used for equipment  ;

classification includes the criteria used for identifying cor.ponents as safety-related.

4.2 Evaluation .

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The licensee's response states that the criteria for determining what plant items and activities are safety-related are specified in Section 3.2' of the Grand Gulf Final Safety Analysis Report (FSAR) and in the licensee's Q-list. These criteria are provided in the response and are consistent f

with the definition given in Item 2.?.1 of Generic Letter 83-28. '

4.3 Conclusion ~

The licer.see's responses to this item are complete and address the staff's concerns. Therefore, we find the lictnsee's responses for this item acceptable. .

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, 5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM *

.,. 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 system handling includes a list of safety-related equipment and that procedures exist to govern its development and validation.

5.2 Evaluation The licensee states that the information handling system being .

developed consists of a component data base (CDB). The licensee's description included the methods used in developing and validating the listing, described how new safety related items are entered, and described, how changes in the classification of listed items are made and verified.

The following procedures are referenced.

Administrative Procedure 01.5.07.14 " Control and Use of the GGNs Equipment Index"  ;

l 1 SIMS Project Procedure No. 2 " Data Entry /QC/ Data Base 1

i Management" l'

SIMS Project Procedure No. 4 " Data Collection" 5.3 Conclusion The licensee's responses describe a system that meets the recommendations of this item. Therefore, we find the licensee's responses '

Jo for this item acceptable.

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ITEM 2.2.1.3 - USE OF THE EQUIPMENT CLASSIFICATION LISTING 6.1 Guideline The licensee's description should confirm that the program for equipment classification includes criteria and procedures that govern how station personnel use the equipme'.. classification information handling >

system to determine that an actly; y .; safety-related. The description should also include procedures for maintenance, surveillance, parts replacement, and other activities defined in the introduction of 10 CFR 50, Appendix B, that apply to thuse safety-related components.

6.2 Evaluation The licensee states that their administrative procedure " Determination of Safety / Quality Classification" is used by station personnel to determine if safety-related activities are being performed on components not listed-l on the MEL. The licensee has shown that station personnel are to use the l

inforration handling system to determine whether an activity is ,

i safety-related; however, the administrative procedures requiring the use of l

the MEL were not complete at the time of the licensee's June 28, 1985 1 submittal. The licensee indicates (Reference 3) that plant procedures will be revised to require the use of the CDB when the CDB is completed.

6.3 Conclusion i

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

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS i

7.1 Guideline The licensee 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 Cvaluation The licensee's response to this item describes managerial controls ,

that will be used to verify that the COB has been prepared according to '

approved procedures and that its contents are verified. The licensee's response describes managerial controls that verify that the COB is being maintained current and that it is being used to determine equipment classification.

7.3 Conclusion e

We find that the management controls used by the licensee assure that the information handling system (CQS) is maintained and is used as intended. Therefore, we find the licensee's responses for this item

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, 8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT 8.1 Guideline 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 comporents and parts. The specification should include qualification testing for expected safety-service conditions and provide support for the licensee's 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 itcensee states that replacement safety-related items are required to be purchased to the original specification requirements or to a revision of those requirements that has been properly reviewed and approved. The ,

licensee also states that administrative procedures require the same quality, technical test, qualification, and review requirements be applied to replacement parts that were part of the original specification i

requirements. Engineering reviews verify the appropriate use of these replacement parts and insure that the technical and quality requirements, including documentation, verification of design capability, and evidence of testing are included in the purchase specification.

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 "IMPORTANT TO SAFETY" COMPONENTS 9.1 Guideline Generic Letter 83-20 states that the licensee's equipment I classification program 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 the licensee to furnish this information as part'of their response, this item will not be reviewed, i

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10. CONCLUSION e

Based on our revier 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 is acceptable. Item 2.2.1.6 was not.

reviewed. as noted in Section 9.1.

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lo 11. REFERENCES 1.. i Letter, NRC (D. G. Eisenhut) to all Licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits, "Rcquired Actions 8ased on Generic Implications of Salem ATWS Events (Generic Letter 83-28)," July 8,1983. '

2. Letter, System Energy Resources, Inc. (L. F. Dale) to NRC, " Response to Generic Letter 83-28, Item 2.2.1," June 28,1985, AECM-85/0201, 3.

Letter, System' Energy Resources, Inc. (0, D. Kingsley, Jr.) to NRC, "1988, Supplemental Response to Generic Letter 83-28 Item 2.2.1," June 17, AECM-88/0121.

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