ML20205L009

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

ML20205L009
Person / Time
Site:	Oyster Creek
Issue date:	07/31/1988
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20205K996	List: ML20205K992 ML20205L009
References
CON-FIN-D-6001 EGG-NTA-7293, GL-83-28, TAC-53698, NUDOCS 8811010441
Download: ML20205L009 (18)

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t EGG-NTA 7293 TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1: EQUIPMENT CLASSIFICATION FOR ALL OTNER SAFETY-RELATED COMPONENTS--0YSTER CREEK Docket No. 50-219 Alan C. Udy Pubitshed July 1988 .

Idaho National Engineering Laboratory EG6G Idaho, Inc.

Idene Falls, Idaho !!415 Prepared for the U.S. Nuclear Regulatory Commission Washington. 0.C. 20555 Under DOE Contract No. DE-AC07-76!D01570 FIN No. 06001

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i A8$ TRACT I This EGM Idaho, Inc., report documents the review of the subetttats  :

from the Oyster Creek Nuclear Generating Station for conformance to Generic r

> Lette'r 83-28, Item 2.2.1.

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Docket No. 50-219 +

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FOREWORD This report is supplied as part of the program for evaluating Itcensee/appitcant conformance to Generte Letter 83-28 "Required Actions Based on Generic Imp 1tcations of Salen ATW$ Events." This work is being <

conducted for the U.S. Nuclear Regulatory Commission, Office of Nuclear .

Reactor Regulation, Otvision of Engineering and System Technology, by EG&G ;

Idaho, Inc., Electrical, Instrumentation, and Control Systems Evaluation Unit.  ;

The U.S. Nuclear Regulatory Commission funded this work under the  ;

authorizetton B&R 20-19-10-11-3, FIN No. 06001. - l Docket Nos. 50-219 TAC No. 53698 111

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' CONTENTS ABSTRACT .............................................................. it FOREWORD .............................................................. 111

1. INTRODUCTION ..................................................... 1

2. REVIEW CONTENT AND FORMAT ........................................ 2

3.  ! TEM 2.2.1 - PROGRAM ............................................. 3 3.1 Guideline .................................................. 3 3.2 Evaluation ................................................ 3 3.3 Conclusion ................................................. . 3

4. ITEM 2.2.1.1 - IDENTIFICATION C RITERI A . . . . . . . . . . . . . . . . . . . . . . . . .

• 4.1 Guideline

.........................................m.... .... 4 4.2 Evaluation ................................................. 4 4.3 Conclusion ................................................. 4

5. ITEM 2.2.1.2 - INFORMATION RANDLING SYSTEM ....................... 5 5.1 Guideline .................................................. 5 5.2 Evaluation ................................................. 5 5.3 Conclusion ................................................. 5

6. ITEM 2.2.1.3 - USE OF EQU!PMENT CLAS$!FICATION LISTING ........... 6 6.1 Guideline .................................................. 6 6.2 Evaluatien . ............................................... 6 6.3 Conclusion ................................................. 6

7.  ! TEM 2. 2.1. 4 - MANAG EMENT CONT ROLS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 7.1 Guideline .................................................. 7 7.2 Evaluation ................................................. 7 7.3 Conclusion ................................................, 7

8.  ! TEM 2.2.1.5 - DE5IGN VERIFICATION AND PROCUREMENT . . . . . . . . . . . . . . . 8

. .... ww.we.lf.e .................................................. 6 S.2 EValuat10n ................................................. 8 8.3 Conclusion ................................................. 8

s.  ! TEM 2.2.1. 6 "!MPORTANT-T0;5AFETY" COMPONENTS . . . . . . . . . . . . . . . . . . 9 9.1 Guideline .................................................. 9

10. CCNCLU5!ON ....................................................... 10

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

CONFORMANCE TO GENERIC LETTER 87 28. ! TEM 2.2.1: E0V!PwENT CLASS!FICATION FOR ALL OTHER SAFETY AELATED COMPONENTS--0YSTER CREEK 1

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On February 25, 1983, beth of the scram circuit br eakers at Unit 1 of the Sales 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, en February 22, 1983, at Unit 1 of the Sales Nuclear Power Plant, an automatte 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 carincidentally with the automatic trip.

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

_ Otrector for Operations (EDO)', directed the NRP staff to investigate and report on the generic implications of these occurrences at Unit 1 of the Salen Nuclear Power Plant. The results of the staff's inquiry into the ceneric topitcations of the Salem incidents are reported in NUREG-1000, j "Generic Implications of the ATW5 Events at the Salen Nuclear Power Plant " As a result of this investigation, the Commission (NRC) requested (by Generic Letter 83-28 dated July 8,1983I ) all Itcensees of operating reactors, applicants for an operating Itcense, and holders of construction permits to respond to the generic issues raised by the analyses of these

] two ATW1 events.

This report is an evaluation of the responses subettted by GPU Nuclear, the Itcen;ee for the Oyster Creek Nuclear Generating 5tation, for

Ites 2.2.1 of Generte Letter 83-28,,, The documents reviewed as a part of this evaluation are listed in the references at the end of this report.

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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 dotat), as indicated in the guideline section for each item within this report.

l As previously indicated, each of the sia items of Item 2.2.1 is evaluated in a sogarate section in which the guideline is presented; en evaluation of the 6teensee's/ applicant's response is made; and conclusions l about the programs of the licensee or applicant for safety-related equipment clas*1fication are dr&wn.

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3. ITEM 2.2.1 - PROGRAM 3.1 Guideline Licensees and applicants should confirm that an equipment classification program exists that provides assurance that all safety-related components are designated as safety-related on plant documentation and in the information handling system that controls safety-related activities. The purpose of this program is to ensure that personnel performing activities that affect such safety-related components are aware that they are working on safety-related components and are guided by safety-related proc 2dures and constraints. Features of this program are evaluated in the remainder of this report.

3.2 Evaluation -

The licensee for the Oyster Creek Nuclear Generating Station responded

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to these requirements with submittals dated November 14, 1983,2 October 23, 1985,3 and May 18, 1988.4 These submittals includet information that describe the licensee's 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 states that the equipment quality classification list is the information handling system referred to. Components are added to the list should the :omponent be classified safety-related 'oy procedurs EP-011, "Qus11ty Classification List." The licensee states that safety-related components are identified as such on plant drawings, design descriptions, specifict :fons, documents, and proceduras.

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

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4. ITEM 2.2.1.1 - IDENTIFICATION CR'TERIA 4.1 Guideline The appitcant or Itcensee should confirm that their program used for equipment classification includes criteria used for identifying components as safety-related.

4.2 Evaluation The licensee's initial submittal stated that the safety-related status of components or ptrts that are part of a safety-related system are determined on a case-by-case basis, based on engineering judgement.

This response was expanded to list' form 5000-ADM-7313.02 as the -

control methodology for determining the safety-related status of components -

and parts. This is described by the licensee as considering the design of and the licensing basis of the component; the component's function; how it operates and a measure of the component's function to plant operation and safety. It is based on a checklist approach and results in a report that is reviewed and approved and issued as a controlled document. The quality assurance department audits and independently monitors this process.

Reference 4 states that new components are added to the list in accordance with procedure EP-011. "Quality Classification List."

l Form 5000-ADM-7313.02 is a part of procedure EP-011. l 1.2 Cen:1:sion We find that the criteria used in the identification of safety-related components meets the requirements of Item 2.2.1.1. Therefore, the licensee's response to this concern is acceptable.

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5. ITEM 2.2.1.2 - INFORMATION HANDLING SY3 TEM 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 eq'uipment and that procedures exist to govern its development and validation.

5.2 Evaluation The licensee's description in Attachment 2 of Reference 3 describes how the listing of safety-related components was originally prepared. The licensee states that the listing will be incorporated as part of their standard ES-011. "Methodology and Control of GPUN Quality Classification." This standard is used by personnel in determining t.ie safety-related status of activities associated with safety-related

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comoonents.

The Itcensee described how new safety-related items are entered, and how changes in the classification of listed items are made, via use of form 5000-ADM-7313.02. EP-11 causes an ongoing validation program to be operated by the Quality Classification group. Unauthorized changes to the listing are prevented because the Quality Classification group is the only group with computer security clearance to mcdi'y the database. Thus, the listing is maintained and distributed to users as an official, single, consistent, and unambiguous version.

5.3 Conclustoj -

The licensee's response to the' item is considered to be complete.

Therefore, the licensee's response to this concern is acceptable.

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6. ITEM 2.2.1.3 - USE OF 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 inforrotion I

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.

l 6.2 Evaluation The licensee's responses describe operational quality assurance requirements.that govern maintenance, modification, and procurement activities.' These requirements include the use of documented procedures in

~~ the accomplishment of safety-related activities. Those pracedures that prescribe safety-related activities are controlled and require approvals l before they are issued. .

1 1 6.3 Conclusion We find thtt the licensee's description of plant administrative controls and procedures meets the requirements of this item. Therefore, the licensee's response to this concern is acceptable.

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS 7.1 Guideline The applicant or licensee should briefly describe the management controls that are used to verify that the procedures for the preparation, validation, and routine utilization of the information handling system have been and are being followed.

7.2 Evaluation The licensee's response states that their quality assurance auditing process serves as the method of managerial control. Audits and inspections, on both scheduled and unscheduled bases, are used to verify the preparation, validation and routine use of the information handling system and to assure that safety-related activities 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 intended. Therefore, the licensee's response for this item is acceptable.

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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 j 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 receipt of testing documentation to support the limits of life recommended by the supplier. If such documentation is not available, confirmation that j the present program meets these requiremerits should be provided.

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8.2 Evaluation 1 .

l The Itcensee states that procedures 125.2 (Appendix C) and EP-031 and l forms 5000-AOM-6230.01 and 5000-ADM-7316 contain requirements concerning I

design verification and qualification testing. Purchase requisition forms PR530-85-0046 and PR5513-85-0362 contain provisions for environmental qualification testing. -

8.3 Conclusion l

We conclude that the lictnsee has addressed the concerns of this l item. Therefore, the licensee's response for this item is acceptable.

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9. ITEM 2.2.1.6 "IMPORTANT-TO-SAFETY" COMPONENTS 9.1 Guideline Generic Letter 83-28 states that the licensi.P 4 or applicant's equipment classification program should include (in addition to the safety-related components) a br;. .e class of components designated as

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"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 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 was not reviewed as noted in ,

Section 9.1.  ;

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11. REFERENCES

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

2. Letter, GPU Nucle.r, (P. B. Fiedler) to NRC, "Generic Letter 83-28,"

November 14, 1983.

3. Letter, GPU Nuclear (P. 8. Fiedler) to NRC (J. A. Zwolinski), "Generic Letter 83-28," October 23. 1985, 2177f/001.  ;

4. Letter, GPU Nuclear (R. F. Wilson) to NRC, "Generic Letter 83-28,"

May 18, 1988, 5000-88-1556.

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EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS: 0YSTER CREEK *"*"'

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P.O. Box 1625 Idaho Falls, ID 83415 06001

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