ML20235L981

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

ML20235L981
Person / Time
Site:	Seabrook
Issue date:	06/30/1987
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20235L969	List: ML20235L966 ML20235L981
References
CON-FIN-D-6001, CON-FIN-D-6002 EGG-NTA-7408, GL-83-28, NUDOCS 8707170013
Download: ML20235L981 (15)

Text

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EGG-NTA-7408 June 1987 l.

' 'o INFORMAL REPORT yf:  ;

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. CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

/daho' EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-SEABROOK-1 AND -2 Nationa/ f ' '

RELATED COMPONENTS:

Engineering; '

Laboratory ,

Alan C. Udy

Managed

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Department ofEnergy b

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Prepared for the d4#"*" "* U. S. NUCLEAR REGULATORY COMMISSION Work performed under '

DOE Contract No. DE AC07 MID01510 8707170013 070625 DR ADOCKODOOjy3

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DISCLAIMER This book was prepared as an account of work sponsored by an ageScy of the United States Government. Neither the United States Government nor any agency thereof, not any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of af.y information, apparatus, proouct or process disc!osed, or represents that its use would not iniringe 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 an) agency tnereof.

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EGG-NTA-7408

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l TECHNICAL EVALUATION REPORT i

i CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

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SEABROOK-1 AND -2 Docket Nos. 50-443/50-444 l

1 Alan C. Udy i

Published June 1987- ,

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

Idaho Falls, Idaho 83415 i

Prepared for the i U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Under 00E Contract No. DE-AC07-761001570 FIN Nos. D6001 & D6002 l

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l ABSTRACT )

l This EG&G Idaho, Inc., report provides a review of the submittals for j Unit Nos. 1 and 2 of the Seabrook Station for conformance to Generic 4 Letter 83-28, Item 2.2.1. l l

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Docket Nos. 50-443/50-444 TAC No. 76416 1

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i FOREWORD -1 This report is supplied as part of the program for evaluating l licensee / applicant conformance to Generic Letter 83-28 " Required Actions 1

Based on Generic Implications of Salem ATWS Events." This work is baing '

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

j. Reactor Regulation, Division of Engineering and System Technology, by EG&G l Idaho, Inc., NRR and I&E Support Branch.

The U.S. Nuclear Regulatory Commission funded this work under the authorization B&R Nos. 20-19-10-11-3 and 20-19-40-41-3, FIN Nos. 06001 and 06002.  !

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e i Docket No. 50-443/50-444  ;

1 TAC No. 76416 j 114 a

CONTENTS ABSTRACT .................... ......................................... ii.

FOREWORD ........... .................................................. iii

1. INTRODUCTION .......................... .......................... 1 a j i

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

3. ITEM 2.2.1 - PROGRAM ............................................. 3 j 3.1 Guideline .................................................. 3 1

3.2 Evaluation ................................................. 3 3.3 Conclusion ...... ..... .................................... 3 1

4. ITEM 2.2.1.1 - IDENTIFICATION CRITERIA ........................... 4 1 i

4.1 Guideline .................................................. 4 4 4.2 Evaluation ... .................... ....................... 4 4.3 Conclusion ................................................. 4

5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM ....................... 5

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5.1 Guideline ............................... ................... 5 )

5.2 Evaluation ................................................. 5 .j 5.3 Conclusion ................................................. 5 3

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6. ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING . . . . . . . . . . . 6 6.1 Guideline ..... .. .... ........ ..... .......... ........ 6 6.2 Evaluation .......... ...................... ............... 6 6.3 Conclusion ..... ... ... ....... ..... ..................... 6 j

7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS ............... ............... 7 7.1 Guideline ... .... ..... ........................ .......... 7 ,

7.2 Evaluation ..... . ..... .......... . ... ................ 7 1 7.3 Conclusion ............... ................................. 7 1

8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ........... ... 8 8.1 Guideline .................................... ............. 8 8.2 Evaluation ........ .................... ......... ......... 8 8.3 Conclusion ... .............................. ............... 8 l

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9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS ....... .......... 9 9.1 Guideline .............................. .. .. ............. 9

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

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

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CONFORMANCE'TO GENERIC LETTER 83-28, ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

SEABROOK-1 AND -2

1. INTRODUCTION 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' i 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 I 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 1 of the Salem Nuclear Power Plant. The results of the staff's inquiry into the ,

I generic implications of the Salem unit 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) requested (by Generic Letter 83-28 dated July 8,19831 ) all licensees of operating reactors, applicants for an operating 1.icense, 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 Public Service Company of New Hampshire, the licensee for Seabrook-1 and the applicant for Seabrook-2, for Item 2.2.1 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.

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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 detail, as indicated in the guideline section for each ,

sub-item within this report.

As previously stated, 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 its acceptability are drawn.

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3. ITEM 2.2.1 - PROGRAM l

3.1 Guideline f 1

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i- Licensee and applicants should confirm that an equipment classification '

program :is in place which will provide assurance that' all safety-related components are designated as safety-related on plant documentation such'.as procedures,' system descriptions, test and maintenance instructions and in-information handling systems so that personnel performing activities that-affect such safety-related components are aware that they are working on l safety-related components 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 l The Public Service Company of New Hampshire responded to these requirements with submittals dated November 4, 19832 and May 4, 1987.3 These submittals include information that describes their safety-related l equipment classification program. In the review of the utility's response l to this item, it 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 utility states that plant documents, operational procedures, system descriptions and the computerized information handling system designate the safety-related status of structures, systems components and parts.  ;

3.3 Conclusion We have reviewed the utility's information and, in general, find that.

their response.is adequate.

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4. ITEM 2.2.1.1 - IDENTIFICATION CRITERIA 4.1 Guideline The applicant or licensee should confirm that their program used for equipment classification includes criteria used for identifying components -

as safety-related.

. i 4.2 Evaluation The utility states that Section 3.2.2 of the Seabrook Station FSAR provides details on the criteria used to identify a component as safety-related. They further state that the criteria is consistent with the staff position footnoted in Section 2.2 of the generic letter, with  !

Regulatory Guide 1.26 and with ANSI N18.2A-1975.

4.3 Conclusion j i

l We find that the utility has confirmed that they have identified the criteria used in the identification of safety-related components, thus meeting the requirements of Item 2.2.1.1.

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5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM l

5.1 Guideline l l

. 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 I that this information handling system includes a list of safety-related equipment and that procedures exist which govern its development and validation.

5.2 Evaluation l

The utility states that the architect / engineer (United Engineers and Constructors) developed the following lists:

1. Equipment list

2. Line list

3. Class-1E list

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4 Standard instrument schedule

5. Cable schedule These lists and schedules were developed and used during the design, construction and startup of the Seabrook Station. The procedures used in preparing these lists and schedules, which are incorporated into the licensee's/ applicant's equipment classification information. handling system, are stated to have included specific instructions for documentation and verification. The lists are routinely re-verified and incorporate change documents upon completion of the work involved in the change.

5.3 Conclusion The utility's response for this item is considered to be complete and 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 their program for equipment classification includes criteria and procedures ,

governing the use of the equipment classification information handling system to determine that an activity is safety-related and what procedures

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j for maintenance, surveillance, parts replacement and other activities

! defined in the introduction to 10 CFR 50, Appendix B, apply to safety-related components, 6.2 Evaluation ,

The utility states that administrative and quality assurance programs are in place, providing the guidance and instructions necessary for m-sintenance and spare parts programs. Further, they state that their Design Control Program provides instructions and procedural controls to insure the appropriate technical, administrative and quality reviews. The licensee / applicant has described the use of the information handling system in determining whether an activity is safety-related and in determining what procedures are used for purchasing, operation, surveillance testing, and maintenance activities.

6.3 Conclusion j i

We find that the utility's description of plant administrative controls and procedures meets the requirements of this item and is, therefore, acceptable.

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS 1

7.1 Guideline

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. . .The applicant or licensee should confirm that the' management controls i used.to verify 'that the procedures for preparation, validation and routine utilization of.the information handling system have been followed.

i 7.2 Evaluation The utility states.that administrative and quality assurance programs,.

l as well as Station Manual procedures, ensure that station requirements are-followed. They state.that there are management controls governing the. ,

input to, the outputs of and process activities related to the info'rmation J].

handling system. The controls include the Station Operational' Review -

Committee for 10 CFR 50.59 reviews, and periodic Quality Assurance audits  !

i and surveillance of the information handling-system. Comparisons to  !

manual data bases are also utilized.as a validation tool, Routine use of- 1 the computer data base is called for in procedures and..in des'ign change instructions.

7.3 Conclusion We find that the management controls used by the utility assure that the information handling system is maintained, is current and is used as-intended. Therefore, the licensee's/ applicant's response for this item is acceptable.

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8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT 1 i

8.1 Guideline l

The applicant's or licensee's submittal should document that past .

j usage demonstrates that appropriate design verification and qualification '

i testing is specified for the procurement of safety-related components and

• i parts. The specifications should include qualification testing for expected safety service conditier5 and provide support for the applicant's/ licensee's receipt af 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.

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l The utility states that the approved stat'ah criteria for Material Purchase Request Preparation and Review ensures that design. verification and qualification testing is specified for the safety-related equipment and components procured. They also state that design and service conditions are identified as a result.

8.3 Conclusion Although the utility did not specify the design criteria applied to this item, we conclude that they have addressed the concerns of this item and, therefore, we find the response for this item 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 utility's equipment 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 utility to furnish this information as part of their response, review of this item will not be performed.

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10. -CONCLUSION Based on our review of the utility's response to the specific requirements .of Item 2.2.1, we find that the information provided by the utility to resolve the concerns of Items 2.2.1.1, 2.2.1.2, 2.2.1.3, 2.2.1.4 ,

and 2.2.1.5 meet the requirements of Generic Letter 83-28 and is l acceptable. Item 2.2.-l.6 was not reviewed as noted in Section 9.1. -

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11. REFERENCES

1. NRC Letter, 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, Public Service Company of New Hampshire (J. DeVincentis) to NRC (G. W. Knighton), " Response to Generic Letter 83-28,"

- ' November 4,1983, SBN-576, T. F. 84.2.99.

3. Letter, Public Service Company of New Hampshire (G. S. Thomas) to NRC,

" Additional Information for Items 2.1 (Part 2) and 2.2 (Part 1) of Generic Letter 83-28," May 4, 1987, NYN-87061.

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Idaho Falls, ID 83415 i D6001/D6002 io sco=soaino oao. wiz.Tio= N.we .mo u.iumo .coatas ri e sm s, Cens us YvPt 08 atPoaf Division of Engineering and System Technology Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission *""'**v'a'o"~'~~~'

Washington, DC 20555 13 SUPPLEMENT.av NOTt5 IJ .85,a.CT (J00 worse er seess This EG&G Idaho, Inc. report provides a review of the submittals from the Public Service Company of New Hampshire 'regarding conformance to Generic Leter 83-28, Item 2.2.1 for the Seabrook Station.

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