ML20235L906

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

ML20235L906
Person / Time
Site:	Beaver Valley
Issue date:	06/30/1987
From:	Udy A EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20235L885	List: ML20235L882 ML20235L906
References
CON-FIN-D-6001, CON-FIN-D-6002 EGG-NTA-7244, GL-83-28, TAC-53652, NUDOCS 8707160868
Download: ML20235L906 (19)

Text

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EGG-NTA-7244 JUNE 1987 INFORMAL REPORT eg S

Idaho

1. #" ' CONFORMANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

. Engineering - EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-Laboratory RELATED COMPONENTS: BEAVER VALLEY-1 AND -2 Managed )

by the U.S. \

Department Alan C. Udy l ofEnergy i

i E kLshe work performed under Prepared for the umocJief#lT!' U.S. NUCLEAR REGULATORY COMMISSION 8707160860 870612 PDR ADOCK 05000334 P PDR

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DISCLAIMER This book was prepared as an account of work sponsored by an agency of the United States Government. Neitner 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 l

not infringe privately owned rights References herein to any Specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessanly 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 necessanly state or reflect those of the United States Government or any agency thereof.

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l EGG-NTA-7244 4

TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER ~83-28, ITEM 2.2.1--EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

BEAVER VALLEY-1 AND -2 l

Docket Nos. 50-334/50-412 l

l Alan C. Udy l Published June 1987 Idaho National Engineering Laboratory EGG &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 Nos. D6001 & D6002 l

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l ABSTRACT This EG&G Idaho, Inc., report provides a review of the submittals from the Deaver Valley Power Station for Unit Nos. I and 2 regarding conformance to Generic Letter 83-28, Item 2.2.1.

Docket Nos. 50-334 and 50-412 TAC No. 53652 ii

a FOREWORD This report is supplied as part of the program for evaluating l 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., NRR and I&E Support Branch.

The U.S. Nuclear Regulatory Commission funded this work under the i authorization B&R Nos. 20-19-10-11-3 and 20-19-40-41-3, FIN Nos. D6001 and 06002.

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l Docket Nos. 50-334 and 50-412 TAC No. 53652 l iii

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l CONTENTS ABSTRACT ... . ............ .......... . . ... ........ .. ... ........ ii FOREWORO ........ .......... ......... .................... ........ iii

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

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

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

. 3.3 Conclusion .... ..... ....................... ... ......... 4

4. ITEM 2.2.1.1 - IDENTIFICATION CRITERIA ........... ......... .. 5 4.1 Guideline ........ ... .. . ... .......... ......... ..... 5  ;

4.2 Evaluation ....... ................... . ..... ...... ..... 5 l 4.3 Conclusion .............. . . ...... . .. ... ............. 5 1

5. ITEM 2.2.1.2 - INFORMATION HANDLING SYSTEM . ..................... 6 5.1 Guideline .................................................. 6 5.2 Evaluation ................................................. 6 l 5.3 Conclusion ............... ......... ....................... 6

6. ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING . . . . . . . . . . . 7 I

6.1 Guideline . . ... .. ...... ..... ................ ....... 7

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! 6.2 Evaluation ...... .... .............. .................... 7 l

1 6.3 Conclusion ...... . ....................................... 7 i

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS ............................... 8 7.1 Guideline ....... . ....................................... 8 l l 7.2 Evaluation ........ . .... ................................ 8 '

l l 7.3 Conclusion ............................ ........... ........ 8 l

l l 8. ITEM 2.2.1.5 - DESIGN VERIFICATION AND PROCUREMENT ...... ........ 9 1 8.1 Guideline ...... ........ ........ . ...... ........... .. 9 8.2 Evaluation ....... . ...... ..... ......... ........ . ... 9 e 8.3 Conclusion . .. . .... .. ..... ... ...... .... .... 9

9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS .. .. . .. ... 10 I

9.1 Guideline ... .. . ... . ..... ........... .. .... .. 10 l

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10. CONCLUSION . ....... .... .... .. ..... . ... ... .... .. 11 '

11. REFERENCES ... .. ........ . ....... . . ... .. . .. ....... 12 iv i

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l CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1--E0VIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

BEAVER VALLEY-1 AND -2 i

1. INTRODUCTION l i

- l 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 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 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 I Director for Operations (EDO), directed the NRC staff to investigate and report on the generic implications of these occurrences at Unit 1 of the ,

l Salem Nuclear Power Plant. The results of the staff's inquiry into the generic implications of the Salem unit incidents are reported in NUREG-1000, " Generic Implications of the ATWS Events at the Salem Nuclear I 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 license, and holders of construction permits to respond to the generic issues raised by the l analyses of these two ATWS events.

a This report is an evaluation of the responses submitted by the Duquesne Light Company, the licensee / applicant for the Beaver Valley Power Station, for Item 2.2.1 of Generic Letter 83-28. The documents reviewed as l a part of this evaluation are listed in the references at the end of this l

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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. ,

a As previously indicated, 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 j about the programs of the licensee or applicant for safety-related equipment classification are drawn.

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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 surveillance testing and orders for replacement parts. Licensee anc applicant responses which address the features of this program are evaluated in the remainder of this report.

3.2 Evaluation The licensee / applicant for the Beaver Valley Power Station responded to these requirements with submittals dated November 4, 1983 2and 3 4 May 4, 1987 for Unit I and March 30, 1984 for Unit 2. These submittals include information that describe their existing safety-relatea equipment classification program. In the review of the utility response 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 the following general concerns.

The licensee states that they are using the master equipment list (MEL) as the primary information handling system referred to. The MEL is complemented by the Nuclear Engineering Department's review of Q*5 documentation, Appendix B to the Quality Assurance Program, the Operating Manual, Electrical and Mechanical Drawings, equipment specifications and Westinghouse Spare Parts Reports.

O The licensee states that maintenance activities are controlled by a Maintenance Work Reauest (MWR) on which is identified the safety-related status of the system or component being worked on.

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1 3.3 Conclusion We have reviewed the licensee's submittals and, in general, find that j 1

the licensee's response is adequate. j i

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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 l l

as safety-related.

4.2 Evaluation )

The utility's response gives the criteria used for identifying safety-related equipment and components. Instruments and equipment are considered safety-related if it is required to assure: (a) the integrity of the reactor coolant system pressure boundary, (b) the capability to achieve and maintain a safe shutcown of the reactor or (c) the capability to prevent or to mit' gate the consequences of an accident which could result in potential offsite exposures.

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.

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

5.2 Evaluation  !

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The utility suomittals icentify the master equipment list as the computerized index that identifies safety-related components. The description includes the methods and procedures used for its development and validation. They state that this list is accessible throughout the station and at other licensee facilities, and thus is a single, official, i consistent and unambiguous document.

5.3 Conclusion We find that the information contained in the utility's submittals is sufficient for us to conclude that the information handling system for j equipment classification meets the guideline requirements. Therefore, the information provided by the Duquesne Light Company for this item is acceptable, i l

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6. ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING 6.1 Guideline I i

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The licensee's or applicant's description should confirm that their l 1

program for equipment classification includes criteria and procedures which l govern how station personnel use the equipment classification information

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handling system to determine that an activity is safety-related and what procedures 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 station procedures that govern maintenance,  !

modification and procurement activities references the master equipment list for determining equipment classification. Thus, this list is 1

i consulted before any maintenance, testing, design changes, engineering I support, setpoint changes or special tests or studies are initiated.

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j 6.3 Conclusion l

We find that the description of plant administrative controls and procedures meets the requirements of this item and is, therefu ee, acceptable.

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7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS l l

l 7.1 Guideline 1 The applicant or licensee should confirm that the management controls

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used to verify that the procedures for preparation, validation and routine utilization of the information handling system have been followed. ,

7.2 Evaluation The utility states that the master equipment list was prepared and l verified and is controlled and updated in accordance with written  !

l procedures. These procedures are subject to audit by the quality assurance '

department. The utility also states that written procedures will call for l l the routine use of this list.

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We find that the management controls used by the utility assure that I the information handling system is maintained, is current and is used as intended. Therefore, the utility'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 applicant's or licensee's submittals should document that past

- usage demonstrates that appropriate design verification and qualification testing is specified for the procurement of safety-related components and l parts. The specifications should include qualification testing for expected safety service conditions and provide support for the applicant's/ licensee's receipt of testing documentation to support the limits of life recommended by supplier. If such documentation is not available, confirmation that the present program meets these requirements should be provided. l 8.2 Evaluation l

The utility's submittals state that Procurement Quality Forms provide I the overall controls over procurement activities for Class 1E electrical components, replacement and spare parts. The design cha,nge program is said to meet the requirements of ANSI N45.2.11. This includes design verification, quality assurance, documentation requirements and qualification testing. The original procurement specifications are used for the procurement of spare and replacement parts.

8.2 Conclusion The utility's response for this item is considered to be complete and is acceptable.

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9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS l

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 licensee or applicant 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 l licensee to resolve the concerns of Items 2.2.1.1, 2.2.1.2, 2.2.1.3, 1

l - 2.2.1.4 and 2.2.1.5 meet the requirements of Generic Letter 83-28 and is acceptable. Item 2.2.1.6 was not reviewed as noted in Section 9.

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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. Duquesne Light Company letter, J. J. Carey to Director of Nuclear . l Reactor Regulation, NRC, " Response to Generic Letter 83-28," (Unit 1),  !

November 4, 1983. l i

Duquesne Light Company letter, J. D. Sieber to NRC, " Generic 3.

Letter 83-28, Item 2.2.1 - Equipment Classification," (Unit 1), ,

May 4, 1987. j 4 Duquesne Light Comoany letter, E. J. Woolever to D. G. Eisennut, NRC,

" Response to Generic Letter 83-28," (Unit 2), Marcn 30, 1984, l 2NRC-4-033.

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P. O. Box 1625 * *.~ oa ca.~ T ~uo.ea Idaho Falls, ID 83415 06001/06002 i 10 $PON50shNG o G.Ns ATION N.Mt .No M*tblNG .Co.ESS esace.se l a Caae, I ta TV'E 08 a tPO.T Instrumentation and Control Systems Branch Office of Nuclear Reactor Regulation 4 U.S. Nuclear Regulatory Commission . ,ia.oo Cov e a n o ,~, . --,

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Tiiis EG&G Idaho, Inc., report provides a review of the submittals from the Duquesne Light Company regarding conformance to Generic Letter 83-28, Item 2.2.1 for Beaver Valley-1 anc -2.

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