ML20214Q931

Conformance to Generic Ltr 83-28,Item 2.2.1 - Equipment Classification for All Other Safety-Related Components: Waterford-3, Informal Rept

ML20214Q931
Person / Time
Site:	Waterford
Issue date:	04/30/1987
From:	Vanderbeek R EG&G IDAHO, INC., IDAHO NATIONAL ENGINEERING & ENVIRONMENTAL LABORATORY
To:	NRC
Shared Package
ML20214Q918	List: ML20214Q914 ML20214Q931
References
CON-FIN-D-6001 EGG-NTA-7446, GL-83-28, TAC-57705, NUDOCS 8706050267
Download: ML20214Q931 (20)

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' INFORMAL REPORT l ,

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IdahoI "1 Nat/onal:' ] CONFORf1ANCE TO GENERIC LETTER 83-28, ITEM 2.2.1--

Eng/neer/ng EQUIPriENT CLASSIFICATION FOR ALL OTHER SAFETY-Laboratory -  : RELATED COMPONENTS: WATERFORD-3 Managed li

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)qEGsG6 l-Prepared for the m' c=>r'*cr - U.S. NUCLEAR REGULATORY COMMISSION Na DE-AC07-MID01570 ';

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DISCLAIMER This book was prepared as an account of work sponsored by an agency of the United States Govemment. Neither the United States Government nor any agency thereof, nor any of their employees. makes any warranty, express or imphed, or assumes any legal liabihty or responsibihty for the accuracy, completeness, or usefulness of any information, apparatus, product or process disclosed, or represents that its use would not intnnge privately owned nghts. References herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise, does not necessanty constitute or imply its endorsement, recommendation, or favonng by the Uasted States Govemment or any agency thereof. The views and opinions of authors expressed herein do not necessanly state or reflect those of the United States Govemment or any agency thereof.

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EGG-NTA-7446

'O TECHNICAL EVALUATION REPORT CONFORMANCE TO GENERIC LETTER 83-28. ITEM 2.2.1--

EQUIPMENT CLASSIFICATION FOR ALL OTHER SAFETY-RELATED COMPONENTS:

WATERFORD-3 Docket No. 50-382 R. VanderBeck 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-AC07-761001570 FIN No. 06001

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ABSTRACT This EG&G Idaho, Inc. report provides a review of the submittals for the Waterford Steam Electric Station, Unit No. 3 for conformance to Generic Letter 83-28, Item 2.2.1.

. Docket No. 50-382

. TAC No. 57705 11

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 Conunission, Office of Nuclear Reactor Regulation, Division of PWR Licensing-A, by EG&G Idaho, Inc.

The U.S. Nuclear Regulatory Commission funded this work under the authorization 8&R 20-19-10-11-3, FIN No. 06001.

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CONTENTS ABSTRACT .............................................................. 11 FOREWORD .............................................................. iii

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

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

3. I T E M 2 . 2 .1 - P R O GR AM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 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 4.3 Conclusion ................................................. 5

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

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

6. ITEM 2.2.1.3 - USE OF EQUIPMENT CLASSIFICATION LISTING ........... 7 6.1 Guideline .................................................. 7 6.2 Evaluation ................................................. 7 6.3 Conclusion ................................................. 7

7. ITEM 2.2.1.4 - MANAGEMENT CONTROLS ............................... 8

, 7.1 Guideline .................................................. 8 7.2 Evaluation ................................................. 8 7.3 Conclusion ................................................. 8 iv

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

9. ITEM 2.2.1.6 "IMPORTANT TO SAFETY" COMPONENTS .................. 10 9.1 Guideline .................................................. 10

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

11. REFERENCES ....................................................... 12 4

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

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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 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 Director for Operations (EDO), directed the 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 l

impilcations 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 I

(by Generic Letter 83-28 dated .luly 8, 1983 ) all licensees of operating j reactors, applicants for an operating license, and holders of construction permits to respond to generic issues raised by the analyses of these two

! ATWS events.

. This report is an evaluation of the responses submitted by Louisiana Power and Light for Waterford Steam Electric Station, Unit No. 3 for Item 2.2.1 of Generic Letter 83-28. The actual 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 / applicant to submit, for staff review, a description of their programs for classification of their safety-related equipment includes supporttag

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information, in considerable detail, as indicated in the guidelines -

preceding the evaluation of each sub-item. ,

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 3.1 Guideline Licensees and applicants should confirm that an equipment

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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 and applicant responses which address the features of this program are evaluated in the remainder of this report.

3.2 Evaluation The licensee for Waterford Steam Electric Station, Unit No. 3 provided a response to Generic Letter 83-28 with submittals dated November 4, 1983 and November 15, 1985. These submittals included information that describes their 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 has provided a description of the equipment classification program for the identification of safety-related activities for repair, maintenance, and procurement. However, the response does not directly confirm that all components designated as safety-related in the MEL/Q-list are also properly designated on plant documents, procedures and in the information handling systems used for safety-related activities.

However, the licensee's response to Items 2.2.1.2 and 2.2.1.3 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.

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

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, .4. ITEM 2.2.1.1 - IDENTIFICATION CRITERIA l

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.

4.2 Evaluation The licensee's response states that safety-related structures, -

systems, and components are identified as safety-related based on the criteria specified in the project management procedure PMP-321,

" Determination of Safety /Q-Level Components for the MEL/Q-List". The procedure was not included in the response; however, review of Section 3.2 of the FSAR identified these criteria.

4.3 Conclusion The licensee's response to this item is considered to be complete and is 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 procedures exist which govern its development and validation.

5.2 Evaluation The licensee's response states that the Q-list is maintained current by a dedicated staff whose activities are governed by project management procedure PMP-321. This procedures is being updated to include requirements for Q-List maintenance activities. The Q-List information for components in the plant is entered in the data base and validated in accordance with project management procedure PMP-320.

5.3 Conclusion The licensee's response to this item is considered to be complete and l 1s 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 which govern how station personnel use the equipment classification information

- 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 8, apply to safety-related components.

6.2 Evaluation The licensee's response identifies the use of the Q-list, and Administrative procedures in the determination of safety-related activities in the areas of parts replacement, storage, maintenance, modification, testing, and surveillance. . Collectively, these documents contain the controls to ensure that safety-related equipment is identified and handled in an appropriate manner.

6.3 Conclusion The licensee's response to this item is considered to be complete and is acceptable.

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7. -ITEM 2.2.1.4 - MANAGEMENT CONTROLS 7.1 Guidelines 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 management controls established for activities related to the development, validation and maintenance of the Q-List are covered by procedures and instructions which are prepared, reviewed, and approved in accordance with project management procedure PMP-001, Preparation and Revision of Project Management Procedure / Instructions". The management controls established for activities related to the routine ut11tration of the Q-List are governed by Administrative procedure UNT-1-002 and QP-5-001. " Instructions, Procedures and Drawings."

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The licensee's response to this item is considered to be complete and i is acceptable.

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8. ITEM 2.2.1.5 DESIGN VERIFICATION AND PROCUREMENT l

8.1 Guideline j The applicant's or licensee's submittal should document that past

. usage demonstrates that appropriate design verification and qualification testing is specified for the procurement of safety-related components and  !

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 the supplier. If such documentation is not available, confirmation that the present program meets these requirements should be provided.

8.2 Evaluation The licensee's response states that specifications imposed upon the vendor are referenced on the Purchase Order Requisition based on either previous orders for the same equipment or specifications supplied by Engineering. Standard Clauses in UNT-8-001 are used to ensure that technical and quality requirements are specified consistently for safety and quality related equipment orders.

8.3 Conclusion The licensee'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 9.1 Guideline The Generic Letter 83-28 states that the licensee'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 applicant / licensee 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 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 Items 2.2.1 of Generic Letter 83-28 is acceptable. Item 2.2.1.6 was not reviewed as noted in Section 9 of this report.

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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 Implication of Salem ATWS Events (Generic Letter 83-28)," July 8, 1983. ,

2. Louisiana Power and Light letter, K. W. Cook to D. G. Eisenhut, NRC, November 4, 1983, W3P83-3911, 4-3-A20.02.02, 3-A1.01.04, L.02. +

3. Louisiana Power and Light letter, K. W. Cook to G. W. Knighton, NRC .

• November 15, 1985, W3P85-3158, A4.05 NQA.

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, the Waterford Steam Electric Station, Unit No. 3.

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