ML16341A649

Requests Addl Info Re Generic Ltr 83-28,Item 1.2 Re post-trip review.Marked-up Technical Evaluation Rept for Facility,W/Initial Results,Encl

ML16341A649
Person / Time
Site:	Diablo Canyon
Issue date:	05/20/1985
From:	Knighton G Office of Nuclear Reactor Regulation
To:	Shiffer J PACIFIC GAS & ELECTRIC CO.
References
GL-83-28, NUDOCS 8506060231
Download: ML16341A649 (36)

Text

Docket Nos.:

50-275 and 50-323

@AY 30 1%5 Mr. J.

D. Shiffer, Vice President Nuclear Power Generation c/o Nuclear Power Generation, Licensing Pacific Gas 8 Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106

Subject:

Generic Letter 83-28, Item 1.2 DCrutchfi el d RKarsch JKramer MMendonca DISTRIBUTION

~50--275l323 NRC PDR LPDR NSIC PRC System LBP3 Reading JLee HSchierling JPartlow BGrimes EJordan

Attorney, OELD ACRS (16)

TBournia RRamirez The staff has performed a preliminary review of the Pacific Gas and Electric Company response to Generic Letter 83-28 (Salem ATWS Events),

Item 1.2 (Post Trip Review - Data and Information Capability).

The response was found to be incomplete in one area.

Enclosed is the Technical Evaluation Report (TER) for Diablo Canyon Units I and 2 providing the results of the initial review.

The report identifies the one area for which the information provided was determined to be incomplete.

The TER was prepared by the staff's consultant, Science Applications International Corporation (SAIC).

The staff has reviewed the report and agrees with its content and conclusions.

Certain pen and ink changes were made to the report by the staff for consistency with the staff approach.

In order to complete our evaluation certain additional information is required as identified in Section 6 of the report.

We propose to discuss the needed information with you in a telephone call within one week of your receipt of this letter.

Mr. Hans Schierling, the Diablo Canyon Project Manager, will arrange for the call.

You should contact him promptly if there are any questions.

Sincerely,

Enclosure:

As stated George W. Knighton, Chief Licensing Branch No.

3 Division of Licensing cc:

See DL:LB33 HSc ierl 5/

/85 page DL:LBA'2 TBournia 5//) /85 D

DL'C chfield GW ghton 5/1 Q/85 5/gO/85

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Mr. J.

D. Shiffer, Vice President Nuclear Power Generation c/o Nuclear Power Generation, Licensing Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106 Philip A. Crane, Jr.,

Esq.

Pacific Gas 5 Electric Company Post Office Box 7442 San Francisco, California 94120 Mr. Malcolm H. Furbush Vice President - General Counsel Pacific Gas 5 Electric Company Post Office Box 7442 San Francisco, California 94120 Janice E. Kerr, Esq.

California Public Utilities Commission 350 McAllister Street San Francisco, California 94102 Mr. Frederick Eissler, President Scenic Shoreline Preservation Conference, Inc.

4623 More Mesa Drive Santa Barbara, California 93105 Ms. Elizabeth Apfelberg 1415 Cozadero San Luis Obispo, California 93401 Mr. Gordon A. Silver Ms. Sandra A. Silver 1760 Alisal Street San Luis Obispo, California 93401 Harry M. Willis, Esq.

Seymour 5 Willis 601 California Street, Suite 2100 San Francisco, California 94108 Mr. Richard Hubbard MHB Technical Associates Suite K

1725 Hamilton Avenue San Jose, California 95125 Mr. John Marrs, Managing Editor San Luis Obis o Count Tele ram Tribune o nson venue P. 0.

Box 112 San Luis Obispo, California 93406 Diablo Canyon Resident Inspector/Diablo Canyon NPS c/o US Nuclear Regulatory Commission P. 0.

Box 369 Avila Beach, California 93424 Ms.

Raye Fleming 1920 Mattie Road Shell Beach, California 93440 Joel

Reynolds, Esq.

John R. Phillips, Esq.

Center for Law in the Public Interest 10951 West Pico Boulevard Third Floor Los Angeles, California 90064 Mr. Dick Blankenburg Editor 5 Co-Publisher South County Publishing Company P. 0.

Box 460 Arroyo Grande,'California 93420 Bruce Norton, Esq.

Norton, Burke, Berry 5 French, P.C.

202 E. Osborn Road P. 0.

Box 10569 Phoenix, Arizona 85064 Mr. W. C.

Gangl off Westinghouse Electric Corporation P. 0.

Box 355 Pittsburgh, Pennsylvania 15230 David F. Fleischaker, Esq.

P. 0.

Box 1178 Oklahoma City, Oklahoma 73101

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Arthur C. Gehr, Esq.

Snell 5 Wilmer 3100 Valley Center Phoenix, Arizona 85073 Mr. Lee M. Gustafson, Director Federal Agency Relations Pacific Gas 5 Electric Company 1050 17th Street, N.W.

Suite 1180 Washington, DC 20036 Regional Administrator - Region V

US Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Mr. Thomas Devine Government Accountability Project Institute for Policy Studies 1901 gue Street, NW Washington, DC 20009 Michael J. Strumwasser, Esq.

Special Counsel to the Attorney General State of California 3580 Wilshire Boulevard, Suite 800 Los Angeles, California 90010 Mr. Tom Harris Sacramento 8ee 21st and 0 Streets Sacramento, California 95814 Mr. H. Daniel Nix California Energy Commission 1516 9th Street, MS 18 Sacramento, California 95814 Lewis Shollenberger, Esq.

US Nuclear Regulatory Commission Region V

1450 Maria Lane Suite 210 Walnut Creek, California 94596

SAIC-85/1514-1 REVIEM OF LICENSEE AND APPLICANT RESPONSES TO NRC GENERIC LETTER 83-28 (Required Actions. Based on Generic Implications of Salem ATMS Events),

Item 1.2 "POST-TRIP REVIEM:

DATA AND INFORMATION CAPABILITIES" FOR DIABLO CANYON. UNITS 1a~d X (50-275> 5~5 )

Technical Evaluation Report Prepared by Science Applications International Corporation 1710 Goodridge Drive McLean, Virginia 22102 Prepared for U.S. Nuclear Regulatory Commission Mashington, D.C. 20555 Contract No. NRC-03-82-096

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FOREWORD This report contains the technical evaluation of the Diablo Canyon, Unit5, lgn6 2. response to Generic Letter 83-28 (Required Actions Based on Generic Implications of Salem ATWS Events),

Item 1.2 "Post Trip Review:

Data and Information Capabilities."

For the purposes of this evaluation.

the review criter ia, presented in part 2 of this report, were divided into five separate categories.

These are:

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The parameter s monitored by the sequence of events and the time history recorders, The performance characteristics of the sequence of events recorders, 3.

The performance characteristics of the time history recorders, 4.

The data output format.

and 5.

The long-term data retention capability for post-trip review material.

All available responses to Generic Letter 83-2& were evaluated.

The plant for which this report is appl'icable was found to have adequately responded to, and met, categories 2, 3, 4 and 5.

The report describes the specific methods used determine the cate-gorization of the responses to Generic Letter 83-28.

Since this evaluation report was intended to apply to more than one nuclear power plant specifics regarding how each plant met (or failed to meet the are not presented.

Instead, the evaluation presents a categorization of the p

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which are not.

The evaluations are based on specific criteria (Section 2) derived from the requirements as stated in the generic letter.

TABLE OF CONTENTS Section Page Introduction.

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Background.

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2 2.

Review Criteria 3

3. Evaluation.....................

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Conclusion.

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References.........

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INTRODUCTION NTcLXFA'5 SAIC has reviewed the submittals prepared in response to Generic Letter 83-28, item 1.2 "Post-Trip Review:

Data and Information Capability".

The submittaQ (see references) contained sufficient information to determine that the data and information capabilities at this plant are acceptable in the following areas.

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The sequence-of-events recorder(s) performance charac-teristics.

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The time history recorder(s) performance characteris-tics.

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The output format of the recorded data.

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The long-term data retention, record keeping, capa-bility.

However, the data and information capabilities, as described in the submittal, either fail to meet the review criteria or provide insufficient information to allow determination of the adequacy of the data and information capabilities in the following area.

e The parameters monitored by both the sequence-of-events and time history recorders.

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On February 25, 1984, 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 occurred during the plant startup and the reactor was tripped manually by the operator about 30 seconds after the initiation of the automatic trip signal.

The failure of the circuit breakers has been determined to be related to the sticking of the under voltage 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 coinci-dentally with the automatic trip.

At that time, because the utility did not have a requirement for the systematic evaluation of the reactor trip, no investigation was performed to determine whether the reactor was tripped automatically as expected or manually.

The utilities'ritten procedures required only that the cause of the trip be determined and identified the responsible personnel that could authorize a restart if the cause of the trip is known.

Following the second trip which clearly indicated the problem with the trip breakers, the question was raised on whether the circuit breakers had functioned properly during the earlier incident.

The most useful source of information in this case, namely the sequence of events printout which would have indicated whether the reactor was tripped automatically or manually during the February 22 incident, was not retained after the incident.

Thus, no judgment on the proper functioning of the trip system during the earlier incident could be made.

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 implications. of the Salem Unit incidents is reported in NUREG-1000, "Generic Implications of ATMS Events at the Salem Nuclear Power Plant."

Based on the results of this study, a set of required actions were developed and included in Generic Letter 83-28 which was issued on July 8, 1983 and sent to all licensees of operating reactors, applicants for operating license, and construction permit holders.

The required actions in this generic letter consist of four categories.

These are:

(1) Post-Trip Review, (2) Equipment

Classification and Vender Interface, (3) Post Haintenance

Testing, and (4)

Reactor Trip System Reliability Improvements.

The first required action of the generic letter, Post-Trip Review, is the subject of this TER and consists of action item l.l "Program Description and Procedure" and action item 1.2 "Data and Information Capability."

In the next section the review criteria used to assess the adequacy of the utilities'esponses to the requirements of action item 1.2 will be discussed.

2.

Review Criteria The intent of the Post Trip Review requirements of Generic Letter 83-28 is to ensure that the licensee has adequate procedures and data and information sources to understand the cause~3nd progression of a reactor trip. This understanding should go beyond a simple identification of the course of the event.

It should include the capability to determine the root cause of the reactor trip and to determine whether safety limits have been exceeded and if so to what extent.

Sufficient information about the reactor trip event should be available so that a decision on the acceptability of a reactor restart can be made.

The following are the review criteria developed for the requirements of Generic Letter 83-28, action item 1.2:

The equipment that provides the digital sequence of events (SOE) record and the analog time history records of an unscheduled shutdown should pro-vide a reliable source of the necessary information to be used in the post trip review.

Each plant variable which is necessary to determine the cause(s) and progression of the event(s) following a plant trip should be monitored by at least one recorder (such as a, sequence-of-events recorder or a plant process computer for digital parameters; and strip charts, a plant process computer or analog recorder f'r analog (time history) variabl esp.

Each device used to record an analog or digital plant variable should be described in sufficient detail so that a determination can be made as to whether the following performance characteristics are met:

Each sequence-of-events recorder should be capable of detecting and recording the sequence of events with a sufficient time discrimination capability to ensure that the time responses-asso-ciated with each monitored safety-related system can be ascer-

tained, and that a determination can be made as to whether the time response is within acceptable limits based on ~

~FSAR Chapter 15 Accident Analyses.

The recommended guideline for the SOE time discrimination is approxi-mately 100 msec.

If current SOE recorders do not have this time discrimination capability the licensee or applicant should show that the current time discrimination capability is sufficient for an adequate reconstruction of the course of the reactor trip.

As a minimum this should include the ability to adequately recon-struct the accident scenarios presented in Chapter 15 of the plant FSAR.

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Each analog time history data recorder should have a sample inter-val small enough so that the 'incident can be accurately

'econstr'ucted following a reactor trip.

As a minimum, the licensee or applicant should be able to reconstruct the course of the accident sequences evaluated in the accident analysis of the plant FSAR (Chapter 15).

The recommended guideline for the sample interval is 10 sec.

If the time history equipment does not meet this guideline, the licensee or applicant should show that the

-current time history capability is sufficient to accurately recon-struct the accident sequences presented in Chapter 15 of the FSAR.

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To support the post trip analysis of the cause of the trip and the proper functioning of involved safety related equipment, each analog time history data recorder should be capable of updating and retaining information from approximately five minutes prior to the trip until.at least ten minutes after the trip.

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The information gathered by the sequence-of-events and time history data collectors should be stored in a manner that will allow for ~

retrieval and analysis.

The data may be retained in either hardcopy

'(computer printout, strip chart output, etc.)

or in an accessible memory (magnetic disc or tape).

This

information should be presented in a readable and meaningful format, taking into consideration good human factors practices (such as those outlined in HUREG-0700).

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All equipment used to record sequence of events and time history information should be powered from a reliable and non-interruptible power source.

The power source used need not be safety related.

'he sequence of events and time history recording equipment should monitor sufficient digital and analog parameters, respectively, to assur e that the course of the reactor trip can be reconstructed.

The parameters monitored should provide sufficient information to determine the root cause of the reactor trip, the progression of the reactor trip, and the response of the plant parameters and systems to the reactor trip.

Specifically, all input parameters associated with reactor trips, safety injections and other safety-related systems as well as output parameters sufficient to record the proper functioning of these systems should be recorded for use in the post trip review.

The parameters deemed necessary, as a minimum, to perform a

post-trip review (one that would determine if the plant remained within its design envelope) are presented on Tables 1.2-1 and 1.2-2. If the appli-cants'r licensees'OE recorders and time history recorders do not monitor all of the parameters suggested in these tables the applicant or licensee should show that the existing set of monitored parameters are sufficient to establish that the plant remained within the design envelope for the appro-priate accident conditions; such as those analyzed in Chapter 15 of the plant Safety Analysis Report.

Information gathered during the post trip review is required input for future post trip reviews.

Oata from all unscheduled shutdowns provides a

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'aluable reference source for the determination of the acceptability of the plant vital parameter and equipment response to future unscheduled shut-downs.

It is therefore necessary that information gathered during all post trip reviews be maintained ir: an accessible manner for the life of the plant.

'I ~'able 1.2-1.

PMR Parameter List SOE Recorder Time History Recor'der Parameter / Si nal 0) x (1) x x

(1) x x

(1) x.

x (2)

(1) x (1) x (1) x (1} x (1) x (3) x x

(1) x (1) x (1) x

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Reactor Trip Safety Injection Containment Isolation Turbine Trip Control Rod Position neutron Flux, Power Containment Pressure Containment Radiation Containment Sump Level Primary System Pressure Primary System Temperature Pressurizer Level Reactor Coolant Pump Status Primary System Flow Safety Inj.; Flow, Pump/Valve Status MSIV Position Steam Generator Pressure Steam Generator Level Feedwater Flow Steam Flow Auxiliary Feedwater System;

Flow, Pump/Value Status AC and DC System Status (Bus Voltage)

Diesel Generator Status (Start/Stop, On/Off)

PORV Position (1): Trip par ameters (2): Parameter may be monitored by either an SOE or time history recorder.

(3}: Acceptable r ecorder options are:

(a) system flow recorded on an SOE

recorder, (b) system flow recorded on a time history recorder, or (c) equipment status recorded on an SOE recorder.

SOE Recorder Table 1.2-2.

BMR Parameter List (wotappl'cr Llc. 40 3)io-L(o Q myoid)

Time History Recorder Parameter / Si nal x

x x

x x

x (I) x (I}

(2) x (I)

(2) x (I) x (1)

X x (I).

x (3) x (I) x (1)

(3)(4)

Reactor Trip Safety Injection Containment Isolation Turbine Trip Control Rod Position Neutron Flux. Power Main Steam Radiation Containment (Dry Mell) Radiation Drywell Pressure (Containment Pressure)

Suppression Pool Temperature Primary System Pressure Primary System Level MSIV-Position Turbine Stop Valve/Control Valve Position Turbine Bypass Valve Position Feedwater Flow Steam Flow Recirculation;

Flow, Pump Status Scram Discharge Level Condenser Vacuum AC and DC System Status (Bus Voltage)

Safety Injection; Flow, Pump/Valve Status

. Diesel Generator Status (On/Off, Start/Stop)

(1): Trip parameters.

(2): Parameter may be recorded by either an SOE or time history recorder.

(3): Acceptable recorder options are:

(a) system flow recorded on an SOE

recorder, (b) system flow recorded on a time history recorder, or (c) equipment status recorded on an SOE recorder.

(4): Includes recording of parameters for al.l applicable systems from the following:

HPCI, LPCI. LPCS, IC. RCIC.

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3.

Evaluation The parameters identified in part 2 of this report as a part bf the review criteria are those deemed necessary to perform an adequate post-trip review.

The recording of these parameters on equipment that meets the guidelines of the review criteria will result in a source of information that can be used to determine the cause of the reactor trip and the plant response to the trip, including the responses of important plant systems.

The parameters identified in this submittal as being recorded by the sequence of events and time history recorders do not correspond to the parameters specified in part 2 of this report.

The information provided in the submittal indicates that the equipment used to monitor the digital and analog parameters meets the minimal requirements set forth in part 2 of this report.

The sequence of events and analog time history recorders are powered from a non-interruptable power supply.

The monitoring characteristics are all within the guidelines of the review criteria.

The data and information recorded for use in the post-trip review should be output in a format that allows for ease of identification and use of the data to meet the review cr iterion that calls for information in a r eadable and meaningful format.

The information contained in this submittal indicates that this requirement is met.

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The data and information used during a pos -trip review should be retained as part of the plant files.

This infor tion could prove useful during future post-tr i p r evi ews.

There fore one presented in part 2 of this report is that information used during a post-trip review be maintained in an accessible manner for the life of the plant.

Information contained within this submittal indicates that this criterion will be met.

4.

Conclusion The information supplied in response to Generic Letter 83-28 indicates that the cur rent post-trip review data and information capabilities are adequate in the following areas:

1.

The SOE recorders meet the minimum performance characteristics.

2.

The time history recorders meet the minimum performance chai'acter-istics.

3; The recorded data is output in a readable and meaningful format.

4.

The information recorded for the post-trip review fs maintained in an accessible manner for the life of the plant.

The information supplied.fn response to Generic Letter 83-28 does not indicate that the post-trip review data and information capabilities are adequate fn the following area:

1.

As described fn the submittal, sufficient analog and digital parameters are not recorded for use fn the post-trip review.

re~;e~ Cribs'r It fs possible that the current data and fnformatfon ca lfties at this 1

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but were not completely described.

Under these circumstances, the licensee should provide an updated, more complete, description to show fn more detail the data and information capabilities at thfs nuclear power plant.

If the information provided accurately represents all current data and information capabilties, then the licensee should either show that the parameters

. currently recorded will.enable,.the licensee to determine that the reactor trip progressed within the design limits of the Safety Analysis Report accident analysis, or detail future modifications that would enable the licensee to meet the intent of the evaluation criteria.

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REFERENCES NRC Generic Letter 83-28.

"Letter to all licensees of operating,

reactors, applicants for operating license, and holders of construction permits regarding Required Actions Based on Generic Implications of Salem ATWS Events."

July 8, 1983.

NUREG-1000, Generic Implications of ATMS Events at the Salem Nuclear Power Plant, April 1983.

Letter from J.O. Schuyler, Pacific Gas and Electric Company, to D.G.

Eisenhut, NRC, dated November 7,

1983, Accession Number 8311110160 in response to Generic Letter 83-28 of July 8, 1983, with attachment.

Response

to Generic Letter 83-28, Status of Current Conformance,

Plans, and Schedules.

Letter from J.O. Schuyler, Pacific Gas and Electric Company to D.G.

Eisenhut, NRC. dated June 27,

1984, DCL-84-242, in response to Item 1.2 of Generic Letter 83-28 of July 8, 1983, with attachment.

Response

to Action Item.1.2 of Generic Letter 83-28, "Post-Trip Review

- Data and Information Capability.

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Suff+cMpk Pop~~~ p<~ mcacou Diablo Canyon 1.

Parameters recorded:

Unsatisfactory See attached table for discrepancies.

2.

SOE recorders performance characteristics:

Satisfactory Plant process computer:

16.6msec time discrimination with a non-interruptible power supply ERFDS:

16.6msec time discrimination with a non-interruptible power supply 3.

Time history recorders performance characteristics:

Satisfactory Plant process computer:

parameters are sampled at 2

and 8

sec intervals for the period from 2 min before to 3 min after the trip ERFDS:

parameters are sampled at 1 sec intervals for the period from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> before to 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the trip (This device samples the required analog parameters.)

4..

Data output format:

Satisfactory SOE data output includes time, event descriptor, and sensor ID.

Analog data output includes time, parameter name and value, and sensor ID.

5.

Data retention capability:

Satisfactory Post-trip review data is" maintained for the life of the plant.

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3)es ir o.4%i SOE Recorder Parameter / Si nal

+4eqe+red PWR Parameters for Post Trip Review (circled parameters are not recorded)

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Time History Recorder 0) x (1) x x

(I) x x

(1) x (2)

(1)(3)

(1) x (1) x (1) x (1) x (4) x x

(1) x (1) x (1) x (4)

Qx Reactor Trip Safety Injection Containment Isolation Turbine Trip Control Rod Position Neutron Flux, Power Containment Pressure Containment Radiation Containment Sump Level Primary System Pressure (Vessel

Pressure, Pressurizer Pressure)

Primary System Temperature Pressurizer Level Reactor Coolant Pump Status Primary System Flow Safety Inj.; Flow, Pump/Valve Status MSIV Position Steam Generator Pressure Steam Generator Level

. Feedwater Flow Steam Flow Auxiliary Feedwater System;

Flow, Pump/Value Status AC and DC System Status Diesel Generator Status PORV Position (1): Trip parameters; pressurizer or primary pressure is a trip parameter (depending on plant).

(2): Parameter may be monitored by either an SOE or time history recorder.

~,'): Acceptable recorder options are:

(a) reactor vessel pressure recorded on both an SOE and time history recorder, or (b) pressurizer pressure recorded on both an SOE and time history recorder.

, (4): Acceptable recorder options are:

(a) system flow recorded on an SOE

recorder, (b) system flow recorded on a time history recorder, or (c) equipment status recorded on an SOE recorder.

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