ML20095C041
| ML20095C041 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 05/07/1986 |
| From: | Brey H PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML19346A656 | List: |
| References | |
| FRN-50FR51992, FRN-56FR23360, RTR-NUREG-1000, RULE-PR-19, RULE-PR-2, RULE-PR-20, RULE-PR-30, RULE-PR-31, RULE-PR-32, RULE-PR-34, RULE-PR-35, RULE-PR-39, RULE-PR-40, RULE-PR-50, RULE-PR-61, RULE-PR-70 50FR51992, AA38-2, AA38-2-0374, AA38-2-374, GL-83-28, P-86290, NUDOCS 9204230239 | |
| Download: ML20095C041 (11) | |
Text
()(2 ma mm L'Sofax0 NLE LM (we 5;yr2) 4 5 nud Public Service ~
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Company of Colorado 2420 W. 26th Avenue, Suite 1000, Denver, Colorado 80211
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May 7, 1986 M
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Fort St. Vrain S-
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P-86290
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Secretary United States Nuclear Regulat Cordission e Washington, D.C.
20555
,W Attn: Docketing and Service Branch Docket No.
50-267
SUBJECT:
John F. Doherty; Petition for Rulemaking, Docket No.
PRM-50-40
REFERENCES:
- 1) Generic Letter 83-28 (G-83256) dated July 8. 1983
- 2) PSC Letter 5-83359) s Lee to Eisenhut, dated November 4, 1983 3)
Procedure SMAP-7 Gentlemen:
Mr. Doherty, in his petition for rulemaking PRM-50-40, indicates that "the licensee, if unable to determine the cause of the reactor trip in eight hours, be required to place the reactor in told shutdown pending 'urther study of the event". He thinks such a rule would lessen any of a number of possible accidents that may occur if a reactor is restarted after a reactor trip before
,1certaining what caused the trip. He cites NUREG-1000, Vol. 1, " Generic Implications of ATWS Events at the Salem Nuclear Power Plant", April 1983 as the source of his concern.
It is the position of Public Service Company of Colorado (PSC) that the NRC and licensees have already taken adequate and appropriate action to resolve the concerns addressed in PRM-50-40 and that Mr.
Doherty's term " cold shutdown" is not universally used at nuclear plants.
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.e p.86290 Page 2 April 28, 1986 The NRC expressed a desire that the pcst trip review or restart of the reactor issue be addressed in Generic Letter 83-28,
" Required Actions Based on Generic Implications of Salem ATWS Event:", dated July 8, 1983.
In Generic Letter 83-28 the NRC stated, "accordingly, pursuant to 10CFR 50.54 (f), operating reactor licensees ------------
are requested to furnish under oath and a ffi rma tion,.
the status of current conformance with the positions contained herein, and plans and schedules for any needed (mcrovems.ts for conformance with the positions".
Generic Letter 83-28 listed four actions requested of each licensee and operating license applicant based on information contained in N'JREG-1000. Action 1 is stated as follows:
"1.
Post Trip Review This action addresses the program, procedures and data collection capability to assure that the causes of unscheduled reactor shutdowns, a:; well as the response of safety related equipment, are fully understood prior to plant restart."
Included in PSC's response to Generic Letter 83-28 vias Procedure "SMAP-7".
This procedure requires the Fort St. Vrain station manager to evaluate the recommendation ;nade by the personnel performing a trip investigation and, if necessary, the investigation review.
The station manager's decision to estart the reactor shall include, among other considerations, a determination that the cause of the trip is known and corrected.
Therefore, the concerns addressed by Mr. Doherty in Docket No. PRM-50-40 have already been resolved, the actions recognize the special nature of each reactor, and any further action is unnecessary and unproductive.
Very truly yours, Y. L /L3 h 7N '7'7<.44 H.L. Brey, Manager Licensing and Fuels Division HLB:JW:jw l
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Interoffice Memo O eubiic service ~
-1 m ss vene company of m bd hIM '
I LA A.g DATE:
April 1,1986 M
TO:
Mr. Michael H. Holnes, Nuclear Licensing Manager, Diamonc Hill FRCM:
Charles H. Fuller, Station Manager, FSV ATTN:
SUBJ:
RESPONSE TO FECERAL REGISTER NOTICE On page 5086 of the Federal Register of February 11, 1986, can e found a Petition for Rulemaking regarding placing the reactor in a colc shutdown cor.dition subsequent to a reactor trip.
The c:nsiderattens 'or :old snut:: *n are not the same for Fort St.
Vrain as tney are for an L'aR.
We need *n responc to this Notice.
Please submit a response ey the(gril 11,19@ required date.
If I can be of assistance, let me know.
Charles H. Fuller CHF/rlo c: Gahm Novacnek Evans Burchfield
~
503s Fabral Register / Vol. 51. Ns ta / Tuesday. February I
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11.1986 / "rw ooed p les proposed i 1135.73 to read as follows:
NUC1. EAR NEQUt.ATORY
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l lHJ$13 Value ofproducer mtlk.
CouMetWON cold shutdown pending harther study of the event.
(a) The portfal payment for nulk to CFR Part $0 39 y,,
sg received dettag the Arst 13 days of the preposal could logically be included in month shall be not less them the I
10 CF1t 30.72 "Immediate Nonf!cetion Minnesota.Wiscoaste prios for the preceding month times the quantity of Joewt F. Doherty; Petittori for Requirements for Operating Nuclear RWomeursg Power Reactors." or in some other milk received.
appropnate section of the regulances acesser: Nuclear Regulatory that could require the proposed licensee Comminion.
action.
hoposedby the Coiry Division, actueen Receipt of petttion for O A **
Agneuhuro/Markettes Semeer rulemakmg.
heposcldo. s The peutioner bases this proposal on Make such cha"4'e as maY be cuan8 8tM Nuc Hr etulatwy a hnding on page 2-4 of NUREC-1000.
necessary to make the entire marketing Corrr.ussica requests pubhc comments Vol.1. "Genenc Implicauona of ATWS agreements and the orders ccaform with on this notice of re:etpt of a pettuon for Events at the Salem Nuclear Power any amendmanta thereto that may ruult rulemaking detsd Ncvember 27.19as.
a cument statu from th2s heanns.
that was filed by John F. Doherty, m
" I ' ' *"
- "'* I" Copies of this notice of heennt end peution was docketed by the the reactor tnp cannot be determmed the ordere may be procured from the Commission on December 2. Isas and within eight hours, the plant ta required Market Admmistrator, W. Joe Albrtsht.
assigned Docket No PRM-50-40.The by company policy to be placed in cold P.O. Box 440e80. Aurore. Colorado peut oner requests that the Comnuselon shutdown pending further study of the amend its regulauens to require that.
80044. or from the Heerms Clerk. Roc n
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' the NN Re fo!!owm 1071 South Building. United States
!icensee.g a power reactor tnp. the Olfice Re n
Department of Agneultura. Washington.
if unable to deerm*= th ci e ug.
C8 avo a
[g"' C' m' reactor ma in eight houn.
D C. 20:30 or may be inspected there.
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_to place the reactor m co44 operational philosophy exhibits the Copias of tha tranacngt of testunony
"" "' N M N -
tatuitively queoconing attwude the? NRC taken at the heartag will not be y,,,,
a vailable for diatnbuttaa through the oavsetSubmit comments by Apttl14.
encourages in its licensees /*
Haaring Clark's OfBoe. If you wish to e
.t98L. Comments receivec amr sa cate Reesen fee the Proposal purchase a copy, arrangements may be
- 'II be considered ifit is practical to do The petitlener contende that the taas made with the reporter at the hearsng.
so. but assurance of consideretttm Salem ATWS event la a prototype of the Frem the time that a hearms nouca is k*
'g*,",',pNa[g[mments kind oflacedent that his proposalis issued and acnt the issuanca of a final c
designed to prevent. He further states decision in a proceeding. Department aconessest Send comments te the that on the day preceding this event at employees mvolved in the decisional Secretary of the Commission. U.S.
Salem there wet a " partial failure to process are prohibited from discusams Nuclear Regulatory Comnussion, SCRAY that the unllry thought had the ments of the bearing issues on an ex
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5.
t om been caused by an operator mannally parte bests wuh any persen having an
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trtyptng the reactor. The petttiener mterest m the proceeding. For this obi"*" * **PY *@' E'"d*8 D states that Salem operated under a rule particular proceeding the prohtbition Y
applies to employees in the following
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," *" g that allowed bisher management to organtzat onal umts:
Nuclear Regulatory Commluion, authertre restart of the reactorif the e
Omce of the Secatary of Agneulture Weshington. DC 20553.
cause for a tnp couid not be idennded.
He further citas NUREC-1000 as Office of the Admmistrator. Agncultural A copy of the petition and of indicaans that in a study of a casa such Markenns Service comments on the petition are available na Salem. a study of procese recorders for inspection or copying for a fee at the Office of the General Counsel would Public Document Room at 1717 H Street. ' failure,have shown that a " SCRAM Datry Division. Agricultural Marketing had occurred and that restart 4
NW., Washmston. DC, would probably lead to e more senoua
'f Servtco (Washaaston OfHee only) poa pummen moosesAtiou contaen
" SCRAM failure." which is what Office of the Market Ad=*at==ator.
John Philips. Chief. Rules and ecurred at Salem.
Crest Basta and I.ake Mead Procedures Branch. Division of Rules
- Cocclumoa -
- rk'U^I ^8'**
and Records. OfHee of Admtmetranon.
Procedural matters are not subMet to U.S. Nuclear Regulatory Commission.
The petitionerconcludas from the Washington. DC 20555. Telephonet 301-information cited from NUREC-1000, the above prohibition and may be 492-70a6 or, Toll Free. W^^ 5642.
discusud at any time.
W1.1. and the senousness oMe 1983 sueetsaamaffART tsepomasA7to8t Signed at Washmston. DC. on: February e.
Petitioner's Proposal h uld t a rule e as h potes.
j y
James C. Handley, The petitioner urges the Commission
. tis 3binks that such a nile would
'eaman 8"Y*I*""* * """"**
Administreter.
to adopt a rule that would state Qat mamW a =mm man at
- " C Followtng a power reactor trip, the EU"' ' #*'""
[FR Doc,86-2931 Filed 2-to-est aAs sm) licensee. if unable to detennine the "nat caused the tnp.
- as caos u m cause of the reactor (trtpl in eight hours.
shan be required to place the reactorin Dated at Washmston. DC. this 5th day of February tees.
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SERVICE COMPANY OF COLORADO I*7(
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B PUBLIC ponT 57. V A AIN NUCLEAA GENERATING STATION Issue 3 page 13 of 14 t
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CCNDITICN III EVENT The Shift Su erviser snall inf:Pm the Stati:n Manager wnen an event is classifiec Concition III er wnen the
- assifi:ati:n cannet ce agreed u::n.
Tne IRC shall e::mmenc :: tre 5:s i:n Manager the re:. -ee actions and tenditions necessary t: aerf:rm a rea::Or restart.
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5:a-f en Manager Evaluati:n anc Cecision
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anacea small avaluate tre e: rreacation ace by tne personne)~
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lavest' att:n
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ce::st:n :: restart tre raaets-e all ia-'t.
e 3e" :.'a; ::ns:: erst :ns:
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7e cause f
-e tri: is ke:wn are
- -*e: ec.
(2) "aj:P safety-related and ther im:Ortant e: t: eat fun::*: cec Or::erly curing t r.e traasisat, er ::rrective maintenance anc sat'sfa::: y tes;ing *as :een perf:r ec Or aill te
- m: ' e.ec wnen Olant
- nci:1:ns :ermit.
(3)
'e clan; est:nse curiag :Pe tric has
- een analy:ec an: :ne clan; rescenced as acti ':a:ac, Or all significar a:n:r alities are
.ccars:::c anc
- Orre ac as "ecessary ensure
- m:lian:e i:n ne Tecnnical S:ect f
- a-icns.
If ne cause f
-e trt; als no
- een
- sitively t:entifisc, ne Station Mana:er snail cetermine if tre cause and tre circumstances surr:uncing the :ause nave een analy:ec ace:uately.
The -e::mmencati:ns f the IRC snali :e : nsidered in :ne cecision
'er reac;;r restart.
l scaw 272 22 seu h"
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UNITED STATES
[
g NUCLEAR REGULATORY COMMISSION t
WASMtNGToN, O. C. 20094 a-4,,
,[
July 8, 1983
-- 832.5 fo I
M% -65 TO ALL LICENSEES OF OPERATING REACTORS, APPLICANTS FOR OPERATING LICENSE, AND HOLDERS OF CONSTRUCTION PERMITS 6entlemen:
SUBJECT:
REQUIRED ACTIONS BASED ON GENERIC IMPLICATIONS OF SALEM ATdS EVENTS (Generic Letter 83-28)
The Commission has recently reviewed intemediate-tem actions to be taken by licensees and applicants as a result of the Salem anticipated transient without scram ( ATWS) events.
These actions have been developed by the staff bmd e
_information contained in NURM innn. " Generic Implications of ATdS Events at tne saiem micer rower Plant." These actions address issues related to reactor trip system reliability and general management capability.
The actions covered by this letter fall into the following four areas:
f 1.
Post-Trip Review - This action addresses the program, procedures and data collection capability to assure that the causes for unscheduled reactor shutdowns, as well as the response of safety-related equipnent, j are fully understood prior to plant restart.
2.
Equi;nent Classification and Vendor Interface - This action addresses the
~
programs for assuring that all components necessary for accomplishing required safety-related functions ara properly identified in documents, procedures, and information handling systems that are used to control safety-related plant activities.
In addition, this action addresses tne establishment and maintenance of a program to ensure that vendor information for safety-related components % complete.
3.
Post-Maintenance Testing - This action addresses post-maintenance operability testing of safety-related components.
4 Reactor Trip Systen Reliablity Improvements --This action is aimed at assuring that vendor-recommended reactor trip breaker modifications and associated reactor proter. tion system changes are completed in PWRs, that a comprehensive progran of preventive maintenance and surveillance testing is implemented for the reactor trip breakttrs in PWRs, that the shunt trip attachment activates automatically in all PWRs that use circuit breakers in their reactor trip system,' and to ensure that on-line functional testing of the re:ctor trip system is performed on all LWRs.
83o7080169
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'l The enclosure to this letter breaks down these actions into several components.
You will find that ali-actions, except four (Action 1.2, 4.1, 4.3, and 4.5),
require software (procedures, training, etc.) changes and/or modifie,ations and do not affect equipment changes or require reactor-shutdown to comrlete.
Action 1.2 may result in some changes to the sequence of events recorder er existing plant computers, but will not result in a plant shutdown to implement.
Actions 4.1, 4.3 and 4.5.2, if applicable, wo'uld require the plant to be shutdown in order to impleent.
The reactor trip system is fundamental-to reactor safety for all nuclear power plant designs. All transient and accident analyses are successful operation to assure acceptable consequences. predicated on its Therefore, the actions listed below, which relate directly to the reactor trip system, are of the highest priority and should be integrated into existing plant schedules first.
1.1 Post-Trip Review (Program Description and Procedure) 2.1 Equipment Classification and Vendor Interface (Reactor Trip _
System Components) 3.1 Post-Maintenance Testing (Reactor Trip Systen Components) 4.1 Reactor Trip System Reliability (Vendor-Related Modifications) 4.2.1 and 4.2.2 Reactor Trip System Reliability (Preventive Maintenance and Surveillance Program for. Reactor Trip Breakers) 4.3 Reactor Trip -System Reliability (Automatic Actuation of Shunt-trip -
Attachment for Westinghouse and 8&W plants)
Most of the remaining intermediate-tem actions concern all other safety-related systems. These systems, while not. sharing the same relative importance to safety as the reactor trip system, are essential in mitigating the'conse-quences of transients and accidents.. Therefore, these. actions should be integrated into existing plant schedules over the longer-term on _a medium priority basis. Some of the-actions discussed in the enclosure will best be i
served by Owners' Group participation, and this is encouraged to the extent practical.
Accordingly, pursuant to 10 CFR 50.54(f), operating reactor licensees and applicants for an operatir.g license (this letter is for information only.
for those utilities that have not acoltea for an acerating license) are requested to rurnish, under oath and affirmation, no-later than 120 days from the date of this _ letter, the status of current conformance-with the. positions-contained herein and plans and schedules for any needed improvements for conformance with the positions.- The schedule for the implementation of these
~
improvements is to-be negotiated with the Project Manager.-
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' Licensees and applicants may request an extension of time for submittals of the required information.
Such a reque ' must set forth a proposed schedule and justification for the delay.
Such ; request shall be directed to the Director, Division of Licensing, NRR. Any such request must be submitted no later than 60 days from the date of this letter.
If a licensee or applicant does not intend to implement any of the enclosed items, the response should so indicate and a safety basis should be provided for each item not intended to be implamented.
Value-impact analysis ct.n be used to support suca responses or to argue in favor of altertiative positions that licensees might propose.
For Operating Reactors, the schedules for implementation of these actions shall be developed consistent with the staf f's goal of integrating new requirements, considering the unique status of each plant and the relative safety importance of the improvements, combined with all other existing plant programs.
There f ore, schedules for implementation of these actions will be negotiated between the NRC Project 4anage and licensees.
For plants undergoing operating license review at this time, plant-specific schedules for the implementation of theste requirements shall be developed in a manner similar to that being used for operating reactors, taking into consideration the degree of completion of the power riant.
For construction pennit holders not under OL review and for construction permit applicants, the requirements of this letter shall be implemented prior to the issuance of an operating license.
This request for infomation was approved by the Office of Management and Budget under clearance nunber 3150-0011 which expires April 30, 1985.
Ccoments on burden and duplication may be directed to the Office of Management and Budget. Reports Management Room 3208, New Executive Of fice Building, Washington, D. C.
20503.
Sincerely, i
N t
LL Darrell G. 'Eisennut, Director Division of Licensing
Enclosure:
Required Actions Based on Generic Implications of Salem AWS Events
/
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ENCLOSURE REQUIRED ACTIONS BASED ON GENERIC IMPLICATIONS OF SALEM Aih3 EVENTS i
1.1 POST-TRIP REVIEW (PROGRAM DESCRIPTION AND PROCEDURE)
Position Licensees and applicants shall describe their program for ensuring that unscheduled reactor shutdowns are analyzed and that a deter nination is made tnat tne plant can be restarted safely. A report describing the program for review and analysis of sucn unstneduled reactor shutcowns should include, as a minimum:
1.
The criteria for determining the acceptability of restcrt.
2.
The responsibilities and authorities of personnel who will perform the review arid analysis of these ev2nts.
l 3.
The necessary qualifications and training for the responsible personnel.
4.
The sources of plant information necessary to conduct the review l
and analysis. The sources of infor.aation should knclude the measures and equipment that provide the necessary detail and l
type of information to reconstruct the event accurately and in sufficient detail for proper understanding. (See Action 1.2) 5.
The methods and criteria for comparing the event information with known or expected plant behavior (e.g., that safety-related equip-ment operates as required by the Technical Specifications or other performance specifications related to the safety function).
6.
The criteria for determining the need-for independent assessment of an vent (e.g., a case in which the cause of the event cannot ba, positively identified, a competent group such as the Plant Operations Review Comittee, will be consulted prior to authorizing restart) and guidelines on the preservation of pnysical evidence (both hardware and software) to support independent analysis of tne event.
7.
Items 1 through 6 above are considered to be the basis for the establishment of a systematic method to assess unscheduled reactor shutdowns. The systematic safety assessment procedures compiled from the above items, which are to be used in conducting the evaluation, should be in the report.
Acolicability This position applies to all licensees and OL applicants.
d X 2.
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Type of Review For licensees, a post implementation review of the program and procedures
(
will be conducted or the staff will perform a pre-implementation review if desired by the licensee. NRR will perform the review and issue Safety Evaluations.
Fcr OL appitcants, the NRR review will be performed consistent with the licensing schedule.
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Occumentation Recuired
)
Licensees and applicants shall submit a report describing their program l
addressing all the items in the position.
,Techncial Specification Changes Reouired No changes to Technical Specifications are required.
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References l,
Section 2.2 of NUREG-1000 Regulatory Guide 1.33 ANSI N18.7 1976/ANS.3.2 Item I.C.5 of NUREG.0660 10 CFR 50 - 50.72 I
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