ML20128G471
| ML20128G471 | |
| Person / Time | |
|---|---|
| Site: | Brunswick |
| Issue date: | 05/15/1985 |
| From: | Vassallo D Office of Nuclear Reactor Regulation |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML20127D675 | List: |
| References | |
| GL-83-28, NUDOCS 8505300168 | |
| Download: ML20128G471 (17) | |
Text
V May 15, 1985.
Docket Nos. 50-325/324 DISTRIBUTION (Docket _Filee NRC PDR Mr. E. E. Utley Local PDR Executive Vice President ORB #2 Reading Carolina Power & Light Company HThompson Post Office Box 1551 OELD Raleigh, North Carolina 27062 SNorris MGrotenhuis
Dear Mr. Utley:
ELJordan JPartlow
SUBJECT:
DRAFT TECHNICAL EVALUATION REPORT (TER)
BGrimes FOR SALEM ATWS ITEM 1.2 (GENERIC LETTER 83-28)
ABournia JKramer Re:
Brunswick Steam Electric Plant, Units 1 and 2 RRamirez ACRS(10)
Gray File The staff has completed a preliminary review to assess the completeness and
-adaquacy of licensee responses to Generic Letter 83-28 Item 1.2.
Your response for the Brunswick Plant was found to be incomplete as indicated
~below.
The enclosed Draft TER provides a technical evaluation representing the staff's initial judgment of the areas evaluated.
In order to preserve.ir present review schedule, we would appreciate your cooperation in proviv.ig the additional information that will permit us to complete our review. The information needed is indicated in the conclusion and on the attached pages
-of the TER.
It would appear that the needed infonnation on your facility could be obtained by telephone conference within one week of your receipt of the DRAFT TER. Your project manager will be working with you to arrange an acceptable time to conduct the necessary conference calls.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Sincerely, Original signed by/
Domenic B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing
Enclosure:
As stated cc w/ enclosure:
See next page 7
ORB #, L:
ORB #2:DL Ef2:DL DL SNorM s:vr MGrotenhuis DVassfilo 05/15/85 05f(/85 05/jf/85 g53OOl68850515 ADOCK 05000324 p
PDR L.
E Mr. E. E. Utley Carolina Power & Light Company Brunswick Steam-Electric Plant; Units 1.and 2 cc:
Richard E. Jones, Esquire J. Nelson Grace Carolina-Power & Light ^ Company Regional Administrator 336 Fayetteville Street Region II Office Raleigh, North Carolina 27602 U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 3100 George F. Trowbridge, Esquire Atlanta, Georgia 30303 Shaw, Pittman, Potts and Trowbridge 1800 M Street, N. W.
Dayne H. Brown, Chief Washington, D. C.
20036 Radiation Protection Branch Division of Facility Services Mr. Charles R. Dietz Department of Human Resources Plant Manager Post Office Box 12200 Post Office Box 458 Raleigh, North Carolina 27605 Southport, North Carolina 28461 Mr.'Franky Thomas, Chairman Board of Commissioners Post Office Box 249 Bolivia, North Carolina 28422 Mrs. Chrys Baggett State Clearinghouse-Budget and Managenent 116 West Jones Street Raleigh, North Carolina 27603 Resident Inspector U. S. Nuclear Regulatory Commission Star Route 1 Post Office Box 208 Southport, North Carolina 28461 i
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SAic-8571523-1 REVIEW OF LICENSEE AND APPLICANT RESPONSES TO NRC 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 BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 (50-325, 50-324)
Draft Technical Evaluation Report Prepared by Science Applications International Corporation 1710 Goodridge Drive McLean, Virginia 22102 Prepared for U.S. Nuclear Regulatory Commission Washington, D.C. 20555 E
Contract No. NRC-03-82-096 l
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I FOREWORD This report contains the technical evaluation of the Brunswick Steam Electric Plant Units 1 and 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 criteria, presented in part 2 of this report, were divided into five separate categories. These are:
1.
The parameters monitored by the sequence of events and the time history recorders, 2.
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 83-28 were evaluated. The plant for which this report is applicable was found to have adequately responded to, and met, categories 2, 4 and 5.
,,;,ycrit*FI" The report describes the specific methods used to determine th cate-gorization of the responses to Generic Letter 83-28.
Since this ev uation report was intended to apply to more than one nuclear power plant pecifics regarding how each plant met (or failed to meet) the r:; !.
m.n6s are not presented.
Instead, the evaluation presents a categorization of the responses according to which categories of r:; ' :....
are satisfied and which are not.
The evaluations are based on specific c iteria (Section 2) derived from the requirements as stated in the generic let r.
yg g,gu sta tor i a.
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TABLE OF CONTENTS Section Page Introduction.........................
I 1.
Background..........................
2 2.
Review Criteria.......................
3 3.
Evaluation..........................
8 4..
Conclusion..........................
9 5.
Re fe re nc e s..........................
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(,. Suffaa.mte @ccumety foA TucM -
O e
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t INTRODUCTION SAIC has reviewed the submittals prepared in response to Generic Letter 83-28, ^ 1 tem 1.2 " Post-Trip Review:
Data and Information Capability".
ThistsubmittaV(see references) contained sufficient information to determine that the data and information capabilities at this plant are acceptable in the.following areas.
t o
The sequence-of-events recorder (s) performance charac-teristics.
e The output format of the recorded data.
e The long-term data retention, record keeping, capa-bility.
However, the data and information capabilit'ies, 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 infomation capabilities -in the,following areas.
e The parameters monitored by both the sequence-of-events and time history recorders.
e The time history recorder (s) performance characteris-tics.
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===1.
Background===
On February 25, 1984, both of the scram circuit breakers it Un.it 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; et 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' written 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 ju.dgment on the proper functioning of the trip l
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 Impitcations of ATWS 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 2
c-Classification and Vender Interface, (3) Post Maintenance 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 ionsists of action item 1.1 " 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' responses to the. requirements of action item 1.2 will be discussed.
2.
Revice 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 caus knd 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 digttal; sequence of events (SOE) record and the analog time history records of an unscheduled shutdown should pro-iride 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 6uch as a sequence-of-events recorder or a plant process computer for digital parameters; and strip charts, a plant process computer or analog recorder for n?. log (time history) variables)
Each device used to record an analog 4r i gital plant variable should be described in sufficient detail sr Fe.
- etermination can be made as to whether the following performance c..aracterotics are met:
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e 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 l
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.
e Each analog time history data recorder should have a sample inter-val small enough so that the incident can be accurately reconstructed 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 cccurately recon-struct the accident sequences presented in Chapter 15 of the FSAR.
e 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.
e 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).
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information should be presented in a readable and meaningful format, taking into consideration good human factors practices (such as those outlined in NUREG-0700).
e 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 j
safety related.
The sequence of events and time history recording equipment should monitor sufficient digital and analog parameters, respectively, to assure l
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 i
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
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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 j
design envelope) are presented on Tables 1.2-1 and 1.2-2.
If the appli-cants' or licensees' SOE 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 remaine,d 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.
Data from all unscheduled shutdowns provides a valuable 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 in an accessible manner for the life of the plant.
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Table 1.2-1.
PWR Parsmeter List
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-SOE Time History ~
Recorder Recorder Parameter / Signal h)x Reactor Trip (1) x Safety Injection x
Containment Isolation (1) x Turbine Trip x
Control Rod Position (1) x
_x Neutron Flux, Power c
x N
Containmer.t Pressure (2)
Containment Radiation x
Containment Sump Level (1) x x
Primary System Pressure (1) x x
Primary System Temperature (1) x Pressurizer Level (1) x Reactor Coolant Pump Status
-(1) x x
Primary System Flow (3)
Safety Inj.; Flow. Pump / Valve Status x
MSIV Position x
x Steam Generator Pressure (1) x x
Steam Generator Level (1) x x
Feedwater Flow (1) x x
Steam Flow (3)
Auxiliary Feedwater System; Flow, Pump /Value Status x
AC and DC System Status (Bus Voltage) x Diesel Generator Status (Start /Stop, On/Off) x PORY Position (1.): Trip parameters (2): Parameter may be monitored 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.
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Table 1.2-2.
BWR Parameter List
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.50E Time History Recorder Recorder Parameter / Signal x
x Safety Injection x
Containment Isolation x
Control Rod Position x (1)-
x Neutron Flux, Power -
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x (1)
Main Steam Radiation (2)
Containment (Dry Well) Radiation x_(1) x Deywell Pressure (Containment Pressure)
(2)
Suppression Pool Temperature x (1) x Primary System Pressure
.x(1) x Primary System Level x
MSIV Position x (1)
Turbine Stop Valve / Control Valve Position x
Turbine Bypass Valve Position x
Feedwater Flow x
Steam Flow (3)
Recirculation; Flow, Pump Status x (1)
Scram Discharge Level x (1)
Condenser. Vacuum x
AC and DC System Status (Bus Voltage)
(3)(4)
Safety Injection; Flow. Pump / Valve Status x
Diesel Generator Status (On/Off, Start /Stop)
(1): Trip parameters'.
(2): Parameter may be recorded by either an SOE or time history recorder.
(1): 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 all applicable systems from the following: HPCI, LPCI, LPCS, IC, RCIC.
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T 3.
Evaluation The parameters identified in part 2 of this report as a 'part tf 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.
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.The review criteria require that the equipment being used to record the sequence of events and time history data required for a post-trip review meet certain performance characteristics.
These characteristics are intended to ensure that, if the proper parameters are recorded, the record-ing equipment will provide an adequate source of information for an effec-tive post-trip review. The information provided in this submittal does not indicate that the time history equipment used would meet the intent of the performance criteria outlined in part 2 of this report.
Information supplied in the submittal does indicate that the SOE equipment meets the performance criteria specified in part 2 of this report.
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 criterion that calls for information in a readable and meaningful format. The information contained in this submittal indicates that this n;2.
1.J. is set.
s.v/fw i. e.
e,rettf',,
The data and information used during a post-trip rev w should be retained as part of the plant files. This information co d prove useful during future post-trip reviews. Therefore, one n;:'n._.
is that infor-mation used during a post-trip review be maintained in a6 accessible manner for the life of the plant. The information contained within this submittal indicates that this criterion will be met.'
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4.
Conclusion The information. supplied in response to Generic Letter 83-28 indicates that the current post-trip review data and information capabilities are adequate in the following areas:
i 1.
The recorded data is output in a readable and meaningful format.
2.
The information recorded for the post-trip review is maintained in an accessible manner for the life of the plant.
t 3.
The sequence of events recorders meet the minimum performance requirements.
The information supplied in response to Generic Letter 83-28 does not
. indicate that the post-trip review data and information capabilities are adequate in the following areas.
1.
Based upon the information contained in the submittal, all of the parameters specified in part 2 of this report that should be recorded for use in a post-trip review are not recorded.
2.
Time history recorders, as described in the submittal, do not meet the minimum performance characteristics.
It is possible that the current data and information capabilities at thy".
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duclear power plant are adequate to meet the intent of these but were not completely described. Under these circumstances, the licensee l
should provide an updated, more complete, descriptica to show in more detail the data and information capabilities at this nuclear power plant.
If the information provided accurately represents all current data and information capabilties, then the licensee should either show that the data and informa-tion capabilities meet the intent of the criteria in (art 2 of this report, h
or dtEU'Y" e 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 8ased on Generic Implications of Sales ATWS Events." July 8, 1983.
NUREG-1000, Generic Implications of ATWS Events at the Salem Nuclear Power Plant, April 1983.
Letter from P.W. Howe, Carolina Power and Light Company, to D.G.
Eisenhut, NRC, serial LAP-83-513 dated November 7,1983, in response to Generic Letter 83-28, with attachment.
s Salem Response Task Force Report NRC Generic Letter 83-28 Response, dated November 5,1983.
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JefhN #cc8 Mess 7 M TQs.ok Brunswick I and 2 1.
Parameters recorded: Unsatisfactory See attached table for discrepancies.
2.
SOE recorders performance characteristics: Satisfactory Plant process computer: 2ms time discrimination and an uninterruptible power source 3.
Time history recorders performance characteristics: Unsatisfactory Plant process computer:
variable scan rates (1 see to 2 min) only record the last scanned value prior to the trip and continuous after the trip.
NSS Post Trip Log:
scan rates are the same as the plant process computer BOP Post Trip Log:
sampling rates are the same as the plant computer:
log duration is from 5 min before to 5 min after trip.
4.
Data output format: Satisfactory SOE data: time, parameter ID, parameter description, and status are among the output Analog data: time, point ID, parameter description, value, high and low limit are among the output 5.
Data retention capability: Satisfactory Post-trip data will be stored for the life of the plant.
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Dasif**'M"
":; M d BWR Parameters for Post Trip Review (circled parameters are not recorded)
SOE Time History Recorder Recorder Parameter / Signal
'x Reactor Trip x
Safety Injection Containment Isolation x
Control Rod Position x(1) x Neutron Flux, Power x (1)
Main Steam Radiation (2)
Containment (Dry Well) Radiation Drywell Pressure (Containment Pressure) x (1) x (2)
Suppression Pool Temperature
- x (' )
x Primary System Pressure 1
x (1) x Primary System level x-MSIV Position x(1)
Turbine Stop Valve / Control Valve Position Turbine Bypass Valve Position x
Feedwater Flow f
x Steam Flow l-(3)
Recirculation; Flow. Pump Status l
x(1)
Scram Discharge Level x(1)
Condenser Vacuum AC and DC System Status L
(3)(4)
Safety Injection; Flow Pump / Valve Status b
x Diesel Generator Status (1):Tripparameters.
(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 l
recorder, (b) system flow ' recorded on a time history recorder, or l
(c) equipment status recorded on an 50,E recorder.
l (4): Includes recording of parameters for all applicable systems from the following: HPCI, LPCI, LPCS, IC, RCIC.
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