ML20128G729

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Provides Updated Info Re 831103 Response to Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events
ML20128G729
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 07/05/1985
From: Jens W
DETROIT EDISON CO.
To: Youngblood B
Office of Nuclear Reactor Regulation
References
GL-83-28, VP-85-0134, VP-85-134, NUDOCS 8507090299
Download: ML20128G729 (22)


Text

Wryne H. Jans vice presioent f

i Nuclear Operates t orth Dute Highway ISOn < Newport, Michrgan 3:3) seu tso 48166 July 5, 1985 VP-85-0134 Director of Nuclear Reactor Regulation Attention: Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Youngblood:

Reference:

(1) Fermi 2, NRC Docket No. 50-341 NRC License No. NPF-33 (2) NRC to Detroit Edison, Generic Letter 83-28,

" Required Actions Based on Generic Imolications of Salem ATWS Events", July 8, 1983 (3) Detroit Edison Letter to NRC, " Detroit Edison Response to NRC Generic Letter 83-28",

EF2-66117, dated November 3, 1983 (4) Detroit Edison Letter to NRC, " Clarification of Detroit Edison's Resoonse to Generic Letter 83-28", EF2-72014, dated November 29, 1984

Subject:

Detroit Edison Undated Status to NRC Generic Letter 03-28 Detroit Edison is providing uodated information concerning commitments made in Reference 3. The subject items are identified below, with proper reference, along with suople-mental information on the undated Fermi 2 response.

Item 1: Page 1 of Reference 3, Item 1.1 Fermi 2 Response: The recently issued INPO " Good Practice, OP-211, Post Trip Reviews" document was reviewed by Detroit Edison and its recommendations were incoroorated, where anoropriate, into Operations Procedure -

Administrative, Number 21.000.03, " Post-Scram Evaluation and Re-Start Authorization". This orocedure controls the oost-scram review orogram used at Fermi 2. A cooy of this procedure is attached to this recort.*

8507090299 DR 850705 f ADOCK 05000341 PDR' 1\0' l

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Mr. B. J. Youngblood July 5, 1985 VP-85-0134 Page 2

  • All of the Detroit Edison procedures referenced in this response to NRC Generic Letter 83-28 are referenced to demonstrate imolementation of the responses, but they are not referenced to document commitments to the NRC. These i procedures are controlled, living documents that may change deoending on Fermi 2 operational and organizational needs.

Item 2: Page 4 of Reference 3, Item 1.1.3 Fermi 2 Response: Training is currently being orovided to those oersonnel responsible for conducting post-scram reviews at Fermi 2. This training orovides familiarization with the techniques used during oost-scram reviews including the use of the sequence of events recorders, strio charts, the olant process computer, and other devices oroviding imoortant information.

Item 3: Page 10 of Reference 3, Item 1.2.4 Fermi 2 Response: Detroit Edison requested in a letter to NRC, EF2-71999, dated November 12, 1984 that the ODerating License reflect December, 1985 as the date required for the Emergency Response Information System (ERIS) to be functional. The date was incorporated in the Fermi 2 OL for the Safety Parameter Display System (SPDS) only. The SPDS is substantially functional at this time, including aoprooriate personnel trained. All that remains for the SPDS to be formally declared functional to satisfy the License Condition is the resolution of a few minor ooen items concerning the completion of acceptance testing. This is exnected to be completed by the end of July, 1985. Detroit Edison expects to have the entire ERIS system functional by December 1985.

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.. Mr. B. J. Youngblood July 5, 1985 VP-85-0134 Page 3 Item 4: Page 12 of Reference 3, Item 2.1.1 Fermi 2 Response: Detroit Edison has complited a review of the Reactor Trip System (RTS) components to ensure that these components are appropriately identified as safety-related. These components include all active components of existing plant systems that function to implement a reactor scram. The results of this review indicate'that Fermi 2 has in place sufficient administrative controls and procedural practices to meet this position.

Item.5: -Pages 12 and 13 of Reference 3, Item 2.1.2.1 Page 14 of Reference 3, Item 2.1.2.2 Pages 19 through 21 of Reference 3, Item 2.2.2.1 Pages 21 and 22 of Reference 3, Item 2.2.2.2 Pages 24 and 25 of Reference 3, Items 3.1.2 and 3.2.2 Fermi 2 Response: Detroit Edison has in place a vendor interface and information program meeting the. requirements of Items 2.1.2.1, 2.1.2.2., 2.2.2.1, 2.2.2.2, 3.2.1, and 3.2.2. See also Item 2 of Reference (4). It should be noted that the Vendor Equipment Technical Information Program (VETIP) as defined in the March 1984 NUTAC document is considered a valid response to Section 2.2.2 of NRC Generic. Letter 83-28.

Detroit Edison has implemented the program as described-therein.

Item 6: Page 28 of Reference 3, Item 4.5.3 Fermi 2 Response: Detroit Edison is actively involved in the BWROG Technical Specification group. This group recently

. completed a special study of the on-line testing intervals in Technical Soecifications which is contained in Topical Report NED C-30844, January 1985. Letter BNROG-8505, January 31, 1985, provided the results of the Group's study to the NRC for its review. When the review is complete, Detroit Edison plans to use the results of this study as a basis for requesting or not requesting changes to the existing on-line testing intervals in the Fermi 2 Technical Specifications.

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  • Mr. B. J. Youngblood July 5, 1985 VP-85-0134 Page 4 The undated information in this letter is being orovided to demonstrate that Detroit Edison has addressed all items of concern and describes the manner in which all commitments made in Reference 2 have been completed.

If you have any further questions on this matter, please contact Mr. O. K. Earle at (313) 586-4211.

Sincerely, I

M cc: Mr. P. M. Byron Mr. M. D. Lynch Mr. T. E. Taylor USNRC Document Control Desk Washington, D. C. 20555

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te SR k Safety Classification FERMI 2 PROCEDURE - OPERATIONS - ADMINISTRATIVE TITLE: POST SCRAM EVALUATION AND RESTART AUTHORI'ZATION REV O NU R ,

ghj Name of preparer: F. E. Abramson /s/

Technically reviewed by: Guy Reece /s/ Date03/07/85 Reviewed / concurred by: W. E. Miller /s/ Date: 05/07/85 Supv - Operational Assurance Approved by: F. E. Abramson /s/ Date: 05/07/85 k Responsible Section Head or OSRO Member / Alt Further approval Required for

  • Safety-Related or Superintendent-Designated Procedures:

Recommended by: R. S. Lenart /s/ Date: 05/07/85 OSRO Chairman / Alternate Approved by: R. S. Lenart /s/ Date: 05/07/85 Superintendent - Nuclear Production I

The following approved procedure Chenge Requests are incorporated in this revision: M3094 ,

This revision lfl does l l does not constitute periodic review.

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MAY 101985 MAY 101985 N C ADMtN.

{ F.i S.* g p RMATION SYSTEMS P.I.S: -

APPROV Al ll[Q'D; YES. NO 1

g 21.000.03 Riv. 8 TABLE OF CONTENTS -

Page_

1 l.0 Purpose.......................................

1 20 Discussion...................................

1 E 3.0 Reference....................................

1 4.0 Definitions..................................

2 5.0 Responsibilities............................. b 4

6.0 Functions....................................

Attachments Attachment 1 Post-Scram Data and Evaluation (050285).......

Post-Scram Investigation Statement $

Attachment 2 Sheet (050285)................................

k 100/CW19/1.0 (Temp. 121A)

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1 21.000.03 f

asv. 8 l Prgt I l

1.0 Purpose .

l$[

11 This procedure is to provide a systematic method diagnosing the causes of unscheduled Reactor Scrams, l t ascertainin to reactor restart and making the determination that the p an can be restarted safely.

E 2.0 Discussion Post-scram reviews establish a consistent, comprehensive 21 systematic method to determine the causes and conditions assoc -

i and This documented review will help '

ated with reactor scrams.

ensure events that may have had an impact on the cause of the scram and subsequentThe equipment responses review results are identified will permit a deter- and thoroughly understood. fl mination to be made as to the readiness of the plant to sa e y return to operation.

3.0 _References _ 11.000.49, Nuclear Operations Interf acing Procedures (NOIP) 31 Document Control and Records Management

[ Deviation and Corrective Action Reporting 3.2 NOIP, 11.000.52, 21.000.01, Shift 3.3 Plant Operations Manual (POM) Procedure, Operations and Cogtrol Room Documentation of Allowable Operating 3.4 POM Procedure, 21.000.06, ,

Transients 3.5 Institute of Nuclear Power Operations (INPO) Good Practice, OP-211, Post-Trip Reviews 4.0 Definitions _

4.1 Cause - The root initiator of an event (usually Whenan the equipment cause mal .

function, procedural error or personnel error).

is corrected, the possibility of the event recurring is minimized.

4.2 Diagnostics - A systematic approach to theThis identification may include of

_ problems and "K-T" selection of appropriate (Kepner-Tregoe) method. measures.a method 4.3 Post-Scram Data - A collection of inforuation The used to con investigation and review of an unscheduled reactor s

( (Attachment 1), hard-copy recorded data and written statements from personnel involved in the event.

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. 21.000.03 j

Riv. 8 Page 3 He shall also aid condition as prescribed by the NSS. fi- ~'

the NSS is determining the required Technical S event reportability. I J

Be shall also sign the Post-Scram Data ,and Evaluation form (Attachment 1) as being in agreement with the class determination event. i The OE shall also review and sign the Post-Scram dData and Evaluation package before the package is submitte6.10 to the Technical Engineer as specified in Section of this procedure.

5.1.4 Plant Personnel TA Plant personnel involved in the unscheduled d reac objective comments that describe their observations Objective an their actions relating to the reactor scram.

comments regarding the cause of the Reactor Scram are particularily important.

Plant Superintendent - Nuclear Production 5.1.5 The plant superintendent or his delegate is responsible for authorization of a plant restart following any unscheduled Reactor Scrams.

5.1.6 Shift Tdchnical Advisor (STA)

The STA is responsible for compiling the data required on theThePost-Scram Data and STA is also responsible withEvaluation form (Attachme the NSS for the 1).

investigation phase of the post-scram review.

5.1.7 Technical Engineer _

The Technical Engineer is responsible for generating h

the necessary documents and reports to ensure t at lessons learned from unscheduled reactor d to scrams are used to improve plant safety and reliability an to the transfer in-house experience of generic interest industry.

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21.000.03

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2. The STA shall collect written statements from plant personnel who were involved in or who ,

observed the reactor scram. The written state-ments should include the following type of information:

  • i
a. plant conditions prior to the reactor scram (for Maintenance and I&C personnel this will include the status of maintenance or 3 testing),
b. first indication that a problem existed,
c. individual action as a result of the indication,
d. subsequent indications and plant response including manual actions,
e. noted equipment malfunctions or inadequacies,
f. procedure deficiencies identified during the situation.
3. The STA shall complete the Post-Scram Data and

( Evaluation form with the aid of the control room Nuclear Supervising Operator (NS0) and the Nuclear Assistant Shif t Supervisor (NASS).

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a. The STA shall assign an in-sequence number to

. each Post-3 cram Data and Evaluation form used. The number shall start with the present year and then a sequential number.

At the beginning of each new year, the numbering sequence shall be zeroed. (e.g.85-001, 85-002) 6.4 Post-Scram Investigation - The NSS and the STA are responsible for the initial post-scram investigation. The purpose of this investigation is to determine the cause of the scramThe and return to to assess the plant readiness to return to operation.

include verification of the following:

operation assessment must

' 6.4.1 Systems / Functions

1. The Reactor Protection System operated properly.
2. No Emergency Core Cooling Systems were actuated with injection into the reactor vessel.
3. The initiating scram signal has been identified.
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21.000.03

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6.5 Scram Classification 6.5.1 Based on the results of the analysis and evaluation of

, the reactor scram and subsequent plant response, the NSS or his delegate and the STA shall classify the scram as one of the following: .

1. Class I - The cause of the scram is positively known and has been corrected; all safety-related and other important equipment functioned properly during and after the scram.
2. Class II - The cause of the scram is positively known and has been corrected; some safety-related and/or other important equipment did not function properly. However, the malfunction has been corrected or Technical Specification constraint does not prohibit a reactor start-up.
3. Class III - Any items specified in 6.4.1 of this procedure have not been satisfied or some safety-related and/or other important equipment functioned in an abnormal or degraded manner during the event which has not been corrected or prevents reactor start-up due to technical

[ specifications constraints.

6.5.2 If the NSS and the STA cannot agree on the scram class-ification, the Post-Scram Data and Evaluation form and associated data will be forwarded to the OSRO for eval-uation.and classification.

6.6 Notifications 6.6.1 Once the scram has been classified, the NSS or his delegate shall notify the Operations Engineer or his delegate and the Technical Engineer or his delegate to allow them an opportunity to determine thoroughness, technical accuracy and consistency of the scram investigation and sign the agreement with the scram classification.

The notification of the Technical Engineer is in addi-tion to the notification specified in 6.3.2 of this i procedure.

6.6.2 If the scram has been classified as a Class III, the OSRO chairman must also be notified.

6.7 Investigation Review 6.7.1 Class I and Class II scrams shall be reviewed by the

( OSRO during the next regularly scheduled meeting. This review is not required prior to reactor restart.

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21.000.03

      • Rev. 8 Peg 2 9 g (.

6.9.2 If the cause of the scram has not been positively identified, the Superintendent - Nuclear Production shall determine if the cause and the circumstances surrounding the cause have been analyzed adequately.

He shall ensure adequate measures are taken to prevent repetitive challenges to safety systems during future power operations. .

6.10 In-House Operating Experience Review 6.10.1 The completed Post-Scram Data and Evaluation form and all associated data shall be reviewed by the OE or his delegate and sent to the Technical Engineer. The '~

Technical Engineer shall review the data and determine if the event has generic significance to plant safety and reliability. The data should also be evaluated to determine if a requirement exists for additional corrective actions such as procedure changes or design modifications. Information copies of the Post Scram Data and Evaluation form will be forwarded to Nuclear g.

Engineering and the Nuclear Safety Review Group for g their review.

The data should also be reviewed to determine if any lessons learned are applicable for incorporation into

[' Plant Staff training or for industry dissemination.

6.11 Retention 6 11.1 After the post-scram data review and evaluation has been completed, the data must be forwarded to the Record Center per reference 3.4 for record retention.

The Post-Scram Data and Evaluation form with all associated data shall be retained for the life of the plant.

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21.000.03 Attcchnert 1 Peg 2 1 cf 10

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POST-SCRAM DATA AND EVALUATION No.

1.0 Reactor Scram Data: .

1.1 Time and date of reactor scram, /

1.2 Control Room NSO on duty, . .

1.3 Initiating scram signal, 1.4 Parameter value at which initiating scram signal occurred, 1.5 Turbine trip time /date / .

1.6 Recirculation pump runback YES NO .

1.7 Recirculation pump trip YES NO .

Cause:

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1.8 Were any control stations taken from AUTO to MANUAL YES NO .

1.8 .1 If YES, specify station and time.

2.0 Initial Condition Prior to Scram:

2.1 Reactor Mode Switch Position:

Shutdown Refuel .

Startup/ Hot Standby Run .

2.2 Reactor Power,  %.

2.3 Generator Gross Load, Mwe.

2.4 Total Core Flow, Mf/hr.

2.5 Reactor Pressure, PSIG.

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l . 21.000.03 Att chsent 1 Pegs 2 of 10

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POST-SCRAM DATA AND EVALUATION (Continued) d IN.

2.6 Reactor Water Level. _

GPM. .

2.7 Reactor Recirculation Loop A Flow - i GPM.

2.8 Reactor Recirculation Loop B Flow ,

g 2.9 RRR Division I Mode / Status -

2.10 RRR Division II Mode / Status 2.11 Reactor Feedwater Control:

2.11.1 Master Control, MAN AUTO .

Elements selected, SINGLE THREE .

2.11.2 Reactor Feed Pump A, MAN AUTO .

2.11.3 Reactor Feed Pump B, MAN AUTO .

2.11.4 2.12 Reactor Pressure Regulator in Service, A _B .

(l( 2.13 CRD Pump in Service, A B . (

2.14 Off normal status of any trains / portions of a safety systems:

Details 2.14.1 RPS 2.14.2 ECCS 2.14.3 SBGTS

' 2.14.4 Emergency Buses /

(Diesels) 2.14.5 DC Buses 2.15 Testing /Surveillances in Progress Status / Step Test Number

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21.000.03 l Attachment 1 l Page 3 of 10 1 POST-SCRAM DATA AND EVALUATION _(Continued)

)

I 3.0 Post-Scram Data _ YES NO .

31 Did all operable control rods fully insert?

3 List control rod number and notch for all operabia 3.1.1 control rods not fully inserted.

_ , Notch _

_ , Notch _

Rod __

Rod _

_ , Notch __

Rod _ _ , Notch _

Rod _ , Notch

_ , Notch _

Rod __ _

Rod _ _ , Notch Rod _ , Notch _

Rod 3.2 SRMs fully inserted YES _ NO _ .

3.3 IRMs fully inserted YES _ NO _ .

3.4 SRM Count Rate and

  • Time:

__ CPS, __

' 3.4.1 SRM A _ _ CPS, _ __

3.4.2 SRM B___

_ CPS, _ _

3.4.3 SRM C _

. _ CPS, __

3.4.4 SRM D YES NO .

3.5 Did any SRVs open?

d 3.5 1 List Safety Relief Valve letter, opening mo if known. PSIG Valve _, Mode _, lif t _ PSIG, Reseat _ PSIGIG, Reseat _ PSIG Valve _

_ _, Mode _, lif t _ PS G Valve

_, Mode _, lif t _ PSI , Reseat _ PSIG Valve _, Mode _, lif t _ PSIG, Reseat _ PSIG Valve Valve

_, Mode _, lif t _, Mode _, lif t _ PSIG, Reseat _ PSIG Valve _, Mode _, lif t _ PSIG, Reseat _

  • Include date if different from scram date.

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050285

21.000.03

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Attechnent 1 Page 4 of 10

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l POST-SCRAM DATA AND EVALUATION (Continued) t 3.5.2 List SRVs which cycled and number of cycles, if known.

t

' 3.6 Did any isolations occur? YES NO .

3.6.1 List any isolations which occurred by group number.

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5 3.7 Describe, if any, the actuation of any Safety Systems and the 4 reason for their actuation.

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  • *Use additional attached description, if necessary.

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- :. _ a 21.000.03 Attcchment 1 Page 5 of 10

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POST-SCRAM DATA AND EVALUATION (Continued) 3.8 Did any process radiation monitors indicate increases in reading?

YES NO .

If YES, list parameter and attach recording chart. -

3.9 The following hard copy data is attached:

NOTE: Where data is not device recorded, a logged record of observation may be used.

(check) 3.9.1 Sequence recorder printout.

3.9.2 Process computer rod position printout.

3.9.3 Copy of the applicable pages of the NSO log.

3.9.4 Copy of the applicable pages of the NSS log.

. ( 3.9.5 APRM - A, B, C, D, E, F.

3.9.6 Reactor vessel water level.

3.9.7 Recirculation pump section temperature.

3.9.8 Core flow.

3.9.9 Reactor vessel pressure.

3.9.10 Main steam flow.

! 3.9.11 MTG control valve position.

3.9.12 Drywell pressure.

3.9.13 Torus water level.

3.9.14 Torus water temperature.

3.9.15 LPCI, CS, HPCI, RCIC flow.

3.9.16 Condenser vacuum.

l 3.9.17 Vessel metal temperature.

3.9.18 Reactor coolant chemistry ' sample results.

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21.000.03 Attachment 1 Page 6 of 10

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POST-SCRAM DATA AND EVALUATION _(Continued) 4.0 Post-Scram Evaluation 4.1 Chronological Series of Events _ B

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I 4.2 Probable Cause of Trip 1

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J 21.000.03 Attachment 1 i Page 7 of 10

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' POST-SCRAM DATA AND EVALUATION (Continued) ll g.

4.3 Unexpected Aspect of Transient Behavior (If event compared with previous similar transient, note the transient with*which com- '

<li

- p..;l pared.)

l Compared With PSAR transient page number Previous trip on /

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i 4.4 Identification of Systems with Inadequate Performance System / Component Description of Probles

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Signature Date Time ,

7 NSS ,

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Signature Date Time STA 1

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21.000.03

, Attachment 1

(( Page G of 10 POST-SCRAM DATA AND EVALUATION (Continued) 5.0 Preliminary Safety Assessment ,

5.1 Transient Data for Pertinent Plant Parameters -

! '.

  • Maximum Minimum

- 5.1.1 RCS pressure as measured Loop A B Loop A B in steam done.

5.1.2 Reactor vessel water level. in. in.

5.1.3 Reactor coolant flow. Loop A B Loop A B 5.1.4 Reactor core thermal power.

5.2 Preliminary Safety Assessment 5.2.1 RPV pressure remained above 825 psig. YES NO 5.2.2 Reactor isolation occurred. YES NO k

5.2.3 RCS pressure increased to safety / relief valve operating

< pressure. YES NO 5.2.4 RCS temperature decrease less than 100* F/hr. YES NO 5.2.5 HPCI/RCIC initiated. YES NO 5.2.6 ADS timer initiated. YES NO 5.2.7 Primary containment. press temp (ave) 5.2.8 Torus water. level temp (ave) 5.3 Scram Class Classify scram as I, II or III according to 6.5 in this procedure.

The scram on at  : is a Class .

Date Time I, II, III 050285 B

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21.000.03 Attachment 1

  • [ Page 9 of 10 POST-SCRAM DATA AND EVALUATION (Continued)

Signature indicates agreement with class. ,

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NSS Date Time

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STA Date Time

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OE/ Delegate Date Time

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TECH. ENG./ Delegate Date Time l Notification

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Superintendent - Nuclear Production notified of event classification.

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Person notified Date Time 6.0 Permission to Start-up 6.1 Class I, II Events ,

6.1.1 Superintendent - nuclear production notified and permission granted to start-up the reactor.

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Nuclear Shift Supervisor Date Time

/

STA Date Time

/

OE/ Delegate Date Time COMMENTS k

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Attachment 1

,( Page 10 of 10 POST-SCRAM DATA AND EVALUATION (Continued) 6.2 Class III Event ,

6.2.1 OSRO review of event on , meeting number 6.2.2 Permission is granted to start-up the reactor.

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OSRO Chairman Date Time i

Supt. -Nuclear Production Date Time 6.2.3 COMMENTS i

s 7.0 OE Review

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  • OE/ Delegate Date Time l

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.. p 21.000.03 Attachment 2

    • Page 1 of 1 POST-SCRAM INVESTIGATION STATEMENT SHEET

. 1 Name .

Time

- It

1. Plant conditions prior to the reactor scram (for maintenance and IEC personnel. This will include the status of maintenance or testing.)
2. First indication that a problem existed
3. Individual action as a result of the indication
4. Subsequent indications and plant response including manual actions
5. Noted equipment malfunctions or inadequacies Procedure defficiencies identified d; ring the situation fh 6.
7. Additional comments Signature Time - Date if additional space is required to answer the above questions, use blank paper and number the answers.

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