ML20137L740

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SER Supporting Util 840330 Response to Generic Ltr 83-28, Items 1.1,3.1.3 & 3.2.3 Re post-trip Review (Program Description Procedure) & post-maint Testing
ML20137L740
Person / Time
Site: Hope Creek PSEG icon.png
Issue date: 01/22/1986
From:
NRC
To:
Shared Package
ML20136G869 List:
References
GL-83-28, NUDOCS 8601280075
Download: ML20137L740 (8)
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Enclosure 1 SAFETY EVALUATION REPORT FOR GENERIC I.ETTER 83-28, ITEM 1.1 - POST-TRIP REVIEW (PROGRAM DESCRIPTION AND PROCEDURE)

HOPE CREEK NUCLEAR STATION, UNIT I DOCKET NO. 50-354 I. INTRODUCTION On February 25, 1983, both of the scram circuit breakers at Unit 1 of the Salem Nuclear Power Plant (SNPP) failed to open upon an automatic reactor This incident occurred trip signal from the reactor protection system.

during plant start-up and the reactor was tripped manually by the operator The about 30 seconds _after the initiation of the automatic trip signal.

failure of the circuit breakers has been On detennined to be related to the February 22, 1983, an sticking of the under voltage trip attachment.

automatic trip occurred during start-up of SNPP, Unit 1, as the result of steam generator low-low level. In this case, the reactor was tripped manually On February by the operator almost coincidentally with the automatic trip.

28, 1983, the hRC Executive Director for Operations, directed the staff to The 8 investigate and report on the' generic implications of these occurrences.

results of the staff investigation are reported in NUREG-1000. " Generic As a result Implications of ATWS Events at the Salem Nuclear Power Plant."

of tMs investigation, the Commission requested (by Generic Letter 83-28 dated July 3,1983) all licensees of operating reactors, applicants for an operating license, and holders of construction permits to respond to certain These concerns are categorized into the following four generic concerns.

areas: (1)- Post-Trip Review, (2) Equipment Classification and Vendor Interface,(3) Post-MaintenanceTesting,and(4) Reactor Trip System f

Reliability Improvements. .

The first action item, Post-Trip Review, consists of Action Item 1.1,

" Program Description and Procedure," and Action It ~ 1.2, " Data and Information Capability." This evaluation addresses' Action Item 1.1 only.

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! 8601280075 860122 DR ADOCK 05000354 PDR

II. REVIEW GUIDELINES f

The following review guidelines were developed after initial t evaluatio several utility responses to Item 1.1 of Generic Letter 83-28 and.inc best features of these submittals. Therefore, these review We guidelines effectively represent a " good practices" cpproach to post-trip review have reviewed the applicant's response to-Item 1.1 against these A.

The licensee or applicant should have systematic safety assessmen procedures established that will ensure t:1at the following resta criteria are met before restart is authorized.

  • The post-trip review team has determined the root cause and sequence of events resulting in the plant trip.
  • Hear term corrective actions have been taken to remedy the c the trip.
  • The post-trip review team has performed an analysis and de that the major safety systems responded to the event within specified limits of the primary system parameters.
  • The post-trip review has not resulted in the discovery of a potential safety concern (e.g., the root cause of the event occ with a frequency significantly larger than expected).

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  • If any of the above restart criteria are not met, then an independent assessment of the event is performed by the Plant Operations Review Committee (PORC), or another designated with similar authority and experience.

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The responsibilities and authorities of the personnel who will pe the review and analysis should be well defined.

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  • The post-trip review team leader should be a member of plant l management at the shift supervisor level or above and shou The team leader or should have held an SR0 license on the plant.

should be charged with overall responsibility for directing d the l post-trip review, including data gathering and data assessm he/she should have the necessary authority to obtain all pe and data needed for the post-trip review.

  • A second person on the review team should be an STA or s a relevant engineering degree with special transient analysis training.
  • The team leader and the STA (Engineer) should be A responsible t concur on a decision /recomendation to restart the plant.

nonconcurrence from either of these persons should be suffici i

prevent restart until the trip has been reviewed by the POR equivalent organization..

C.

The licensee or applicant should indicate that the plant h the respons trip event will be evaluated and a determination made as to whe The evaluation should plant response was within acceptable limits.

include:

  • A verification of the proper cperation of plant systems and equipment by comparison of the pertinent data obtained d post-trip review to the applicable data provided in the FSAR
  • An analysis of the sequence of events to verify the proper Where functioning of safety related and other important equipment.

possible, comparisons with previous similar events shou D.

The licensee or applicant should have procedures to ensure d th physical evidence necessary for an independent assessment i

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E.

Each licensee or applicant should provide in its submittal, copies of l the plant procedures which contain the information required in Items A through D. As a minimum, these should include.the following:

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  • The criteria for determining the acceptability of restart
  • The qualifications, responsibilities.and authorities of key

< personnel involved in the post-trip review process

  • The methods and criteria for determining whether the plant 7 variables and system responses were within the limits as described in the FSAR
  • The criteria for determining the need for an independent review.

III. EVALUATION AND CONCLUSION l 30, 1984; December 17, 1984; July 15, 1985; and By letters dated March August 7,1985, the applicant provided infonnation regarding its Post-Trip Review Program and Procedures. By letter dated October 30, 1985, the applicant further provided for our review a draft copy of the Hope Creek l

Station Operating Procedure (OP-AP.ZZ-101.0), " Post Reactor Scram /ECCS Actuation Review and Approval Requirements," which provides guidance for l

post-trip ar.alysis, determination of root cause, and the requirements an We have evaluated the applicant's draft program and criteria for start-up. ,

procedures against the review guidelines developed as described in A brief description of the applicant's response and the staff'sSection II.

evaluation of the response against each of the review guidelines is provided below:

l A. With regard to the criteria for determining the acceptability of restart,.the applicant indicated that prior to the authorization of restart, the Operating Procedure requires: a clear determination of the root cause of the event; a satisfactory evaluation of equipment fe

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l performance; and corrective actions to reduce the probability of event recurrence.

We find that the applicant's criteria for determining the acceptability of restart conform with the guidelines as described in Section II.A and, therefore, are acceptable.

B. The qualifications, responsibilities and authorities of the personnel We who will perform the review and analysis have'been clearly defined.

have reviewed the applicant's chain of command for responsibility for a_ .,

post-trip review and evaluation and find it acceptable.

C.

The licensee has described the methods and criteria for comparing the Based on our event information with known or expected plant behavior.

review, we find them to be acceptable.

D.

With regard to the, criteria for determining the need for independent assessment of an event, the applicant has indicated that if the cause of the event has not been clearly detennined or equipment and/or systems performance is questionable, an independent assessment will be perf In addition, the applicant by the Station Operations Review Connittee.

has established procedures to ensure that all physical evidence We find that necessary for an independent assessment is preserved.

these actions to be taken by the applicant conform to the' guidelines as described in Section II.A and D, and are acceptable.

E. The applicant has provided for our review a draft systematic safety Based on our assessment program to assess unscheduled reactor trips.

review, we find that this program is acceptable.

Based on our review of the above cited operating procedure, we conclude that the applicant's Post-Trip Review Program and Procedures for Hope Creek Nuclear Station, Unit 1, are acceptable, provided that the applicant's commitment as described in the draft of the Hope Creek Station Operating ZZ-101.0) remains unchanged in the final procedure.

Procedure (OP-AP:

Enclosure 2 SAFETY EVALUATION REPORT GENERIC LETTER 83-28, ITEMS 3.1.3 AND 3.2.3 POST-MAINTENANCE TESTING (RTS COMPONENT C ALL OTHER SAFETY-RELATED COMPONENTS)

HOPE CREEK NUCLEAR GENERATING STATION, UNIT 1 DOCKET NO. 50-354 INTRODUCTION AND

SUMMARY

Generic Letter 83-281 describes intermediate term actions to be taken by licensees and applicants to address the generic issues raised by t'he two ATWS events that occurred at Unit 1 of Salem Nuclear Power Plant.

This report is an evaluation of the responses submitted by Public Service Electric and Gas Company, the applicant for the Hope Creek Nuclear Generating Station, Unit 1 for Items 3.1.3 and 3.2.3 of the Generic Letter. The actual documents reviewed as part of this evaluation are listed in the references at the end of this report.

The requirements for these two items are identical with the exception that Item 3.1.3 applies these requirements to the Reactor Trip System components and Item 3.2.3 applies them to all other safety-related components. Because of this similarity, the responses to both items were evaluated'toge'ther.

REQUIREMENT Licensees and applicants shall identify, if applicable, any post-maintenance test requirements in existing Technical Specifications which can be demonstrated to degrade rather than enhance safety. Appropriate changes to these test re-quirements, with supporting justification, shall be submitted for staff )

approval.

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EVALUATION The applicant for the Hope Creek Nuclear Generating Station, Unit I responded to these requirements with submittals dated March 30, 1984 , 2December ~ 17, 19843 ,

and May 21, 19854 . These submittals were reviewed by the NRC staff and our contractor, EG&G Idaho, Inc. The applicant stated in these submittals that there were some 18 post-maintenance testing requirements in Technical Specifications fnr either the reactor trip system or other safety-related components but stated they did not perceive these post-maintenance tests requirements to degrade safety.

CONCLUSION Review of the applicant's submittals was conducted by the NRC staff and EG&G Idaho, Inc. Attached is the Technical Evaluation Report (TER) prepared by EG&G Idaho, Inc. dncumenting their review. We concur with the TER finding that, based on the applicant's statement that no post-maintenance test requirements were found in Technical Specifications that degraded safety, the licensee's responses are acceptable for Items 3.1.3 and 3.2.3 of Generic Letter 83-28 REFERENCES

1. NRC Letter, D. G. Eisenhut to all Licensees of Operating Reactors, Applicants for Operating License, and Holders of Construction Permits,

" Required Actions Based nn Generic Implications of Salem ATWS Events (Generic Letter 83-28)," July 8, 1983.

2. Letter, R. L. Mitti,'Public Service Electric and Gas Co., to A. Schwencer NRC, March 30, 1984 .

. i REFERENCES (CONTINUED)

3. Letter, R. L. Mitt 1, Public Service Electric and Gas Co., to A. Schwencer, 1

NRC, December 17, 1984. .

4. Letter, R. L. Mittl, Public Service Electric and Gas Co., to W. Butler.,

NRC, May 21, 1985.

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