ML20138R642

Requests Addl Info within 30 Days Re Response to Generic Ltr 83-28,Item 1.2.Parameters Necessary to Perform post-trip Review & Info Re Time History Equipment Incomplete.Draft Technical Evaluation Rept,Based on Initial Response Encl

ML20138R642
Person / Time
Site:	Callaway
Issue date:	11/07/1985
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Schnell D UNION ELECTRIC CO.
References
GL-83-28, NUDOCS 8511180712
Download: ML20138R642 (18)

Text

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Docket No.: 50-483 NOV 07 385 Mr. D. F. Schnell Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, Missouri S3166

Subject:

Request for Additional Information Regarding Generic Letter 83-28 Item 1.2 for Callaway, Unit 1 The NRC staff is continuing its review of Union Electric Company's response to Generic Letter 83-28. The enclosed Draft Technical Evaluation Report (Review of Licensee and Applicant Responses to NRC Generic Letter 83-28, Item 1.2) has been prepared for Callaway with regard to item 1.2 of Generic Letter 83-28.

Based upon our review of your submittals we have concluded that:

(1) All of the parameters considered necessary by the staff to perform an adequate post-trip review have not been identified as being recorded; (2) The information provided in your submittal does not indicate that the tirre history equipment used will meet the intent of the staff's per-formance criteria.

Please provide additional information that establishes either, that the above items meet the staff's guidelines or, that your post-trip data and information capabilities are sufficient to accurately reconstruct the accident sequence presented in Chapter 15 of your FSAR.

To permit us to continue our review, please provide the requested information within 30 days of your receipt of this letter.

Sincerely, Odc n. t fcJ By:

Paul W. O'Connor

,.g;/B.J.Youngblood, Chief s Licensing Branch No. 1 Division of Licensing

Enclosure:

As stated COfSTRIBUTION: Docket Fil d P0'Connor MRushbrook cc: See next page NRCPDR-~ OELD TA?exion LPDR ACRS (16) BGrimes .

NSIC Edordan JPartlow PRC System LBW1 R/F LB#1:0 LB#1:DL LB#1:DL M TAlexionidah P0'Connor BJYoungbTood 11/ 7 /85 11/q /85 4)11/ 7 /85 0511100712 051107 PDR ADOCK 05000403 p PDR

Mr. D. F. Schnell Callaway Plant ~

NOV 07 IN5 Union Electric Company Unit No. 1 cc:

Mr. Nicholas A. Petrick Mayor Howard Steffen* .

Executive Director - SNUPPS Chamois, Missouri 65024 5 Choke Cherry Road -

Rockville, Maryland 20850 Professor William H. Miller i

Missouri Kansas Section American Gerald Charnoff, Esq. Nuclear Society Thomas A. Baxter, Esq. Department of Nuclear Engineering Shaw, Pittman, Potts & Trowbridge 1026 Engineering Building i 1800 M Street, N. W. University of Missouri Washington, D. C. 20036 ,

Columbia, Missouri 65211 i

~ Mr. J. E. Birk Mr. Robert G. Wright Assistant to the General Counsel Assoc. Judge, Eastern District Union Electric Company County Court, Callaway County, Post Office Box 149 Missouri

- St. Louis, Missouri 63166 Route #1

_] Fulton, Missouri 65251

, Lewis C. Green Esq. ,

U. S. Nuclear Regulatory Comission Green Hennings & Henry Resident Inspectors Office Attorney for Joint Intervenors RR#1 314 N. Broadway, Suite 1830 Steedman, Missouri 65077 St. Louis, Missouri 63102 Mr. Donald W. Capone, Manager Mr. Earl Brown Nuclear Engineering School District Superintendent Union Electric Company Post Office Box 9 -

Post Office Box 149 Kingdom City, Missourt 65262

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St. Louis, Missouri 63166 '

Mr. Harold Lottman

• - . A.-Scott Cauger, Esq. Presiding Judge, Dasconade County Assistant General Counsel for the Route 1 Missouri Public Service Comm. Owensv111e, Missouri 65066 Post Office Box 360 Jefferson City, Missourt 65101 Mr. John G. Reed Route #1 Ms. Marjorie Reilly Kingdom City, Missouri 65262 Energy Chairman of the League of Women Voters of Univ. City, M0 Mr. Dan I. Bolef, President 7065 Pershing Avenue Kay Drey, Representative University City, Missouri 63130 Board of Directors Coalition for the Environment Mr. Donald Bollinger, Member St. Louis Region .~

Missourians for Safe Energy 6267 Delmar Boulevard 6267 Delmar Boulevard University City, Missouri 63130 University City, Missouri 63130 .

Callaway Plant NOV 0 7 MM5 Unit No. 1 cc:

Regional Administrator .

U. S. NRC, Region III -

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799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Ronald A. Kucera, Deputy Director Department of Natural Resources P. O. Box 176 Jefferson City, Missouri 65102 Mr. Glenn L. Koester

. Vice President - Nuclear Kansas Gas and Electric Company

__ 201 North Market Street Post Office Box 208

'- Wichita, Kansas 67201

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Eric A. Eisen, Esq.

Birch, Norton, Bittner and Moore .

Suite 1200 1155 Connecticut Avenue, N. W.

Washington, D. C. 20036

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. ENCLOSURE

- o SAIC-85/1523-2 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 CALLAWAY PLANT, UNIT 1 (50-483)

[ Technical Evaluation Report Prepared by Science Applications International Corporation ,

1710 Goodridge Drive McLean, Virginia 22102 Prepared for U.S. Nuclear Regulatory Commission

_2 -- Washington, D.C. 20555 -

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. Contract No. NRC-03-82-096

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FOREWORD This report contains the technical evaluation of the Callaway Plant, Unit I 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 3 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 characteris' tics of the sequence of events

_ recorders,

_ 3. The performance characteristics of the time history recorders,

". 4. The data output format, and

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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.

l The report describes the specific methods used to 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 review criteria are not i_ presented. Instead, the evaluation presents a categorization of the

! responses according to which categories of reveiw criteria are satisfied and

" ; which are not. The evaluations are based on specific criteria (Section 2) derived from the requirements as stated in the generic letter.

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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 . . . . . . . . . . . . . . . . . . . . . . . . . . 10

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INTRODUCTION .

SAIC has reviewed the utility's response to Generic Letter 83-28, item 1.2 " Post-Trip Review: Data and Informatier. Capability." The response (see references) contained sufficient information to determine that the data and information capabilities at this plant are acceptable in the following areas.

e The sequence-of-events recorder (s) performance charac-

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teristics.

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e The output format of the recorded data.

e 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

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information to allow determination of the adequacy of the data and

• information capabilities in the following areas.

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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 at Unit.1.of the Salem Nuclear Power Plant failed to open upon an automatic re' actor 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 I

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investigation was performed to detaymine whether the reactor was tripped automatically as expected or manually. The utilities' written procedures required only that the cause of the trip be deterrained and identified the i responsible personnel that could authorize a restart if the cause of the .  !

j trip is known. Following the second trip which charly indicated the i _

problem with the trip breakers, the question was faised en whether the i

circuit breakers had functioned properly during the earlier incident. The most useful source of information in this casa, 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

'4 1 after the incident. Thus, no judgment on the proper functioning of the trip

(( . system durir.g the earlier incident could be made.

io'11owing 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 t

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 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 andJsent to all licensees of operating reactors, applicants for operating lidense, and '

construction permit holders. The required actions in this gener'ic letter consist of four categories. These are: (1) Post-Trip Review. (2)7 Equipment  !

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Classification and Vender Interface, (3) Post Maintenance hesting, and (4)

Reactor Trip System Reliability Improvements.

The first required action of the generic letter, Post-Trip keview, is the subject of this TER and consists 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. 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 m information sources to understand the cause(s) and progression of a reactor

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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 thet a decision on the acceptability of a reactor restart can be made.

_ The following are the review criteria developed for the requirements of .

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Generic Letter 83-28, action item 1.2:

n. _ 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

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trip review. Each plant variabic which is necessary to deter:-dne the caust(s) and progression of the event (s) following a plant trip should be monitore.d 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 for analog (time history) vr.riables].  !

Each device used to record an analog or digital plant variable ,should be describediin sufficient detail so that a determination can be gade as to whether t'je.following performance characteristics are met: .

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o 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 asce'r-tained, and that a determination can be made as to .whether the time response is within acceptable limits based on FSAR (hapter 15 Accident Analyses. The recommended guideline for the SOE time discrimination is approximately 100 msec. If current SOE recorders do not have this time discrimination capability the licensee or applicant should show that the current time discrimi-nation capability is sufficient for an adequate reconstruction of the course of the reactor trip.- As a minimum this should include

_ the ability to adequately reconstruct the accident scenarios pre-sented in Chapter 15 of the plant FSAR.

N 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

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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

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current time history capcbility is sufficient to accurately 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 recoraer 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 re,tained in either hardcopy (computer printout, strip chart output ( etc.) or in an accessible memory (magnetic disc or tape). This irrformation should be presented in a readable and meaningful format, taking 4

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 f r o m a r e l i a b 1'e _a n'd n o n -

interruptible power source. The power source used need not be safety related.

The sequence of events and time history recording equipment should monitor sufficient digital and analog parameters, respectively, to assure 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 trio 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' 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 .

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establish that the plant remained within the design envelope for the appro-

_'=e - priate accident conditions; such as those analyzed in Chapter 15 of the A __ ; - plant Safety Analysis Report.

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. Information gathered dwing 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 pl a nt.- --

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l Table 1.2-1. PWR Parameter List

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SOE Time History -

Parameter / Signal Recorder Recorder ,

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x Reactor Trip (1) x Safety Injection x Containment Isolation (1) x Turbine Trip x Control Rod Position (1) x x Neutron Flux, Power x x Containment Pressure (2) Containment Radiation x Containment Sump Level

". (1) x x Primary System Pressure (1) x x Primary System Temperature (1) x Presturizer 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

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(1) x x Steam Flow Auxiliary Feedwater System; Flow.

(3)

Pump /Value Status

.- x AC and DC System Status (Bus Voltage) x Diesel Generator Status (Start /Stop, On/Off) x PORV Position (1): Trip parameters --

(2): ParametermaybemonitoredbyeitheranSOEortimehistor'y(ecorder.

(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 SOE Time History , ,

Recorder Recorder Parameter / Signal -

x Reactor Trip { ,

x Safety Injection x Containment Isolation x Turbine Trip x Control Rod Position x (1) x Neutron Flux, Power x (1) Main Steam Radiation

. (2) Containment (Dry Well) Radiation

~ x (1) x Drywell 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

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x Feedwater Flow x Steam Flow ,

(3) Recirculation; Flow. Pump Status

. x (1) Scram Discharge Level g, x (1) ,

Condenser Vacuum

x AC and DC System Status (Bus Voltage)

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(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.

(3.): Acceptable recorder options are: (a) system flow recorded on an SOE recorder, (b) system flow recorded on a time history re& order, or (c) equipment status recorded on an SOE recorder. ,

(4): Includes recording of parameters for all applicable systemi' 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 of .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 iriformation 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 tnis report.

The review criteria require thht 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 a,re 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

_1 _ should be output in a format that allows for ease of identification and use m . 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 criterion is met.

The data and information used during a post-trip review should be retained as part of the plant files. This information could prove useful during future post-trip reviews. Therefore, one criterion is that infor-mation used during a post-trip review be maintained in an 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:

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.

3. The sequence of events recorders meet the minimum performance

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characteristics.

n 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 .

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the minimum performance characteristics.

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r _ __.; .It is possible that the current data and information capabilities at this nuclear power plant are adequate to meet the intent of these review

_ criteria, but were not completely described. Under these circumstances, the 1

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licensee should provide an updated, more complete, description to show in more detail the data and information capabilities at this nuclear power l plant. If the information provided accurately represents all current data l

and information capabilties, then the licensee should either show that the data and information capabilities meet the intent of the criteria in part 2 of this report, 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'const'ruction permits regarding Required Actions Based on Generic Implications of Salem ATWS Events." July 8, 1983.

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

Letter from D.F. Schnell, Union Electric Company, to H.R. Denton, NRC, dated November 18, 1983, Accession Number 8311280188 in response to Generic Letter 83-J8, with attachment.

Attachment untitled.

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Letter from D.F. Schnell, Union Electric Company, to H.R. Denton, NRC, dated March 12, 1984, Accession Number 8403160323 providing additional

_. response material to Generic Letter 83-28.

Letter from D.F. Schnell, Union Electric Company, to H.R. Denton, NRC, dated May 21, 1984, Accession Number 8405300057 providing additional -

information relative to implementation schedule associated with the provisions of Generic Letter 83-28, with attachment.

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S Ut*v*cwraMir 60 oc.une u2- R>< T%LewH l-Callaway 1 , ,

1. Parameters recorded: Unsatisfactory See attached table for discrepancies.

2. SOE recorders performance characteristics: Satisfactory Westinghouse PRODAC 2500: monitors NSSS paraiaeters with a time dis-crimination of 16.7 ms., powered from a non-interruptible power source Honeywell TDC-4500: monitors B0P parameters with a time discrimination of Ims, powered from a non-interruptible power source

-~_ 3. Time history recorders performance characteristics: Unsatisfactory Westinghouse PRODAC computer which monitors NSSS analog parameters -

scans these variables at 10 sec intervals minimum, with a non-interruptible power source, the longest '.ime duration is 2 min

__ before and 3 min after the trip, with a shorter duration of 10 sec before and 10 sec after the trip (for Group 2 parameters)

Honeywell TDC-4500, monitoring BOP parameters scans variables at 5 sec

_ intervals, powered by a non-interruptible source. Time history .

. duration is from 5 min before to 10 min after trip

_- 4. Data output format: Satisfactory

~ SOE data: time, parameter identifier, and change of state are omong output Analog data: time, parameter ID, and parameter values are among output

5. Data retention capability: Satisfactory Reactor Trip Report and all pertinent data will be maintained as a QA record for the life of the plant.

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Desirable PWR Parameters for Post-Trip Re' view (circled parameters are not recorded)

SOE Time History .-

Recorder Recorder Parameter / Signal [.

x Reactor Trip --

(1) x Safety Injection

@ Containment Isolation (1) x Turbine Trip

@ Control Rod Position (1) x x Neutron Flux, Power x x Containment Pressure (2) Containment Radiation

_ x Containment Sump Level (1) x x Primary System Pressure

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(1)'x x Primary System Temperature (1) x Pressurizer Level (1) x Reactor Coolant Pump Status -

(1)@ @ Primary System Flow

. ._ (3) Safety Inj.; Flow. Pump / Valve Status x MSIV Position

@ x Steam Generator Pressure

_ (1) x x Steam Generator Level -

(1) x x Feedwater Flow (1) x x Steam Flow A _; -

(3) Auxiliary Feedwater System; Flow.

Pump /Value Status

. x AC and DC System Status (Bus Voltage) x Diesel Generator Status (Start /Stop, On/Off)

@ PORV 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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