ML20150C564

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Advises That Util post-trip Review Data & Info Capability Acceptable Based on Util 880204 Summary of 860418 Telcon,In Response to Item 1.2 of Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events
ML20150C564
Person / Time
Site: River Bend Entergy icon.png
Issue date: 03/10/1988
From: Paulson W
Office of Nuclear Reactor Regulation
To: Deddens J
GULF STATES UTILITIES CO.
References
GL-83-28, TAC-61030, NUDOCS 8803210094
Download: ML20150C564 (5)


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UNITED STATES

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NUCLEAR REGULATORY COMMISSION i c.<

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March 10,1988 Docket No, 50-458 Mr. James C. Deddens Senior Vice President, (RBNG)

Gulf States Uti7ities P. O. Box 220 St. Francisville, LA 70775 ATTN: Fuclear Licensing l

Dear Mr. Deddens:

SUBJECT:

RIVER BEND STATICN, l' NIT I - GENERIC LETTER 83-28 ITEM 1.2 (POST TRIPS REVIEW:

DATA AND INFORMATION CAPABILITIES) (TAC NO. 61030)

Py letter dated March 1,1985 Gulf Stat

'"ies (GSU) submitted a final response to Item 1.2 of Generic Letter E

'tred Actions Based on Generic Implications of Salen ATWS Event

s consultant, Science

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Apolications International Corporation (b ic a Technical Evaluation Report (enclosed) that identified a number o v

1 items. The FPC staff cencurred with the SAIC Technical Evaluation %

bsequently, on April 18, 1986, the NRC staff and representatives of GSU d)..;ssed the open items vie telecon. By letter dated February 4,1988, GSU submitted a sumary of the April 18,19P6 telecon and also additional supplerental infomation.

In sunnary, +he February 4,1988 letter identified that:

1.

Information and data used during a post-trip review is retained as a pemar.ent plant recoro.

2.

The emergency response infomation system (ERIS) records the neutron flux, drywell pressure, primary system pressure, primary system level, feedwater flow, and steam flow. The safety parameter display system monitors these parameters every one second.

3.

Containment isolation and turbine trip are monitored en ERIS. Control red position is monitored by both the process computer and ERIS. Alam types and scram times (all rods in) are recorded. Containment (drywell) radiation is monitored by the digital radiation renitoring system (DRMS)

- continuous monitorirg and time tagged.

J 4.

The sequence of events and time history recorders are powered through an uninterruptable power source.

8803210094 000310 PDR ADOCK 05000458 P

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j P,ased on the supplemertal informat*:en provided in GSU's February 4,1988 submittal, the staff fir.ds that the Post-Trip Review Data and Informatior.

Capebility is acceptable.

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This completes the staff action for Item 1.2 of Generic Letter C3-78.

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Sincerely.

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ho, heflpv' Walter A. Paulson, Project Mananer 1

Project Directorate - IV Division of Reactor Project: - III, l

'4 IV, Y and Special Pro.iects Enclesure:

As stated l

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Based on the supplemental information provided in GSll's February 4, 1988 submittal, the staff finds that the Post-Trip Review Data and Information i

j Capability is acceptable, j

This completes the staff action for Item 1.2 of Generic Letter 83-28.

j Sincerely, r

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Walter A. Paulson, Project Panager Project Directorate - IV-Division of Peactor Projects - III,

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IV, Y and Special Projecte

Enclosure:

As stated l

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Based on the supplemental irfomation providad in Ge s February 4,1988 submittal, the staff finds that the Post Trip Review Data and Information Capability is acceptable.

This completar. the staff action for iten 1.2 of Generic Letter 83-28.

Sincerely,

\\S Pelter A. Paulson, Project Panager Project Directorate - IV Division of Peactor Projects - III, IV, V and Special Projectr Encicsure:

As stated cc w/ enclosure:

See ner.t page DISTRIBUTION Docket File P:PC PDR Lncal PDR PD4 Readirg DR4A/J. Collins J. Calvo P. Noonan W. Paulson J. Kramer W. Regan OGC-Pockville E. Jordan J. Pertlow ACRS (10)

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Mr. James C. Deddans Gulf States Utilities Company River Bend Nuclear Plant cc:

Troy B. Conner, Jr., Esq.

Mr. J. E. Booker Conner and Petterhahn Manager-River Bend Oversight 1747 Penrsylvania Avenue, NW P. O. Box 2951 Washington, D.C.

20006 Beauront, TX 77704 Mr. William H. Spell, Administrator Director - Nuclear Licensing Nuclear Enargy Divir, ion Gulf States Utilitics Company Office of Envirnrrental Affairs P. O. Box 220 P. O. Box 14690 i

St. Frencisville, LA 70775 Baton Rouge, Louisiare 70298 Richard M. Troy, Jr., Esq.

Assistant Atterrey Genaral in Charge Mr. J. David McNeill, III Str.te of Louisiare Department of Justice Villiam G. Davis, Esq.

i 234 Lcyola Avenue Departnent cf Justice New Orleans, truisiana 70112 Attorney Gereral's Office 7434 Perkins Road Resident Inspecter Baton Rouge, Louisiana 70808 P. O. Box 1051 St. Francisville, Louisiana 70775 H. Anne Plettinger r

4 3456 Villa Pose Drive Gretchen R. Rothschild-Peinike Baton Rouge, Leuisiana 70806 Louisianians for Safa Energy, Inc.

2108 Broadwe," Street 1

New Orlear.9, Louisiana 70118-546:

President of West Feliciana Police Jury i

Regional Administrator, Region IV P. O. Bcx 1921 U.S. Nuclear Regulatory Corrission St. Francisville, Louisiana 70775 Office of Executive Director i

for Operations Mr. Frank J. Uddo i

611 Ryan Plaza Drive Suite 1000 Uddo & Porter L

Arlington, Texas 76011 6305 Elysian Fields !. venue 1

Suite 400 l

Philip G. Harris New Orleans, Louisiana 7012" l

I Cajun Electric Power Coop. Inc.

10719 Airline Highway l

P. O. Box 15540 i

Baton Rouge, LA 70895 e

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ENCLOSUPE

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REV!EW 0F LICENSEE AND APPLICANT RESPONSES TO NRC GENERIC LETTER 83-28 (Required Actions Based on Generic Implications of Salem ATWS Events). Item 1.2 i

' POST-TRIP REY!EW: DATA AND INFORMATION CAPABILITIES" FOR RIVER BEND STATION, UNIT 1 (50 458) i l

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Technical Evaluation Report Prepared by 5:ien:e Applications International Corporation 1

1710 Goodridge Drive M: Lean, Virginia 22102 i

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Prepared for l

i U.S. Nu: lear Regulatory Co"nission Washington, D.C. 20555 4

Contract No. NRC-03-82-095 l

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i TA3LE OF CONTENTS Se: tion Page I

Introduction.........................

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1.

Background..........................

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Review Criteria.......................

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1 3.

Evaluation...................

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Con:1usion..........................

9 Re ftrtnetS..........................

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TOREWDRD 4

This report contains the technical evaluation of the River Bend t

Station.1) nit I response to Generic Letter 83-2B (Required Actions Based on Generit Implications of Salen ATW5 Events). Item 2.2 "Post Trip Review:

Data and Information tapabilities."

For the purposes of this evaluation, the review triteria, presented in part 2 nf this report, were divided into five separate categories. These are:

1.

The perameters,conitored by the sequente of events and the time

- tilstory recorders.

2.

The perfernan:e.tharacteristics.mf the sequence of events Te: orders.

3.

The Terforman:e charatteristics of the time history recorders.

4 The data catput format, and t

.5.

The long-ter., data.etention capability for post-trip review

{

taterial.

All available responses to Generic Letter B3-28 wer* evaluated. The plant for which this.eport is applicatie was.found to tave ade:uately responded to, and met, tategories 2 and 4 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 sore than1me nuclest power plant spec 1f1es regerding how enth plant set (or failed to 1eett) the review criterte are not r esented.

Instead, the evaluation presents a categoritation of the responses according to which categories of review criteria are satisfied and which are mot.

The evaluations are based on specific criteria (Section 2) derived frcm the far.uirements as stated in the generic letter.

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INTRODUCTION SAIC has reviewed the utility's response to Generic Letter 83 23, item 1.2 "Post Trip Review:

Data and Information Capability." The response (see references) contained sufficient information to determine that the data and infernation capabilities at these plants are acceptable in the following areas.

e The segaence.of. events recorder (s) performance charac.

teristics.

e The output format of the recorded data.

However, the data and information capabilities, as described in the submittal, either fall to meet the review criteria or provide insufficient information to allow determination of the adequacy of the data and infor ation capabilities in the following areas, The parameters monitored by both the sequence of. events e

and time history recorders, The time history recorder (s) performance characteris.

e tics.

The long term data retention, record keeping, capa.

e bility.

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Backgrour.d l

l 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 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, 1933; 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 r t have a requirement for the systematic evaluation of the reactor trip, no inves tigation was performed to determine whether the reactor was tripped autcmatically as expected or manually.

The utilities' written procedures re;uired 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 tie 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 af ter the incident. Thus, no judgmer.t on the proper functioning of the trip system during the earlier incident could be made.

Following these incidents; on February 28, 1983; the NRC Executive Director for Operations (E00), directed the staff to investigate and ranort

,g on the generic implications of these occurrences at Unit 1 of the Su sem Nuclear Power Plant. The results of the sta f f's inquiry into the generic implications of the Salem Unit incidents is reported in NUREG-1000. "Generic Implications of ATWS Events at tha Salem Nuclear Power Plant." Based on thc 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, acolicants for operating license, and construction permit holders. The reqwired actions in this generic letter consist of four categories.

These are:

(1) Post-Trip Review, (2) Equipment 2

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

Reactor Trip System Reliability Improvements.

i The first required action of the generic letter, Post-Trip Review, 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 i

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 83-23 is to ensure that the licensee has adequate procedures and data and information sources to understand the cause(s) and progression of a reactor trip. This understanding should go beyond a simple identification of the course of the event.

It should include the capability tc determine the root cause of the reactor trip and to determine whether safety limits have been i

exceeded and if so to what extent. Suf ficient 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 Jeveloped for the requirements of Generic letter 83-28. action item 1.2:

The equipment that providas the digital sequence of events (50E) record and the analog time history records of an unscheduled shutdowq should pro-

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vide a reliable source of the necessary information to te used in the post trip review.

Each plant variable which is necessary to determine the cause(s) and progresstori of the event (s) following a plant trip should be monitored 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) variables).

Each device used to record an analog or digital plant variable should be described in suff.icient detail so that a determination can be made as to whether the following performance characteristics are met:

3

Each sequence of-events recorder should be capable of detecting e

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 time response is within acceptable limits based o-FSAR Chapter 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 suf ficient 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.

Each analog time history data recorder should have a sample ir.ter-e 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 sequence; evaluated in the accident analysis of the j

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 accurately recon-struct the accident sequences presented in Chapter 15 of the FSAR.

To support the post trip analysis of the cause of the trip and the e

proper functioning of involved safety related equipment, each analog time history data recorder should be capable of updating and retaining information from approximately five minute' prior to the trip until at least ten minutes after the trip.

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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 amory (magnetic disc or tape). This information should be presented in a readable and meaningful format, taking 4

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into consideration good human factors practices (such as those cutlined in NUREG-0700).

All equipment used to record sequence of events and time history o

informa tion should be powered from a reliable and n o r. -

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 suf ficient 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 assn-lated with reactor trips, safety injections and other safety-related sys'. ems as well as output parameters suf ficient to record the proper functi:r,ing of these systems should be recorded for use in the post trip review.

The parameters deemed necessary, as a minimum, to perform a p0st 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 establish that the plant remained 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.

Oata from all unscheduled shutdowns pt ovides 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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t Table 1.2 1.

PWR Parameter List SOE Time History Recorder Recorder Parameter / Signal x

Reactor Trip (1) x Safety injtetton x

Containment Isolation (1) x Turbine Trip x

Control Rod Position (1) x x

Neutron Flux, Power

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x x

Containment Pressure (2)

Containment Radiation Containment Sump Level x

(1) x Primary System Pressure x

(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

MS!V 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 AC and DC System Status (Bus Voltage) x Diesel Generator Status (Start /Stop, x

On/Off) x PORY Position (1): Trip parameters (2): Parameter may be monitored by either an SOE or time.51 story recorder.

(3): Acceptable recorder options are: (a) system flew recorded ca 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 Containment Isolation v

x Turbine Trip z

Centrol Rod Position x (1) x Meutron Flux. Power x (1)

Main Steam Radiation (2)

Containment (DryWell) 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 x

Feedwater Flow x

Steam Flow (3)

Recirculation; Flow. Pump Status x (1)

Scram Discharge Level x (1)

Condenser Vacuum AC and DC System Status (Bus Voltage) x (3)(4)

Safety injection; Flow Pump / Valve Status Diesel Generator Status (On/Off, x

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 recorder, or (c) equipment status recorded on an SOE recorder.

(4): Includes recording of parameters for all appitcable systems 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 information that can be used to determine the cause of the reactor trip and the plant l

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.

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 racorded, the record-in; equipment will provide an adequate source of information for an ef fec-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 performan:e 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 l

indicates that this criterion is met.

  • A 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. There fore, one criterion is that infor-mation used during a post trip review be maintained in an accessible manner j

for the life of the plant.

The informatios contained within this submittal l

does not indicate that this criterion will be met.

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_ 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 sequence of events recorders meet the minimum performance characteristics.

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The information supplied in response to Generic Letter 83-28 does not indicate that the post-trip review data and infor. nation 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.

Ti e history recorders, as described in the submittal, do not meet the minimum performance characteristics.

3.

The data retention procedures, as described in the submittal, may not ensure that the information recorded for the post trip review is maintained in an accessible manner for the life of the plant.

lt is possible that the current data and information capabilities at this nuclear power plant are adequate to meet the intent of these review j

criteria, but were not completely described. Under these circumstances, the licensee should provide an updated, more complete, description to show in more detail the data and information capabilities at this nuclear power pl a nt.

If the information provided accurately represents all current data and information capabilities, then the licensee should 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.

9

d REFERENCES NRC Generic Letter 83 28.

"Letter to all licensees of operating i

reactors, applicants for operating license, and holders of construction permits regarding Required Actions Based on Generic Implications of Salem ATWS Events." July 8, 1933.

NUREG-1000. Generte Implications of ATWS Events at the Salem Nuclear Poner plant, April 1983.

Letter fror. J,3. Weigand, Gul f States Utilities Company, t o H.R.

Centon, NRC, dated February 4, 1985, Accession Number 8502110105 revising s".hedule for completion of response to item 1.2 of Generic letter 83 28.

Letter from J.E. Booker, Gul f States Utilities Company, to H.R. Denton, NRC, dated March 1,1985, Accession Number 8503050348 submitting final l

response to item 1.2 of Generic Letter 83 28.

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