ML20236Y345

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Safety Evaluation Recommending Licensee Take Necessary Actions to Correct Listed Deficiencies,Per Util 831107 Response to Generic Ltr 83-28,Item 1.1 on post-trip Review. SALP Input Also Encl
ML20236Y345
Person / Time
Site: Pilgrim
Issue date: 04/18/1984
From:
NRC
To:
Shared Package
ML20149B797 List:
References
FOIA-87-644 GL-83-28, NUDOCS 8712110258
Download: ML20236Y345 (6)
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Enclosure 1 i SAFETY EVALUATICN REPORT FOR l GENERIC LEHER 83-28, ITEP l_1 - POST-TRIP REVIEW (PROGRAM DESCRIPTION AND PROCEDURE)

PILGRIM STATION DOCKET NO.: 50 293

!. INTRODUCTION Or February 25, 1983, both oT 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 piant start-up and the rearcor was tripped manually by the operator about 30 seconds af ter the initttion of the automatic trip signal. The failure of the circuit breakers has been detennined 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 gemerated based on steam generator low-low level during plant' start-up. In this case, the reactor was tripped manually by the operator almost coincidentally with the automatic trip. Following these incidents, on Februa ry 28, 1983, the NRC Executive Director for Operations (ED0), directed the staff to investigate and report on the generic implications of these occurrences at Unit 1 of the Salem Nuclear Power Plant. The results of the staff's inquiry into the generic implications of the Salem unit incidents are reported in NUREG-1000. " Generic Implications of ATWS Events at the Salem Nuclear Power Plant." As a result of this investigation, the Consnission (l@C) requested (by Generic Letter 83-28 dated July 8,1983) all Itcensees o' operating reactors, applicants for an operating license, and holders of ccrnstruction pennits to respond to certain generic concerns. These concerns are categorized into four areas: (1) Pest-Trip Review, (2) Eouipnent Classification and Vendor Interface, (3) Post-Maintenance Testing, and (4) Peartnr Trip System Reliability improvements.

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

" Program Description and Drocedure" and Action iterr 1.2. " Data and 87121102503371209 PDR FOIA PDR SORGIB7-644

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fr. formation Cepability." This safety evaluation report (SER) addresses Action Item 1.1 only.

11. REVIEW GUIDELINES The following review guidelines were developed af ter initial evaluation of various utility responses to Item 1.1 of Generic Letter 83-28, and incorporate the best features of these submittals. As such, these review guidelines in effect represent a " good praf.tices" approach to post-trip review. We have reviewed the licensee's response to item 1.1 against these 9uidelines: .

A. The licensee or applicant should have systematic safety assessment procedures established that will ensure that the following restart criteria are met before restart is authorized.

The post-trip review tear 1 has deterinined the root cause and sequence of events resulting in the plant *. rip.

Near term corrective actions have been taken to remedy the cause of ,

the trip.

The post-trip review team has perfomed an analysis and determined that the rejor safety systerns responded to the event within specified limits of the prirery syster' parameters.  ;

i The post-trip review has not resulted in the discovery of e potential safety concern (e.g., the root cause of the event occurs with a frequency significantly larger than exp*cted).

If any of the above restart criteria are net met, then an independent essessment of the ever,t is per'orred by the Plant Operations Review Comittee (POPC), or another designated group with similar authority and experience, 1

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3 B. The responsibilities and authorities of the personnel who will p:rforr th review and analysis should be well defined. j The post-trip review team leader should be a merber of plant management at the shif t supervisor level or above and should hold or should have held an SRO license on the plant. The team leader I should be charged with overall responsibility for directing the '

post-trip review, including data gathering and data assessment and he/she should have the necessary authority to obtain all personnel and date needed for the post-trip review.

A second person on the review team should be an STA or should hold a relevant engineering degree with ipecial transient analysis training.

The team leader and the STA (Engineer) should be responsible to concur on a decision /reconrendation to restart the plant. A nonconcurrence from either of these persons should be sufficient to prevent restart until the trip has been reviewed by the PORC or equivalent organization.

C. The licensee or applicant should indicate that the plant response to the trip event will be evaluated and e determination rude as to whether the plant response was withir acceptable limits. The evaluation should include:

  • A verification of the proper operation cf plant systers and eouipnent by comparison of the pertirent data obtained durirg the post-trip review to the applicable data provided in the ISAR.

An analysis of the sequence of events te verify the proper functioning of sa'ety related red other important equipment. Where possible, comparisons with previcus similar events shoulti te made.

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4 D. The licensee or applicant should have procedures to ensure that all physical evidence necessary for an independent assessment is preserved.

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

The criteria for determining the acceptability of restart The qualifications, responsibilities and authorities of key personnel involved in the post-trip review process

'l The methods and criteria for determining whether the plant variables and system responses were within the limits as described in the FSAR 1

The criteria for determining the need for an independent review. ,

III. EVALUATIOh AND CONCLUSION By letter dated November 7,1983, the licensee of Pilgrim Station provided information regarding its Post-Trip Review Progran and Procedures. We have evaluated the licensee's program and procedures agairst the review guidelines developed as described in Section 11. A brief description of the licensee's 3 respense and the staff's evaluation of the response against each of the review guidelines is provided below:

A. The licensee has established the criteria for de'ernining the acceptability of restart. Based on our review, we find that the licensee's criteria conform to the guidelines as described in the above i Section II. A and, therefore, are acceptable.

B. The Qualifications, respon ibilities and authorities of the perscenel )

who will perfortn the review and analysis have been clearly described.

We have reviewed the licensee's chain of commerd for responsibility for post-trip review and evaluation, and find it acceptable.

C. The licensee has not addressed the methods and criteria for comparirg  ;

the event infortnation with known or expected plant behavior. We

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recorrnend that the pertinert data obtained during the post-trip review be compared to the applicable data provided in the FSAR. Where possible, comparisons with previous similar events should be made.

1 D. The licensee has indicated that if the cause of the tr.p is unkvcwn, an t independent assessment conducted by the Operation Review Cocenittee is required for the event. We find that this action to be taken by *.he , ,

licensee is not sufficient to ensure safe plant operation. We reconsnend that if any of the restart criteria are not met an independent assessment of the event should be perfomed. The licensee has established procedures to ensure that all physical evidence necessary for an independent assessment is preserved.

,E. The licensee has not provided for our review a systematic safety assessment program to assess unscheduled reactor trips. We recoernend that the licensee develop a systematic safety assessment program to handle unscheduled reactor trips.

Acceptable responses to the ebove noted deficiencies are recuired be' ace we r a a. complete our review of the licensee's Post-Trip Review Program and Procedures for Pilgrim Statien. We will review these responses when received ard report our findings in a supplement to this SER.

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Enclosure 2 SALP EVALUATION PILGRIM STC ION DOCKET 10.: 50-293 GENERIC LETTER 83-26 I'Ew 1.1 POST TRIP REVIEW A.

Functionel Areas: Licensing Activities - Generic Letter 83-28 Item 1.1, Post Trip Review

1. Management involvement in assuring qsality Based on our review of the licensee's respense to Generic Letter 83-28 and providing that the licensee will resolve our concerns as described in the SER, the licensee will have an effective systematic assessment procedure to assess unscheduled reactor trips.

1 Rating: Category 2 2.

Approach to resolution of technical issues from a safety standpoint Rating: N/A

3. Responsive to NRC initiatives Based on our review, we find that the '.icensee is responsive to NRC initiatives.

Rating: Category 2 a

4 Staffing Rating: N/A

3. Reporting and analysis of reportable events Rating: N/A
6. Training and qualification effectiveness Rating: N/A 7.

Overall Rating for Licensing ac tivity Functional Areas: Catecory 2 l i

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