ML20244D398

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Review of Licensee & Applicant Responses to NRC Generic Ltr 83-28,(Required Actions Based on Generic Implications of Salem ATWS Events),Item 1.1, `Post-Trip Review:Program Description & Procedure for La Salle County Station..
ML20244D398
Person / Time
Site: Pilgrim, LaSalle, 05000000, Trojan
Issue date: 07/10/1985
From:
SCIENCE APPLICATIONS INTERNATIONAL CORP. (FORMERLY
To:
NRC
Shared Package
ML20235V135 List:
References
CON-NRC-03-82-096, CON-NRC-3-82-96, FOIA-87-644 GL-83-28, SAIC-85-1559, NUDOCS 8507160686
Download: ML20244D398 (11)
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,$N!EW Of LICENSErvAND APPLICANT RESPONSES

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" POST TkiP REVIEWi PR(60 DE$rWif 0k AND PROCEDURE";EORL LA SALLE COUNTY STAliq% UNITN1l A40 7. (50 373, 50-374)

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FOREWORD This report contains the technical evaluation of the licensee and applicant responses to Generic Letter 83-28 (Required Actions ~ Based on Generic Implications of Salem ATWS Events). Item 1.1, " Post Trip Review:

Program Description and. Procedure" for. the following plants:

La Salle County Station, Units 1 and 2 Pilgrim Station Trojan Nuclear Plant For the purposes of this evaluation, the review criteria, presented in-part 2 of this report, were divided into seven separate categories.

These are:

1.

The procedure used to determine the acceptability of the restart, 2.

The responsibilities and authorities of the responsible personnel performing the post-trip review, 3.

The necessary qualifications and training of the responsible personnel, 4.

The source of plant information to conduct the review and analysis of the trip, 5.

The methods and criteria used for comparing the event with expected plant performance, 6.

The criteria for determining the need for independent assessment of the event, 7.

The submitted procedures.

All available responses to Generic Letter 83-28 were evaluated. The plants for which this report is applicable were found to have adequately responded to, and met, categories 3 and 5.

The report describes the specific methods used to determine tk 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 requirements are not presented.

Instead,. the evaluation presents a categorization of the responses according to which categories of requirements 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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I TABLE 0F CONTENTS:

.e Section Page1 Ij Introduction.................:............-..-

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Background..................:.........c. (.i

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. Review Criteria 3:

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E v al u a t i on........................ 3

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01 Re fe rences..................... :. -. :.......

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INTRODUCTION SAIC has reviewed the submittals prepared in response to Generic Letter' 83-28, item 1.1, " Post-Trip Review:

Program Description and Procedure" for-the previously listed. nuclear power pl a nts.

These ' submittal.s - (see.

l references) contained sufficient information to determine that the program; I

description and procedures at these plants are acceptable in the following areas.

e The necessary qualifications and training of the responsible-o personnel.

1 The methods and criteria used for comparing' the event with' expected e

plant performance.

However, the program description and procedures, as described.in the submittal, either fail to meet the review ' criteria or provide (insufficient information to allow determination of the adequacy of t'ie ' data' and 1

l information capabilities in the following areas.

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The procedure used to determine the acceptability of the restart.

The responsibilities and authorities of the responsible ' personnel-e performing the post-trip review..

1 The source of plant information to conduct the review and analysis' I

e of the trip.

o The criteria for determining the need for independent assessment of-l the event.

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'o The submitted procedures.

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===1.

Background===

On February 25, 1984, both of the scram circuit breakers at' Unit 1 of the Sales 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, 1983; at Unit 1 of the Salem Nuclear Power Plant'an automatic trip signal.'

i 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

investigation was performed to determine whether the reactor was tripped-automatically as expected or manually.

The utilities' written procedures required only that the cause of the trip be determined and identified the j

responsible personnel that could authorize a restart if the cause of the l

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 the earlier incident. -The i

most useful source of information in this case, namely the sequence of j

events printout which would have indicated whether the reactor was tripped automatically or manually during the February 22 incident, was not retained j

after the incident. Thus, no judgment on the-proper functioning of the trip system during the earlier incident could t>e made.

1 Following these incidents; on February 28, 1983, the NRC E::ecutive Director for Operations (EDO), directed the staff to investigate and report on the generic implications of _these occurrences at Unit 1 of the Ealem Nuclear Power Plant. The results of the staff's inquiry into the generic 4

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

'I 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, applicants for operating license, and construction permit holders. The required actions in this generic letter consist of four categories.

These are:

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

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

Reactor Trip System Reliability Improvements.-

i The first action ites, 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 "Cata and Information Capability."

In the next section the review l

criteria used to assess the adequacy of the utilities' responses to the requirements of action item 1.1 will be discussed.

2.

Review Criteria The, following are the review criteria developed for the requirements of Generic Letter 83-28, Item 1.1.

Generic Letter 83-28 Item 1.1 Review Criteria i

1.

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

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The post trip review team has ' determined the root cause and s

sequence of events resulting in a plant trip.

i Near term corrective actions have been taken to remedy the cause I

e and sequence of the trip.

l The post trip review team has performed an analysis and determined e

that the primary system parameters and major safety systems have j

responded to the sequence of the event within specified limits.

The post trip review has not resulted in the discovery of a l

e potential safety concern (e.g., the root cause of the event occurs j

with a frequency significantly larger than expected).

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l If any of the above criteria are not met an independent review by the plant Safety Review Committee, Plant Operations deview Committee or an l

equivalent organization must be performed prior to the authorization of restart.

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' The responsibilities land authorities of_ thel personnel? whoL will? perform:

the review and. analysis l should be well defined.NThe? post ' trip. review

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team. shduld' have Lat least one person' with the lfo11ow' ng, respon'sibilik

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~ i ties and authorities related to. thel post trip l review process. -

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Overall: responsibi.11ty; for ' direct 1ng the post trip review / process '

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including data gathering operations ~and data assessment.;

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e The responsibility and: authority:to.obtain all; necessary personnelf and ' equipment. for the post trip; review. -

w At 'least' two people involved in the" post trip revi.ewj processi must' have m

.the responsibility to. concur onLa decision;to restart [the ' plank lEachj,

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of these personnel sh'ould h' ave the unilateral"authoriito; prevent a restart.

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The person with the overal1 authority for" directing'the post, trip:

d review process and with the' authority and. responsibility to obtain tM' l

necessary personnel and equipment ' for' the" post-tripj review Lshould 'at -

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least have the qualifications of a iShif t Supervisor.

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l responsibility to ensure' that an engineering analysis ;of thefanalog and i

digital data is performed can belong to the shift technical advisor (STA).

u The personnel who must concur on' a decision to restart must be i

qualified to hold one of _the following positionsD(However,7 all:

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personnel who must concur on a decision-to restart cannot! hold the same j

position):

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Be, as a minimum, a l'icensed. Shift Supervisor,. '

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.Be an STA or have ~ a relevant engineering ' degrees have an. operating'.

e license and'have special transient a'nalysis training;.

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The licensee or applicant should indicate thatithe" following. data, j

sources will-be available to the post trip review team. -

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e The operating staf f on duty at: the -time of the ' event' mustL be'

available for interviews.with. the post. trip review team..
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An analog time history ~of'the event $hich: includes the parameters 1 e.

needed:to determine!the causeLof.. thel transient.and the plan't.

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response.

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A digital sequenceof events record of.the event which includesI e

the parameters neces'saryl to deteEmine. the. cause ofithe l transient.

and the:plantLresponse, inbludingidjta for evaluating lthe-.per! orm -

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. ance of safety systeres!and: other important. systems.;,

5.

The licensee'er applicant lshould indicste that the' plant responselto.

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1 the trip event-.is evaluated and!a determinationiis made as? tofwhether-f, s

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the plant. response was within acceptable. limits.- The' evaluation.should e include-g m

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The pertinent data obtained. during.Ethe Lpost trip' review Si s?

compared to the applicable-Technical Specifications: to.ver,1fy proper operation of the systems'or. equipment.

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o A reconstruction of the trip event that' canibe used to' determine J

the proper functioning of safety related'and,other importa'nt equipment.

Where possible comparisons with previous similars events should be 'made.

d 6.

The licensee or applicant should indicate that;if any ofIth'e restart-criteria are not met.then an independent' assessment'of the event is-performed by the Plant Safety Review Committee or a. group with similar u,

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authority and experience.

The licensee or? applicant [should h' ave.

M procedures.to ensure.that allE physical ' evidence ~necessary1 for. an independent assewment. are preserved; The information used uin performing the post trip review is 'of. sufficient /importance to(be-s maintained as part of the plant; files for the life of the plant.

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7.

Each licensee or. applicant should provideTin their; submittal' copies o'f

.the plant procedures which contain the information required in11tems;1

'l through 6.

As a minimum' this should. include the following:.

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The criteria for determining the acceptability of frestart.-

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The responsibilities and authorities of key personnel involved.in' the post trip review process..

' The methods and ' criteria for determining 'whetheri the.plantL i

e' variables and system responses were within 'specifled limits.1, o

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

3.

Evaluation i

The program and procedures-.descrip, tion of the-post-trip review submitted was evaluated against the review criteria described above.

Based on our review of various segments of the submittal we have' determined;that:1 The procedure described in. the ' submittal' to.. determine the 'accepta-:

a.

bility of the restart does not meet the intbnt of the criteria described above.

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The submittal does not properly address one or more of the respon-1 sibilities, and authorities of the responsible. personnel ' perform-

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ing the post-trip review.

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The necessary qualifications and training' of the responsible j]

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personnel are satisfactory, d.

The source of plant information to conduct the review and analysis' of the trip is either non-existent or is not adequately described.:

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The methods and criteria used 'for comparing the event with -

expected plant. performances satisfy the requirements of 'the l

criteria.

f.

The submittal does not indicate if there is a criteria for

' determining the need for independent assessment of the eventiend

'j how this is performed.

This segment of~ the' submittal does not satisfy the requirements of the review criteria..

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The procedures submitted'do. not include all the required informa-:

q tion listed in' the review criteria.

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Conclusion l

The submittal does not satisfy the requirements of the review; criteria' f

in the following areas:

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1 1..

The criteria for determining,the acceptability of the restart.'.

2.

Required information aboutithe responsibilities and authorities;of-the responsible personnel performing' the. post-trip' review.

3.

The source of plant information necessary to conduct the review and analysis of the' trip.

4 The criteria for determining the -need. for independent assessment j

of the event.following a' trip.

5.

The minimum required information' that 'must be ' included'in the j

procedures submitted.

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REFERENCES j

i NRC Generic Letter 83-28.

" Letter to all licensees of operatin; reactors, applicants for operating ' license, and holders of construction 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.

LaSalle County Station, Units 1 and 2 1.

Letter from P.L. Barnes, Commonwealth Edison, to H.R. Denton, NRC, dated November 5,1983 Accession Number 8311090218 in response to Generic Letter 83-28 of July 8,1983, with attachment.

2.

Part 4. LaSa'le County Station, Units 1 and 2, Response to Generic Letter 83-28.

3.

Letter from P.L. Barnes Commonwealth Edison, to H.R. Deston, NRC, dated June 1,1984 Accession Number 8406050418 transmitting supple-mental response to Generic Letter No. 83-28 of July 8,1983, with

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attachment.

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4.

Letter from G.L. Alexander, Commonwealth Edison, to H.R.'Denten. NRC, l

dated June 30, 1984, Accession Number 8407060235 in response to Generic Letter 83-28 of July 8,1983.

l Pilgrim Station 1.

Letter from W.D. Harrington, Boston Edison Company, to D.B. Vassallo, i

NRC, dated November 7,1983 Accession Number 8311090331 in response to l

Generic Letter 83-28 of July 8,1983, with attachment.

Trojan Nuclear Plant 1.

Letter from B.C. Withers, Portland General Electric company, to D.G.

Eisenhut, NRC, November 4, 1983. Accession Number 8311080379 in response to Generic Letter 83-28 of July 8,1983, with attachseet.

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