ML20134P924

Responds to NRC 850521 Request for Addl Info Re post-trip Review (Generic Ltr 83-28).Systematic Assessment Program for Assessing Unscheduled Reactor Trips Resulted from Revs to Operating Procedure OP-1

ML20134P924
Person / Time
Site:	Fort Calhoun
Issue date:	08/30/1985
From:	Andrews R OMAHA PUBLIC POWER DISTRICT
To:	Butcher E Office of Nuclear Reactor Regulation
References
GL-83-28, LIC-85-385, NUDOCS 8509090098
Download: ML20134P924 (3)

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Omaha Pubilt Power District 1623 Harney Omaha. Nebraska 68102 402/536 4000 August 30, 1985 L IC-85-385 Mr. Edward J. Butcher, Acting Chief Operating Reactors Branch #3 Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555

References:

(1) Docket No. 50-285 (2) HRC Generic Letter 83-28 dated July 8,1983 (3) Letter NRC (E. G. Tourigny) to OPPD (R. L. Andrews) dated May 21, 1985 (4) Letter OPPD (R. L. Andrews) to NRC (E. J. Butcher) dated June 27,1985 (LIC-85-268)

Dear Mr. Butcher:

Request for Additional Infonnation on Iten 1.1 Generic Letter 83-28 The Omaha Public Power District (OPPD) received Reference (3) which requested additional infomation concerning post-trip review. Accordingly, please find attached OPPD's response to the Reference (3) concerns.

Sincerely, d!Na M R. L. Andrews Division Manager Nuclear Production RLA/DJM/rh Attachment cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hampshire Avenue, N.W.

Washington, DC 20036 Mr. E. G. Tourigny, NRC Project Manager Mr. L. A. Yandell, NRC Senior Resident Inspector 8509090098 850 PDR ADOCK O 0

PM 5 ( p$bl'I P J 45 SQ4 Employmen dh qu ! Opponunny

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NRC Request and Recommendation A. With regard to the criteria for detennining the acceptability of restart for any unscheduled reactor trip, the licensee indicated a post-trip re-view is conducted to identify the cause of the trip and the subsequent corrective action taken prior to the plant restart. We find that this action taken by the licensee is not sufficient to ensure a safe plant operation. We recommend that prior to the authorization for restart, an analysis should be conducted to verify that systens which are important to reactor safety have performed as required.

District Response A step has been added to Fort Calhoun Station Operating Procedure OP-1 to re-quire (for startup following an unscheduled reactor trip) Shif t Technical Advisor and Shift Supervisor signoffs verifying that the major safety systens which are important to reactor safety have functioned as required.

NRC Request and Recommendation B. The responsibilities and authorities of the personnel who will perfonn the review and analysis have not been clearly defined. We recommend that the post-trip review team include a member of plant management at the Shift Supervisor level or above who holds or has held an SR0 license on the plant (the Shift Supervisor who was on shift at the time of the event would be acceptable) and who has the responsibility and authority to ob-tain all necessary personnel and data to ensure a thorough and conplete post-trip review. In addition, the post-trip review team should include an STA or an Engineer who has had special transient analysis training.

These two people should have a joint responsibility to concur on a deci-sion to restart the plant, and each should have the unilateral authority to prevent a restart.

District Response Revisions have been made to Fort Calhoun Station Operating Procedure OP-1. The trip recovery procedure portion of OP-1 has been revised to require joint sign-off by both an STA and the Shift Supervisor after an unscheduled reactor trip.

Approval to take the reactor critical will not be given until the Plant Review Committee concurs that appropriate actions have been taken, and authorizes re-start.

NRC Request and Recommendation C. The lic?nsee has not addressed the methods and criteria for comparing the event information with known or expected plant behavior. We recommend that the pertinent data obtained during the post-trip review be compared to the applicable data provided in the FSAR to verify pecper operation of the systems or equipment. Where possible, comparisons with previous sim-ilar events should be made.

2 District Response A step has been added to Fort Calhoun Station Operating Procedure OP-1 requir-ing (for startup following an unscheduled reactor trip) Shif t Technical Advisor and Shift Supervisor signoff verifying that pertinent data from the post-trip review have been compared to applicable events in the USAR and systems and equipment have been verified to have operated properly.

NRC Request and Recommendation D. The licensee has not addressed the criteria for detennining the need for independent assessment of an event. We recommend that if any of the re-view guidelines (as stated in Section II.A of this SER) are not met, an independent assessment of the event should be performed by the PORC or a group with similar authority and experience.

District's Response A step has been added to Fort Calhoun Station Operating Procedure OP-1. This step is part of the Trip Recovery Procedure to be performed prior to restart following an unscheduled reactor trip. Both the STA and Shift Supervisor nw sign off verifying that the post-trip review has not resulted in the discovery of a potential safety concern.

Additionally, both the STA and Shift Supervisor must sign off verifying that the root cause has been detennined and corrected. Systems important to reactor safety are verified as having operated as required. Independent assessment is assured as the Plant Review Committee must review OP-1, concur that appropriate actions have been taken, and authorize restart before the reactor can be taken critical .

NRC Request and Recomendation E. With regard to a systematic safety assessment program to assess unsched-uled reactor trips, the licensee referred to plant operating procedure (OP-1), plant operating orders (0-2 and 0-5), and report fonn (FC-96).

We have reviewed these plant operating procedures, orders and report fonns, and have not been able to conclude that the licensee has in place a systematic safety assessment program to assess unscheduled reactor trips. We recommend that the licensee develop a systematic safety assess-ment program in accordance with the guidelines as described in the above Section II.E to handle unscheduled reactor trips.

District's Response A systenatic assessment program for assessing unscheduled reactor trips has resulted from the above described revisions to Fort Calhoun Station Operating Procedure OP-1.

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