ML20138B550

Submits Addl Info in Response to Generic Ltr 83-28,Item 1.2, Post-Trip Review Data Retention Capability, Per 851023 Request.Systematic Safety Assessment of Unscheduled Reactor Shutdown to Determine Root Causes Will Be Performed

ML20138B550
Person / Time
Site:	Wolf Creek
Issue date:	12/06/1985
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
GL-83-28, KMLNRC-85-260, TAC-57387, NUDOCS 8512120329
Download: ML20138B550 (4)

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KANSAS GAS AND ELECTRIC COMPANY T>E ELECTRrc COMPANY OLENN L KCESTER vect Pass @E47 NUCLEAR Decerber 6, 1985 Mr. Harold R. Denton, Director Office of mclear Reactor Regulation U.S. tbclear Regulatory Comission Washington, D.C. 20555 KMLtGC 85-260 RE: Docket Ib. SUN 50-482 SUBJ: Response to Request for Information on Generic Letter 83-28, Item 1.2 " Post Trip Review Data Retention Capability" REF: NRC letter dated October 23, 1985 from Ik7Youngblood to GMoester, KG&E

Dear Mr. Denton:

The referenced letter requested additional information be provided concerning the Wolf Creek Generating Station (FX'GS) response to Generic Ietter 83-28, Item 1.2, concerning Post Trip Review Data Information Capabilities. The enclosure contains the information requested.

Yours very truly, b

Glenn L. Koester Vice President - Ibclear G E:see Enclosure xc: PO'Connor (2)

JCumins 0 9'h 2120329 851206 }

p ADOCK 05000482 PDR 201 N. Market - WicNta, Kansas - Mad Address: PO. Box 208 I WIchsta, Kansas 67201 - Telephone: Area Code (316) 261-6451 J

Mr. H.R. Denton KMIRRC 85-260 Page 1 Decenber 6,1985 Enclosure Response to Request for Information Concerning Generic Ietter 83-28, Item 1.2-Post Trip Review (Data Information Capability)

INFRWUCTION: 'Ihe methodology used at Nblf Creek Generating Station for Post Trip Reviews not only includes the Sequence of Events (SOE) and the Time History Event Recorder printouts, but for every Reactor Trip, Administrative Procedure ADM 02-400, Post Trip Review, is conpleted. Data collection also includes the alarm typewriter printouts for normal alarms, copies of all applicable strip chart recoroings and Operator's statements.

The review package contains parameters monitoring Pre and Post Trip as well as sections for testing that was on-going, equipment malfunctions and safety parameters. The entire data package is then reviewed to determine the cause of the Trip and obtain permission to Restart. Plant Trips can be adequately reconstructed from the data collection process that Nblf Creek has inplemented.

I. Question: 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.

Response: The following were noted not to be available on the SCE capabilities of the NSSS and BOP coup.Iters:

A. Safety Iniection

1. Even though the SOE Recorder does not include automatic Safety Injection as a Trip parameter, this parameter is fully monitored. The NSSS SOE Recorder does monitor the digital points of Containment Pressure, Pressurizer Pressure, manual SI and Steam Pressure as Reactor Trip parameters which cause an SI.

2. The BOP SOE Recorder does print out the status of Emergency Core Cooling System (ECCS) punps as SIUP/RUN, as well as the charging system to the Boron Injection Tank Isolation Valve positions as Not Oper/Open which would be an indication of a i Safety Injection.

3. The alarm typewriter in the Control Room will also indicate the ECCS punp and BIT isolation valve positions which are indications of an SI.

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Mr. H.R. Denton KMLNRC-260 Page 2 Decenter 6,1985 Enclosure B. Containment Isolation

1. As a part of NCGS procedure ADM 02-400, Post Trip Review, and Emergency Operating Procedure EMG E-0, Safety Injection, the containment isolation is verified by the operator by indications in the control room and any corrective actions needed performed. This is noted in the Post Trip Review Report.

C. Control Rod Position

1. The NSSS SOE Recorder monitors reactor trip breakers position, but it does not have the capability to monitor all control rod positions as SOE events.

2. There is a sign off block with time indication in the Post Trip Review procedure to verify that all controls rods did fully insert. Verification of rod bottom lights lit on the Digital Rod Position Indication is in the imediate actions of Emergency Operating Procedure EMG E-0, Safety Injection.

D. Steam Flow /Feedwater Flow

1. These are not Trip parameters at NCGS and thert e not a part of the SCE Recording capabilities.

2. The Analog values are recorded on the Time History Recorder in Klbe/hr.

E. PORV Position

1. Even though the current SCE and Time History recording capabilities do not include this parameter, pressurizer PORV status is documented on the BOP alarm typewriter printout. In addition, PORV change of status can be obtained from pressurizer pressure trace strip chart recorder.

Even though the current SOE recording capabilities do not contain the parameters listed above, they are all monitored and would be a part of the Post Trip Review package to be analyzed prior to restart. The information can be J

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Mr. H.R. Denton KMmRC-260 Page 3 Decenber 6,1985 Enclosure utilized to adequately reconstruct the accident scenarios presented in Chapter 15 of the Final Safety Analysis Report (FSAR) and sufficient to establish that the plant remained within the design envelope for the appropriate accident conditions.

II. Question: Time History recorders do not meet the mininum performance characteristics.

Response: The NSSS Time History Recorder will scan the data points two (2) minutes before the event to three (3) minutes after. The BOP Time History Recorder will scan the data l points five (5) minutes before the event to ten (10) minutes after. The duration of the NSSS Time History (2 minutes before trip and 3 minutes after trip) provides sufficient information to adequately assess the caum and analyze the progression of unscheduled reactor shutdowns.

III. Question: The data retention procedures may not ensure that the information reviewed for the Post Trip Review is maintained in an accessible manner for the life of the plant.

Response: In accordance with ADM 02-400, Post Trip Review, the Post Trip Review data package is a lifetime Q.A.

record. This information was inadvertently omitted from previous responses.

SGMARr Utilizing the data and information sources as noted above and in the letter dated February 29, 1984, a systematic safety assessment of the unscheduled reactor shutdown to determine the root cause(s) and progression of the trip will be perforned prior to restart.

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