ML16342B557
| ML16342B557 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/26/1989 |
| From: | Rood H Office of Nuclear Reactor Regulation |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| References | |
| GL-88-17, TAC-69740, TAC-69741, NUDOCS 8905040084 | |
| Download: ML16342B557 (14) | |
Text
spy'i,l 26, j.9.89 Docket Nos.
50-275 and 50-323 Mr. J.
D. Shiffer, Vice President Nuclear Power Generation c/o Nuclear Power Generation, Licensing Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106
Dear Mr. Shiffer:
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NRC
& LPDR BGrimes GHolahan HBa lukjian MVirgi 1io MNHodges
- JLee, ACRS (10)
HRood GKnighton PDV Plant File OGC (for information only)
SUBJECT:
NRC STAFF COMMENTS REGARDING PG&E
RESPONSE
TO GENERIC LETTER 88-17 IN THE AREA OF EXPEDITIOUS ACTIONS FOR LOSS OF DECAY HEAT REMOVAL (TAC NOS. 69740 AND 69741)
Generic Letter (GL) 88-17 was issued on October 17, 1988 to address the potential for loss of decay heat removal (DHR) during non-power operation.
In GL 88-17, the staff requested (1) a description of your efforts to implement the eight recommended expeditious actions of the GL and (2) a description of the enhancements, specific plans and a schedule for implementation of the six recommended program enhancements.
Pacific Gas and Electr ic Company (PG&E) responded to GL 88-17 by 'letters dated January 6,
1989 and February 6, 1989.
The January 6, 1989 letter addressed the expeditious actions recommended by GL 88-17, and the February 6, 1989 letter addressed the programmed enhancements recommended by GL 88-17.
As you know, the expeditious actions are interim measures to achieve an immediate reduction in risk associated with operation with reduced reactor coolant system water inventory.
These measures will be supplemented by, and may in some cases be replaced by, the programmed enhancements.
The NRC staff has completed its review of PG&E's January 6, 1989 response and finds that it is generally complete and appears to meet the recommendations of the gener ic letter with respect to expeditious actions.
However, in a few
- areas, the PG&E response is sufficiently vague that the staff cannot fully understand the actions taken in response to GL 88-17.
You may wish to consider the following staff observations in order to provide assurance that the actions are adequately addressed:
1.
The January 6,
1989 PG&E response to GL 88-17 provided an extensive outline of training related to loss of DHR for licensed operators and continued training for reduced inventory operation, where lowered loop operations are anticipated, with licensed individuals of your staff.
While PG&E's training program appears to be comprehensive, the January 6,
1989 response does not specifically state that maintenance personnel are also included in any of the training.
The NRC staff intended that this item included all personnel who can affect reduced inventory operation.
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- place, care should be taken to resolve any discrepancy between the measurement systems.
Also, the pressure of the'eference leg should approximate the pressure of the void 'in the hot leg or be, compensated to obtain the correct level value.
6.
The January 6, 1989 PG&E response states that, steam generator manways will be removed to provide vent openings on the hot side of the RCS to relieve RCS pressurization.
However, calculations should be performed to verify the effectiveness of RCS openings, because even with relatively large hot side openings in.the,'RCS,'ressurization to several psi can still result.
For example, with removal of a,pressurizer,
- manway, large steam flows in combination with flow restriction's in the surge line and lower pressurizer hardware may sti ll,lead to
'ressurization.
There is no need to respond by letter to the above observations.
Howeve~,
the NRC staff intends to audit PG&E's response to both the expeditious actions described in the January 6,
1989 lette'r and the programmed enhancements described in the February 6, 1989 letter.
The areas discussed
- above, in which the staff does not fully understand the PG&E response, may be covered in the audit of expeditious actions.
This completes the NRC staff review of PG&E's January 6,
1989 response to the expeditious actions listed in GL 88-17.
The PG&E programmed enhancement program discussed in the February 6, 1989 letter will be addressed in a subsequent staff letter. If you have any questions regarding this matter, please contact me.
S incere ly, ori ginal si gned by cc:
See next page Harry Rood, Senior Project Manager Project Directorate V
Division of Reactor Projects - III, IV, V and Special Projects DRSP/PD5
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UNITED STATES t
NUCLEAR REGULATORY COMMISS ON WASHINGTON, D. C. 20555 April 26, 1989 Docket Nos. 50-275 arid 50-323 Nr. J.
D. Shiffer, Vice President Nuclear Power Generation c/o Nuclear Power Generation, Licensing Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106
Dear Nr. Shiffer:
SUBJECT:
NRC STAFF COMMENTS REGARDING PG&E RESPONSE TO GENERIC LETTER 88-17 IN THE AREA OF EXPEDITIOUS ACTIONS FOR LOSS OF DECAY HEAT REYOVAL'1'AC NOS. 69740 AND 69741)
Generic Letter (GL) 88-17 was issued on October 17, 1988 to address the potential for loss of decay heat removal (DHR) during non-power operation.
Iri GL 88-17, the staff requested (1) a description of your efforts to implement the eight recoIIImended expeditious actions of the GL and (2) a description of the enhancements, specific plans and a schedule for implementation of the six
'recommended program enhancements.
Pacific Gas and Electric Company (PG&E) responded to GL 88-17 by letters dated January 6,
1989 and February 6, 1989.
The January 6, 1989 letter addressed the expeditious actions recommended by GL 88-17, and the February 6, 1989 letter addressed the programmed enhancements recoIImerided by GL 88-17.
As you know, the expeditious actions are interim measures to achieve an immediate reduction in risk associated with operation with reduced reactor coolant system water inventory.
These measures will be supplemented by, and may in some cases be replaced by, the programmed enhancements.
The NRC staff has completed its review of PG&E's January 6, 1989 response and finds that it is generally complete and appears to meet the recommendations of the generic letter with respect to expeditious actions.
However, in a few
- areas, the PG&E response is sufficiently vague that the staff cannot fully understand the actions taken in response to GL 88-17.
You may wish to consider the following staff observations in order to provide assurance that the actions are adequately addressed:
1.
The January 6,
1989 PG&E response to GL 88-17 provided an extensive outline of training related to loss of DHR for licensed operators and continued training for reduced inventory operation, where lowered loop operations are anticipated, with licensed individuals of your staff.
While PG&E's training program appears to be comprehensive, the January 6,
1989 response does not specifically state that maintenance personnel are also included in any of the training.
The NRC staff intended that this item included all personnel who can affect reduced invenrory operation.
Hr. J.
D. Shiffer 2.
For containment closure, the January 6,
1989 PG&E response identified the flow paths of concern as "pathways which communicate between the containment and outside atmosphere...."
However, the NRC staff is concerned with all containment penetrations that could cause a release (e.g., penetrations from the containment into a fuel handling or auxiliary building).
The PG&E response describes steps to control a path from the fuel transfer tube to the auxiliary building, but there may also be piping and electrical penetrations that should be closed.
3.
In addressing containment closure, the January 6, 1989 PG&E response provided no information regarding how you will keep track of and control the many potential openings (piping, electrical, hatches) which may have"-
to be closed simultaneously.
The staff assumes that PG&E will address this topic in procedures and administrative controls.
t 4.
The January 6, 1989 PG&E response mentions that a minimum of two incore thermocouples will be displayed on the Post-Accident Honitoring System (PANS) in the control room whenever the core is in mid-loop condition and the reactor vessel head is on the reactor vessel.
However, the response did not specifically state whether or not the temperature indications would be periodically checked and recorded by an operator or continuously monitored and alarmed as recommended in Generic Letter 88-17.
5.
The January 6, 1989 PG&E response indicates that at least two independent, continuous RCS water level indications are provided by the reactor vessel refueling level indication system (RYRLIS).
These are a
wide range (WR) RYRLIS tap off the loop No.
2 cold leg and a narrow range (NR) RVRLIS tap off the loop No.
3 hot leg.
In addition, there is a tygon standpipe tap off the loop No.
4 crossover leg.
The PG&E response indicated that the NR and WR RVRLIS will be monitored in the control room.
However, there was no statement as to whether or not these indications will also be alarmed.
The PG&E response indicated that the tygon tube reading will be monitored by an operator stationed inside of containment who will forward the reading to the control room.
However, there was no statement as to whether or not the readings will be recorded at intervals no longer than 15 minutes during normal conditions as stated in GL 88-17.
The January 6, 1989 PG&E response does not fully describe the type of level indicator used for the NR and WR RVRLIS.
The response mentions that the WR RVRLIS has an accuracy of a 7 inches.
This is likely to be inadequate at the critical region where vortexing occurs.
The PG&E response indicates that some conditions will cause disagreement between the NR and MR indication.
When two or more level instruments are in
Nr.'. D. Shiffer 3
April 26, l989
- place, care should be taken to resolve any discrepancy between the measurement systems.
Also, the pressure of the reference leg should approximate the pressure of the void in the hot leg or be compensated to obtain the correct level value.
6.
The January 6, 1989 PG&E response states that steam generator manways will be removed to provide vent openings on the hot side of the RCS to relieve RCS pressurization.
However, calculations should be performed to verify the effectiveness of RCS openings, because even with relatively large hot side openings in the RCS, pressurization to several psi can still result.
For example, with removal of a pressurizer manway, large steam flows in combination with flow restrictions in the surge line and lower pressurizer hardware may still lead to pressurization.
There is no need to respond by letter to the above observations.
- However, the NRC staff intends to audit PG&E's response to both the expeditious actions described in the January 6,
1989 letter and the programmed enhancements described in the February 6, 1989 letter.
The areas discussed
- above, in which the staff does not fully understand the PG&E response, may be covered in the audit of expeditious actions.
This completes the NRC staff review of PG&E's January 6,
1989 response to the expeditious actions listed in GL 88-17.
The PG&E programmed enhancement program discussed in the February 6, 1989 letter will be addressed in a subsequent staff letter.
If you have any questions regarding this matter, please contact me.
S incere ly, Harry Rood, Senior Project Manager Project Directorate V
Division of Reactor Projects - III, IV, V and Special Projects cc:
See next page
Mr. J.
D. Shiffer P'acific Gas and Electric Company CC:
Richard F. Locke, Esq.
Pacific Gas 5 Electric Company Post Office Box 7442 San Fr ancisco, California 94120 Janice E. Kerr, Esq.
California Public Utilities Commission 350 McAllister Street San Francisco, California 94102 Ms. Sandra A. Silver 660 Granite Creek Road Santa Cruz, California 95065 Mr. W. C. Gangloff Westinghouse Electric Corporation P. 0.
Box 355 Pittsburg, Pennsylvania 15230 Managing Editor San Luis Obis o Count Tele ram ri une 13c~~on son Avenue P. 0.
Box 112 San Luis Obispo, California 93406 Mr. Leland M. Gustafson, Manager Federal Relations Pacific Gas and Electric Company 1726 M Street, N.
W.
Washington, DC 20036-4502 Dsan M. Grueneich Marcia Preston Law Office of Dian M. Grueneich 380 Hayes Street, Suite 4
San Francisco, California 94102 Diablo Canyon NRC Resident Inspector Diablo Canyon Nuclear Power Plant c/o U.S. Nuclear Regulatory Commission P. 0.
Box 369 Avila Beach, California 93424 Mr. Dick Blakenburg Editor 8 Co-Publisher South County Publishing Company P. 0.
Box 460 Arroyo Grande, California 93420 Bruce Norton, Esq.
c/o Richard F. Locke, Esq.
Pacific Gas and Electric Company Post Office Box 7442 San Francisco, California 94120 Dr. R. B. Ferguson Sierra Club - Santa Lucia Chapter Roc'anyon Star Route Creston, California 93432 Chairman San Luis Obispo County Board of Supervisors Room 270 County Government Center San Luis Obispo, California 93408 Director Energy Facilities Siting Division Energy Resources Conservation and Development Commission 1516 9th Street Sacr amento, California 95814 Ms. Jacquelyn Wheeler 3033 Barranca Court San Luis Obispo, California 93401
Pacific Gas 8 Electric Company Diablo Canyon CC:
Ms. Laurie McDermott, Coordinator Consumers Organized for Defense of Environmental Safety 731 Pacific Street, Suite 42 San Luis Obispo, California 93401 Mr. Paul Szalinski, Chief Radiological Health Branch State Department of Health Services 714 P Street, Office Building 88 Sacramento, Ca lifo>nia 95814 Regional Administrator, Region V
U.S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Ms. Nancy Culver 192 Luneta Street San Luis Obispo, California 93401 Pr esident California Public Utilities Commission California State Building 350 McAllister Street San Francisco, California 94102 Michael M. Strum@asser, Esq.
Special Assistant Attorney General State of, California Department of Justice 3580 Wilshire Boulevard, Room 800 Los Angeles, California 90010
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