ML17251A395

Advises That 890104 Response to Generic Ltr 88-17 on Loss of DHR Meets Ltr Intent Re Expeditious Actions.Simplified Quick Closure of Equipment Hatch Should Be Tested & Verified to Assure Hatch Meets Closure Criteria

ML17251A395
Person / Time
Site:	Ginna
Issue date:	03/13/1989
From:	Stahle C Office of Nuclear Reactor Regulation
To:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
References
GL-88-17, TAC-69745, NUDOCS 8903200282
Download: ML17251A395 (6)

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Docket Nos.

50-244 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 13, 1989 Dr. Robert C. Mecredy General Manager Nuclear Production Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649

SUBJECT:

COMMENTS ON THE ROCHESTER GAS AND ELECTRIC CORPORATION

RESPONSE

TO GENERIC LETTER 88-17 FOR THE R.E.

GINNA STATION UNIT 1 FOR EXPEDITIOUS ACTIONS FOR LOSS OF DECAY HEAT REMOVAL (TAC NO. 69745)

The NRC staff has reviewed your response (letter of January 4, 1989) to Generic Letter 88-17.

We find that it meets the intent of the generic letter with respect to expeditious actions.

You may wish to consider several observations.

in order to assure yourselves that the actions are adequately addressed:

1.

The guidance in Generic Letter 88-17 requires establishing containment closure following initial loss of RHR cooling.

Time constraints of 30

minutes, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> correspond to the plant configurations summarized in the Westinghouse analysis (WCAP-11916).

This is acceptable.

The simplified quick closure of the equipment hatch should be tested and verified to assure that it meets the closure criteria.

2.

3.

You state that a hot side vent of about 0.5 square feet is required for Configuration No.

3 for which the time constraint for containment closure is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

However, you later state that the surge line thermal sleeve limits the pressurizer manway vent to 0.39 square feet.

Prior to any action that will reduce RCS inventory you need to verify that this vent size adequate to prevent pressurization.

No informa ion is provided in your submittal of January 4, 1989 regarding how you will keep track of and control the many potential openings (piping, electrical, hatches) which may have to be closed simultaneously.

Your procedures and administrative controls should address this topic.

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4.

You indicate that since the spring 1988 refueling you h

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y o having two core exit thermocouples remain operable during you ave mp emented a

reduced inventory operations.

Also, they have readout indication in the outa e

ou have main control room.

You have stated that prior to the 1989 f li g

y provisions to provide the control room operator with an alarm on the Plant Process Computer System (PPCS).

If the PPCS is not be lo ed ever I

operating you indicate that the core exit thermocouple temp t

ll empera ures wi the control r gg y

5 minutes.

Because this reading is being monitor d i ore n

of loss of RHR.

You ma i

ol room, the need for frequent logging only arises f th e

or e case an initiation criterion.y wish to consider a less demanding logging frequenc 5.

6.

7.

8.

You indicate that an existing means of level indication with permanently mounted dp.cell is located in the loop "B" hot leg a

d

't d '

control room.

You indicate that a second permanent installation is planned but that you have an interim provision to install 1

transmitter in the loo e

oop hot leg.

Also, an existing second temporary means of level indication with plastic tube is available.

When two instruments are in place, care should be taken to resolve any discrepancy etween the two 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.

Walking the temporary plastic tube following installation t'o verify lack of kinks or loop seals is necessary.

Periodic walkdowns should be conducted after installation.

Daily walkdowns should be carried out when the plastic tube is in use, with an additional walkdown immediatel rio its being placed in use.

You stated that you have operating experience and procedures developed to reduce RHR flow according to the water level relative to the loop centerline.

This correlation of flow reduction with water level is ver desirable for avoiding vortexing and entrainment.

Your use of gravity feed depends upon an adequate vent path, as you ravit correctly state.

Since a pressurization of only a few s

ld psi wou remove sit a g

y feed as a possibility, you should carefully address th uation.

We note that relatively large hot side openings in the

RCS, is such as a pressurizer

manway, can still lead to a pressure of several t e large steam flow and the combination of flow restrictions in ra psi the surge line - lower pressurizer hardware - manway opening.

Calculations should be performed to verify the effectiveness of the opening.

March 13, 1989 9.

You plan to work within existing technical specifications in meeting the generic letter recommendations which is acceptable to the staff.

As you are aware, the expeditious actions you have briefly described are an interim measure to achieve an immediate reduction in risk associated with reduced inventory operation.

These will be supplemented and in some cases replaced by programmed enhancements.

We intend to audit both your response to the expeditious actions and your programmed enhancement program.

The areas where we do not fully understand your responses as indicated above may be covered in the audit of expeditious actions.

Sincerely, Carl Stahle, Senior Project Manager Project Directorate I-3 Division of Reactor Projects I/II cc:

See next page DISTRIBUTION: Docket File, NRCSLocal

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Dr. 'Robert C. Mecredy Rochester Gas and Electric Corporation R.

E. Ginna Nuclear Power Plant CC:

Harry H. Voigt, Esquire

LeBoeuf, Lamb, Leiby and MacRae 1333 New Hampshire

Avenue, N.W.

Suite 1100 Washington, D.C.

20036 Ezra Bialik Assistant Attorney General Environmental Protection Bureau New York State Department of Law 2 World Trade Center New York, New York 10047 Resident Inspector R.E. Ginna Plant c/o U.S.

NRC 1503 Lake Road

Ontario, New York 14519 Stanley B. Klimberg, Esquire General Counsel New York State Energy Office Agency Building 2 Empire State Plaza

Albany, New York 12223 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Supervisor of the Town of Ontario 1850 Ridge Road

Ontario, New Yot k 14519 Ms.

Donna Ross Division of Policy Analysis 5 Planning New York State Energy Office Agency Building 2 Empire State Plaza

Albany, New York 12223 Mr.

Br uce A. Snow, Superi entendent Nuclear Production Rochester Gas

& Electric Corporation 89 East Avenue Rochester, N.Y. 14649-0001 Charlie Donaldson, Esq.

Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271