ML17304B154

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Discusses Util 890106 Response to Generic Ltr 88-17, Loss of Dhr. Response Re Expeditious Actions Acceptable. Observations Encl
ML17304B154
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 05/05/1989
From: Chan T
Office of Nuclear Reactor Regulation
To: Karner D
ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
GL-88-17, TAC-69762, TAC-69763, TAC-69764, NUDOCS 8905150007
Download: ML17304B154 (10)


Text

May 5, 1989 locket Nos:

STN 50-528, STN 50-529 and STN 50-530 Mr. Donald B. Karner Executive Vice President Arizona Nuclear Power Project

'Post Office Box 52034 Phoenix, Arizona 85072-2034

Dear Mr. Karner:

DISTRIBUTION NRC 5 LPDRs PD5 Reading MVirgi 1 io JLee TChan OGC (f/info only)

EJordan BGrimes MDavis

SUBJECT:

RESPONSE

TO GENERIC LETTER 88-17, "LOSS OF DECAY HEAT REMOVAL,"

PALO VERDE NUCLEAR GENERATING STATION (TAC NOS. 69762,

69763, AND 69764)

On October 17,

1988, Generic Letter

(,GL) 88-17, "Loss of Decay Heat Removal" was issued, and in part, requested licensees to respond to recommended "expedi-tious actions" and "programmed enhancements,"

aimed'oward reducing the probability of loss of decay heat removal and mitigating the consequences in the event a loss of decay heat.removal capability occurs.

Arizona Nuclear Power Project (ANPP) responded to the recommended "expeditious actions" and "programmed enhancements 'n letters dated January 6 and February 6, 1989, respectively.

We have reviewed your January 6,

1989 letter with respect to expeditious actions and find it to be responsive to the generic letter.

However, your response to certain items" is brief and unspecific.

'As such, we ask that you consider the. observations contained in the Enclosure in order. to assure yourselves that the actions are adequately addressed.

A response to these observations is not required.

As you are "aware,'he expeditious actions are intended to be interim measures to achieve an immediate, reduction in risk associated with reduced inventory operation.

These actions wil.l be -supplemented and in some cases replaced by programmed enhancements.

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

The observations which are discussed in the Enclosure may also be covered in the audit of expeditious actions.

Please contact me if you have questions'n this matter.

'incerely,

,/s/

Enclosure:

As stated Terence L. Chan, Senior Project Manager Project Directorate V

Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation cc:

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STN 50-528, STN 50-529 and STN 50-530 Mr. Donald B. Karner Executive Vice President Arizona Nuclear Power Project Post Office Box 52034

Phoenix, Arizona 85072-2034

Dear Mr. Karner:

SUBJECT:

RESPONSE

TO GENERIC LETTER 88-17, "LOSS OF DECAY HEAT REMOVAL,"

PALO VERDE NUCLEAR GENERATING STATION (TAC NOS. 69762,

69763, AND 69764)

On October 17, 1988, Generic Letter (GL) 88-17, "Loss of Decay Heat Removal" was issued, and in ~art, requested licensees to respond to recommended "expedi-tious actions" and

'programmed enhancements,"

aimed toward reducing the probability of loss of decay heat removal and mitigating the consequences in the event a loss of decay heat removal capability occurs.

Arizona Nuclear Power Project (ANPP) responded to the recommended "expeditious actions" and "programmed enhancements" in letters dated January 6 and February 6, 1989, respectively.

We have reviewed your January 6,

1989 letter with respect to expeditious actions and find it to be,.responsive to the generic letter.

'However, your response to certain items is brief and unspecific.

As such, we ask that you consider the observations contained in the Enclosure in order to assure yourselves that the actions are adequately addressed.

A response to these observations is not required.

As you are aware, the expeditious actions are intended to be interim measures to achieve an immediate reduction in risk associated with reduced inventory operation.

These actions 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 observations which are discussed in the Enclosure may also be covered in the audit of expeditious actions.

Please contact me if you have questions on this matter.

Sincerely, j

Fps~ M+

'c~'<

Terence L. Chan, Senior Project Manager Project Directorate V

Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosure:

As stated cc:

See next page

41

Mr. Donald B. Karner Arizona Nuclear Power Project Executive Vice President Post Office Box 52034 Phoenix, Arizona 85072-2034 Palo Verde CC:

Arthur C. Gehr, Esq.

Snell

& Wilmer 3100 Valley Center Phoenix, Arizona 85073

'harles R. Kocher, Esq. Assistant Council James A. Boeletto, Esq.

Southern California Edison Company P. 0.

Box 800

Rosemead, California 91770 Mr. Tim Polich U.S. Nuclear Regulatory Commission HC-03 Box 293-NR Buckeye, Arizona 85326 Regional Aaministrator, Region V

U. S. Nuclear Regulatory Commission 1450 Maria, Lane Suite 210 Walnut Creek, California 94596

~

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Mr.. Charles B. Brinkman Washington Nuclear Operations Combustion Engineering, Inc.

12300 Twinbrook Parkway, Suite 330 Rockville, Maryland 20852 Mr. Charles Tedford, Director Arizona Radiation Regulatory Agency 4814 South 40 Street Phoenix, Arizona 85040 Chairman Maricopa County Board of Supervisors 111 South Third Avenue Phoenix, Arizona 85003

lk 41 II I

Enclosure PALO VERDE NUCLEAR GENERATING STATION N

L 1.

You mention discussion of the Diablo Canyon event with operations personnel and training for specific mid-loop operation and cooldown/

draindown with your staff.. It is not specifically stated that main-tenance personnel are also included.

The item was intended to include all personnel who can affect reduced inventory operation.

2.

You state that 'you will'impleme'nt the appropriate administrative controls and procedures to reasonably assure containment closure within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

If you plan.to use less than a full compliment of bolts for sealing the equipment hatch, then you should first verify that you can make a proper seal of the mating surfaces.

3.

You mentioned a containment closure but provided no information regarding how you wi.ll keep track of and control the many potential openings (piping, electrical, personnel hatches) which may have to be, closed simultaneously.

Your procedures and administrative controls should address this topic.

4.

You indicated that you will have at least two core exit thermocouples (CETs) available whenever the RCS is in mid-loop condition and the reactor vessel head is located on top of the reactor vessel.

The CETs will provide temperature indication to the control room operators.

You have not stated any frequency of recording of the temperatures.

Because the CETs are being monitored in the control room, the need for frequent logging only arises for the case of loss of RHR.

5.

You indicate that each Palo Verde unit is equipped with two independent tygon tube level monitoring systems during reduced inventory operations.

One of the. systems, which is connected to an operating shutdown cooling loop, requires correcting factors w'hich depend on the flow rate.

,A TV

J

'L camera indication will be available in the control room.

Also, a perma-nent RCS level monitoring system is to be installed during the next re-fueling outage for each Palo Verde Unit.

When two instruments are in

place, care should be taken to resolve any discrepancy between the two measurement systems,.

Also, the pressure of the reference leg should approximate the pressure of the void in.the'ot leg or be compensated to obtain the correct level value..

6.

Walking the level hose follow'ing installation to verify lack of kinks or

'I loop seals is good.

Experience shows that periodic walkdowns are needed after installation.

We recommend daily walkdowns when the. level hose is in use, with an additiona1 walkdown immediately prior to its being placed in use.

7.

You state that your criteria for providing backup equipment includes the provision of at least two avai lable means of add'ing inventory to the RCS in addition to the pumps that are a normal part. of the shutdown cooling systems.

You state that you do not believe that it is necessary to constrain outage related activities by requiring that one of the means of providing RCS makeup be a high pressure safety injection pump.

This is acceptable as long as there is the capability for another pump to be aligned to inject RCS makeup into the hot leg a't an acceptable flow rate with pressurization resulting from boiling in the core.

We note that technical specification changes will be considered if existing specifi-cations are overly restrictive for meeting the generic letter recommenda-tions.

8'.

You mention that procedures are being revised to provide a hot leg vent path.

A pressurizer manway or steam generator manway is often used as means to provide RCS, venting.

We note that relatively large hot side openings in the

RCS, such as a pressurizer
manway, can sti 11 lead to a pressure of several psi.

The large steam flow rate in combination with flow restrictions in the surge line and lower pressurizer hardware may lead to pressurization.

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

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