ML18005A753
| ML18005A753 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 01/03/1989 |
| From: | Mcduffie M CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-88-17, NLS-88-293, NUDOCS 8901130009 | |
| Download: ML18005A753 (12) | |
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Q1 BUTION DKMONs ON sYFI KM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:8901130009 DOC.DATE: 89/01/03 NOTARIZED:
YES'ACIL:50-'400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFILIATION MCDUFFIE,M.A.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION DOCKET-N 05000400 Document Control Branch (Document Control Desk)
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SUBJECT:
Forwards response to Generic Ltr, "Loss of DHR."
DISTRIBUTXON CODE:
A061D COPIES RECEIVED:LTR ENCL D. SIZE:
TITLE: OR/Licensing Submittal:
Loss of Residua Heat Re oval (RHR) GL-87-12 D
= NOTES:Application for permit renewal filed.
05000400 8
RECIPXENT ID CODE/NAME PD2-1 LA BUCKLEY,B INTERNAL: ACRS NRR BALUKJXAN,H NRR/DEST/ADE 8H NRR/DOEA/TSB 11 OGC/HDS 1 RES SPANO,A RES/DSR/PRAB COPIES LTTR ENCL 1
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NRR/DEST/ADS 7E 1
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I NOTE TO ALL "RIDS" RECIPIENIS PIZASE HELP US 'IO REHJCE HASTE.'ONZACT 'XEK DOCUMENI'CÃIBOLDESK, ROOM Pl-37 (EXT. 20079)
TO ZZJMZHATE YOUR MME FKR DISTRIBUTION LXSTS FOR DOCUMENIS YOU DON'T NEEDf TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL 22
CIPLL Carolina Power 4 LightCompany P. O. Box1551 ~ Raleigh, N.C.27602 dAN 0 S 1989 M. A. McDUFFIE Senior Vice President Nuclear Generation SERIAL:
United States Nuclear Regulatory'ommission ATTENTION; Document Control Desk Washington, DC 20555 e
SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 GENERIC LETTER 88-17 LOSS OF DECAY HEAT REMOVAL Gentlemen:
Carolina Power itr Light hereby submits the Shearon Harris Nuclear Power Plant'(SHNPP) response to the expeditious actions required by Generic Letter 88-17 "Loss of Decay Heat Removal".
The generic letter provides recommendations for expeditious actions and programmed enhancements to assure protection from loss of shutdown cooling while in a reduced inventory condition.
Licensees are required to submit their plan to implement each expeditious action recommendation within 60 days "of receipt of the generic letter, and to submit their plans and schedule for implementation of the programmed enhancement recommendations within 90 days of receipt.
The'nclosure to this letter provides 'a description of the actions taken and planned at SHNPP to, implement the expeditious actions specified in the generic letter.
Based on information provided by NRC and the Westinghouse Owners Group prior to issuance of Generic Letter 88-17, CPGL took an aggressive approach at SHNPP in developing a program for controlled mid-loop operation prior to our first refueling outage in the summer of 1988.
As a result, most of the expeditious actions required by the generic letter had already been addressed by changes to plant operating procedures for mid-loop operations, prior to the refueling outage which commenced in July 1988.
Since the generic letter requires some of these actions to be implemented during reduced inventory conditions as well as during mid-loop conditions, further changes to these procedures will be made to fully implement the specific requirements contained in the generic letter.
These changes are described in the attachment to this letter, and will be implemented prior to operation in a reduced inventory condition.
S5'Oii30009 890i03 PDR AQOCK 05000400 P
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Document Control Desk NLS-88-293 / Page 2
Please refer any questions regarding this submittal to Mr. Steven Chaplin at (919) 836-6623.
Yours very truly, M. A. McDuffie MAM/SDC Enclosure cc:
Mr. R. A. Becker Mr. W. H. Bradford Mr. M. L. Ernst M. A. McDuffie, having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power Light Company.
My commission expires: ///2//cPQ N
ary (Seal)
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Item 1
Trainin Action Discuss the Diablo Canyon event, related events, lessons
- learned, and implications with appropriate plant personnel'rovide training shortly before entering a
reduced inventory condition.
Response-Training lesson RTT-88-050 covers the Diablo Canyon'vent, other related industry events, lessons learned and implications with licensed operators, shift technical
- advisors, and Operations auxiliary operators.
This training was presented shortly before entering mid-loop operations during the July 1988 refueling outage.
This training package will be updated, and will be instituted prior to any future reduced inventory evolutions.
Item 2'ontainment Closure Action Implement procedures and administrative controls that reasonably assure that containment closure will be achieved prior to the time at which a core uncovery could result from a loss of DHR coupled with an inability to initiate alternate cooling or addition of water to the RCS inventory.
Containment closure procedures should include consideration of potential steam and radioactive material release from the RCS should closure activities extend into the time boiling takes place within the RCS.
These procedures and administrative controls should be active and in use:
(a) prior to entering a reduced RCS inventory condition for NSSSs supplied by Combustion Engineering or Westinghouse, and (b) prior to enter into an RCS condition wherein the water level is lower than four inches below the top of the flow area of the hot legs at the junction of the hot legs to the RV for NSSSs supplied by Babcock and Wilcox, and should apply whenever operating in those conditions.
If such procedures and administrative controls are not operational, then either do not enter the applicable condition or maintain a closed containment.
Response-Procedures were in place to maintain containment closure during mid-loop operations for the July 1988 refueling outage.
These procedures will be revised to ensure containment closure exists during reduced inventory conditions as well as during mid-loop operations, as noted in the attachment to the generic letter.
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Item 3
RCS Tem erature Measurements Action Provide at least two independent, continuous temperature indications that are representative of the core exit conditions whenever the RCS is in a mid-loop condition and the reactor vessel head is located on top of the reactor vessel.
Temperature indications should be periodically checked and recorded by an operator or automatically and continuously monitored and alarmed.
Temperature monitoring should be performed either:
(a) by an operator in the control room (CR), or Response-(b) from a location outside of the containment building with provision for providing immediate temperature values to an operator in the CR if significant changes occur.
Observations should be recorded at an interval no greater than 15 minutes during normal conditions.
Procedure's presently require that at least two incore thermocouples are operational as a prerequisite for mid-loop operations.
Procedures will be revised to require logging of core temperature at 15 minute intervals during mid-loop operations.
Item 4 RCS Water Level Measurement Action Provide at least two independent, continuous RCS water level indications whenever the RCS is in a reduced inventory condition.
Water level indications should be periodically checked and recorded by an operator or automatically and continuously monitored and alarmed.
Water level monitoring should be capable of being performed either:
(a) by an operator in the CR, or (b) from a location other than the CR with provision for providing immediate water level values to an operator in the CR if significant changes occur.
Observations should be recorded at an interval no greater than 15 minutes during normal conditions.
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Response-Procedures presently require the installed RVLIS be operational and that a vessel standpipe be installed.
Vessel level is continuously monitored during periods of level change.
Procedures will be revised to require logging of vessel level at 15 minute intervals when in a reduced inventory condition.
Item 5
Administrative Control of Plant Activities Action Implement procedures and administrative controls that generally avoid operations that deliberately or knowingly lead to perturbations to the RCS and/or to systems that are necessary to maintain the RCS in a stable and controlled condition while the RCS is in a reduced inventory condition.
If operations that could perturb the RCS or systems supporting the RCS must be conducted while in a reduced inventory condition, then additional measures should be taken to assure that the RCS will remain in a stable and controlled condition.
Such additional measures include both prevention of a loss of DHR and enhanced monitoring requirements to ensure timely response to a loss of DHR should such a loss occur.
Response-A caution presently exists in the operating procedures to provide control/prevention of perturbations to the RCS and/or systems needed for control of the RCS.
The training lesson described in Item 1 also emphasizes the need to control evolutions in progress during periods of mid-loop operation.
Planning for outages at SHNPP identifies the reactor vessel level on the timeline
- schedule, and Operations personnel are involved in determining the scheduling of concurrent activities during reduced inventory conditions.
No further action is required.
Item 6
Inventor Addition Ca abilit Action Provide at least two available or operable means of adding inventory to the RCS that are in addition to pumps that are a part of the normal DHR systems.
These should include at least one high pressure injection pump.
The water addition rate capable of being provided by each of the means should be at least sufficient to keep the core covered.
Procedures for use of these systems during loss of DHR events should be provided.
The path of water addition must be specified to assure the flow does not bypass the reactor vessel before exiting any opening in the RCS.
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Response
Plant technical specifications already require that one high pressure injection pump be operable during cold shutdown.
Operability of an additional high pressure injection pump is prohibited by Technical Specifications due to 10CFR50 Appendix G requirements for reactor vessel integrity.
Since the generic letter specifically disallows credit for inventory addition via the decay heat removal pumps, a second path must necessarily be passive in nature; for example, a gravity feed from the refueling water storage tank to the RCS could be used, The two means of adding inventory will be included in the operating procedure as a prerequisite for mid-loop operations.
Plant abnormal operating procedures already address adding inventory to the RCS during a loss of decay heat removal event.
Item RCS Nozzle Dams 6 Vent Action (Applicable to Westinghouse and Combustion Engineering Nuclear Steam Supply (NSSS) designs)
Implement procedures and administrative controls that reasonably assure that all hot legs are not blocked simultaneously by nozzle dams unless a vent path is provided that is large enough to prevent pressurization of the upper plenum of the RV.
Response-Maintenance procedures presently provide the proper sequence for installation and removal of nozzle dams.
Procedures will be revised to ensure an adequate vent path is provided prior to installation of hot leg nozzle dams.
Item 8
Loo Sto Valves Action (applicable to NSSSs with loop stop valves)
Implement procedures and administrative controls that reasonably assure that all hot legs are not blocked simultaneously by closed stop valves unless a vent path is provided that is large enough to prevent pressurization of the RV upper plenum or unless the RCS configuration prevents RV water loss if RV pressurization should occur.
Closing cold legs by nozzle dams does not meet this condition.
Response
This item does not apply to SHNPP as the plant does not have loop stop valves.