ML18005A908

Comments on Util 890103 Response to Generic Ltr 88-17 Re Expeditious Actions for Loss of Dhr.Informs That Response Appears to Meet Intent of Generic Ltr W/Respect to Expeditious Actions

ML18005A908
Person / Time
Site:	Harris
Issue date:	05/10/1989
From:	Becker R Office of Nuclear Reactor Regulation
To:	Eury L CAROLINA POWER & LIGHT CO.
References
GL-88-17, TAC-69747, NUDOCS 8905180127
Download: ML18005A908 (7)

Text

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:8905180127 DOC.DATE: 89/05/10 NOTARIZED-NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME, AUTHOR AFFILIATION BECKER,R.A.

Project Directorate II-1 RECIP.NAME RECIPIENT AFFILIATION EURY.,L.W.

Carolina Power &,Light Co.

SUBJECT:

Comments on util 890103 response to Generic Ltr 88-17 re expeditious actions for loss of DHR.

DISTRIBUTION CODE:

DF01D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: Direct Flow Distribution:

50 Docket (PDR Avail)

NOTES:Application for permit renewal filed.

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 May 10, 1989 Docket No. 50-400 Mr. Lynn W. Eury Executive Vice President Power Supply Carolina Power 5 Light Company P. 0.

Box 1551

Raleigh, N.C.

27602

SUBJECT:

COMMENTS ON THE CAROLINA POWER 8

LIGHT COMPANY RESPONSE TO GENERIC LETTER 88-17 WITH RESPECT TO EXPEDITIOUS ACTIONS FOR LOSS OF DECAY HEAT REMOVAL FOR SHEARON HARRIS NUCLEAR POWER PLANT (TAC NO. 69747)

Generic Letter (GL) 88-17 was issued on October 17, 1988 to address the potential for loss of decay heat removal (DHR) during nonpower operation.

In the GL, we 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.

The NRC staff has reviewed your r esponse to Generic Letter 88-17 on expeditious actions in the letter of January 3, 1989.

We find that your response appears to meet the intent of the generic letter with respect to expeditious actions.

However, your response is brief and sufficiently vague that we cannot fully understand your actions taken in response to GL 88-17.

You may wish to consider several observations in order to assure yourselves that the actions are adequately addressed:

1.

You have provided a brief discussion of training related to loss of DHR for licensed operators, shift technical advisors and auxiliary operators of your staff.

Your brief response does not present an outline of the subjects covered.

Also, it does not specifically state that maintenance personnel are also included in any of the training.

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

2.

In some plants the quick closure of the equipment hatch is achieved by the installation of a reduced number of bolts.

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

3.

You have not presented any times for containment closure.

Generic Letter 88-17 states that "containment penetrations including the equipment

hatch, may remain open provided closure is reasonably assured within 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of initial loss of DHR."

This time will be less if there are vent areas totaling greater than 1 square inch in the cold leg (see Enclosure 2, Section 2.2.2 of GL 88-17).

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Hr. Lynn W. Eury Nay 10, 1989 4 ~

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Your addressing of containment c'closure 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.

We assume your procedures and administrative controls will address this topic.

You indicate that your procedures require that the installed RVLIS be operational and that a vessel stand pipe be installed.

You have not described the RVLIS system.

However, usually RVLIS measures at discrete levels and is therefore not very useful for mid-loop operation unless there are discrete measuring points in the range of the hot leg.

The RVLIS can be useful for checking the level reading against the second level measuring system.

You mention that your second system is a

standpipe.

We assume it is a tygon tube standpipe.

You have not provided information on its range,

accuracy, or where the taps are located.

Al'so, you have not indicated if the readings can be monitored in the control room by means such as a

TV monitor or if the readings will be alarmed.

If the tygon tube reading will be monitored by an operator stationed inside of containment the readings will need to be forwarded periodically to the control room.

You have not stated if the readings wi 11 be recorded at intervals no longer than 15 minutes during normal conditions as stated in GL 88-17.

When two or more level instruments are in 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.

For the expeditious action regarding provision of at least two available or operable means of adding inventory to the RCS that are in addition to pumps that are a part of'he normal DHR systems, you have provided information on two means.

One of these means is the high pressure injection pump.

The second means is gravity feed from the RWST.

You have not described the injection path.

As alluded to in Enclosure 2,

Section 2.2.2 of GL 88-17, if openings totaling greater than I square inch exist in the cold legs, reactor coolant pumps and crossover piping of the RCS, the core can uncover quickly when pressurized under loss of RHR conditions.

If this situation should arise, it is generally more effective to inject makeup water into the hot leg rather than the cold leg.

When using gravity drain from the RWST a proper means for venting must be in place and verified by calculations (see next item).

You have not stated the use of any specific vent openings on the hot side of the RCS to relieve RCS pressurization.

Calculations need to be performed to verify the effectiveness of RCS openings,

however, because even for relatively large hot side openings in the RCS, pressurization to several psi can still result.

For example, with removal of a pressur izer 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 to the above observations.

Mr. Lynn 1<.'ury 3w May 10, 1989 I

As you are aware, the'xpeditious actions you have briefly described are an interim measure to achieve an immediate reduction in risk associated with reduced inventory operation, and these will be supplemented and in some cases replaced by programmed enhancements.

$!e 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.

This closes out the staff review of your responses to the expeditious actions listed in the GL.

The area of programmed enhancements will be addressed in a separate letter.

Sincerely, cc:

See next page Original Signed By:

Richard A. Becker, Project Manager Project Directorate II-1 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation DISTRIBUTION NRC PDR Local PDR PDII-1 Reading S.

Varga G. Lainas E. Adensam P. Anderson R. Becker OGC E. Jordan B. Grimes ll. Hodger H. Balukjian ACRS (10)

SHEARSON HARRIS 14-E-4 14-H-3 14-B-20 14-B-20 14-B-20 15-8-18 MNBB-3302 9-A-2 8-E-23 8-E-23 P-315 FILE LAP 1

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Mr. L. W. Eury Carolina Power

& Light Company CC:

Mr. R.

E. Jones, General Counsel Carolina Power

& Light Company P. 0; Box 1551 Raleigh, North Carolina 27602 Mr. D. E. Hollar Associate General Counsel Carolina Power

& Light Company P. 0.

Box 1551 Raleigh, North Carolina 27602 Resident Inspector/Harris NPS c/o U. S. Nuclear Regulatory Commission Route I, Box 315B New Hill, North Carolina 27562 Mr. R. A. Watson Vice President Harris Nuclear Plant P. 0.

Box 165 New Hill, North Carolina 27562 Mr. H. A. Cole Special Deputy Attorney General State of North Carolina P. 0.

Box 629 Raleigh, North Carolina 27602 Shearon Harris Nuclear Energy Public Information Committee c/o Triangle J Council of Governments P. 0.

Box 12276 Research Triangle Park, NC 27709 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street Suite 2900 Atlanta, Georgia 30323 Mr. C. S. Hinnant Plant General Manager Harris Nuclear Plant P. 0.

Box 165 New Hill, North Carolina 27562 Mr. Dayne H. Brown, Chief Radiation Protection Section Division of Facility Services N.

C. Department of Human Resources 701 Barbour Drive Ra'leigh, North Carolina 27603-2008

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