ML18153B639

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Advises That 890106 Response to Generic Ltr 88-17 on Loss of DHR Meets Intent of Ltr Re Expeditious Actions.Guidance to Ensure That Actions Adequate Listed.Calculations Should Be Performed on RCS Hot Side Openings
ML18153B639
Person / Time
Site: Surry  Dominion icon.png
Issue date: 03/10/1989
From: Buckley B
Office of Nuclear Reactor Regulation
To: Cartwright W
Virginia Power (Virginia Electric & Power Co)
References
GL-88-017, TAC-69783, TAC-69784 NUDOCS 8903200441
Download: ML18153B639 (3)


Text

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Docket Nos.*.-50-280

, and 50-281 Mr. ~I. R. Cartwright Vice President'- Nuclear Virginia Electric and Power Company 5000 Dominion Blvd.

Glen Allen, Virginia 23060

Dear Mr. Cartwright:

March 10, 198~

DISTRIBUTION

  • Docket Fi le NRC &- Loca_l PDRs PDII-2 r/f GLainas EAdensam DMiller BBuckley OGC EJordan BGrimes ACRS (10)

SUBJECT:

COMMENTS ON THE VIRGINIA ELECTRIC AND POWER COMPANY RESPONSE TO GENERIC LETTER 88-17 WITH RESPECT TO EXPEDITIOUS ACTIONS FOR LOSS

The NRC staff has reviewed your January 6, 1989 response to Generic Letter (GL) 88-17.

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

However, your response to some items is brief and therefore does not provide the detail to allow us to fully understand some of your actions taken in. response to GL 88-17.

We have provided the following comments as guidance for y_ou to assure yourselves that your actions are adequate.

1.

You reference the actions to be implemented prior to entering a reduced inventory condition.

We assume this refers to planned entries such as for maintenance.

2.

You mention discussion of the Diablo Canyon event with operations personnel and training for specific mid-loop operation and coo ldown/drai ndow*n with your staff. It is not specifically stated that maintenance personnel. are

  • also included.

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

3.

You reference an example of containment closure in which operators had the-personnel hatch closed within 15 minutes of notification, and final containment closure was achieved with the closing of the equipment hatch within 34 minuteso No mention was made of previous checks on the* ability to assure leak tightness of the hatch with the simplified quick closure.

4.

You mentioned a containment closure team but 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.

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. 8903200441 890310 1

PDR ADOCK 05000280';'* l I

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Mr. W.,P,-. Cartwright March 10, 1989

5.

You indicate that one continuous means of level indication using temporary tubing is now in place and that a TV camera indication will be available in the control room during the 1989 refueling outage.

Also, a second means of level indication is under review.

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 hot leg or be compensated to obtain the correct l eve 1 value.

6.

As you correctly state, we will accept use of one level indication in the short term at Surry.

Si nee this dependence on one instrument is somewhat susceptible to errors, we suggest additional care be taken to avoid difficulties, particularly during mid-loop operation, and, until your longer-term improvement program provides better instrumentation, that you consider additional mitigation measures in case RHR should be lost.

7.

Wal king the level hose following installation to verify lack of kinks or 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 additional walkdown immediately prior to its being placed in use.

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 Re:actor Coolant System (RCS) venting.

We note that relatively large hot side openings in the RCS, such as a pressurizer manway, can still lead to a pressure of several psi due to the large steam flow rate and the combina-tion of flow restrictions in the surge line - lower pressurizer hardware -

manway opening.

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

There is no need to respond to the above comments.

However, 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 opera-tion. These actions will be supplemented, and in some cases replaced, by programmed enhancements.

We intend to audit both your response to the expedi-tious actions and your longer-term enhancement program.

Our observations to your responses, as indicated above, may also be covered in the audit of expeditious actions.

cc:

See next page

[TAC NOS 69783/69784]

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001 Sincerely, Original signed by Bart C. Buckley, Senior Project Manager Project Directorate II-2 Division of Reactor Projects-I/II Office of Nuclear Reactor Regulation D:iD~T~

HB~~_7 03/ /o /89

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Mr. W.-R. Cartwright Virginia Electric and Power Company cc:

Michael W. Maupin, Esq.

Hunton and Williams Post Office Box 1535 Richmond, Virginia 23212 Mr. Michael Kansler, Manager Surry Power Station Post Office Box 315 Surry~ Virginia 23883 Resident Inspector Surry Power Station*

U.S. Nuclear Regulatory CoD1Tiission Post Office Box 166, Route 1 Surry, Virginia 23883 Mr. Sherlock Holmes, Chairman Board of Supervisors *Of Surry County Surry County Courthouse Surry, Virginia 23683 Mr. W.* T. Lough*

Virginia Corporation Conmission..

  • Division of._ Energy Regulation Post Office Box 1197 Richrrond, Virginia 23209 Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323 _

C. M. G. Buttery, M.D., M.P.H.

Department of Health 109 Governor Street Richmond, Virginia 23219 e

Surry Power Station Attorney General Supreme Cour~ Building 101 N~rth 8th Street Richmond, Virginia* 23219