ML19098B423
| ML19098B423 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/22/1977 |
| From: | Stallings C Virginia Electric & Power Co (VEPCO) |
| To: | Reid R, Rusche B Office of Nuclear Reactor Regulation |
| References | |
| Serial No. 150/040177 | |
| Download: ML19098B423 (3) | |
Text
e VIRGINIA ELECTRIC.A.ND POWER COMPANY (
RICHMOND, VIRGINIA. 23261
. ~--
Apr i l 2 2, 19 77 Mr. Benard c. Rusche Director of Nuclear Reactor Regulation
- u. s. Nuclear Regulatory Commission Washington, D. c.
20555 Attn: Mr. Robert W. Reid, Chief Operating Reactors Branch 4
Dear Mr. Rusche:
J;<<\\JJy;;,
,,J Serial No. 150/040177 PO&M/TAP:dgt Docket Nos. 50-280 50-281 License Noso DPR-32 DPR-37 This is in response to your letter of April 1, 1977, in which you addressed an overpressure problem observed at an operating PWR and requested our conformance with your restated guidelines. Let me assure you that the significance of an overpressure event has beeti realized by my staff and that operations personnel have been informed and instructed on the possibilities and consequences of an overpressure event.
A brief review of our interpretations and actions with respect to an event of this type is appropriate:
- 1. Let us review the terminology in use. "Water Solid Condition" means a condition of the primary coolant system when it has been filled, vented and is at a pressure sufficient to run a RCP; i.e., the system is 'hard' and has no significant'air bubble. Therefore, pump 'jogs' for venting are not included under "RCP starts while in a water solid condition."
- 2. Let us restate our needs for RCP starts including overpressure con-siderations. In your January' 10, I977, letter you stated, "POSITION:
We will require that all licensees include adequate provisions to prevent RCP starts while in a water solid condition unless absolutely necessary." We must start a RCP to circulate and heat-up the primary coolant to get chemistry into specification prior tci drawing\\a bubble.
Our Standing Order on Solid Plant Operation (2-28-77) requires that we ascertain/or estimate the temperature profile prior to requesting the Operating Supervisor's permission for starting the RCP. We also state.in the same Standing Order to run a RCP for an additional three hours during a plant cooldown to reduce this temperature differential should the* shutdown be brief.
- 3. The following procedures indicate our compliance with your request
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. VIRGINIA ELECTRIC AND POWER COMPANY TO Mr. Benard C. Rusche Page No. 2 of April 1, 1977, that stated, "In the event that a RCP start while water-solid cannot be avoided we request that your plant operating procedures include non-optional pre-requisite steps 1to ensure that the RCS temperature profile is determined and if that profile is excessive, that appropriate measures are specified to achieve an acceptable profile prior to starting a RCP."
- a. OP-1.1 between the Fill and Vent steps says, "Loops have never been isolated or drained and pressurizer level maintained in the indicating band during outage and [o2J within specific~tion.
Yes No If yes, draw bubble in pressurizer prior to starting a RCP. If no, refer to Standing Order on Solid Plant Operation Prior to Starting First RCP."
- b. OP-1.2 cautions not to start a RCP, if all RCP's have been idle for more than 5 minutes a~d the RCS temperature is greater than the seal injection temperature, without the Operating Supervisor's permission.
- 4. The three above numbered statements are our reply to your request that we implement the required procedures immediately. We believe we are in compliance.
1 In addition, as a result of your April 1, 1977, letter, we have conducted a critical review of our procedures to ensure that they are fully responsive to all of the positions stated in your letter of January 10, 1977, ahd restated on April 1, 1977. However, the results of our RCS pressure response analysis are not yet avaiiable and the evaluation of our procedures with respect to the results will not be able to be done until the results have been received and evaluated. The initial generic analysis is due to be received at the end of April and the applicability of the results and the need for further analysis will then be able to be determirled.
cc: Mr. Norman C. Moseley Very truly yours,
~ >>1. }ditlt6~ 1d C. M. Stallings Vice President-Power Supply and Production Operations
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