ML20008E051
| ML20008E051 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/11/1980 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| IEB-80-17, TAC-42227, TAC-47003, TAC-47004, NUDOCS 8010240126 | |
| Download: ML20008E051 (3) | |
Text
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TO DAC:ADM:
CEtlTRAL FILES PDR:HQ LQA8i LP
,,DR GENERI p, o. 8oX 499. CoLUN Nebraska Pubh.c Power Distn. t mE~=E i risIc
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e STATE September 11, 1980 Mr. Karl V. Seyfrit, Director U.S. Nuclear Regulatory Commission Of fice of Inspection and Enforcement Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas-76011
Subject:
IE Bulletin No. 80-17, Supplement No. 1
Dear Mr. Seyfrit:
This letter is written to update you on the status of our planned installation of continuous level monitoring of the SDV.
In our earlier letter dated August 15, 1980, we indicated a completed installation approximately 2 weeks after an "at best" equipment delivery date of October 15.
We have now firmed up our design and order of the equipment.
An equipment delivery date of October-8 is now expected with installation, testing, and operation of the continuous level monitoring by October 10, 1980.
We were also asked to increase the frequency of our surveillance proceduces to monitor residue water in the SDV. The original bulletin required that the SDV be monitored daily for residue water for 6 days and, if results are acceptable, the interval could be extended to 7 days. We expeditiously developed a test and performed the test daily with no indication of residue water in the header.
We also have complied with a later directive to continue l
daily surveillance even though we have'found no indications of residue water.
We successfully completed the two scheduled scrams on July 26,1980, as required by the original bulletin with no indications of slow rod insertion or residue water being held up in the SDV.
We had an unexpected scram on August 4,1930 and a planned manual scram on the subsequent startup on August 4, 1980.
On both occasions the CRD system' worked as per design and with no indications of residue water during the following SDV surveillance test.
We had completed a rework of scram valves during our last refueling outage and feel that gross leakage from these valves is not probable.
- Thus, we have considered our daily check acceptable to assure adequate SDV.
Supplement No. I required a response.t<-
t.
following three items if a continuous monitor of the residue writ tr the SDV could not be installed by_ September 1,1980.
801024O/N L
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'Mr. Karl V. Seyfrit September 11, 1980 Page Two 1)
Documentation in detail why the installation cannot be completed by 9-1-80.
- 2) A commitment to a firm schedule for installation.
- 3) A comnitment to equipment changes and/or surveillance requirements in ado; tion to those not in effect that will provide adequate assurance of SDV operability in ' tha interim until installation is completed.
In response to item 1, it takes time and manpower to properly review require--
ments and provide an adequate design to meet such requirements.
Although providing level monitoring on a section of pipe seems rather simple, it becomes more complex when the results of that monitoring must be supplied to the control room.
Manpower is required to assure that wires are properly routed, fire penetration barriers are not jeopardized and that the overall plant safety is not reduced by a hurried or haphazard installation.
A reliable installation is also desirable.
The installation could not be completed by 9-1-80 because the above preliminary work was not completed and equipment could not be delivered.
The preliminary work has now progressed such that we know what we need and generally how we plan to do the job.
The equipment has been ordered.
In response to item 2, we believe the installation will be completed by October 10 providin6 the equipment is delivered as per schedule.
In response to item 3, we have installed a redundant check valve on each SDV to improve venting reliability. We have also initiated action as required by Supplement 3 to assure proper actions in event of a degraded air system.
We believe a more frequent surveillance test would be counterproductive to overall nuclear safety.
The manpower involved to properly conduct the test could be bette'r spent on other aspects of plant operation.
The impact of required performance of unnecessary tests also dilutes the entire surveillance -
program.
We, however, will commit to a surveillance test ramediately following (within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) any activity that we believe may increase the probability of leakage to'the SDV, such as' scram testing of control rods.
We will also increase the frequency of our testing if we have any indication that residue water in the SDV is becoming a problem or will become a problem.
And, of course, rather than shut down the plant because of an " order" we would undoubtedly increase our surveillance frequency to once per shift i
l i
Mr. Karl-V. Seyfrit September 11, 1980 Page Three even though it may be counterproductive to overall safety.
This decision would be based on our need for power from our nuclear station and economic consideration. ~ We trust that our actions and this response will be adequate such that the aforementioned is not necessary.
If you have any questions on this response or desire further discussion,
-please contact L. C. Lessor.
Sincerely, f
M J. i. Pilant Director of Licensing and Quality Assurance JMP:LCL:jmb I
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