ML20055F165

Forwards Comments Re NUREG-1410

ML20055F165
Person / Time
Site:	Vogtle
Issue date:	07/09/1990
From:	Hairston W GEORGIA POWER CO.
To:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
References
RTR-NUREG-1410 NUDOCS 9007160012
Download: ML20055F165 (2)

Text

George Power Compsny 333 Pcomont Avense Attenta Georp a 3030B N ' Teeephone 404 $20 3195

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W. Q. Ha6rston. HI Senior Vice Pics. dent Necar Operanons [(y.01881 0233 Docket Hos. 50-424 50-425 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 ATTN: James M. Taylor Executive Director for Operations Gentlemen:

V0GTLE ELECTRIC- GENERATING PLANT COMMENTS ON NUREG-1410

.Your letter of June 8,1990 transmitted a copy of the NRC incident Investigating Team (111) report (HUREG-1410) and stated that any comments should be provided by July 9, 1990. We believe that the 111 performed a thorough investigation of the event and that the report in general represents an accurate description of the circumstances surrounding the Site Area Emergency on March 20, 1990. We have reviewed the document and specific comments are attached.

Sincerely, yl.) ll<+h%

W. G. Hairston, 111 WGH,I11/HWM/gm Attachment

. xc: Georaia Power Company Mr. C. K. McCoy Mr. G. Bockhold, Jr.

Mr. R. M. Odom Mr. P. D. Rushton NORMS U. S. Nuclear Reaulatory Commission Mr. S. D. Ebneter, Regional Administrator l Mr..T. A. Reed, licensing Project Manager, NRR p 01 Mr. B. R. Bonser, Senior Resident inspector, Vogtle

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9007160012 900709 PDR. ADOCK 05000424 P PDC

i ENCLOSURE COMMENTS ON NUREG-1410

1. P. 1-5 states that the risk of core damage is greater from m'id-loop operation than d" % a fuel handling accident; no basis to support this assumption is r uvide

2. P. 2-3 states s v" asly that *special containment building penetrations had >

been construtte i anticipation of the need to quickly close the containment building during ~ outage." They were in fact constructed to permit SG sludge lancing with the equipment hatch closed.

3. P. 3-11 (3.2.5) needs to recognize that an emergency start of the diesel generators at VEGP has been changed to include starting on loss of offsite power.

4. P. 5-22 (5.5.2.2) states that maintenance personnel should be trained in mid-loop opcrations. This has not been determined to be appropriate for required naintenance training through systematic analysis of job tasks.  !

5. P. 7-5 and Appendix K (p. k-8) (Also, on page 7-7 for the first refueling outage) list several "nonconservative conditions" that existed in the plant, with the implication that, in retrospect, these conditions should not have existed. GPC contends that sufficient risk analysis does not exist to show that the list is non-conservative.

6. P. 10-3 (Conclusion 10.4.1) and J-28 state that foreign material in the DG jacket water temperature switches is considered the most likely cause of the DG trips during the event. GPC concurs that internal contamination is the most likely cause of one switch tripping. The second switch, although it had 1 internal foreign material, was also set low as a result of inadequate calibration procedures. Subsequent additional testing has shown that these switches are temperature sensitive, requiring that consistent calibration techniques be used to achieve the desired setting (reference LER 50-424/1990-006, revision 1). Therefore, GPC has concluded that the primary cause of the intermittent actuation of the. jacket water temperature switches was inadequate calibration in conjunction with foreign material.

7. P.10-8 (Conclusion 10.7.3) states that Vogtle had a high number of failures of DG sensors compared to the rest of the industry, from Appendix 1 (p. 1-8) of the report which itemizes these failures, a large percentage of the problems were calibration setpoint out of specification during construction 1

i. acceptance testing. Out of calibration in this application is not typically counted as a failure by either Vogtle or other plants in accordance with NPRDS reporting criteria; hence the NRC conclusion that Vogtle has a higher I number of switch failures is not based on comparable data.

8. P. K-2, states erroneously that future SG eddy current testing will be conducted on only 20 percent of the tubes. VEGP currently plans to follow the EPRI guidelines which require a minimum of 20 percent of the tubes to be tested as a base scope, plus an augmented sample of additional tubes for any active damage mechanism.

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