ML20100B693
| ML20100B693 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/07/1995 |
| From: | Kitchens W GEORGIA POWER CO. |
| To: | |
| References | |
| OLA-3-I-MOS-234, NUDOCS 9601190282 | |
| Download: ML20100B693 (2) | |
Text
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r interoffice Correspondence DOCKET'Uborgia Power 1 i
UShRC r'
'95 DCT 20 P3 :28 DATE:
September 15, 1989 0FFICE OF SECPETARY CDCKETING & SERVICE RE:
Addition of Hydrogen Peroxide During 1R1 ggjacg Log: NOV-00385 Security Code:
NC l
l FROM:
W. F. Kitchens TO:
G. Bockhold, Jr.
During shutdown for the first refueling outage, hydrogen peroxide was added to the RCS as a cleanup measure to reduce radiation exposure to outage workers.
This was a planned activity shown on the schedule, and was perfortned in MODE 5 during the initial RCS drain down.
The chemical was added in amounts of approximately 2.5 gallons four times during October 12, 1988 and October 13, 1988.
(Attached is a chronology l of operations performed on these dates, as documented in the SS logbook.)
l l
To comply with Tech Spec 3.4.1.4.2, a clearance (#1-88-371) was i used to ensure that certain RMWST valves were locked closed per procedure 14228-1.
During the hydrogen peroxide additions, three of these valves l were momentarily opened uncer functional test provisions.
The action l statement was entered each time, and these valves reclosed within four l minutes or less, as documented in the SS logbook.
l Operations Management was consulted on the appropriateness of l entering the ACTION statement of 3.4.1.4.2 to perform chemical addition l in MODE 5 with RCS loops not filled. Management provided concurrence.
l and gave a tech spec interpretation that allowed momentary entry into this ACTION statement.
(Based on accepted practice at another nuclear plant, verbal guidance was given that "immediate" action must be taken within five (5) minutes.) After consulting with the NSAC Manager, a Tech Spec cnange request was initiated to make it clear that these q.
valves coulc be opened momentarily for addition of chemicals.
This Jg change would avoid the need to enter the ACTION statement.
The LDCR oo n, was initiated, and scheduled for completion prior to the next refueling.
$8 Also, an outage critique comment was initiated to track this Tech Spec yQ 1mprovement.
CD U Today, I was infortned of a concern by a Technical Support staff memtar that a " tech spec violation" had occurred when the RMWST valves 0<
were opened during 1R1.
This staff member was processing the LDCR C
for the Tech Spec change, and when he discovered we voluntarily entered ACTION statement 3.4.1.4.2, was concerned that we may have violeted o'n. o Tech Specs.
This memo is to document the facts, and address this concern.
NUCLEAR REGULATORY COMMISSION
- PLAltTyr8 OfPDg Docket No. $0-424/425-Ot.A-3 EXHIBIT NO. "(1 - 7M f
DNel7 p)g in the matter of Georale Power Co. et af.. Voatie Units 1 & 2 g
O staff G Applicant [Intervonor O Other
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O Idantifip Moived O Rejected Reporter
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G. Bockhold, Jr.
Page 2 l
September 15. 1989 In my opinion, no violation of Tech Specs occurred, because when l
the LCO was not satisfied, the appropriate ACTION statement was entered l
and ennropriate actions were taken per 3.4.1.4.2.
This is a basic l
Tc
- compliance issue, and direction for such compliance is given ins 3.0.1 and 3.0.2.
The BASIS for these Tech Specs was not I know of no legal restriction upon voluntary entry into 3i, icch Spec ACTION statement, so long as the action is taken as stated.
l Lince I would prefer to not have to enter ACTION statements to perform l
routine plant operations I continue to support the LDCR for a Tech i
Spec change.
A side issue that was addressed because of our experience during the first refueling was to define "with reactor coolant loops not filled".
As part of the review described above, af ter consultation with Westinghouse, we issued, on 2/22/89, a written Tech Spec interpretation.
A verbatim definition would be that loops are not filled when level has been drained below 188'-3" (top of hot leg).
I believe that level was above Jt taE pf the hot l_egs when the hydrocen neroxide was added to the RCS on 10/12/88 and 10/13/.8 Wherefore, an argument coulTbe made that l
l 3.4.1.4.2 was not applicable ata hat time. Our current Tech Spec interpretation
~
py_t t this specification into effect upon drain aown oeiow e5w pressurizer cold cal level, and is conservath e.
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l WFK/ erd Attachment xc:
J. E. Swartzwelder R. L. LeGrand A. G. Rickman M. B. Lackey A. L. Mosbaugh NORMS 0
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