ML20129H789
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MEETING NO.
PR8 89-124 OATE 9/14/89 PAGE 1 0F 3 MEETING CONVENED 1:00 AM/PM: M ETING ADJOURNED 2:50 AN/PM 1
THIS M ETING @ ISED BF:
(
) CHAIRMAN ( X ) VICE-CHAIRMAN:
A. L. Mosbaugh REGULAR MEMBERS PRESENT: J.E. $wartzwalder M.W. Norton J. G. Aufdenkampe R.L. LeGrand H.M. Handfinger M.8. Lackey (non-voting) G.R. Frederick (non-voting)/
PR8 Secretary - C.L. Cross THESE ALTERNATES ARE HERE8Y AUTHORIZED TO REPRESENT ASSENT REGULAR MEM-BERS:
1 VOTING ALTERNATE:
FOR YOTING ALTERNATE:
FOR NON-VOTING ALTERNATE:
FOR NON-VOTING ALTERNATE:
FOR NON-VOTING ALTERNATE:
FOR NON-VOTING ALTERNATE:
FOR w.v. h PRB CHAIRMAN GUESTS
.GGNSWhTANTS/ TECHNICAL ADVISORS:
l G. Bockhold i
E. J. Toucin (OPC)
A. G. Rickman J. N. Roberts l
PR8 ACTION ITDt3 INITIATED: PR8 P9-124-01 and PR8 89-124-02 l
PRS ACTION ITDt5 CLOSED:
None PR8 MINUTES APPROVED:
89-122 and 89-123
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SECREIARY l
U 9611040042 960827 PDR FOIA i
KOHN95-211 PDR
PR8 89-124
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Page 2 of 3 PRS METIIIG MIIRfTES CONTIIRIRTION SMET A.
Meeting Minutes89-122 and 89-123 were approved as presented.
j Clariftsation was made to 89-123 noting that W. F. Kitchens was l
in attendance onsite.
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G. Sockhold briefed the board on discussion issues from the 9/13/89 Safety Review Board Meeting.
Unanimous decisions - SR8 discussed whether safety related items approved by non-unanimous decision should not be implemented until a unanimous decision can be rendered.
C. K. McCoy will determine policy on this issue.
Safety Analysis - All PR8 Members,need to review NSAC-125 for j
use in Safety Evaluations for PR8 review items.
C.
G. Bockhold briefed the board on a general policy to be followed j
when an individual has a problem question or issue on reportability.
2 Policy Individual should use line management if help is needed in making reportability determination.
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Alternatives Quality Concern Program
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Deficiency Card
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G. Bockhold agreed that an overall consistency was needed for what constitutes reportability of "outside the design basis".
A request will be made for Corporate to provide a written interpretation.
The board discussed the issue of adding hydrogen peroxide in the RCS via the chemical addition tank valves prior to refueling.
An REA has been written to allow manipulation of these valves.
j Initial cost estiastes for the analysis is $50.000.
The board also discussed the operation of tnese valves during the last refueling outage and whether or not this action may be reportable.
Further review and discussion of this topic was deferred until the following PR8 meeting when W. F. Kitchens could be in attendance.
Ron LeGrand was given a PR8 Action Item to look into.
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a) Overall plant configuration and Chemistry procedures to ensure that too much hydrogen peroxide couldn't be added.
b) Sample sink 4
l This action item will be PR8 Action Item 89-124-01.
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A revision to the August 1989 NRC Monthly Operating Report was unanimously recomuended for approval.
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PR8 89-124 Page 3 of 3 i
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LDCR FS-89-045 to FSAR Appendix 9A which provides justifications
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for deviations on separation of safe shutdown circuits on es6edded conduits was unanimously recommended for approval with comment.
j The board cosiiknted that the justification writeup should exclude reference to an Operations Abnormal Operating Procedure. No unreviewed i
safety question involved.
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The.following procedures were unanimously recommended for approval.
j No unreviewed safety question involved.
l 36020-C, Rev. 4
" Radioactive Gaseous Effluent Re. lease Permit l
Generation and Data Control - Computer Method" 13216-1, Rev.16. " Liquid Waste Release" 13216-2, Rev. 4
" Liquid Waste Release" j
36016-C, Rev. 3
" Radioactive Liquid Effluent Permit Generation j
and Data Control - Manual Method" 2
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The following procedures were unanimously recommended for approval 2
with comment.
No unreviewed safety question involved.
4 91204-C Rev. 10
" Emergency Response Cosmunications" i
Ensum step 5.9.11 conforms with procedure 00051-C.
J.N. Roberts was given action to pursue deleting classification of NUE upon loss of P8X.
PRS Action Item 89-124-02.
i' 36010-C, Rev. 4 "Offsite Dose Calculation (0DCM) Implementation" Correct note on Pg. 9 to be consisten.t with i
36020-C.
36015-C, Rev. 8
" Radioactive Liquid Effluent Release Pamit Generation and Data Control - Computer Method" l
Correct mci to uCi in NOTE on Pg. Ig.
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The board unanimously gave approval to add to design list, the j-reconuendation of an RER to install blocking switches for Radiation i
Monitors 1RX0003 and 1RX2565 in order to prevent unplanned ESF l
Actuations during testing.
M.W. Norton took the action to place this DCR on future design list.
Ref. Open Item 1570g.
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Temporary Jumper and Lifted Wire 89-001 to clear ground alam on 10Y18, restoring alam for breaker trips was unanimously recommended for approval with comment.
No unreviewed safety question involved.
The board commented that the response should be "No" to question j
2.2 of the safety evaluation since the TJ & LW to defeat the i
ground /undervoltage alam will not increase the probability or consequences of a me1 function of safety related components or j
equipment.
This is in confomance with NSAC-125.
Meeting Adjourned l
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TEST REVIEW 80ARD 4
i 89-124-01 ACTION IT M TRS-
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DATE 9-15-89 1
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i Description Investicate 1) overall plant configuration i
j and Chemistry procedures to ensure that'too much hPTRB hydrogen peroxide can't be added to RCS 2) sample j
5ecretary sink.
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Resp. Mas 6er R.L. LeGrand Oue Oste 10/15/89 Ref. Document (s) i l
4 Resolution J
Re'ponsible s
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@ TRS i
Member
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I sismature/Date i
i Meeting No.
Approval Yes h
Date,,
No.
l Meeting r n u secretary Reaerts i
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1 1EG9 TEST REVIEW 804R0
-ACT!tNI IMTRB. 89-124-02 j
DATE 9-15-89
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l Description Pursue deletion of classification of NUE upon loss of P8X.
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1 Secretary
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Resp. Mes6er K.'R. Holmes (J.N. Roberts) i Due Date 10/15/89 i
I Ref. Documer.c (s)
Resolution 5
l Responsible
@ TRB Mes6er l
Attachments sisensure/nate Meeting No.
Approval Yes _
h Date No Meeting i
<-/ ins secretary Ms i
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V C.QC I Y
Interoffice Correspondence GeorgiaPower1 DATE: September 15, 1989 RE:
. Addition of Hydrogen Peroxide During 1R1 Log: NOV-00385 Security Code: NC FRON:
W. F. Kitchens T0:
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 performed 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 of operations performed on these dates, as documented in the SS logbook.)
To comply with Tech Spec 3.4.1.4.2, a clearance (#1-88-371) was used to ensure that certain RWST valves were locked closed per procedure 14228-1. During the hydrogen peroxide additions, three of these valves were momentarily opened under functional test provisions. The action statement was entered each time, and these valves reclosed within four minutes or less, as documented in the SS logbook.
Operations Management was cc:.sulted on the appropriateness of entering the ACTION statement of 3.4.1.4.2 to perform chemical addition in MODE 5 with RCS loops not filled. Management provided concurrence.
.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 i
within five (5) minutes.) After consulting with the NSAC Manager.
i a Tech Spec change request was initiated to make it clear that these valves could be opened momentarily for addition of chemicals. This change wuld avoid the need to enter the ACTION statement. The LDCR was' initiated, and scheduled for completion prior to the next refueling.
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Also, an outage critique consent was initiated to track this Tech Spec improvement..
Today..I was informed of a concern by a Technical Support staff member that a " tech spec violation".had occurred when the RWST valves
-were opened during 1RI. This staff member was processing the LDCR i
for the Tech Spec change, and when he-discovered we voluntarily entered j
ACTION statement 3.4.1.4.2 was concerned that we may have violated Tech Specs. This meno is to document the facts, and address this concern.
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- s. Sockhold, Jr.
Page 2 September 15, 1989 In my opinion, no violation of Tech Specs occurred, because when the LCO was not satisfied, the appropriate ACTION statement was entered
.and appropriate actions were taken per 3.4.1.4.2.
This is a basic Tech Spec compliance issue, and direction for such compliance is given in sections 3.0.1 and 3.0.2.
The BASIS for these Tech Specs was not violated.
I know of no legal restriction upon voluntary entry into any Tech Spec ACTION statement, so long as the action is taken as stated.
Since I would prefer to not have to enter ACTION statements to perform routine plant operations, I continue to support the LDCR for a Tech
. Spec change.
A side issue that was addressed because of our experience during the first refueling was to define "with reactor coolant loops not ff11ed".
As part of the review described above, after consultation with Westinghouse, we issued, on 2/22/89, a written Tech Spec interpretation. A verbatim definition would be that loops are not filled wher. level has been drained below 188'-3" (top of hot leg).- I believe that level was above the top of the hot legs when the hydrogen peroxide was added to the RCS on 10/12/88 and 10/13/88. Therefore, an argument could be made that 3.4.1.4.2 was not applicable at that time. Our current Tech Spec interpretation puts this specification into effect upon drain down below 255 pressurizer cold cal level, and is conservative.
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Attachment I
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J. E. Swartzwelder R. L. LeGrand i
A. G. Rickman N. 8. Lackey j
A. L. Mosbaugh j
NORMS i
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UNIT 1 SHIFT SUPERVISOR LOG SUf8ERY f
10/11/88 0536 MODE 5, 65 psig, 90*F in RCS.
0721 Initiated RCS drain down.
t 1053 Verified RWST valves locked closed per 14228-1.
1505 Initiated RCS drain down to 194' elevation.
1646 RCS drain stopped at 194' elevation.
10/12/88 0400 CVCS ches mixing pot loaded with hydrogen peroxide. Functional clearance #1-88-371 to allow sending chemicals. Valves 1-1208-U4-177, 176, and 181 opened to fill drain pot. Above mentioned valves immediately shut upon completion of fill in accordance with Tech Spec 3.4.1.4.2. -
0705.
Valves 1-1208-U4-177,176, and 181 opened to inject hydrogen peroxide into RCS.
0709 Valves'1-1208-U4-177, 176, and 181 locked closed.
0754
'RCS drain down halted at 188'-3" per tygon tube.
i 10/13/88 t
1030 Valves 1-1208-U4-177, 176, and 181 opened to inject hydrogen
~ peraxide into RCS.
1034 Valves 1-1208-U4-177, 176, and 181 locked closed.
1640 Opened 1-1208-U4-177, 176, and 181 to inject hydrogen peroxide to RCS.
1644 1-1208-U4-177, 176, and 181 locked closed, i
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