ML20151S537

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Discusses Response to IE Bulletin 84-003,verifying That No Significant Refueling Cavity Seal Leakage Occured Prior to Fuel Movement.Visual Check Will Not Be Performed Due to Exposure of Inspectors to Significant Radiation Levels
ML20151S537
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 04/22/1988
From: Counsil W
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
IEB-84-03, TXX-88399, NUDOCS 8804280365
Download: ML20151S537 (3)


Text

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--F9 Log # TXX-88399

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Fi1e # 10115 C

Ref. # IEB 84-03 1UELECTRIC April 22, 1988

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Evenam Vuw Presk, U. S. Nuclear Regulatory Commission ATTN:

Regional Administrator, Region IV Arlington, Texas 76011

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION /rPSES)

DOCKET NOS. 50-445 AND 50-446 IE BULLETIN 84-03: RffUELING CAVITY WATER SEAL Gentlemen:

1 By letter dated December 4,1984, we provided our response to IE Bulletin 84-03.

In that response we committed to performing a visual check of the reactor cavity af ter filling the refueling cavity, to verify that there was no significant refueling cavity seal leakage prior to fuel movement.

Subsequently we reviewed industry experience associated with reactor cavity inspections, specifically, IE Inspection Notice 84-19, and concluded that this inspection exposes the inspectors to significant radiation levels and is unwarranted in light of ALARA considerations.

It is therefore our intention not to perform this visual check.

As was discussed in our_ initial bulletin response, the CPSES refueling cavity seal design is not expected to be susceptible to gross failure as described in the bulletin, The seal is expected to leak before any significant failure t

occurs.

Should leakage occur, adequate measures are provided for early detection and mitigation.

These measares include:

Remote monitoring (from-the control room) of the reactor cavity sump level and the reactor cavity sump pumps run time instrumentation, during and l

after refueling cavity fill. A reactor cavity sump high level alarm is also provided in the control room.

By Techical Spt:cifications, the refueling cavity level is monitored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to the start of and every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereaf ter during fuel movement when the fuel being moved or the fuel in the reactor vessel is t

irradiated. A refueling cavity low level alarm is provided at the spent fuel pool panel with a refueling cavity system trouble alarm in the control room.

Procedures are in effect which provide the operators specific instructions to identify and mitigate the effects of potential refueling cavity seal leakage.

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TXX-88399 April 22, 1988 Page 2 of 2.

We believe that the above indications, alarms, Technical Specifications and procedures provide sufficient assurance-that potential seal leakage will be detected and mitigating actions taken long before any damage resulting from the leakage can occur.

Very truly yours, k

W. G. Counsil 8SD/amb c - Mr. R. F. Warnick, USNRC OSP-CPSES Resident Inspectors, CPSES (3)

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.4' TXX-88399 April-22, 1988 UNITED STATES OF AMERICA NUCLEAR ~ REGULATORY C0ffilSS10N In the Matter of.

Texas. Utilities Electric Company Docket Hos. 50-445 50-446' (ComanchePeakSteamElectric Station, Units 1 & 2)

AFFIDAVIT W. G. Counsil.being duly sworn, hereby deposes and says that he is Executive Vice President, Nuclear Engineering and Operations of 10 Electric, the Applicant herein; that he is duly authorized to sign and file with the Nuclear Regulatory Commission this response to IE Bulletin 84-03 and that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.

flV71 W. G. Counsil Executive Vice President, Nuclear Engineering and Operations STATE OF TEXAS COUNTY OF DALLAS Subscribed and sworn to before me, a Notary %

Public in and for c,2 p

, on this h a day of 6

, 1988.

l aL Notary Public My commission expires: 1 /.),/ 4 o

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