ML20235J488

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Comments on Util 890106 Response to Generic Ltr 88-17 Re Expeditious Actions for Loss of Dhr.Experience Shows That Periodic Walkdowns of Tygon Tube Following Installation Needed.Audit Will Be Conducted
ML20235J488
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 02/13/1989
From: Engle L
Office of Nuclear Reactor Regulation
To: Cartwright W
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
GL-88-17, TAC-69756, TAC-69757, NUDOCS 8902240296
Download: ML20235J488 (3)


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February 13,'1989' Docket Nos.: 50-338 DISTRIBUTION T6M and50-339l

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' Mr. W. R; Cartwrights DMiller Vice President'--Nuclear LEngle t Virginia; Electric and Power Company'

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5000 Dominion Blvd.

EJordan, MNBB 3302 Glen Allen, Virginia 23060 BGrimes, 9/A/2:

BWilson, RII

Dear Mr. Cartwright:

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SUBJECT:

COMMENTS'ON THE VIRGINIA ELECTRIC AND POWER COMPANY RESPONSE TO GENERIC LETTER-88-17 WITH RESPECT TO EXPEDITIOUS ACTIONS FOR LOSS OF DECAY HEAT REMOVAL FOR NORTH ANNA POWER STATION UNITS 1 AND 2 (TACNOS.69756AND69757) 1

- The NRC staff has reviewed your January 6,1989 response to Generic Letter 88-17.-We find.that your response meets the intent of the generic letter with respect to expeditious actions. However, your response to some of the items is brief and therefore does not provide the detail to allow us to fully understand j

- some of your actions taken in response to GL 88-17..We have provided the following comments as guidance to assure that your actions are adequate.

1.

You reference the actions to be implemented prior to entering a

. reduced inventory condition.

We assume this refers to planned entries such as for maintenance.

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2.

You mention discussion of the Diablo-Canyon event with operations

- personnel and training for specific mid-loop operation and cooldown/draindown with your staff.

It is not specifically stated that maintenance personnel are also included. The item was intended to include all personnel who could affect reduced inventory operation.

3.

Yot. reference an example of containment closure in which operators had the personnel hatch closed within 15 minutes of notification, and final containment closure was achieved with the closing of the equipment hatch within 34 minutes.

No mention was made of previous checks on the ability to assure leaktightness of the hatch with the simplified quick closura.

4.

You mentioned a containment closure team but provided no information regarding how you will keep track of and control the many potential openings (piping, electrical, hatches) which may have to be closed simultaneously. We assume your procedures and administrative controls will address this topic.

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8902240296 890213 PDR ADOCK 0500 S

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W. R. Cartwright February 13, 1989 5.

You indicate that one continuous means of level indication using temporary l

tubing is now in place and that a TV camera indication will be available in the control room during the 1989 refueling outages.

Also, a second means of level indication is under review. When two instruments are in place, care should be taken to' resolve any discrepancy between the two measurement systems. Also, the pressure of the reference leg should approximate the pressure of the void in the hot leg or be compensated to obtain the correct level value.

6.

As you correctly state, we will accept use of one level indication in the short term at North Anna.

Since this dependence on one instrument is somewhat susceptible to errors, we suggest additional care be taken to avoid difficulties, particularly during mid-loop operation, and, until your longer term improvement program provides better instrumentation, that you consider additional mitigation measures in case RHR should be lost.

7.

Walking the tygon tube following installation to verify lack of kinks or loop seals is good.

Experience shows that periodic walkdowns are needed after installation. We recommend daily walkdowns when the tygon tube is in use, with an additional walkdown immediately prior to its being placed in use.

8.

You mention that procedures are being revised to provide a hot leg vent path. A pressurizer manway or steam generator manway is often used as means to provide Reactor Coolant System (RCS) venting. We note that relatively large hot side openings in the RCS, such as a pressurizer manway, can still lead to a pressure of several psi due to the large steam flow and the combination of flow restrictions in the surge line - lower pressurizer hardware - manway opening. Calculations should be performed to verify the effectiveness of the opening.

There is no need to respond to the above comments.

However, as you are aware, the expeditious actions you have briefly described are an interim measure to achieve an immediate reduction in risk associated with reduced inventory operation. These actions will be supplemented, and in some cases replaced, by program enhancements. We intend to audit both your response to the expeditious actions and your longer-term enhancement program. Our observationsto your response, also be covered in the audit of your expeditious actions.

Sincerely, Original signed by Leon B. Engle, Project Manoger Project Director 4te 11-2 Division of Reactor Projects-l/II Office of Nuclear Reactor Regulation cc:

See next page

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Mr. W. R. Cartwright North Anna Power Station 1

Virginia Electric & Power Company Units 1 and 2-l cc:

l Mr. William C. Porter, Jr.

C. M. G. Buttery, M.D., M.P.H.

County Administrator Department of Health Louisa County 109 Governor Street P.O. Box 160 Richmond, Virginia _23219 Louisa, Virginia' 23093 Regional Administrator, Region II Michael W. Maupin, Esq.

U.S. Nuclear Regulatory Comission Hunton and' Williams 101 Marietta Street N.W., Suite 2900 P. O. Box 1535 Atlanta, Georgia 30323 Richmono, Virginia 23212 Mr. W. T. Lough Virginia Corporation Comission Mr. G. E. Kane Division of Energy Regulation P. O. Box 402 P. 0. Box 1197 Mineral, Virginia 23117 Richmond, Virginia 23209 4

Old Dominion Electric Cooperative c/o Executive Vice President Innsbrook Corporate Center 4222 Cox Road, Suite 102 Glen Allen, Virginia 23060 Mr. W. L. Stewart Senior Vice President - Power Virginia Electric and Power Co.

Post Office Box 26666 Richnond, Virginia 2326'1 Mr. Patrick A. O' Hare Office of the Attorney General Supreme Court Building 101 North 8th Street Richmond, Virginia 23219 l

Resident Inspector / North Anna c/o U.S. NRC i

Senior Resident Inspector Route 2, Box 78 Mineral, Virginia 23117 l

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