ML20236A997

Comments on Licensee Response to Generic Ltr 88-17 Re Expeditious Actions for Loss of Dhr.Advises That Licensee May Wish to Consider Several Observations in Order to Assure That Actions Adequately Addressed

ML20236A997
Person / Time
Site:	Byron, Braidwood, 05000000
Issue date:	03/01/1989
From:	Olshan L Office of Nuclear Reactor Regulation
To:	Bliss H COMMONWEALTH EDISON CO.
References
GL-88-17, TAC-69725, TAC-69726, TAC-69728, TAC-69729, NUDOCS 8903200269
Download: ML20236A997 (6)

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-o NUCLEAR REGULATORY COMMISSION t

,E I WASHINGTON, D. C. 20665 3 [ March 1, 1989 i

Docket Nos. 50-454, 50-455 and 50-456, 50-457 '

Mr. ' Henry E. Bliss .

Nuclear Licensing Manager-Commonwealth Edison Company 1 Post Office Box 767 1 Chicago, Illinois 60690' I

SUBJECT:

COMMENTS ON THE COMMONWEALTH EDIS0N RESPONSE TO GENERIC- i_

LETTER 88-17 FOR BYRON STATION, UhlTS 1 AND 2, AND BRAIDWOOD 1

-STATION, UNITS 1 AND.2, FOR EXPEDITIOUS ACTIONS FOR LOSS OF l DECAY HEAT.. REMOVAL (TAC NOS. 69728, 69729, 69725, AND 69726) 1 The NRC staff has reviewed your response (letter of December 30, 1988) to ,

Generic Letter 88-17.. We find that it appears to meet the intent of the generic letter with respect to expeditious actions.-

Your response is brief and therefore does not allow us to fully understand your actions taken in response to GL 88-17. You may wish to' consider several observations in~ order to assure yourselves that the actions are adequately addressed:

1 1._ You mention discussion'of he Diablo Canyon event with operations J' personnel and training for rpecific mid-loop operation and cooldown/

draindown with your staff. R. M not specifically stated that maintenance personnel are also included. The item was intended to include all personnel wha can affect reduced inventory operation.

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2. You reference many of the responses as limited to " intentionally" entering a reduced inventory condition, We assume your meaning _ is for_ any entry into a reduced inventory concition that is deliberate on the part of the operators. Hence, an ent:ry for the purpose of repairing an unanticipated reactor coolant pump seal failure would be an intentional entry. An entry due to a loss of, coolant a":ident would be unintentional.

3. You reference the containment closure times of 30 minutes and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and indicate that you intend "to utilize the results of analysis that extends the time required for containment closure ...." This is acceptable.

4. Your addressing of containment closure is cursory r.nd no information is provided regarding how you will keep track of and control the many potential openings which may have to be closed simultaneously. We assume your procedures and administrative controls will address this topic.

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Henry E. Bliss l

5. Small changes in level between two measurement systems can make the difference between acceptable operation and loss of RHR. Also, two level instruments measuring at different locations may well sense different l 1evels. The accuracy and reliability of the level instrumentation may '

l need more thought.

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6. Walking the tygon tube following installation to verify lack of kinks or loop seals is good. Experience shows that periodic walkdowns are ner ied i after installation. We recomend daily walkdowns when the tygon tube is  !

in use, with an additional walkdown immediately prior to its being placed j in use.

7. As you correctly state, we will accept use of one level indication in the short term at Byron Unit 2 and Braidwood Units 1 and 2. Since this dependence on one instrument is somewhat susceptible to errors, we suggest additional care be taken to avoid difficulties, particularly during midloop operation, and that you consider additional mitigation measures in case RHR should be lost until your longer term improvement program provides better instrumentation.

8. Your use of gravity feed depends upon an adequate vent path, as you correctly state. You did not mention the vent size or otherwise indicate what you have.in mind. Since a pressurization of only a few psi would remove gravity feed as a possibility, you should carefully address this situation. 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 Tine - lower pressurizer hardware - manway opening.

Calculations should be performed to verify the effectiveness of the opening.

9. You appear to be attempting to work within existing technical specifications in meeting the generic letter recommendations. We note that technical specification changes will'be considered if existing specifications are overly restrictive.

There is no need to respond to the above observations at this time.

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, and these will be supplemented and in some cases replaced by programmed enhancements. We intend to audit both your response to

Henry E. Bliss the expeditious actions and your programmed enhancement program. The areas where we do not fully understand your responses as indicated above may be covered in the audit of expeditious actions.

Sincerely, h, .

Steph n P. Sands, Project Manager []tfleonard N. Olskan, Project Manager Project Directorate III-2 U Project Directorate III-2 Division of Reactor Projects - III, Division of Reactor Projects - III, IV, V and Special Projects IV, Y and Special Projects I

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e Mr. ' Henry Bliss - Byron /Brs '4 wood. Power Station' Commonwealth Edison Company Units 1 anu 2 CC:'

Mr. Jack Tain Dr.. Bruce von Zellen -

Atomic Power Distribution Department of Biological Sciences Westinghouse Electric Corporation Northern Illinois University ,

Post Office Box 355- DeKalb, Illinois 61107 Pittsburgh, Pennsylvania 15230.

U. S. Nuclear Regulatory Commission Joseph Gallo Esq. Byron / Resident Inspectors Office Hopkins and Sutter .

4448 North German Church Road -i 1050 Connecticut Ave., N.W. Byron, Illinois 61010

. Suite 1250 Washington, D.C. 20036 'Ms. Lorraine Creek Rt. 1, Box 182 C. Allen Bock, Esquire Manteno, Illinois 60950 .

Post Office Box 342  !

Urbana, Illinois 61801 Mrs. Phillip B. Johnson 1 1907 Stratford Lane Regional' Administrator Rockford, Illinois'61107 U. S. NRC, Region III 799 Roosevelt Road, Bldg. f4 Douglass Cassel, Esq.

Glen Ellyn, Illinois 60137 109 N. Dearborn Street Suite 1300

'Ms. Bridget Little Rorem Chicago, Illinois 60602 Appleseed Coordinator 117 North Linden Street' Ms. Pat Norrison Essex, Illinois '60935 913 N Main Street #707-Rockford, Illinois 61103-7058 Mr. Edward R. Crass -

Nuclear Safeguards and Licensing David C. Thomas, Esq.

Division 77 S. Wacker Drive Sargent & Lundy Engineers Chicago, Illinois 60601 55 East Monroe Street Chicago, Illinois 60603 Mr. Charles D. Jones, Director Illinois Emergency Services V. S. Nuclear Regulatory Commission and Disaster Agency Resident Inspectors Office 110 East Adams Street RRil, Box 79 Springfield, Illinois 62706 Braceville, Illinois 60407 l

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- Mr. Henry E. Bliss -

2- Byron /Braidwood Commonwealth Edison Company cc:

Mr. Michael C. Parker, Chief Division of Engineering Illinois Department of ,

Nuclear Safety l 1035 Outer-Park Drive Springfield, Illinois 62704 Michael Miller, Esq. l Sidley and Austin One First National Plaza Chicago, Illinois 60603 George.L. Edgar

.Newman & Holtzinger, P.C.

.1615 L Street, N.W.

Washington, D.C. 20036 Commonwealth Edison Company Byron Station Manager 4450 North German Church Road Byron, Illinois 61010 e

March 1, 1989 Henry E. Bliss the expeditious actions and your programmed enhancement program. The areas where we do not fully understand your responses as indicated above may be covered in the audit of expeditious actions.

Sincerely, 6

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Stephen P. Sands, Project Manager Leonard N. 01shan, Project Manager Project Directorate III-2 Project Directorate III-2 Division of Reactor Projects - III, Division of Reactor Projects - III, IV, V and Special Projects IV, V and Special Projects cc: See next page DISTRIBUTION EDocket file _'

NRC & Local PDRs PDIII-2 r/f GHolahan MVirgilio LLuther DMuller SSands L01shan OGC EJordan BGrimes ACRS(10)

Plant file PDIII-MPDIII- PDIII-PDIII2 h ; i DMuller Olshan:km SSansis LLuth -

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