ML20244D779

Comments on Util 890103 Response to Generic Ltr 88-17 Re Expeditious Actions for Loss of Dhr.Expeditious Actions to Achieve Immediate Reduction in Risk Associated W/Reduced Inventory Operation Will Be Replaced by Program Enhancement

ML20244D779
Person / Time
Site:	Davis Besse
Issue date:	06/12/1989
From:	Wambach T Office of Nuclear Reactor Regulation
To:	Shelton D TOLEDO EDISON CO.
References
GL-88-17, TAC-69739, NUDOCS 8906190255
Download: ML20244D779 (4)

Text

F June 12, 1989 t

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.l l Docket No. 50-346 DISTRIBUTION:

u Docket files NRC & Local PDRs PDIII-3 r/f MVirgilio L JHannon TWambach Mr. D. C. Shelton PKreutzer 0GC-WF1 Vice President Nuclear EJordan BGrimes Toledo Edison Company ACRS(10) PDIII-3 Gray files Edison Plaza 300 Madison Avenue Toledo, Ohio 43652

SUBJECT:

COMMENTS ON THE TOLEDO EDIS0N COMPANY RESPONSE TO GENERIC LETTER 88-17 WITH RESPECT TO EXPEDITIOUS ACTIONS FOR LOSS OF DECAY HEAT REMOVALFORDAVIS-BESSENUCLEARPOWERSTATION(TACN0.69739)

Generic Letter (GL) 88-17 was issued on October 17, 1988 to address the potential loss of decay heat removal (DHR) during noppower operation. In the GL, we requested (1) a description of your efforts to implement the eight recommended expeditious actions of the GL; and (2) a description of the enhancements, specific plans and a schedule for implementation of the six recommended program enhancements.

The NRC staff has reviewed your response to GL 88-17 on expeditious actions in the letter of January 3,1989. We find that it appears to meet the intent of the generic letter with respect to expeditious actions. Your response to some items 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. You mention initial training related to loss of DHR with license candidates and continued training for reduced inventory operation, where lowered loop operations are anticipated, with licensed individuals of your staff. It is not specifically stated that maintenance oersonnel are also included.

The item was intended to include all personnel who can affect reduced inventory operation.

2. You indicate that quick closure of the equipment hatch can be made with a minimum of four bolts. You should first verify that you can make a proper seal of the periphery mating surfaces of the equipment hatch to meet the closure criteria when using less than the full compliment of bolts.

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1 Mr. Donald C. Shelton 3. For. containment closure you have identified flow paths of concern as

" flow paths to the atmosphere ...." However,.we are concerned with all containment penetrations that could.cause a release.(e.g., penetrations from the containment into a fuel handling or auxiliary building).

4. Your addressing of containment closure provided no information 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.

.5. You mention that a minimum of two incore thermocouple will be monitored in the control room whenever the core is_in mid-loop condition and the reactor vessel head is on the. reactor vessel. It was not specifically stated whether the temperature indications would be alarmed as recommended in GL 88-17.

6. You indicate that you have plans for a long term modification for two reactor coolant system (RCS) level indications in the control room.

However, at present your level measurement is by a tygon tube system in which a local operator records RCS water level every 15 minutes and contacts the control room hourly. You also are considering the use of a closed circuit television in the control room instead of a local operator.

You have not described the level instrumentation tap locations or the  ;

instrument accuracy. The pressure in the reference leg should approximate the pressure in the void in the hot leg or be compensated to'obtain a correct value. A single level indication is acceptable in the'short term.

Since dependence on one instrument is more susceptible to errors, additional care should be taken to avoid difficulties during midloop operation.

7. Walking the tygon tube following installation to verify lack of kinks or loop seals is necessary. 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 have not stated the use of any vent opening on the hot side of the RCS to relieve RCS pressurization. The removal of a pressurizer manway or steam generator manway is a means to provide RCS venting. Calculations need to be performed to verify the effectiveness of RCS openings, however, because even for relatively large hot side openings in the RCS, pressurization to several psi can still result. For example, with removal of a pressurizer manway large steam flows in combination with flow restrictions in the surge line and lower pressurizer hardware may still lead to pressurization.

There is no need to respond to the above observations.

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.s l Mr. Donald C. Shelton- As you are aware, the expeditious actions you have briefly described are an )

-interim measure to achieve an immediate reduction in risk associated with l reduced inventory operation, and these will be supplemented and in some cases '

replaced by programmed enhancements. We intend to audit both your response to I 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.

1 This closes out the staff review of your res)onses to the expeditious actions  :

listed in the GL. The area of programmed enlancaments will be addressed in a  !

separate letter.

Sincerely, l

/s/ 1 Thomas V. Wambach, Sr. Project Manager Project Directorate III-3 Division of Reactor Projects - III, .

IV, V and Special Projects  !

Office of Nuclear Reactor Regulation ]

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l Office: LA/PDII -3 PM/ I PD/SDII-3 Surname: PKreat r TWambach/tg /Hannon Date: (,/jg/89 g //Z/89 p/l M9 i

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,,' 3 k g . 4 L:. Mr. Donald C. Shelton Davis-Besse Nuclear Power Station Toledo Edison Comp ny Unit No.'1

- cc:-

David E. Burke, Esq.

The Cleveland Electric Radiological Health Program Illuminating Comp my Ohio Department of Health P. O. Box 5000 1224 Kinnear Road Cleveland, Ohio 44101 Columbus, Ohio 43212 Mr. Robert W. Schrauder Attorney General Manager, Nuclear Licensing Department of Attorney Toledo Edison Company General Edison Plaza 30 East Broad Street 300 Madison Avenue Columbus, Ohio 43215 Toledo, Ohio 43652 Mr. James.W. Harris, Director Gerald Charnoff, Esq. (AddresseeOnly)

' Shaw, Pittman, Potts Division of Power Generation and Trowbridge Ohio Department of Industrial Relations 2300 N Street N.W. 2323 West 5th Avenue Washington, D.C. 20037 P. O. Box'825 Columbus, Ohio 43216 Regional Administrator, Region III

- U.S. Nuclear Regulatory Comission Ohio Environmental Protection Agency 799 Roosevelt Road 361 East Broad Street Glen Ellyn, Illinois Columbus, Ohio 43266-0558 President, Board of Mr. Robert B. Borsum County Commissioners of

- Babcock & Wilcox Ottawa County Nuclear Power Generation Division Port Clinton, Ohio 43452 Suite 525, 1700 Rockville Pike Rockville, Maryland 20852 State of Ohio Public Utilities Comission Resident Inspector 180 East Broad Street U,S. Nuclear Regulatory Comission Columbus, Ohio 43266-0573 5503'N. State Route 2 Oak Harbor, Ohio 43449 4

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