ML20246B817

Comments on Licensee 881017 Response to Generic Ltr 88-17 Re Expeditous Actions for Loss of DHR During Nonpower Operation

ML20246B817
Person / Time
Site:	Three Mile Island
Issue date:	06/29/1989
From:	Hernan R Office of Nuclear Reactor Regulation
To:	Hukill H GENERAL PUBLIC UTILITIES CORP.
References
GL-87-12, GL-88-17, TAC-69785, NUDOCS 8907100126
Download: ML20246B817 (4)

Text

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4 L , June 29, 1989 Docket No. 50-289- DISTRIBUTION

'QDocketJUet RHernan NRC T fobal~PDRs OGC (info.only)

PDI-4 Reading EJordan Mr. H. D. Hukill .

SVarga BGrimes Vice President and Director, TMI-1 BBoger ACRS(10)

CPU Nuclear Corporation SNorris P. O. Box 480 Middletown, Pennsylvania 17057

SUBJECT:

COMMENTS On THE GPU NUCLEAR CORPORATION RESPONSE TO GENERIC LETTER 88-17 WITH RESPECT TO EXPEDITIOUS ACTIONS FOR LOSS OF DECAY fiEAT REMOVAL FOR THREE MILE ISLAND, UNIT 1 (TACNO.69785)

Generic Letter (GL) 88-17 was issued on October 17, 1988 to address the potential for loss of decay heat remeval (DHR) during nonpower 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 de:cription, specific plans and schedule for implementation of the six recommended pregram enhancements.

The NRC staff has reviewed your January 3, 1989 a.sponse to GL 88-17 on expeditious actions. We find that your response is generally complete and meets the intent of the generic letter with respect to expeditious actions. In this review, we have also taken into account your' October 30, 1987 response to GL 87-12 where appropriate. We also acknowledge the positive findings in Section 2.3 of Inspection Report 50-289/88-05 with regard to GL 87-12 activities.

However, in a few areas, your response is unclear to the extent that we cannet 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 edequately addressed:

1. You have provided a description of *,he training related to loss of DHR for licerse>i operators and contiwed cyclic requalification training for reducec inventory operation, where lowered loop cperations are anticipated, with licensed individuals of your staff. This included the outline of subjects for three lesson plans and a simulator exercise.

While your training propram appears to be comprehensive, your January 3, 1939 response does not specifically state that maintenance personnel are alru included in any of the training. The response to GL 87-12, Item 6 was somewhat vague in this area. The item was intended to include all personnel who can affect reduced inventory operation.

i n r 8907100126 890629 hk i O PDR ADOCK 05000289 l P FDC i

4 Mr. H. D. Hukill 2. You indicate that a detailed analysis is being performed for the time available to achieve containment closure. In the neantime, before plant specific times are obtained, you have not presented any times for containment closure. Generic Letter 88-17 states that " containment penetrations including the equipment hatch, may remain open provided closure is reasonably assured within 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of initial loss of DHR."

These provisions should be implemented prior to operating in a reduced inventory condition.

3. In some plants the quick closure of the equipment hatch is achieved by the installation of a reduced number of bolts. If you plan to use less than the full complement of bolts for sealing the equipment hatch then you shoula verify that you can make a proper seal of the periphery mating surfaces to meet the closure criteria.

4. Your accressing of containment closure did not specify how you will control the many potential openings (piping, electrical, hatches) which may have to be closed to establish containment integrity. We assume your procedures and administrative controls will address this topic following the revision scheduled for July 1989.

5. You state that one of your RCS level indications is by means of level transmitter (LT) 1037 wh1ch can be continuously anonitored in the control room where it has a digital readout and recorder. You state that LT 1037 is periodically checked by the operator and recorded at least once each shift. In your response to GL 87-12 dated October 30, 1987, you stated that the range of LT 1037 extends from the center of the B cold leg to 120 inches above. You have not provided information for LT 1037 regarding where the taps are located and the accuracy of the instrument. You indicate that a second means for RCS level measurement is being considered for i implementation by July 1989. This will be one of the following: (a)a ]

local ty90n standpipe providing RCS leyc1 frum the cold leg centerline with i closed circuit television camera providing control room monitoring i capability rencout; (.c;)(b) otherameans temporary level that are transmitter evaluated with to be continuous equivalent control room or superior to ]

the above. We will be interested in knowing the tap locations and accuracy l for the new level measurement systems being considered. When two or more i level instruments are in operation, care should be taken to resolve any  !

discrepancy between the measurement systems. Also, the pressure of the reference leg should approximate the pressure of the void in the hct leg or 1

be ccopensate<' to obtain the correct level value.

6. You state that one of your level measurement instruments may be a tygon l tube. Walking the tygon tube following installation to verify lack of l kinks or loop seals is necessary. Experience shows that periodic walkdowns are needed after installation. We recommend caily walkdowns when the tygon tube is in use, with an additional walkdown immediately prior to its being placed in use. The details should be in your ,

procedures. '

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,4 Mr. H. D. Hukill -S- June 29, 1989

7. -For the expeditious action regarding provision of at least two available -

or operable means of adding inventory to the RCS that are in addition to pumps that are a part of the normal DHR systems, you have indicated that you are working on a detailed analysis and when completed appropriate administrative controls will be developed to control the additional pumps )

and pathways. You referred to your response to GL 87-12 of October 30, '

1987 in which eleven pumps of varying pump capacity were listed for consideration. As stated in Enclosure 2, Section 2.6 of GL 88-17, at least one high pressure injection pump'should be provided. The water addition rate capable of being provided by each of the means should be at least sufficient to keep the core covered. Procedures for use of these systems during loss of DHR events should be provided. The path of water I

addition must be specified to assure the flow does not bypass the reactor vessel before exiting any opening in the.RCS. These provisions shoulf be bplemented prior to operating in a reduced inventory conditio6.

8. You have not stated the use of vent openings on the hot side of the RCS to relieve RCS pressurization. Calrvlations 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 formally respond to the above observations; however, they should be considered during implementation of actions resulting from GL 87-12 and GL 88-17.

- As you know, the expeditious actions you have briefly described are an interim i measure to echieve an imediate reduction in risk associated with reduce inventory operation, and these will be supplemented and in some cases replaced i by programed enhancements. Wa intend to audit both your response to the expeditious actions and your programmed enhancement prcyram. The areas where '

we do not fully understand your responses as indicated above will be covered in  !

the audit of expeditious actions.

l This closes out the staff ic/lew of your responses to the expeditious actions listed in GL 88-17. The area of proorammed enhancements will be addressed in a sepa*nt ktter.

l Sincerely.

Original signed by Ronald W. Hernan, Sr. Project Manager Project Directorate I-4 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation ec: See next page

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Mr. Henry D. Hukill- Three Mile Island Nuclear Station, GPU Nuclear Corporation Unit No I cc:

G. Broughton Francis I. Young 0&M Director, TMI-1 Senior Resident Inspector'(TMI-1)

GPU Nuclear Corporation U.S.N.R.C.

Post Of fice Box 480 Post Office Box 311 Middletown, Pennsylvania 17057 Middletown, Pennsylvania 17057 l Richard J. McGoey Manager, PWR Licensing Regional Administrator, Region I GPU Nuclear Corporation U.S. Nuclear Regulatory Comission 100 Interpace Parkway 475 Allendale Road Parsippany, New Jersey 07054 King of Prussia, Pennsylvania 19406 C. W. Smyth Robert B. Borsum THI-1 Licensing Manager j

Babcock & Wilcox GPU Nuclear Corporation Nuclear Power Generation Division Post Office Box 480 Suite 525 Middletown, Pennsylvania 17057 1700 Rockville Pike Rockville, Maryland 20852 Ernest L. Bla ke, Jr. , Esq. Governor's Office of State Planning Shaw, Pittman, Potts & Trowbridge and Development 2300 N Street, N.W. ATTN: Coordinator, Pennsylvania Washington, D.C. 20037 State Clearinghouse Post Office Box 1323 Harrisburg, Pennsylvania 17120 Sally S. Klein, Chairman Thomas M. Gerusky, Director Cauphin County Commissioner Bureau of Radiation Protection Dauphin County Courthouse Pennsylvania Department of l Front and Market Streets Environmental Resources Harrisburg, Pennsylvania 17120 Post Office Box 2063 Herrisburg, Pennsylvania 17120 Kenneth E. Witmer, Chairman Board of Supervisors of Londonderry Township 25 Roslyn Road E112abethtown, PA 17022 i l

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