ML20246L836
| ML20246L836 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/08/1989 |
| From: | Pickett D Office of Nuclear Reactor Regulation |
| To: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| References | |
| GL-88-17, TAC-69793, NUDOCS 8905180413 | |
| Download: ML20246L836 (5) | |
Text
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May 8, 1989 Docket No.. 50-482 Mr. Bart D. Withers-President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation
.P. 0. Box 411 Burlington, Kansas.66839 i
Dear Mr. Withers:
1
SUBJECT:
COMMENTS ON THE WOLF CREEK NUCLEAR OPERATING CORPORATION'S i
I RESPONSE TO GENERIC LETTER 88-17, LOSS OF DECAY HEAT REMOVAL (TAC NO.'69793)
We have received your letters of December 23, 1988 (ET 88-0193) and February 2, i
1989(WM89-0041) responding to Generic Letter 88-17, Loss of Decay Heat Removal. We have reviewed these responses with regard to the eight recommended expeditious actions and the six progrrmmed enhancement recommendations identified in the generic. letter. As part of our audit inspection of licensee responses to the generic letter, Wolf. Creek is currently being considered for a joint NRC headque"ters/ region based inspection team to followup your responses to the q
generic letter.
In anticipation of such an inspection effort, the Division of.
4 Engineering and Systems Technology of the Office of Nuclear. Reactor Regulation has prepared a list of comments and observations resulting from their review of your responses..These comments and observations are enclosed.
There is no requirement for you to respond to the enclosure. You may wish to consider the enclosed comments and observations in order to assure yourselves i
that your proposed actions regarding the generic letter are adequate and complete. Finally, the enclosure would identify specific areas of interest for the anticipated joint inspection team.
Sincerely,
/s/
Douglas V. Pickett, Project Manager J
Project Directorate IV Division of Reactor Projects III, IV, V j
and Special Projects
)
Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/ enclosure:
See next page Mof DISTRIBUTION:
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May 8, 1989 Docket No. 482.
Mr. Bart D.' Withers President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P. O. Box 411.
Burlington, Kansas 66839
Dear Mr.~ Withers:
SUBJECT:
COMMENTS'0N THE WOLF CREEK NUCLEAR OPERATING CORPORATION'S RESPONSE.TO GENERIC LETTER 88-17, LOSS OF DECAY HEAT REMOVAL
.(TAC.NO.69793)
We have received your letters of December 23,1988 (ET 88-0193) and February 2, 1989..(WM89-0041) responding' to Generic Letter 88-17, Loss of Decay Heat '
Removal. We have reviewed these responses with regard to the eight recommended.
expeditious actions and the_six programmed enhancement recommendations' identified in the generic letter. As part of our audit inspection of licensee responses to the generic letter,. Wolf Creek'is currently being considered for a joint NRC headquarters / region based inspection. team to followup your responses to the generic letter.
In anticipation of such an inspection effort, the Division of Engineering and Systems Technology of the Office of Nuclear Reactor Regulation has prepared a_ list of comments and observations resulting from their review of your responses. These coments and observations are enclosed.
There is no requirement for you to respond to the enclosure. You may wish to-consider the enclosed comments and observations in order to assure yourselves that your proposed actions regarding the generic letter are adequate and complete.
Finally, the enclosure would identify specific areas of interest for the anticipated joint inspection team.
Sincerely, Q V TM Douglas V. Pickett, Project Manager Project Directorate IV Division of Reactor Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated L
.cc w/ enclosure:
E See next page i
1
.a
~
l
' Mr. Bart D. Withers
.C Wolf Creek Generating Station Wolf Creek Nuclear Operating Corporation Unit No. 1 R
cc:
Jay Silberg, Esq.
Mr. Gerald Allen Shaw, Pittman, Potts & Trowbridge Public Health Physicist 1800 M Street, NW Bureau of Air Quality & Radiation Washington, D.C.
20036 Control.
Division of Environment Chris R. Rogers, P.E.
Kansas Department of Health
, Manager, Electric Department and Environment Public Service Comission' Forbes Field Building 321 P. O. Box 360-Topeka, Kansas 66620 Jefferson City, Missouri 65102 Mr. Gary Boyer, Plant Manager Regional Administrator, Region III Wolf Creek Nuclear Operating Corp.
U.S. Nuclear Regulatory Comission P. O. Box.411 799 Roosevelt Road ~
Burlington, Kansas 66839 Glen Ellyn,' Illinois 60137 Regional Administrator, Region IV Senior Resident Inspector / Wolf Creek U.S. Nuclear Regulatory Comission c/o U. S. Nuclear Regulatory Comission Office of Executive Director P. O. Box 311 for Operations Burlington, Kansas 66839 611 Ryan Plaza Drive Suite 2000 Arlington, Texas 76011
.Mr. Robert Elliot, Chief Engineer Utilities Division..
Mr. Otto Maynard, Manager Licensing Kansas Corporation Comission Wolf Creek Nuclear Operating Corp.
4th Floor - State Office Building P. O. Box 411 Topeka, Kansas 66612-1571 Burlington, Kansas 66839 Office of the Governor State of Kansas Topeka, Kansas 66612 Attorney General 1st Floor - The Statehouse Topeka, Kansas 66612 Chairman, coffey County Comission Coffey County Courthouse Burlington, Kansas 66839 l
l 1
l Enclosure l
C0l'MENTS AND OBSERVATIONS RELATED TO WOLF CREEK RESPONSE TO GENERIC LETTER 88-17 DIVISION OF ENGINEERING AND SYSTEMS TECHNOLOGY 1.
You reference the commitments as implemented prior to entering a reduced inventory condition. The staff interprets this to mean that your commitments will b'e implemented prior to any entry into a reduced inventory condition that is deliberate on the part of the operators such as, for example, an entry for the purpose of repairing an unanticipated reactor coolant pump seal failure. On the other hand an entry due to a loss of coolant accident for example may not be deliberate and might be addressed in an alternate manner.
2.
You mention discussion of the Diablo Canyon event and other industry related events with plant operators.
It is not specifically stated that maintenance personnel are also included. The item should include all personnel who can affect reduced inventory operation and all personnel involved in plant operations during DHR system operation conditions.
3.
Your response to the Diablo Canyon event did not provide an outline of the subjects covered in the training provided before entering a reduced inven-tory condition. Training should ensure that personnel are aware of risks associated with operation in a condition with the RCS partially drained.
4.
You reference an example of containment closure when draining to greater than three feet below the reactor vessel flange but do not mention any times for closure of the personnel and equipment hatch. to Generic Letter 88-17 provides containment closure actions and times that we consider appropriate. You have not made any specific commitments for closure times.
Your response made no mention of a checkout on the ability of the equipment hatch to meet closure criteria with the simplified quick closure.
5.
You mentioned containment closure but provided no information regarding how you will keep track of and control the many potential cpenings (piping, electrical, hatches) which may have to be closed simultaneously.
Your procedures and administrative controls should address this topic.
6.
Your response to the core exit temperature measurement did not specify the i
time interval for recording the readings when using local monitoring. The l
recording intervals should be 15 minutes or less, and there should be pro-visions for immediate notification of the operator for temperature values outside the predetermined range.
1
7.
You indicate that one means of level indication using temporary tygon tubing is available which will be continuously monitored (with comunica-tions to the control room). Your response did not indicate an acceptable time interval of the recordings. Observations should be recorded at an interval no greater than 15 minutes during normal conditions. 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 va1ue.
8.
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 recomend daily walkdowns when the tygon tube is in use, with an additional walkdown imediately prior to its being placed in use.
9.
Your response to backup equipment did not indicate that equipment to be i
used would be available in time to prevent uncovering of the core.
You state that per Technical Specification 3/4.5.4 the Safety Injection Pump breaker and handswitch are tagged cut of service for cold overpressure protection but that off normal procedure OFN 00-015 describes actions re-quired for use. We recomend that you evaluate the time necessary to bring the Safety Injection Pump into use while preventing uncovering of the core.
1 10.
You mention that procedures are in place to provide a hot leg vent path.
You have not stated what opening you plan to use. A pressurizer manway or steam generator manway is often used as means to provide 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. The large steam flow rate in combination with flow restrictions in the l
surge line and lower pressurizer hardware may lead to pressurization. You l
mention an analysis for the minimum vent size. The calculations made should verify the effectiveness of the opening to be used.
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