ML20246N131

Comments on Util 890103 Response to Generic Ltr 88-17 for Expeditious Loss of Dhr.Nrc Intends to Audit Util Response to Expeditious Actions & Programmed Enhancements

ML20246N131
Person / Time
Site:	Seabrook
Issue date:	03/20/1989
From:	Nerses V Office of Nuclear Reactor Regulation
To:	Ellen Brown PUBLIC SERVICE CO. OF NEW HAMPSHIRE
References
GL-88-17, TAC-69776, NUDOCS 8903270307
Download: ML20246N131 (5)

Text

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March 20,1989 ya .

Docket No. 50-443

. Mr. Edward Brown -

. President & Chief Executive Officer

'New Hampshire Yankee Division Public. Service Company of New

Hampshire ,

Post Office Box 300 Seabrook, New Hampshire :03874 ,

SUBJECT:

-COMMENTS ON THE PUBLIC SERVICE OF NEW HAMPSHIRE RESPONSE TO GENERIC LETTER 88-17 FOR THE SEABROCK UNIT 1 STATION FOR EXPEDITIOUS ACTIONS FOR LOSS OF DECAY HEAT REMOVAL (TACNO.69776)

The NRC staff has reviewed your letter of January 3,1989 to Generic Letter .

(GL)8817. We find that your actions are directed toward meeting the intent of the generic letter with respect to expeditious actions. There are a numLer of instances where the details were lacking to fully' understand your actions taken in response to GL'88-17. You should consider our comments given in the enclosure in order to assure that your actions adequately addressed the intent of GL 88-17. There is no need to respond to the comments in the enclosure 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 the expeditious actions and your programmed enhancements. The areas where we do not fully understand'your responses, as indicated above, may be covered in

.the audit of expeditious actions. ,

Sincerely, 48 ga. On.gma . l signed by:

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'o Victor Nerses, Project Manager w Project Directorate I-3 Division of Reactor Project I/II

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st OFFICIAL PECORD COP,Y

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, , . Edward A. Brown S:abrook Nuclear Power Station

.':Public Service Company of New Hampshire cc:

Thomas Dignan, Esq. E. Tupper Kinder Esq.

John A. Ritscher, Esq. G. Dana Bisbee, Esq.

Ropes and Gray Assistant Attorney General 225 Franklin Street Office of Attorney General

' Boston, Massachusetts 02110 208 State House Annex Concord, New Hampshire 03301 Mr. Bruce B. Beckley, Project Manager Public Service Company of New Hampshire Resident Inspector Post Office Box 330 US Nuclear Regulatory Commission Manchester, New Hampshire 03105 Post Office Box 1149 Seabrook, New Hampshire 03874 Dr. Mauray Tye, President Sun Valley Association- Mr. A. M. Ebner, Project Manager 209 Summer Street United Engineers & Constructors Haverhill, Massachusetts 01830 Philadelphia, Pennsylvania 19101 Robert Backus, Esq.

Backus, Meyer and Solomon Steven Oleskey, Esq.

116 Lowell. Street Office of the Attorney General Manchester, New Hampshire 03106 One Ashburton Place P.O. Box 330 Diane Curran, Esq. Boston, Massachusetts 02108 Harmon and Weiss 2001 S Street, NW Carol S. Sneider, Esq.

Suite 430 Office of the Assistant Attorney General Washington, D.C. 20009 One Ashburton Place-P.O. Box 330 Philip Ahren, Esq. Boston, Massachusetts 02108 Assistant Attorney General State House, Station #6 D. Pierre G. Cameron, Jr., Esq.

Augusta, Maine 04333 General Counsel Public Service Company of New Hampshire Mr. Edward A. Brown, President Manchester, New Hampshire 03105 and Chief Executive Officer New Hampshire Yankee Division Mr. James M. Peschel Public Service Company of Public Service Company of New Hamsphire New Hampshire P.O. Box 300 Post Office Box 300 Seabrook, New Hampshire 03874 Seabrook, New Hampshire 03874 l

Seacoast Anti-Pollution League Regional Administrator, Region I 5 Market Street U.S. Nuclear Regulatory Commission Portsmouth, New Hampshire 03801 475 Allendale Road 25 Maplewood Ave.

King of Prussia, Pennsylvania 19406 Ms. Diana P. Randall Ashod N. Amirian, Esq.

70 Collins Street Town Counsel for Merrimac

! Seabrook, New Hampshire 03874 376 Main Street Haverhill, Massachusetts 08130 '

Mr. T. Feigenbaum Public Service Company of New Hamsphire Post Office Box 330 Seabrook, New Hampshire 03874

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Edward A. Brown, Public -Seabrook Nuclear' Power Station Service Company of New Hampshire cc:  !

Mr. Calvin A. Canney, City Manager Mr. Alfred V. Sargent, City Hall Chairman 126 Daniel Street Board of Selectmen Portsmouth, New Hampshire 03801 Town of Salisbury, MA 01950 Board of Selectmen Senator Gordon J. Humphrey RFD Dalton Road ATTN: Tom Burack

-Brentwood, New Hampshire 03833 531 Hart Senate Office Building. I U.S. Senate Ms. Suzanne Breiseth, Washington, D.C. 20510 Board of Selectmen Town of Hampton Falls Drinkwater Road Mr. Owen B. Durgin Chairman Hampton Falls, New Hampshire 03844 Durham Board of Selectmen Town of Durham Mr. Guy Chichester, Chaiman Durham, New Hampshire 03824 '

Rye Nuclear Intervention

' Committee Jane Spector. .

c/o Rye Town Hall Federal Energy Regulatory 10 Central Road Commission Rye, New Hampshire 03870 825 North Capital Street, NE Room 8105 Chairman, Board of Selectmen Washington D. C.-20426 RFD 2 South Hampton, New Hampshire 03827 Mr. R. Sweeney R. Scott Hill - Whilton Three Metro Center Lagoulis, Clark, Hill-Whilton Suite 610

& McGuire Rethesda, Maryland 20814 79 State Street Newburyport, Ma. 01950 Mr. Richard Strome, Director Ms. R. Cashman, Chairman New Hampshire Office of Emergency Board of Selectmen Management Town of Amesbury State Office Park South Town Hall 107 Pleasant Street Amesbury, Massachusetts 01913 Concord, New Hampshire 03301 Adjudicatory File (2)

Honorable Peter J. Matthews Atomic Safety and Licensing Board '

Mayor, City of Newburyport Panel 'scket City Hall U.S. Nuclear Regulatory Commission Newburyport, Massachusetts 01950 Washington, D.C. 20555 Mr. Donald E. Chick, Town Manager Congressman Nicholas Mavroules Town of Exeter 70 Washington Street 10 Front Street Salem, Massachusetts 01970 Exeter, New Hampshire 03823 Mr. G. Thomas Mr. John C. Duffett ,

Public Service Company of President-and Chief Executive Officer New Hampshire Public Service Company of New Hampshire Post Office Box 330 1000 Elm St., P.O. Box 330 Seabrook, New Hampshire 03874 Manchester, New Hampshire 03105

i ENCLOSURE  !

Comments on New Hampshire Yankee's January 3,1989 i Submittal on Generic Letter 88-17

1. You mention discussion of the Diablo Canyon event with operations i personnel of your staff. It is not specifically stated that maintenance personnel are also included. The item was intended to include all personnel who can affect reduced inventory operation.

2. Your addressing of containment closure is cursory and no information is provided regarding how you will keep track of and control the many potential openings which may have to be closed simultaneously. Procedures and administrative controls should address this topic.

3. You mention that a procedure revision will be made to ensure containment closure in appropriate time limits in the event of loss of decay heat removal capability. However, you did not mention commitment to an explicit time for closure. Enclosure 2 to Generic Letter 88-17 provides acceptable times. If you plan to use less than a full complement of bolts for sealing the equipment hatch then you should first verify that you can ,

make a proper seal of the periphery mating surfaces to meet the closure criteria.

4. You indicate that core exit temperatures will be logged every 15 minutes by an operator in the control room. Because this reading is being monitored in the control room, the need for frequent logging only arises for the case of loss of RHR. You may wish to consider a less demanding logging frequency and initiation criterion.

5. You indicate that Seabrook currently has two tygon tube sight glasses for RCS level indication which will be removed after programmed enhancements. Each tygon hose is connected to the bottom of a different RCS loop tap and is vented to the containment. You indicate that an observer will record level indications every fifteen minutes and that there will be communications with the control room. You also mention a Level Indicator No. 9405 which provides level indication locally and in the control room through the main plant computer. However, no details are given about the type of level indicator or where the reference legs are ,

located. 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. 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.

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7. You have indicated that a centrifugal charging pump will be availables whenever the RCS is in a reduced inventory condition.as the required high pressure safety injection pump.- You state that you have not designated a second means of adding water tn the RCS yet.- This will need to be identified and procedures in place in order to enter into a reduced inventory condition.

8. You state that " prior to installing nozzle dams, an appropriately sized opening on the hot leg side of RCS is provided." You have not stated what this opening is. Often a pressurizer manway or steam generator manway is used as a 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 in combination of flow restrictions in the surge line and lower pressurizer hardware may lead to pressurization. Calculations should be performed to verify the effective-ness of the opening.

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