ML20247B241

Comments on Expeditious Actions & Notice of Audit on Generic Ltr 88-17 Re Potential Loss of Dhr.Requests Addl Info Re Training Packages,Administrative Controls for Containment Closure & RCS Level Indications

ML20247B241
Person / Time
Site:	Mcguire, Catawba, McGuire, 05000000
Issue date:	05/17/1989
From:	Hood D Office of Nuclear Reactor Regulation
To:	Tucker H DUKE POWER CO.
References
GL-88-17, TAC-69732, TAC-69733, TAC-69752, TAC-69753, NUDOCS 8905240061
Download: ML20247B241 (6)

Text

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WASHINGTON, D. C. 20555 1

t [ May 17, 1989 Docket Nos.: 50-369, 50-370, 50-413, and 50-414 Mr. H. B. Tucker, Vice President Nuclear Production Department Duke Power Company 422 South Church Street Charlotte, North Carolina 28242

SUBJECT:

COMMENTS ON EXPEDITIOUS ACTIONS AND NOTICE OF AUDIT ON GENERIC LETTER 88-17 MCGUIRE AND CATAW A NUCLEAR STATIONS, UNITS 1 AND 2 (TAC NOS. 69732, 69733, 69752, AND 69753)

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

The NRC staff has reviewed your response to Generic Letter 88-17 'on expeditious actions in the letter of January 3,1989. As you are aware, the expeditious actions you have briefly described are an interim measure to achieve an

[ immediate reduction in risk associated wii aduced inventory operation, and these will be supplemented and in some cam replaced by programed enhancements.

We find that your response on expeditious actions appears to meet the intent of the GL but lacks some of the details requested in Enclosure 2 of GL 88-17. The j brevity of the iesponse to some items does not allow us to fully understand I your actions takan in response to GL 88-17. You may wish to consider several observations in oader to assure yourself that the actions are adequately addressed:

1. You mention a training package developed for appropriate personnel, including shift operators, supervisors, licensed staff senior plant staff, Operations Section Heads, and Outage Job Sponsors on the Diablo Canyon event. It is not specifically stated that maintenance personnel are also included in the training. The item was intended to include all personnel who can affect reduced inventory operation. The response was brief and did not provide an outline of topics covered.

2. You indicate that administrative controls have been developed and procedures are in place to reasonably assure that containment closure can be achieved with'n the time at which core uncovery could result from a loss of DHR coupled with an inability to initiate alternate cooling or l addition of water to the RCS inventory. You have not presented any times for containment closure. Generic Letter 88-17 states that " containment l penetrations including the equipment hatch, may remain open provided l

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Mr. H. B. Tucker May 17, 1989 closure is reasonably ued 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."

This time will be less , there are vent areas totaling greater than one square inch in the cold leg (see Enclosure 2, Section 2.2.2 of GL 88-17).

3. In some plants the quick closing of the equipment hatch is achieved by the installation of a reduced nunter of bolts. If you plan to use less than the 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 the RCS level indications at McGuire and Catawba are sensed at the hot leg of the vessel. The level indications are input to the Operator Aid Computer (0AC) which will automatically and continuously monitor the RCS level with alarm capability. You have referred to the level measurements in the plural form so it is assumed that there are at least two level systems. You have not indicated what type of level sensors are used. Also, you have not indicatec where the sensing taps are located. If the same taps are used for two level systems, a common error may occur and extra precautions are needed. When two instruments are in place, care should be taken to resolve any discrepancy between the two measurement systems.

5. For 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 provided information on two means with flow paths " protected" to ensure their availability during all phases of the outage. These means include a high head safety injection pump and a low head safety injection pump. You state that a loss of residual heat removal abnormal procedure provides guidance tc the operator on the use of the available makeup paths. .ou have not stated if this path is for hot or cold leg injection. As mentioned in Enclosure 2, Section 2.2.2 of GL 88-D, if openings totaling greater than 1 square inch exist in the cold legs, reactor coolant pumps and crossover piping of the RCS, the core can uncover quickly when pressurized under loss of RHR conditions. If this situation should arise, it is generally more effective to inject makeup water into the hot leg rather than the cold leg.

6. Procedures shculd be in place for relieving pressure, such as an adequate hot leg vent, whenever the RCS is in a reduced inventory condition with '

all nozzle dams installed. The removal of a pressurizer manway or steam generator manway, for example, 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 r6strictions in the surge line and lower pressurizer hardware may still lead to pressurization.

Mr. H.B. Tucker May 17, 1989

-There is no need to respond to the above observat ons at this time as we intend to audit both your response to the expeditious r , ions and your programmed enhancement program. The areas where we do not ally understand your responses as indicated above may be covered in the audit .f expeditious actions. Mr. K.

Jabbour or I will be arranging details c' " .sudit, including schedule > by telephone discussions with your Regulatory Compliance staff.

This closes out the staff review of your responses to the expeditious actions listed in the GL. The area of programed enhancements will be addressed in a separate letter.

Sincerely,

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'//Pb Darl S. Hood, Project Manager Project Directorate 11-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc: See Next Page

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Mr. fi. B. Tucker May 17, 1989 There.is no need to respond to the above observations at this time as we intend to audit both your response to the' expeditious actions and your programed enhancement program. The areas where we do not fully understand your responses as indicated above may be covered in the audit of expeditious actions. Mr. K.

Jabbour or I will be arranging details of the audit, including schedule, by telephone discussions with your Regulatory Compliance staff.

This closes out the staff review of your responses to the expeditious' actions listed in the GL. .The area of programmed enhancements will be addressert in a separate letter.

Sin cerely ,

N Darl S. Hood, Project Manager Project Directorate II-3 -4 Division of Reactor Projects - 1/II '

Office of Nuclear Reactor Regulation cc: See Next Page DISTRIBUTION:

MDocket:filec M. Rood 'ACRS(10) P-315 "itRC/ Local PDR D. Hood McGuire Plant File PDII-3 Reading H. Balukjian 8-E-23 Catawba Plant File S. Varga 14-E-4 OGC (FYI) 15-B-18 G. Lainas 14-H-3 E. Jordan MNBB-3302 D. Matthews 14-H-25 B. Grimes 9-A-2 PI PDh- DI -3 DHood:ls KJabbour /% DMatthews 05/g/89 05/p/89 05/q /89 U 05//7/89

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Mr. H. B. Tucker Duke Power Company Catawba Nuclear Station cc:

A.V. Carr, Esq. North Carolina Electric Membership Duke Power Company Corp.

422 South Church Street 3400 Sumner Boulevard Charlotte, North Carolina 28242 P.O. Box 27306 Raleigh, North Carolina 27611 J. Michael McGarry, III, Esq.

Bishop, Cook, Purcell and Reynolds Saluda River Electric Cooperative, 1400 L Street, N.W. . Inc.

Washington, D. C. 20005 P.O. Box 929 Laurens, South Carolina 29360 Nccth Carolina MPA-1 Senior Resident Inspector Suite 600 Route 2, Box 179N 3100 Smoketree Ct. York, South Carolina 29745 P.O. Box 29513 Raleigh, North Carolina 27626-0513 Regional Administrator, Region II U.S. Nuclear Regulatory Commission Ms. S. S. Kilborn 101.Marietta Street, NW, Suite 2900 Area Menager, Mid-South Area Atlanta, Georgia 30323 ESSD Projects Westinghouse Electric Corp. Mr. Heyward G. Sheal,*, Chief MNC West Tower - Bay 239 Bureau of Radiological! 4ealth P.O. Box 355 South Carolina Departme. ' of Health Pittsburgh, Pennsylvania 15230 and Environmental Contrul 2600 Bull Street County Manager of York County Columbia, South Carolina 29201 York County Courthouse York, South Carolina 29745 Ms. Karen E. Long Assistant Attorney General Richard P. Wilson, Esq. N.C. Department of Justice Assistant Attorney General P.O. Box 629 S.C. Attorney General's Office Raleigh, North Carolina 27602 P.O. Box 11549 Columbia, South Carolina 29211 Mr. Peter G. LeRoy Nuclear Production Department Piedmont Municipal Power Agency Duke Power Company 100 Memorial Drive P.O. Box 33189 Greer, South Carolins 29651 Charlotte, North Carolina 28241 l Mr. Alan R. Herdt, Chief Project Branch #3 U.S. Nuclear Regulatory Comission 101 Marietta Street, NW, Suite 2900 l

Atlanta, Georgia 30323 l

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+.'. i Mr. H.'B. Tucker Duke Power Company McGuire Nuclear Station cc:

Mr. A.V. Carr, Esq.- Dr. John M. B:rry Duke Power Company _

Department of Environmental Health P. O. Box 33189 Mecklenburg County -

422 South Church Street 1200 Blythe Boulevard Charlotte, North Carolina 28242 Charlotte, North Carolina 28203 County Manager of Mecklenburg County Mr. Dayne H. Browa,- Chief -

720 East Fourth Street Radiation Protection Branch Charlotte, North Carolina 28202 Division'of Facility Services' Department of Human Resources 701 Barbour Drive Mr. J..S. Warren Raleigh, North Carolina: 27603-2008 Duke Power Company .

Nuclear Production Department Mr. Alan R. Herdt, Chief P.- 0. Box 33189 Project Branch #3 Charlotte, North Carolina 28242 U.S. Nuclear Regulatory Connission 101 Marietta Street, NW, Suite 2900 J. Michael McGarry, III, Esq. Atlanta, Georgia 30323 Bishop, Cook, Purcell- and Reynolds

-1400 L Street, N.W. Ms. Karen E. Long

' Washington, D. C. 20005 Assistant Attorney General

. N. C.- Department of Justice

. Senior. Resident Inspector P.O. Box 629 c/o U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27602 Route.4, Box 529 Hunterv111e, North Carolina 28078 Regional Administrator, Region II U.S. ' Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia -30323 Ms. S. S. Kilborn Area Manager, Mid-South Area ESSD Projects Westinghouse Electric Corporation MNC West Tower - Bay 239 P. O. Box 355 Pittsburgh, Pennsylvania 15230 l l

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