ML20247L448

Comments on Licensee 881229 Response to Generic Ltr 88-17 W/Respect to Expeditious Actions for Loss of Dhr.Response Appears to Meet Intent of Ltr But Lacks Details for Listed Items

ML20247L448
Person / Time
Site:	Farley
Issue date:	05/25/1989
From:	Reeves E Office of Nuclear Reactor Regulation
To:	Hairston W ALABAMA POWER CO.
References
GL-88-17, TAC-69742, TAC-69743, NUDOCS 8906020171
Download: ML20247L448 (4)

Text

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UNITED STATES

8. n NUCLEAR REGULATORY COMMISSION y E WASHINGTON, D. C. 20555

%, * . . . # May 25. 1989 Docket Nos.: 50-348 and 50-364 Mr. W. G. Hairston, III Senior Vice President, Nuclear Operations Alabama Power Company P. O. Box 1295 Birmingham, Alabama 35201 l

Dear Mr. Hairston- '

SUBJECT:

COMMENTS ON THE RESPONSE TO GENERIC LETTER 88-17 WITH RESPECT TO EXPEDITIOUS ACTIONS FOR' LOSS OF DECAY HEAT REMOVAL FOR FARLEYNUCLEARPLANTUNITS1AND2(TACNOS.69742AND69743)

On October 17, 1988, GenericLetter(GL)88-17was'issuedtoaddresstheloss of decay heat removal during nonpower operation. In the GL, all licensees were asked to provide descriptions of 1) efforts to implement the eight recommended expeditious actions set forth in the GL, and 2) enhancements, specific plans, and a schedule for implementation of the six recommended programmed enhancements.

The NRC staff has reviewed your response dated December 29, 1988 to Generic Letter (GL)88-17. It appears to meet the intent of the generic letter with respect to expeditious actions. However, your response lacks sufficient detail to 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 discussion of the Diablo Canyon event with operations personnel and training for specific mid-loop operation and cooldown/

draindown with 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. You reference an exam)1e of 3rompt containment closure in which closing of the equipment hatc1 is ac11eved by the installation of four bolts. No mention was made of a checkout of the ability of the hatch to meet the closure criteria with the simplified quick closure.

3. You state that core-exit temperature indications will be provided which will allow control room operators to have continuous, independent, and representative indications. You have not indicated if there will be an alarm. You state that operations procedures will specify that temperature indications be periodically checked and . recorded by control  ;

room personnel. Because the reading is being monitored in the control l room, the need for frequent logging only arises for the case of loss of I RHR.  !

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A 9 Mr. W. G. Hairston, III May 25, 1989 {

4. You state that plant procedures call for two RCS water level indications  ;

whenever the plant is in a reduced inventory condition. One of these is '

an independent level indicator obtained by rescaling and recalibrating an RCS loop flow transmitter (loop A or C) to provide indication in the control room when in a reduced inventory condition. The other RCS water level indicator is a pressure transmitter installed in loop B with indication provided in the control room and a tygon hose affixed to the same loop. Since both use a common tap off the loop B RCS, only one will be considered as independent. We note that the tygon tube is acceptable at present, but not as a candidate for use in programmed enhancements, i You indicate that a continuous watch is placed at the tygon hose with l continuous communication to the main control room. As noted in Enclosure 2 l to GL 88-17, when in a reduced inventory condition with level monitoring from a location other than the control room, observations should be recorded at intervals no greater than 15 minutes. 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.

5. You state that the hose for level measurement will be verified to be free of kinks. Experience shows that periodic walkdowns are needed after installation. We recommend daily walkdowns when the level hose is in use, with an additional walkdown immediately prior to its being placed in use, to verify that the hose is free of kinks or loop seals.

6. You state that procedures will be revised to require the availability of at least two means of adding water to the RCS in case both RHR pumps become inoperable. At least one of these injection means will be a high pressure charging pump capable of injecting water into the RCS. For the  !

second means, you state that either a charging pump or gravity drain from the refueling water storage tank (RWST) will be used. This procedure for the second means must be in place before entering reduced inventory operation. If using gravity drain from the RWST, a pro s for ventin see Item 7 below)g must be in place and verified by calculations (per

7. You mention that procedures are being revised to require that the reactor vessel head be detensioned and capable of relieving pressure, or that an adequate hot leg vent be provided, whenever the RCS is in a reduced inventory condition with all nozzle dams installed. 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 surge line and lower pressurizer hardware may lead to pressurization.

Calculations should be performed to verify the effectiveness of the opening.

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. i Mr. W. G. Hairston, III  ;

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l 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; 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 enhancement program. The areas where we do not fully understand your responses as indicated above, niay be covered in the audit of expeditious actions.

You are not required to respond to the seven observations presented above.

This completes our review of your response with respect to expeditious actions as listed in GL 88-17. The area of programmed enhancements will be addressed in a separate letter.

Sincerely, i

Edward A. Reeves, Senior Project Manager Project Directorate II-1 Division of Reactor Projects I/II, NRR cc: See next page Distribution:

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Mr. W. G. Hairston, III Alabama Power Company Joseph'M. Farley Nuclear Plant

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CC Mr. R. P. Mcdonald Resident' Inspector Executive Vice President U.S. Nuclear Regulatory Commission Alabama Power Company P. O. Box 24 - Route 2 P. O. Box 2641 Columbia, Alabama 36319 i Birmingham, Alabama 35291-0400 Mr. Bill M. Guthrie D. Biard MacGuineas', Esquire Executive Vice President Volpe, Boskey and Lyons Alabama Power Company 918 16th Street, N.W.

P. 0. Box 2641 Washington, D.C. 20006 Birmingham, Alabama 35291-0400 Mr. Louis B. Long, General Manager Mr. Charles R. Lowman Southern Company Services, Inc. Alabama Electric Corporation P. O. Box 2625 P. O. Box 550 Birmingham, Alabama 35202 Andalusia, Alabama 35420 Chairman .

Regional Administrator, Region II Houston County Commission U.S. Nuclear Regulatory Commission Dothan, Alabama 36301 101 Marietta Street, Suite 2900 Atlanta, Georgia' 30323 Errest L. Blake, Jr., Esquire Shaw, Pitman, Potts and Trowbridge Claude Earl Fox, M.D.

2300 N. Street, N.W. State Health Officer Washington, DC 20037 State Department of Public Health State Office Building Montgomery, Alabama 36130 Robert A. Buettner, Esquire Balch, Bingham, Baker, Hawthorne, Mr. D. N. Morey Williams and Ward General Manager - Farley Nuclear Plant P. O. Box 306 P. O. Box-470 Birmingham, Alabama 35201 Ashford, Alabama 36312

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