ML20244C786

Comments on Util Response to Generic Ltr 88-17 Re Expeditious Actions for Loss of Dhr.Response Meet Intent of Generic Ltr But Lacks Some Details Requested in Encl 2 of Ltr.Nrc Observations Listed

ML20244C786
Person / Time
Site:	Arkansas Nuclear
Issue date:	06/07/1989
From:	Craig Harbuck, Poslusny C Office of Nuclear Reactor Regulation
To:	Tison Campbell ARKANSAS POWER & LIGHT CO.
References
GL-88-17, TAC-69721, TAC-69722, NUDOCS 8906150138
Download: ML20244C786 (5)

Text

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• [p'l%g .,o UNITED s7ATEs t

3 y >m'gg NUCLEAR REGULATORY COMMISSION .

5' > E WASHINGTON, D. C. 20555 k..v ..+

f June 7, 1989 /

Docket Nos. 50-313 and 50-368 Hr. T. Gene Canpbell Vice President, Nuclear Operations Arkansas Power & Light Company P. O. Box 551 Little Rock Arkansas 72203

SUBJECT:

COMPENTS ON THE ARKANSAS FCWER AND LIGHT COMPANY RESPONSE i TO GENERIC LETTER 88-17 WITH RESPECT TO EXPEDITIOUS ACTIONS FOR LOSS OF DECAY HEAT REMOVAL FOR ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 (TAC NCS. 69721 AND 69722)

Ger.eric Letter (GL) 88-17 was issued on October 17, 1988 to address the potential loss of decay heat removal (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 description of the enhancements, specific plans and a schedule for implementation of the six recommended program enhancements.

The NPC staff has reviewed your response to Generic Letter 88-17 on expeditious actions in the letter of January 5,1989. We find that it appears to meet the intent of the GL but lacks some of the details requested irs Enclosure 2 of GL 88-17. Your response to some items is brief and therefore does not allow us to fully understand your actions taken in response to GL 88-17. You may wish to consider several staff observations in order to assure yourselves that the actions are adequately addressed:

1. ecific information for procedures controlling You reactor have"not'provided ec'olant system sp(RCS) draining but state that the procedures are being revispd. These revisions arc to satisfy the intent for containment closure within the guidelines provided in GL 88-17. 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 compliment of bolts for sealing the equipment hatch then you first should verify that ycu can riake a proper seal of the periphery mating surfaces to meet the closure criteria. Ycu have not preserted any times for containment cicsure.

Generic Let'ter 88-17 stetcs that "ccntaintnent penetrations including the

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equipment hatch, may remain open provided ticsure is reasonably assured within 2.5' hours of initiel loss of DHR." This time will be less if there are vent areas totaling greater than one square inch in the cold leg (see Section' 2.2.2 of GL 88-17).

8906150138 890607

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. Mr. T. Gene Campbell -

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2. Your addressing of containment closure is cursory and'no information?is-provided regarding how you will- keep track of. and control the many i potential m enings (piping, electrical, hatches) which will.have to be..

closed simultaneously. We assume your procedures and administrative -l controls will address this topic.

3. You state that procedures are being revised t'o require operation of;iwo independent core exit thermocouple-(CETs) when in mid' loop condition.

Your response is. vague ~ in some details. For' Arkansas- Nuclear One, Unit 1 (ANO-1) it is not citar if in addition' to the periodic recording of the-thermocouple that the' readings may be automatica11y'and continuously nonitored and alarmed in the control. room. This would appear. to be .

.pcssible es the thermocouple leads, remain in their normal'1ocation at the bottom of the core"With the head off. For ANO-2 you state that."when.

indications that are~not automatically monitored.and alarmed are used, ..1 provisions will be made~ for periodically checking and- recording 'l temperatures." We can not discern if you are planning.to use automatic l monitoring and alarms for ANO-2 or just periodic checking and recording.

For a system which is monitored by. an operator in the control room,' thel need for frequent logging only arises for the case of loss of residual- )

g heat removal (RHR). ..

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4. You state that "ANO-1 and'2 logs are being revised as required to provide  !

for periodic recording.and checks of at least two. independent continuous i RCS water level indications during DHR operation." You state that ANO I has hot leg level indication for both RCS' loops. -However, no details are i given about the type cf level indicator, or.if the level indications have  ;

alarms and where the reference legs are located. You state that ANO-2 has 'l a refueling level indication consisting cf delta-p instrumentation'between j the 'A' hot leg and the pressurizer. In addition, you state' that both plants have temporary tygon tubing level instrumentation. When two:

instruments are in piece, 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.

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5. Walking the.tygon tube following installation to verify lack of kinks or '

loop seals is necessary. Erperience shows that periodic walkdowns are' i 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. You have not discussed how the tygen tube readings- i will be monitored. If the readings are only monitored in the containment,  ;

then observations should be recorded at an interval no longer then 15 minutes during normal conditions and provisions'should be provided for.

irrediate communication of water level values to en operator in the control room if significant changes occur. .

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. 'i Mr. T. Gene Campbell -3'. '

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6. You have not stated the use of'any vent opening on the hot side of'the RCS to relieve RCS pressurization. The removal of a pressurizer manway or steam generator marway .can be used as a means-to provide RCS venting. ,

We note that relatively large-hot side openings in'the'RCS, such as a i pressurizer manway, can still lead to a pressure of.several psi. The-large steam flow in combination with flow restrictions in the surge line and icwer pressurizer hardware may lead.to pressurization. . Calculations should be perfomed to verify the effectiveness of.the opening.

As you are aware, the expeditious actions you have briefly. described are an interim measure to achieve an imediate reduction in risk associated with reduced inventory operation, and these will~be supplemented and in.some cases replaced by programed enhancements.. We intendf 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, may bel' covered in the audit of expeditious actions.

j This closes out the staff review of your responses to the expeditious: actions.

listed in the GL. There is no need to respond to the above observations. The i area of programed enhancements will be addressed in a separate letter.

Sincerely, il

/; C. Craig Harbuck, Project Manager f

Project Directorate - IV Divisien of Reactor Projects - III,

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IV, V and Special Projects.

l Office of Nuclear Reactor Regulation

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7 U h'ChesterPoslusny,ProjectManager Project Directorate .IV Division'of Reactor. Projects - III, IV, V'and Special' Projects l Office of Nuclear Reactor Regulation j cc: See next page j

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Mr. T. Gene Campbell 6. You have not stated the use of any vent opening on the hot side of the RCS to relieve RCS pressurization. The removal of a pressurizer manway or steam generator manway can be used as a means to provide RCS venting.

We note that relatively large hot side openings in the RCS, such as a- j pressurizer manway, can still lead to a pressure of several psi. The 1 large steam flow 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.  !

1 As you are aware, the expeditious actions you have briefly described are an i 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 enhancement program. The areas 1 where we do not fully understand your responses as indicated above, may be covered in the audit of expeditious actions.

This closes out the staff review of your responses to the expeditious actions .

litted in the GL. There is no need to respond to the above observations. The {

area of programmed enhancements will be addressed in a separate letter.

Sincerely, l OriginalSirred By l George F. Dick, Jr.

C. Craig Harbuck, Project Manager

, Project Directorate - IV i Division of Reactor Projects - III, 4 IV, V and Special Projects Office of Nuclear Reactor Regulation j OriginalSieced By Gecrge F. D!rk Jr.

Chester Poslusny, Project Manager Project Directorate - IV Division of Reuctor Projects - III, i

IV, V and.Special Projects Office of. Nuclear Reactor Regulation cc: See next page DISTRIBUTION IIchket File NRC PDR Local PDR PD4 Reading G. Holahan L. Rubenstein F. Hebdon P. Noonan 0GC-Rockville C. Harbuck C. Poslusny E. Jordan B. Grimes ACRS (10) PD4 Plant File DOCUMENT NAME: MEMO CALVO ARKANSAS GL 8817 l -

PD4/L Q ( 4/PH PD4/PM PD4/ ,

PNoona'n 4 ACHarbuck FCPosiusny:bj FHebd 06/b/89 06#//89 /

06/c6/89 06/]/89 E___-- - - - - - - - _ - - - - - - - - - - - - - - -

[ Mr. T. Gene Campbell Arkansas Nuclear One Arkansas Power & Light Company Unit Nos. I and 2 cc:

Mr. Dan R, Howard, Manager Mr. Charles B. Brinkman, Manager Licensing Washingten Nuclear Operations Arkansas Nuclear One Combustion Engineering, Inc.

P. O. Box 608 12300 Twinbrook Parkway, Suite 330 Russellville, Arkansas 72801 Rockville, Maryland 20852 Mr. James M. Levine, Executive Director Site Nuclear Operations Honorable Joe W. Phillips Arkansas Nuclear One County Judge of Pope County P. O. Box 608 Pope County Courthouse Russellville, Arkansas 72801 Russellville, Arkansas 72801 Nicholas S. Reynolds, Esq. nb Bishop, Cook, Purcell

& Reynolds 1400 L Street, N.W.

Washington, D.C. 20005-3502 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Office of Executive Dircctor for ,

Operations ,

611 Ryan Plaza Drive, Suite 1000 '

Arlington, Texas 76011 Senior Resident Inspector U.S. Nuclear Regulatory Commission 1 Nuclear Plant Road Russellville, Arkansas 72801

' Ms. Greta Dicus, Director Division of Environmental Health Protection Arkansas Department of Health a815 West Markam Street Little Rock, Arkansas 72201 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 220 1700 Rcckville Pike, Suite 525 Rockville, Maryland 20852

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