A07028, Responds to Generic Ltr 88-02 Re Isap Ii.Util Will Continue to Participate in Isap & Will Submit Proposed License Conditions Endorsing Isap for Utils.Proposal Made in Generic Ltr 88-02 for Isap II Endorsed

Responds to Generic Ltr 88-02 Re Isap Ii.Util Will Continue to Participate in Isap & Will Submit Proposed License Conditions Endorsing Isap for Utils.Proposal Made in Generic Ltr 88-02 for Isap II Endorsed

ML20149M605
Person / Time
Site:	Millstone, Haddam Neck, 05000000
Issue date:	02/19/1988
From:	Mroczka E, Sears C CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
A07028, A7028, GL-88-02, GL-88-2, NUDOCS 8802260163
Download: ML20149M605 (5)

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UEO General Offices < Seiden Street, flerlin. Co inecticut 1 AsE' NsIrNw P.O. BOX 270 HARTFO'1D CONNECTICUT 06141-0270 k k J $ NwS. "w ". (203) 665-500o February 19, 1938 Docket Nos. 50-213 50-245

. 50-336 50-423 A07028 Re: Integrated Safety Assessment Program U.S. Nuclear Regulatory Comission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

Haddam Neck Plant Hillstone Nuclear Power Station, Unit Nos.1, 2, and 3 Integrated Safety Assessment Program II Response to Generic letter 88-02 On January 20, 1988, the NRC Staff issued Generic Letter 88-02,(I) regarding implementation of the Integrated Safety Assessment Program II ("ISAP II").

The Generic Letter broadly describes the program and solicits utility comments. Specifically, in response to a request from the Commission, the Staff wishes to determine whether any licensees are interested in participation. Attached is our response to the questionnaire forwarded in -

Generic Letter 88-02.

As you are well aware, Connecticut Yankee Atomic Power Company (CYAPC0) and Northeast Nuclear Energy Company (NNECO) have been deeply involved in implementing the pilot ISAP at the Haddam Neck Plant and Millstone Unit No. I since its inception. We are committed to continued participation in ISAP and intend to submit to the NRC Staff proposed license conditions that endorse ISAP for the Haddam Neck Plant and Millstone Unit No.1 in the near future.

In addition, we are prepared to commit to participate in ISAP for Millstone Unit No. 2 and Millstone Unit No. 3. We believe that continuation of ISAP for these plants will further demonstrate the program to be the most efficient regulatory process for enhancing safe reactor operations on a properly prioritized and cost-effective basis.

(1) F. J. Miraglia letter to all Power Reactor Licensees, "Integrated Safety Assessment Program II (ISAP II) (Generic Letter 88-02)," dated January 20, 1988. L

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p U.S. Nuclear Regulatory Commission A07028/Page 2 February 19, 1988 As part of our experience with ISAP, CYAPC0 and NNEC0 have developed, in conjunction with the NRC Staff, a sophisticated ISAP methodology known as the Analytical Ranking Methodology ("ARM"). This has allowed us to achieve an integrated evaluation and prioritization of all proposed and ongoing plant-specific modifications and engineering evaluations at each of the subject plants. The prioritizations have subsequently been utilized in '

developing an Integrated Implementation Schedule for each plant, recently submitted to the NRC. CYAPC0 and NNECO are very encouraged by the results of the pilot ISAP and wish to extend this methodology to Millstone Unit Nos. 2 and 3.

An additional benefit we see to the program is the interactive approach to addressing issues which has developed between CYAPC0/NNECO and the NRC Staff. ,

The ISAP has helped to foster an environment of cooperation where the utility and the regulators meet to review and evaluate issues that arise. This can be attributed to the fact that we are developing with the NRC Staff, a mechanism for addressing utility and regulatory concerns that tends to enhance the utility-NRC relationship.

Additionally, the Staff states that ISAP can be incorpcrated into a licensee's '

plant-specific response to the Severe Accident Policy Statement. We believe this is an important benefit to be obtained by participation in ISAP.

With respect to timing, Millstone Unit No. 3 currently has a completed Level 3 PRA. We believe that ISAP 11 could be initiated almost immediately for that unit. In fact, NNEC0 has already been taking steps toward applying ISAP to Millstone Unit No. 3 by identifying topics to be included and defining the scopes for those topics. Because the public safety sub-model of the ARM depends upon the plant-specific PRA, the timing for a complete prioritization for Millstone Unit No. 2 will depend upon completion of the PRA, which has been partially completed.

CYAPC0 and NNEC0 also endorse the concept, expressed in Generic Letter 88-02, of an industry /NRC seminar to discuss ISAP II and to generate industry-wide interest. We would be pleased to participate in such a seminar.

In conclusion, we endorse the proposal made in Generic Letter 88-02 for ISAP II. CYAPC0 and NNECO would like to expand our participation in ISAP by including Hillstone Unit No. 2 and Millstone Unit No. 3. This proposal offers us the chance to extend ISAP across our entire system of nuclear power plants, ultimately allowing resource-efficient planning of all plant-improvement projects and plant outage schedules. We would, of course, be pleased to meet with you to further discuss our participation in ISAP II.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY D d.D w E. J. Mroczka

• Senior Vice President t M_

By: C. F. Sears Vice President i

U.S. Nuclear Regulatory Commission A07028/Page'3 February 19, 1938 cc: W. T. Russell, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shediosky, Resident Inspector, Haddam Neck Plant M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 R.. L. Ferguson, NRC Project Manager, Millstone Unit No. 3 W. J. Raymond, Senior Resident Inspector, Millstor.e Unit Nos. 1, 2, and 3 I

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Docket Nos. 50-213 50-245 '

336-50-423 A07028 -

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Attachment Haddam Neck Plant  !

Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3  !

Response to Questionnaire -!

Generic letter 88-02

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i February, 1988

Intearated c a fety Assessment Proaram (ISAP) II Response Format to Generic letter 88-02 Facility Name: Haddam Neck Plant: Millstone Unit Nos.1. 2 and 3 Utility: Connecticut Yankee Atomic Power Comoanv/ Northeast Nuclear Enerav Comoany Individual Contact Name: R. M. Kacich Phone Number: 203-665-3298 An expression of interest will not be considered a commitment to participate on the part of the utility.

1. Would you be interested in participating in ISAP II? If so, in what time frame?

Yes. We intend to continue the ISAP for Haddam Neck and Millstone Unit No. 1, expand it to Millstone Unit No. 3 in the near term and to encompass Millstone Unit No. 2 in the longer term.

2. Do you believe that an in6stry/NRC seminar consisting of a brief

• discussion by NRC followed by a question and answer period would be beneficial prior to making a decision?

We have already made a decision regarding the continuation and expansion of ISA' to all our nuclear units. Nonetheless, we would be pleased to participate in any indastry/NRC sem'inar regarding the ISAP.

3. Would you be interested in a one-on-one meeting with the NRC to discuss I your particular facility or facilities?

l We believe that adequate communication between the NRC Staff and CYAPC0/NNECO has been ongoing in support of the ISAP for Haddam Neck and

. Millstone Unit No. 1. Discussions regarding expansion to Millstone Unit Nos. 2 and 3 may be appropriate, i

4. If you remain undecided regarding participation, what additional information do you need in order to make a decision?  ;

Not Applicable.  ;

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, 5. Do you have any potentiti concerns about participating in ISAP II? i No. However the reduction in scopo of ISAP II enhances the attractiveness of the program.

6. Do you have any suggestions for program improvements or changes?

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ICAP has proven to be a resource-efficient and cost-effective process for  :

enhancing nuclear power plant safety and for scheduling fa.ility modifications. In addition, we believe it fosters improved communications between the NRC and licensees regarding the bases for decisions. Hence, CYAPC0/NNEC0 endorse the concept of ISAP II.

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