CY-97-031, Informs NRC Staff of Final Status & Cancellation of Remaining SEP Issues Which Are Controlled Under Iis,Usi A-46 Outliner Resolutions,Ipeee Outliner Resolutions & Associated Commitments for Plant

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Informs NRC Staff of Final Status & Cancellation of Remaining SEP Issues Which Are Controlled Under Iis,Usi A-46 Outliner Resolutions,Ipeee Outliner Resolutions & Associated Commitments for Plant
ML20140D828
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 04/18/1997
From: Mellor R
CONNECTICUT YANKEE ATOMIC POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
REF-GTECI-A-46, REF-GTECI-SC, TASK-A-46, TASK-OR CY-97-031, CY-97-31, NUDOCS 9704240153
Download: ML20140D828 (15)


Text

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' ONNECTICUT YANKEE ATOMIC POWER COMPANY I

HADDAM NECK PLANT l 362 INJUN HOLLOW ROAD e EAST HAMPTON, CT 06424-3099 l

April 18,1997 )

Docket No. 50-213 CY-97-031 Re: 10CFR50.90 llS,SEP, l l

USl A-46 IPEEE 4

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Haddam Neck Plant Final Status and Cancellation of Remainina SEP. IIS. USl A-46 and IPEEE Items The purpose of this letter is to inform the NRC Staff of the final status and cancellation of the remaining Systematic Evaluation Process (SEP) Issues which are controlled under the Integrated Implementation Schedule (llS), Unresolved Safety issue (USI) A-46 Outlier Resolutions, Individual Plant Examination for External Events (IPEEE) Outlier i Resolutions and associated commitments for the Haddam Neck Plant (HNP). This letter I is a follow up to the letter dated December 23,1996,W which requested a hold be l placed on removal of License Condition 2.C.616egrated Implementation Schedule Program Plan". Based on the limited number of systems required to support storage of the spent fuel, the time available to restore cooling, if it is lost, and the additional bases provided below, the remaining commitments that were part of the llS are no longer required. Therefore, CYAPCO respectfully requests that the NRC Staff proceed with l processing the proposed license amendment to remove License Condition 2.C.6. pN USI A-46 Final Status Generic Letter 87-02, Supplement 1 was issued to implement the USl A-46 resolution

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which concluded that the seismic adequacy of certain equipmen plants should be reviewed against seismic criteria not in use when these plants were D -

W =i i i i F. C. Rothen to USNRC, " Withdrawal of Proposed License Amendments" dated (  !

December 23,1996, EB - l l

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i licensed. The Generic Implementation Procedure (GIP), Revision 2 was used to resolve

! USI A-46. The GIP-2 provides an initial screening process, detailed technical approach,  ;

! generic procedures and documentation guidance to verify the seismic adequacy of *

! mechanical and electrical safe shutdown equipment. As part of the GIP requirement,  ;

licensees are to identify equipment necessary to bring the plant to, and maintain it in, a '

hot shutdown condition during the first 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a Safe Shutdown Earthquake.  !

If safe shutdown equipment should fail to pass this initial screening, an ' outlier' is i

! classified and a more detailed method for verifying its seismic adequacy may be used.

  • j The USI A-46 final walkdowns were completed during the Cycle 17 refueling outage i

!- and in a letter dated January 14,1994,(2) a summary report including Safe Shutdown i Equipment List (SSEL) & Outliers was sent to the NRC Staff, f i

! IPEEE Final Status .

l Generic Letter (GL) 88-20, Supplement 4 requested all licensees to perform an IPEEE to I J find plant-specific severe accident vulnerabilities initiated by external events and to  !

j subrnit the results together with any determined improvements and corrective actions to i the NRC. The selected use of Seismic Probabilistic Risk Asussment (SPRA) ,

i. methodology for the IPEEE is in conformance with the gukiance provided by GL 88-20, '

I Supplement 4 and the detailed guidance provided in NUREG-1407. In a letter dated

!. December 27,1994, ( ) a summary report including a recommendation for implementation ,

l of design and procedural changes for severe accident risk outliers was submitted to the j NRC.

Since the IPEEE plant walkdown requirements are consistent with the requirements in the USl A-46 review document, the SSEL created by A-46 has been integrated into IPEEE component selection. Therefore, many of the A-46 outliers also appear as IPEEE outliers. Attachments 1 & 2 provide the status of the current USI A-46/IPEEE outlier resolutions since the last request for updated information was sent to the NRC. The i

m J. F. Opeka to USNRC, " Unresolved Safety Issue A-46 Walkdown Summary Report and Proposed Expansion of Licensing Basis for Verification of Equipment Seismic Adequacy", dated January 13,1994.

m J. F. Opeka to USNRC, " Response to Generic Letter 88-20, Supplement 4, IPEEE Summary Report", dated December 27,1994.

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U. S. Nuclear Regulatory Commission CY-97-031/ Page 3 l canceled outliers identified in the USI-A46 ( 3 total) and IPEEE status (9 total) will no l longer be performed based on the following: l l

1. The permanent defueled condition of the plant falls outside the scope of USI-A46  ;

and IPEEE program commitments.

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2. None of the canceled outliers are deficiencies against the existing plant licensing l

or design basis. Therefore, there is no reportability and operability implications pursuant to the Technical Specifications and the FSAR.

3. The HNP has determined that the remaining outliers would have negligible or no i public risk significance and thus, is closing the remaining outliers without 3

implementation.

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IIS Final Status I The llS contained eleven commitments that were scheduled to be completed by the I

end of the cycle 20 refueling outage. Attachment 3 provides a list of the remaining i commitments that are no longer required to support storage of the fuelin the spent fuel pool. Note that the air cooled diesel generator was installed in 1996. It was originally

designed to reduce the impact on core melt frequency for station blackout as well as for certain fire and tornado scenarios. CYAPCO plans to continue using the air-cooled
diesel to provide an alternate power source for the spent fuel building.

J In summary, CYAPCO requests that the NRC Staff close the USI A-46, IPEEE and IIS topics for the HNP. We also request that the NRC Staff proceed with processing the <

proposed license amendment to remove License Condition 2.C.6.

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1 U. S. Nuclear Regulatory Commission CY-97-031/ Page 4 If you have any questions, please contact Mr. G. P. van Noordennen at (860) 267-3938.

Very Truly Yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY R. A.Illellor i Director of Site Operations and Decommissioning cc: H. J. Miller, Region I Administrator M. B. Fairiite, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident inspector, Haddam Neck Plant l

l Subscribed and sworn to before me I this i@ day of April,1997

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Date Commission Expires: \\ 30 49 t i l

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j Docket No. 50-213 i CY-97-031 2

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ATTACHMENT 1

! Haddam Neck Plant 1

j. Outstandina USl -A46 Outlier Resolution Status i

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CY-97-031 Attachment - 1

, , OUTSTANDING USI-A46 OUTLIER RESOLUTIONS STATUS RISK OUTLIER PROPOSED FIX STATUS SEISMIC

2. SPEC 200 RPS rack sections B1 A, B18, B2A 1. Tie down or relocate file Resolved.

are part of the SSEL. There are unrestrained cabinets south of the Anchoring of file cabinet file cabinets near the south end of this Spec SPEC 200 cabinet, completed via WO # 200 cabinet. CY95-14360 for MSEE  !

No.95-004.

ii. For the long-term, ensure Resolved.

l that the house keeping Procedures have been procedure prevents addressed per Ref.1.

recurrence of this type of '

spatialinteraction.

3. C channel frame restrains movement of valve Remove / modify the frame to Resolved.

BA-MOV-349 through a bolt on top of the valve eliminate interference. Cutting of existing actuator. Based on discussions with a piping notches was completed engineer, the frame serves no function for the via WO #CY9511515 for pipe. NCR 95-307 disposition

4. C channel frame restrains movement of valve 1. Remove / modify the frame Resolved.

BA-MOV-386 through a bolt on top of the valve to eliminate The same WO as item actuator. Based on discussions with a piping interference. #3.

engineer, the frame serves no function for the ,

pipe. Also need to resolve field installation problems with grout under the stanchion.

Resolved.

ii. Repair grout Grouting was repaired through WO #CY >

08403 per NCR 95-296 disposition.

S. Spacing between battery BT-1 A cells does not install crushable foam between the Cancelled per have tight fit, railing and battery cells or add Reference 6 spacers / shims between the vertical post and side rail to provide snug fit.

7. Duct work over Buses 1-4, 5,6, 7 is supported Investigate the overhead duct Cancelled per with unknown type of anchors supports to determine the type and Reference 6 ,

capacity of the concrete anchors used.

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8. Existing cabinets 8DB1 A and 9DB1 A of Diesel Tie together or provide cushioning Resolved. .

Aux. Control panel (EG-2A) are not bolted to between cabinets to preclude any No modifications required adjacent cabinet 9081. impact. per justification provided in Ref. 2.

9. Existing cabinets 8DB1 A and 9DBI A of Diesel Tie together or provide cushioning Resolved.

Aux. Control panel (EG-28) are not bolted to between cabinets to preclude any No modifications required adjacent cabinet 9DB1. impact. perjustification provided in Ref. 2.

13. Three anchors on EDG fuel oil level transmitter Replace and tighten anchors. Resolved.

LT-1700A are missing. (4) 1/4' hitti bolts installed via WO #CY95-14543 for NCR 95-290 disposition, l&C work was implemented under WO CY96-00379 in 2/26/96.

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CY-97-031 i Attachment - 1

, , OUTSTANDING USl-A46 OUTLIER RESOLUTIONS STATUS RISK OUTLIER PROPOSED FIX STATUS I' No DCN & PDCR l required per Ref. 3. I

. 14. Anchorage on EDG fuel oil level transmitter Tighten anchors. Resolved. j LT 1700B is loose. (4) 1/4* bilti bolts installed via WO'#CY95-14543 for NCR 95-290 disposition.

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l No DCN & PDCR required per Ref. 3.

19. Various outlier relays consisting of : bad actor a. Perform evaluations to Cancelled per i relays, relays with no GERS, and relays of determine if compensating Reference 6 unknown make. operator actions can be credited

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[ if the actions need to be

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included in the seismic AoPs.

b. Resolve seismic issues or replace remaining relays.

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, Additional Outlier

There was an oversight in the original submittal Demonstrate the low contribution of Resolved. I which resulted in three tanks (DWST, PWST, the tanks to public risk by Per Ref. 5, PRA does not and RWST) being omitted from the Outlier determining whether the public recommend upgrading Seismic Verification Sheet (OSVS). The safety benefits from upgrading the these tanks due to large
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documentation was modified to reflect the tanks is negeglible. cost and neglible seismic changes and sent to the NRC per Ref. 4. CDF safety benefits.

References:

1. M. P. Derrig to J. K. Rothert, Memo CY-TS-94-0656, "lPEEE Outliers",

j' dated October 19,1994.

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. 2. A. Vaysbord to J. F. Bibby, Memo DECY-95-0574, " Responses to A/R No. 950626453 for USI-A46 Outliers items 8 & 9 and A/R No. 95002274 for IPEEE Risk Outlier items 7 & 8", dated September 22,1996.

j 3. S. Pornprasert to J. F. Bibby, Memo DECY-95-0480, " Response to A/R i

No. 95024388 for USI-A46 Outlier No.13 & 14", dated August 9,1995.

4. J. F. Opeka to USNRC, Docket No. 50-213 B14881, dated June 22,1994.

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, 5. S. Pornprasert to E. P. Perkins, Memo DECY-96-0494, " Response to A/R j No. 96003989 for USI-A46 Outlier Resolutions of RWST and DWST",

dated August 23,1996.
6. T. C. Feigenbaum letter to the NRC " Certification of Permanent Cessation of Power Operation And That Fuel Has Been Permanently Removed From The Reactor" dated December 5,1996.

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i Docket No. 50-213 CY-97-031 s

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l Attachment 2 1 Haddam Neck Plant j IPEEE Risk Outlier Resolution Status d

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. . CY-97-031 Attachm:nt - 2 t IPEEE RISK OUTLIER RESOLUTIONS STATUS RISK OUTLIER PROPOSED FlX STATUS SEISMIC ,

2. SPEC 200 RPS rack sections B1 A, B18. D2A 1. Tie dew.: or 'ekcate file Resoived, are part of the SSEL. There are unrestrained c9eine'.s soun O? Anchoring of file cabinet i file cabinets near the south end of this Spec SPEG 200 catinet completed via WO # 200 cabinet. CY95-14360 for MSEE No.95-004.

ii. For the long-term, unsure Resolved.

that N house keepnn Procedures have been prowdure prevents addressed per Ref.1.

recurrence of this type of i spatial Interaction.

3. C chene! frrne restrante movement of valve Remove / modify the frame to Resolved.

BA-MGM42 %rengh a belt on top of the valve eliminate interference. Cutting of existing notches ertuator. Based he &$cusions with a piping was completed via WO engsect, tM frame serves no function for the #CY9511515 for NCR 95- I pipe. 307 disposition 1

4. C channel frame restrains movement of valve 1. Remove / modify the frame Resolved.

BA-MOV-386 through a bolt on top of the valve to eliminate The same WO as item #3.

actuator. Based on discussions with a piping interference.

engineer, the frame serves no function for the pipe. Also need to resolve field installation problems with grout under the stanchion.

Resolved.

ii. Repair grout Grouting was repaired via WO #CY 95-08403 for NCR 95-296 disposition.

5. Spacing between battery BT-1 A cells does not install crushable foam between the Cancelled per have tight fit. railing and battery cells or add Reference 13 spacers / shims between the vertical t post and side rail to provide snug fit.
7. Existing cabinets BDB1A and 9DB1A of Diesel Tie together or provide cushioning Resolved.

Aux. Control panel (EG-2A) are not bolted to between cabinets to preclude any No modifications required adjacent cabinet 9DB1. impact. perjustification provided in Ref. 2.

8. Existing cabinets 8DB1 A and 90B1 A of Diese8 Tie together or provide cushioning Resolved.

Aux. Control panel (EG-28) are not bolted to between cabinets to preclude any No modifications required adjacent cabinet 9DB1. impact. per justification provided in Ref. 2.

12. Three anchors on EDG fuel oil level transmitter Replace and tighten anchors. Resolved.

LT 1700A are missing. (4) 1/4" Hitti bolts installed via WO #CY95-14543 for HCR 95-290 disposition.

l&C work was implemented under WO CY96-00379 in 2/26/96.

l No DCN & PDCR required per Ref. 3. l

13. Anchorage on EDG fuel oil level transmitter Tighten anchors. Resolved.

! LT-1700B is loose. (4) 1/4' Hitti bolts installed ,

via WO #CY95-14543 for '

NCR 95-290 disposition.

No DCN & PDCR required

  • per Ref. 3.
18. Throughout the plant the floor grating is not Replace missing anchors and modify Resolved.
always secured. appropriate housekeeping procedure Work completed per Ref.

l to ensure that they stay anchored 4.

through periodic inspections.

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CY-97-031

< Attachmint - 2 IPEEE RISK OUTLIER RESOLUTIONS STATUS

19. Hydrogen skid tank in yard is not anchored. Bolt it down. Resolved.

(4) 3/4" Hilti HVA Adhesive Anchoring system installed via WO #96-00771 for i MSEE No.95-030.

22. Boric acid pumps' anchorage is inadequate. Strengthen the anchorage by Cancelled per The median capacity is calculated at 0.01g. weiding stiffeners. Reference 13
23. FW heaters have very low seismic capacity. Perform additional analysis and Resolved.

0.03g. upgrade FW heater anchorage as FW heater anchorage required. modified per PDCR No.

1563.

24. CAR Fan has very low seismic capacity, Perform additional Resolved. >

investigations / modifications to No modifications required improve CAR Fan capacity or per justrFications provided perform evaluations.fo determine in Ref. 5.

whether the Containment Spray system is adequate to support the feed and bleed function.

26. Service water piping has low seismic capacity. Perform additional evaluations to Cancelled per  !

improve seismic capacity or add Reference 13 additional supports.

27. There are bad actor relays in the HPSI and Perform evaluations to determine Cancelled per LPSI pump circuits. compensating operator actions to be Reference 13 included in the seismic AOP ,

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28. There are bad actor relays in the emergency Perform evaluations to determine Resolved. l diesel circuitry. compensating operator actions te be Engineering valuation in '

included in the seismic AOP. Ref. 6 indicated (4) Filed j Flash Cut-out (FFCO) and (4) 59A, B/1-8 & 59A,B/1-9 (W-SV) relays contact chatter during SSE do not cause unacceptable consequences.Thus,no action is considered warranted for FFCO relays in the diesel excitation control panels and W-SV relays in the CB/8DB1 & CB/9DB1 <

panels.

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29. SW-MOV- 3 and 4 have relays whose Perform evaluations to determine Resolved.
capacities are unknown. cenpensatM uperator actions to be These (5) Auxiliary relays  ;

incluaed in the setmic AOP. (GOULD/ITE J20A40) the type found ireaide Bus 11 '

are associated with the USI- A46 SSEL. The A-46 SSEL is a subset of

! IPEEE. Per Dwg.16103-30091, the devices are in energized state with normally open (NO).

l These relays were tested 4

as part of the entire

! SWGR assembly (Test Report ABB 48-66281 SSA). TRS envelop -

SWGR 'B' El. 41'-6" RRS.

30. AFW socket welded fittings have low seismic Strengthen by adding additional Cancelled per surports to susceptible fittings in the page 2 of 5

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CY-97-031 AttaChmint - 2

IPEEE RISK OUTLIER RESOLUTIONS STATUS

, , capacity. (identified 09/02/94) l area of the FW Reg valves l Reference 13 EXTERNAL FLOODING '

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31. Service water strainer cleaning capabilities for IPEEE to determine risk and provide Resolved.

enreme flooding conditions (SWOPI). recommendation. AOP 3.2-24 was revised to install duplex SW strainers I

for the DG's in the event of a flood per Ref. 7.

l SNOW & ICE l

33. Service / Control bu!! ding. Service / Aux. Bay, Generate Snow /lce removal Resolved.

l Service / Service Bay, and PAB have limited procedure. Develop of new procedure -

roof capacity, '

not required. Justifications

provided in Ref 8.  ;

FIRE l 34. Relatively high probability of diesel B Develop procedure for connecting Cancelled per

! unavailability Air Cooled DG. Reference 13

35. Potential coincidentalloss of DC bus A and BX Develop procedure to deal with the Cancelied per due to their spatial proximity. loss of DC buses A and BX. Reference 13
36. Cable vault and cable spreading area -large Change training philosophy to Cancelled per l consequences of a fire in an area where there increase sensitivity and awareness Reference 13 l Is a high concentration of cables of both trains of transient combustibles and ,

i A & B. maintenance activities in the cable j

spreading area and cable vault to i same level as for control room and i

! switchgear rooms.

l- 37. Cable spreading area cable separation Installation of additinnal sprinkler Resolved.

j concerns. heads on trays where numerous No modifications required cable sprays are stacked above perjustifications provided each other. in Ref. 9.

38. Trains A & B control cable separation in the improve AOP 3.2.57 for recovery Resolved.

control room and cable spreading area. from control room, switchgear room The existing procedures l A and cable spreading area fires. and process are adequate ,

! Also, for the cable spreading area per justifications in Ref. j revise procedures for 'A' charging 10. In addition, PRA has -

pump so that it can be credited for performed further fire scenario in cable spreading investigation and area. concludes that the past and current practices and procedures associated with this issue are acceptable, Ref.11.

39. Trains A & B cable separation in the PAB Re-route either charging pump B Cancelled per corridor (trays C1 and C7) for charging pump main or auxiliary lube oil pump Reference 13 supports. cables.

FIRE / SEISMIC INTERACTIONS

40. Vertical unanchored waste oil tank in the installation of additional anchorage Resolved.

waste oil area can topple over flammable liquid to prevent toppling. No modifications required i containers in that area. per justifications provided l in Ref.12. Kerosene l containers removed from l the oil storage room. Filled lube oil containers

! replaced with empty containers above the first shelf rack by the waste oil i tank. Caution signs posted for installation of new racks and placing of empty containers above first shelf only.

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. . CY-97-031 Attachment - 2

t IPEEE RISK OUTLIER RESOLUTIONS STATUS
41. End bottle of Carbon Dioxide fire suppression Modify end bottle restraint to Resolved.

system for containment cable vault requires adequately restrain bottle. Welding of end restraint restraint modification (IN 9412). completed via generic maintenance AWO # CY-95-05650.

42. Batteries to the diesel fire pump require installation of anchorage to prevent Resolved restraining (IN 94-12), battery movement Hilti anchors, spacers and straps installed (BT-3A/38) via WO # CY95-16001 for MSEE No.95-002.

Peer Review Comment Air Handling Unit (AC 23-1 A) had not been Perform internal wh;.down Reso!ved.

available for internal inspection of the inspection of the fan / motor spring As part of a response to fan / motor skid on spring isolators when the isolators when the unit is out of the NRC RAl. Ref.17. CY PRA walkdown was performed. service. has committed (No.

B15571-2) to implement the mods by RFO 19.

The support upgraded to limit moverment in the longitudinal direction (parallelto axis of the fan / motor system). The upgrade consisted of a 1/4" neoprene pads attached to existing base frame and an angle steel with Hilti bolts anchored to the 6" thick reinforced concrete pad.

Mods completed under AWO CY96-01254 for MSEE No.96-005.

References:

1. M. P. Derrig to J. K. Rothert, Memo CY-TS-94-0656, "lPEEE Outliers",

dated October 19,1994.

2. A. Vaysbord to J. F. Bibby, Memo DECY-95-0574, " Responses to A/R No. 95026453 for USI-A46 Outliers items 8 & 9 and A/R No. 95002274 for IPEEE Risk Outlier items 7 & 8", dated September 22,1995.
3. S. Pornprasert to J. F. Bibby, Memo DECY-95-0480, " Response to AIR No. 95024388 for USI-A46 Outlier No.13 & 14", dated August 9,1995.
4. S. Pornprasert to J. F. Bibby, Memo DECY-95-0432, " Responses to A/R No. 95002274 for IPEEE Risk Outlier No.18", dated July 17,1995.
5. S. Pornprasert to J. F. Bibby, Memo DECY-95-0476, ' Responses to A/R No. 95002274 for IPEEE Risk Outlier No. 24,' dated August 7,1995.
6. Engineering Evaluation CY-EV-960001, "MKW Power Systems Part 21 ,

Report No.10CFR21-0069", Rev. O.

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7. J. K. Rothert to R. W. Kasuga, Memo NE-95-SAB-163, " Closure of SWOPl Inspection Request #101 A SW Strainer Avialability/ External i Flooding", datcd April 18,1995. j page 4 of 5

.. , CY 97-031

  • ' .- Attachm:nt - 2 )

IPEEE RISK OUTLIER RESOLUTIONS STATUS t .-

, , 8. J. Rothert to S. Pornprasert, Memo NE-96-SAB-011. "CY IPEEE Risk l Outlier #33: Snow & Ico", dated January 15,1996.  !

9. J. K. Rothert/S. D. Weerakkody to S. Pornprasert, Memo NE-96-SAB- '

045, "CY IPEEE Risk Outlier #37, Cable Spreading Area Cable  !

, Separation Concems", dated February 22,1996 Justification Memo for item #37 from J. Rothert.

10. J. Pointkowski to J. H. Rothert, memo ODM 96-020, "CY IPEEE Meeting

- CY Position Outlier # 38," dated February 26,1996 memo for item #38.

11. J. K. Rothert to S. Pornprasert, Memo No. NE-96-SAB-234, PRA Closure of CY IPEEE Risk Outlier #38," dated September 17,1996.
12. J. K. Rothert to S. Pornprasert, Memo NE-95-SAB-427, "lPEEE Fire / Seismic Risk Outlier #40," dated October 19,1995.
13. T. C. Feigenbaum letter to the NRC " Certification of Permanent Cessation of Power Operation And That Fuel Has Been Permanently 3 Removed From The Reactor" dated December 5,1996.

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1 April,1997 Docket No. 50-213 CY-97-031 l

Attachment 3 Haddam Neck Plant ilS Commitment Matrix i

April,1997 l

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U.S. Nuclear Regulatory Commission -l

, 6Y-97-031/Attachm::nt 3/Page 1 l

! Haddam Neck Plant Proposed Revision to Operating License DPR-61 '

Deletion of

, License Condition 2.C.6 -Integrated Implementation Schedule Commitments Matrix ISAP Topic No. Scope of Commitment Completion Date i

. 1.19 Replace existing containment isolation valve, Cancelled VS-SOV-12-1, to provide local, mechanical position indication.

1.48 A. Complete Outlier #5 - spacing between Cancelled station batteries cells and railing as not See item 5 on Attachments having close-fitting. 1 and 2

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B. Complete Outlier #7 - interaction between Cancelled ductwork and various busses is a concern See Item 7 on Attachment 1 since the type and capacity of anchors is

- unknown. <

l C. Complete Outlier #19 - concerns relays Cancelled  !

with no Generic Equipment Ruggedness See item 19 on Attachment 1 Spectrum (GERS) and relays consisting of )

" bad actors."

1.64 Replace RH-V-808A with a motor-operated Cancelled gate valve.

1.121 Complete Phase I of Post Accident Sampling Cancelled System Enhancement modifications to improve the ability to separate dissolved gas samples from the reactor coolant system and quantitatively analyze the samples for l hydrogen noble gases.

1.04 A. Complete modifications to the feedwater Cancelled system to raise system seismic fragilities.

B. Complete modifications to the auxiliary Cancelled

feedwater system to raise system seismic 1

fragility.

C. Complete modifications to the service Cancelled water system to raise system seismic fragility.

2.145 Install an air-cooled diesel generator for Cancelled station blackout as well as for certain fire and tornado scenarios to reduce impact on core melt frequency.

2.146 Replace all main control board equipment as Cancelled part of rod position indication system upgrade.