CY-98-153, Forwards Final Response to NRC 961009 RAI Re Configuration Mgt Project at Plant.No New Commitments Made within Ltr or Attachment
| ML20154B929 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 09/30/1998 |
| From: | Mellor R CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CY-98-153, NUDOCS 9810060058 | |
| Download: ML20154B929 (8) | |
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CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT 362 INJuN HOLLOW ROAD e EAST 4AMPToN, CT 06424-3099 September 30,1998 Docket No. 50--213 CY-98-153 Re: 10CFR50.54(f)
U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Haddam Neck Plant NRC Recuest For Information Pursuant To 10CFR50.54m 0
in a letter dated October 9,1996 ), The NRC requested that the Connecticut Yankee Atomic Power Company (CYAPCO) provide information on the Configuration Management Project (CMP) at the Haddam Neck Plant (HNP) within 120 days of receipt of the letter. In letters dated i bruary 6,1997(2) and December 24,1997, CYAPCO provided an interim W
response: and a subsequent status update. The purpose of th's letter is to provide a find response.
Since the receipt of the NRC letter of October 9,1996, CYAPCO submitted a letter dated December 6,1996"), that informed the NRC that the Board of Directors of CYAPCO had decided to permanently cease operations at the HNP and that the fuel had been permanently l{
removed from the reactor.
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NRC Letter, from J. M. Taylor, to B. D. Kenyon, " Request For Information Pursuant to 10 CFR 50.54(f) Regarding Adequacy And Availability Of Design Basis Information," dated October 9,1996.
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CYAPCO Letter B16187, from T. C. Feigenbaum, to the U. S. Nuclear Regulatory Commission, "NRC Request For Information Pursuant To 10CFR50.54(f)," dated February 6,1997.
CYAPCO Letter CY-97-125, from R. A. Mellor, to the U. S. Nuclear Regulatory Commission, "NRC Request For Information Pursuant To 10CFR50.54(f)," dated December 24,1997.
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CYAPCO Letter B16066, from T. C. Feigenbaum, to the U. S. Nuclear Regulatory Commission,
" Certifications Of Permanent Cessation Of Power Operation And That Fuel Has Been Permanently Removed From The Reactor," dated Deccmber 5,1996.
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U. S. Nuclear Regulatory Commission CY-98-153/Page 2 CYAPCO has completed the 10CFR50.54(f) activities including completion of the licensing and design ba'ses for the safe storage of spent fuel, updating the UFSAR, configuration j
. management of major processes, and identification of commitments. Attachment 1 provides i
the final response to the request for information.
There are no new commitments made within this letter or its attachment.
I If the NRC staff should have any questions or comments, please contact
' Mr. G. P. Van Noordennen at (860) 267-3938.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY I
l Russell A.Mr i
Vice President - Operations and Decommissioning i
Attachments cc:'
H. J. Miller, NRC Region i Administrator T. Frederichs, NRC Senior Project Manager, Haddam Neck Plant W. J. Raymond, NRC Senior Resident inspector, Haddam Neck Plant E. Wilds, Director, CT DEP Monitoring and Radiation Division Subscribed and sworn to before me this 36 M day of September,1998 hs n/ b orn,., k a d$r.nsn Date Commission Expires: Be-lv 7/.200A J
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._y Docket No. 50-213 CY-98-153 i
Haddam Neck Plant NRC Request For Information Pursuant To 10CFR50.54(f)
. Final Response l'
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i-5 September 1998 1
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U. S. Nuclear Regulatory Commission CY-98-153/ Attachment 1/Page 1 NRC Reauest For Information (a)-
J Description of engineering design and configuration control processes, including those that implement 10 CFR 50.59,10 CFR 50.71(e), and Appendix B to 10 CFR Part 50.
Final Response
~ The final response was provided by CYAPCO letter dated December 24,1997.
W NRC Reauest For information (b)
' Rationale for concluding that design bases requirements are translated into operating, maintenance, and testing procedures.
l Final Response The objective of CYAPCO's 10CFR50.54(f) program is to provide assurance that the HNP will be decommissioned in accordance with the terms and conditions of the operating license, NRC regulations and the UFSAR. Management and CY Oversight has reviewed and verified
. the following areas to ensure that the objective is met:
.1. Licensing Commitments
- 2. Revised Accident Analyses-
- 4. Spent Fuel Storage Licensing and Design Bases Reviews CY Oversight has also provided for independent review of these areas to verify effective implementation. The scope and status for each area are discussed in the following:
1.
Licensina Commitments Licensing commitment activities are divided into the following two work activities:
a.
Commitments have been identified from correspondence to and from the NRC and placed into a database. The correspondence includes LERs, docketed letters by CYAPCO, and fetters from the NRC to CYAPCO. The commitments have been characterized in the database by source document, date, system, program and other attributes to assist in the determination of applicability in the defueled condition. Over 13,500 commitments have been identified.
This task has been completed.
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CYAPCO Letter CY-97-125, from R. A. Mellor, to the U. S. Nuclear Regulatory Commission, "NRC Request For information Pursuant To 10CFR50.54(f)," dated December 24,1997.
U. S. Nucl:ar R::gulatory Commission CY-98-153/ Attachment 1/Page 2 b.
Approximately 2,080 of the over 13,500 commitments were initially identified as hpplicable to the defueled condition. Further review of these 2,080 commitments demonstrated that the majority had been appropriately implemented and were completed or are no longer applicable to the present plant configuration. However, the review indicated that approximately two hundred eighteen (218) commitments remain as either active commitments or commitments which require action. Eighty-eight (88) commitments are being actively implemented by design documentation,
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plant procedures, programs or processes. Approximately one hundred thirty (130) commitments were identified as requiring action to implement the commitment.
None of these 130 commitments are considered to be overdue. In certain cases, the required action may involve a procedure revision with an associated footnote. A procedure or procedure step is required to be footnoted when the procedure serves to implement a commitment. The action to footnote or revise procedures is being j
tracked under the plant action tracking system. The commitment tracking system i
reflects the status of those commitments which require action to be taken. Future commitments are identified, managed and dispositioned under Licensing Department Instruction LDI 2.01
i This review has been completed.
2.
Revised Accident Analvses The UFSAR Chapter 15 accident analyses activities verified important plant parameters. The area was divided into the following work activities:
a.
Key parameters associated with the redefined accident analyses assumptions and inputs, and the structures, systems, components and programs required to support tile safe storage of spent fuel have been identified and documented.
b.
The key parameters were verified by reviewing each parameter against associated calculations, UFSAR sections, surveillance procedures, setpoint control documents and other documentation with respect to the safe storage of spent fuel.
The Chapter 15 accident analyses have been revised for the defueled configuration and have been included in the January 26,1998* revision to the UFSAR. As decommissioning progresses, the accident analyses are reviewed and revised, as appropriate for the changing plant conditions.
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CYAPCO Letter CY-98-005 from R. A. Mellor, to the U. S. Nuclear Regulatory Commission,
" Decommissioning Updated Final Safety Analysis Report", dated January 26,1998.
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U. S. Nuclear Rrgulatory Commission CY-98-153/ Attachment 1/Page 3 3.
Uodated Final Safety Analvsis Reoort (UFSAR)
The UFSAR has been reviewed to identify and correct deficiencies applicable to structures, systems, components and programs required to support the defueled condition, licensing and design bases and decommissioning activities. The resulting revision reflects those systems recategorized for the defueled condition to date, as well as correction of known deficiencies associated with the defueled condition. The recategorization process is a
. continuing process and the UFSAR will be periodically updated to reflect changes.
The Licensing Commitments,' UFSAR Chapter 15 accident analyses, Defueled Technical Specifications, and Defueled Condition Licensing and Design Bases Reviews have been compared to the UFSAR. The changes identified were evaluated using the 10CFR50.59 i
safety evaluation process.
i A complete' revision to the UFSAR was docketed on January 26,1998.
4.
Soent Fuel Storage Licensing And Design Bases Reviews For structures, systems, components and programs required to support the safe storage of spent fuel, the licensing and design bases have been identified and verified. As part of this I
review, new calculations have been developed for the spent fuel pool heatup rates and for
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the UFSAR Chapter 15 accident analyses. The licensing basis identification included reviews of correspondence commitments as well as licensing basis documents such as the UFSAR, Technical Specifications, Technical Requirements Manual, Safety Evaluation Reports, and Facility Description and Safety Analysis. The design basis identification included reviews of design changes, Design Basis Document Packages, calculations, drawings, specifications, vendor information, etc. The verification of plant configuration with the license and design bases was performed through reviews of operating, maintenance, and surveillance procedures and walkdowns. This effort was focused on maintaining the integrity i
of the spent fuel in the spent fuel pool. The following approach was established and completed:
Review the basic calculations for the hydraulics, structures, electrical distribution and instrumentation needed for the safe storage of spent fuel.
Review docketed correspondence to establish the licensing and design basis for the safe storage of spent fuel.
. - Reconcile the design basis with the UFSAR, operating, maintenance and surveillance procedures, and Technical Specifications.
Perform walkdowns to verify expected configurations.
Document the licensing and design basis for the safe storage of spent fuel.
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U. S. Nucisar Regulatory Commission CY-98-153/ Attachment 1/Page 4 The Licensing Basis and Design Basis Document is controlled by procedure ACP 1.2-2.84 -
Changes and. Revisions to Licensing Basis and Design Basis (LB/DB) Document. Other licensing and design basis documents such as the UFSAR, Technical Specifications, Technical Requirements Manual are also controlled by existing station procedures.
The licensing and design bases reviews and documentatior; have been completed. An independent review and a separate third-party review, of the licensing and design bases documentation, was conducted. Results to date have shown an effective configuration process for maintenance of the licensing and design basis.
Current CY Oversight Surveillance Activity CYAPCO responded to a Level IV violation, involving incomplete channel calibration of the stack flow monitor, in a September 21,1998 Notice of Violation response letter. One of the W
corrective actions being taken as a result of this violation is a verification of all portions of License Amendment 125 (i.e., conversion to Standard Technical Specification format and definitions) that remain in effect as amended by License Amendment 193 (i.e., defueled Technical Specifications). The Oversight organization is verifying that for each Technical Specification surveillance requirement, the existing procedure (s) adequately perform (s) the activity required by the Technical Specifications.
Actions such as this CY Oversight surveillance are an example of the ongoing efforts to ensure that design basis requirements are translated into plant procedarbs. As
' decommissioning progresses, any deviations from the licensing and design basis are reported through our Adverse Condition Reporting (ACR) Program.
NRC Reauest For Information (c)
Rationale for concluding that systems, structures, and component configuration and performance are consistent with the design bases.
Final Resnonse As described above in the response to item 4 (Spent Fuel Storage Licensing And Design Bases Reviews).
NRC Reauest For Information (d)
Processes for identification of problems and implementation of corrective actions, including actions to determine the extent of problems, action to prevent recurrence, and reporting to the NRC.
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CYAPCO Letter CY-98-151, From R. A. Mellor to the U. S. Nuclear Regulatory Commission,
" Reply to a Notice of Violation (NOV) NRC Integrated Inspection Report No. 50-213/98-03",
dated September 21,1998.
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U. S. Nucl ar R2gulatory Commission CY-98-153/ Attachment 1/Page 5 Final Response i
The final response was provided by CYAPCO letter dated December 24,1997.
NRC Reauest For Information (e)
The overall effectiveness of your current process and programs in concluding that the
. configuration of your plant is consistent with the design bases.
Final Re8EQnER An independent review and a separate third-party review, of the licensing and design bases documentation, was conducted. These reviews confirmed the configuration of the plant with the documented design basis. Results to date have shown an effective configuration process for maintenance of the licensing and design basis. Going forward, any deviations from the licensing and design basis are reported through our ACR Program.
CY Oversight has monitored, and continues to monitor, the activities related to the CYAPCO licensing and design bases and configuration management, j
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