ML17256B047
| ML17256B047 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 06/11/1982 |
| From: | Maier J ROCHESTER GAS & ELECTRIC CORP. |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-1.C.1, TASK-1.D.1, TASK-2.D.1, TASK-2.K.3.30, TASK-3.A.1.2, TASK-3.A.2.2, TASK-3.D.3.4, TASK-TM GL-82-10, NUDOCS 8206180180 | |
| Download: ML17256B047 (14) | |
Text
REGUI ATOR, FORMATION DISTRIBUTION S EM (RIDS)
'AOCE'SSION NBR:8206180180 DOC ~ DATE: 82/06/11 NOTARIZED:
NO DOCKET FACIL:SO 244 Robert Emmet Ginna Nuclear Planti Uni,t li Rochester G
05000240 AUTH BYNAME AUTHOR AFFILIATION MAIEREJ ~ E, Rochester Gas 8 Electric Corp.
IREC IP ~ NAME RECIPIENT AFFILIATION ORUTCMFIELDEO ~
Operating Reactors Branch S
SUBJECT:
Forwards response to Generic Ltr 82 10 -requesting confirmation for completion of certain TMI items L addi schedular info'IST RISUTION CODE,'040S COPIES RECEIVED:LTR f ENCL /
SIZE:
TITLE: Response to NUREG "0737/NUREG-0660 TMI Action Plan Rgmts (OL's)
NOTES:NRR/OL/SEP icy'500024tt RECIPIENT ID CODE/NAME ORB 05 BC 01 INTERNAL; ELD/HOSP IE/DEP EPDS NRR/DE DIR 21 NRR/DE/ADMQE 23 NRR/DHFS/DEPY29 NRR/DL/ADL 16 NRR/DL/ADSA 17 NRR/DSI DIR 2Q NRR/DSI/ADRP 26 NRR/DS I/AEB NRR/DS I/RAB DGP 31 REG FILE EXTERNAL: ACRS 3Q INPO J ~ STARNES NRC PDR 02 NTIS NOTES:
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1 RECIPIENT ID CODE/NAME IE/DEP D IR 33 IE/DEP/EPLO NRR/DE/ADCSE 22 NRR/DHFS DIR 28 NRR/DL D IR 14 NRR/DL/AOOR 15 NRR/DL/DRAB.18 NRR/DSI/ADDPS25 NRR/DS I/ADRS 27 NRR/DS I/ETSB NRR/DST D IR 30 NRR/DST'/ADT 32 RGN1 FEMA REP DIV LPDR 03 NSIC 05 COPIES LTTR ENCI 1
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~ 89 EAST AVENUE, ROCHESTER, N.Y. 14649 JOHN E. MAlBR Vke Preskfent TELEPHONE AREA cooK 7le 546.2700 June ll, 1982 Director of Nuclear Reactor Regulation attention:
Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch No.
5 U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Post-TMX Requirements (Generic Letter 82-10)
R. E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Crutchfield:
Darrel Eisenhut's letter dated May 5, 1982 and addressed to all licensees of operating power reactors requested that we confirm the completion of certain TMI items and provide additional schedular information for other items.
The applicable items of the enclosure to Mr. Eisenhut's letter which require a response are addressed in attachment K of this letter.
Very truly yours, Jo n E. Maier attachment 8206180180 8Zohii PDR. ADQCK 05000Z44
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ATTACHMENT A NUREG-0737 ITEMS SCHEDULED AFTER MARCH 1, 1982 Item l.A.1.3.1 Limit Overtime REQUIREMENT:
Revise administrative procedures to limit overtime in accordance with NRC Policy Statement issued by Generic Letter No. 82-02 dated February 8,
1982.
RESPONSE
RGE administrative procedures which limit overtime are in substantial agreement with the NRC Policy Statement.
Descriptions of the RGE'overtime policy and administrative procedures were provided in letters dated October 13,
- 1980, December 15, 1980 and December 30, 1980.
NRC acceptance of this policy and the procedures was given in a November 16, 1981 letter from Dennis M. Crutchfield to John E. Maier.
1.A.1.3.2 REQUIREMENT:
Augment current shift staffing to Minimum conform with the minimum levels set forth on page 3-9 Shift Crew of NUREG-0737.
RESPONSE
An RGE letter dated February 1,
1982 provided a schedule for implementation and the basis for that schedule.
1.C.1 REQUIREMENT:
Revise procedures by next refueling Revise outage; first refueling after October 1, 1982.
Emergency Procedures
RESPONSE
Complete restructuring of existing emer-gency procedures is;,amonumental task.
The work has involved Westinghouse, our NSSS supplier, the Westinghouse Owners Group and INPO.
Generic procedural guidance based upon system analyses, is produced by Westinghouse.
INPO is producing written guidance for use by utilities in implementing generic procedures, for" verification of the procedural techniques and validation of the revised procedures.
The best estimates that we have been given for com-pletion of the Westinghouse and INPO Emergency Operating Procedure (EOP) work are given below:
Product Generic Procedures for Low Head SI Plants Generic EOP Implementation Guidance Generic EOP Writers Guide Generic EOP Verification Guidance Generic EOP Validation Guidance W
INPO INPO INPO INPO 8/82 10/82 12/82 12/82 12/82
~su lier Date
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At. least a year will be required to produce an accept-able EOP network after the guidelines are in hand.
Significant time has been spent by licensed operators and staff in training, retraining and plant simulation exercises with the existing procedures.
The new pro-
- cedures, and the personnel training which must occur prior to procedure implementation, must be written and implemented only with due deliberation.
- Thus, the earliest that we expect to have a new set of EOPs in place for use is December 1983.
This estimate may prove to be optimistic as we proceed further with procedure work.
We will inform you if revisions to this schedule are necessary.
In the interim, we are confident that our existing procedures and the experience of our operating staff are adequate to cope with emergency conditions.
II.D.1.2 RV 8(
SV Test Program REQUIREMENT:
Submit plant specific reports on relief and safety valve program.
RESPONSE
The recommended submittal date of April 1, 1982 was revised to July 1, 1982 by Darrel Eisenhut's letter dated September 29, 1981.
RGE stated in a letter dated April 15, 1982 that our plant specific evaluations had been initiated and a preliminary evaluation of results was underway, but that completion of the evaluation might extend beyond July 1, 1982.
A comprehensive valve qualification report is being prepared to address in depth the pertinent issues required by NUREG-0737.
It is expected that the Ginna specific valve evaluations will be completed during July 1982 and will be submitted to you shortly thereafter.
Our preliminary evaluation of April 15, 1982 which stated that the valves tested r'epresent the Ginna safety and relief valve designs and that the conditions tested envelope the range of expected operating and accident conditions for the Ginna plant remains valid'.
il lt A preliminary evaluation of the Ginna discharge piping is expected to be completed in August 1982.
Thermal hydraulic evaluations are being performed now. If the results indicate that no reanalysis is required and no plant modifications are necessary, a submittal of the results could be prepared by October 1, 1982. If addi-tional analyses or plant modifications are required, an implementation schedule will be formulated and submitted after completion of conceptual design work.
Conceptual modification design, if required, will not be completed before January 1,
1983.
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3 II.D.1.3 REQUIREMENT:
Submit report of test program.
Block Valve Test Program II.K.3.30 and 31 SB LOCA Analysis
RESPONSE
It is anticipated that a generic report of block valve testing results prepared by EPRI will be submitted to the NRC before July 1, 1982 by the chairman of the utility valve testing group.
REQUIREMENT:
Submit plant specific analyses one year after staff approval of model.
III.A.1.2 Staffing Levels for Emergency Situations
RESPONSE
An RGE letter dated January 19, 1982 provided the Westinghouse position on small break LOCA analysis models'and the schedule for submittal of a revised model.
RGE will develop a schedule,.for submitting revised analyses, if required, after the NRC ha's approved a revised model and the extent of the reanalysis, the number utilities requiring reanalysis and the work load of Westinghouse has been evaluated.
1.
REQUIREMENT:
Provide for augmentation of sta ffing in accordance with Generic Letter 81-10 dated February 18, 1981.
RESPONSE
An RGE letter dated May.1, 1981 described our capabilities for response to emergency situations.
Existing call-in procedures, coupled with the proximity of corporate support and staff training, provide adequate staffing and augmentation of normal staffing levels when required.
III.A.1.2 Upgrade Emergency Support Facilities REQUIREMENT:
Complete modifications by October 1, 1982.
RESPONSE
Plant modifications necessary to provide an Operations Support Center (OSC), Technical Support Center (TSC) and Emergency Offsite Facility (EOF) have been completed.
All of these facilities were demon-strated to function adequately during the Ginna tube rupture incident on January 25, 1982.
Additional equipment for monitoring plant parameters in the TSC and EOF remains to be installed.
The additional monitoring capability will enhance the support facility operation although adequate capability already exists.
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The equipment to be added in the TSC and EOF will receive input from the Safety Assessment.
System (SAS) and a new plant process computer.
The specification for the SAS was provided to the NRC Staff with a letter dated June 8,
1981.
Development of this advanced data acquisition and display system is proceeding on schedule with installation expected no earlier than late 1984.
III.A.2.2 REQUIREMENT:
Complete modifications by October 1, 1982.
METEOROLOGICAL DATA
RESPONSE
An RGE letter dated July 1, 1981 provided a
description and a schedule of implementation for an upgraded meteorological measurements and analysis program.
We are implementing the program on the schedule that we provided, with one change to the program.
The proposed long term meteorological system configuration shown on Figure 4 of the July 1 submittal, which was to use RGE computers for data.,analysis, will not be implemented at this time.
The proposed near term meteorological system configuration using an onsite minicomputer and offsite contracted computing facilities will remain as the planned configuration.
Our July 1, 1981 submittal requested an expeditious review of our proposed plan because the NRC requirements were not clearly defined and we had been informed that the requirements might be revised.
We have recently received (May 27, 1982) an Emergency Preparedness Appraisal from Region 1 which includes at least an ISE review of our capabilities.
We have not yet completed a detailed review of the appraisal.
If any changes to our program are necessary we will develop an implementa-tion schedule and submit it at an appropriate time.
Discussions with members of both NRR and IE indicate that some requirements are still in a state of flux and some may not yet be formulated.
In either case a
definitive implementation schedule cannot be laid out.
The meteorological measurements and analysis program being implemented by RGE is, in our view, acceptable and will provide the information necessary for effective management.
of emergency situations to protect public health and safety.
III.D.3.4 REQUIREMENT:
Control study.
Room Habitability Modify facility as identified by licensee
RESPONSE
An RGE letter dated September 4,
1981 provided an evaluation of the Ginna control room HVAC
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Plant modifications identified as a result of this evaluation are summmarized below along with the scheduled installation date.
July 1, 1983 Modification Date
- 1. Limit maximum intake rate of outside air
- 3. Alter existing ductwork to assure proper filtration in post-accident operation 82 refueling In addition, RGE committed to evaluate charcoal filter residence times and to evaluate alternatives for reducing control room ammonia concentrations by July 1, 1982.
Modifications" 1 and 2 are expected to be completed on schedule.
Modification 3 was completed during our recent refueling outage.
The evaluations to be com-pleted by July 1, 1982 will be delayed because of the length of the outage and the additional work which resulted from the January 1982 tube" rupture incident.
Those evaluations are expected to be completed by October 1, 1982.
Other reviews of the Ginna control room HVAC system conducted for SEP and environmental qualification of equipment may result in additional modifications.
If so, it is anticipated that. the additional modifications will be performed on a schedule consistent with the currently proposed regulation 10CFR 50.49.
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