ML19210E670

Responds to NRC 791018,22 & 1121 Requests Re short- & long- Term Recommendations for Auxiliary Feedwater Sys Requirements

ML19210E670
Person / Time
Site:	Millstone
Issue date:	11/28/1979
From:	Counsil W NORTHEAST UTILITIES
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
TAC-42410, NUDOCS 7912050502
Download: ML19210E670 (3)

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November 28, 1979 Docket No. 50-336 Mr. Darrell G. Eisenhut, Acting Director Division of Operatin-

ters Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555

References:

(1)

D. G. Eisenhut letter to W. G. Counsil dated October 22, 1979.

(2)

W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979.

(3)

W. G. Counsil letter to H. Denton dated November 21, 1979.

Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 NRC Requirements for Auxiliary Feedwater Systems In Reference (1), NNEC0 was requested to review Millstone Unit No. 2 against the applicable requirements of Enclosure (1) of Reference (1) to determine the current degree of conformance.

The results of this evaluation and a schedule and commit-ment for implementation of changes was also requested.

In addition, NNECO was requested to respond to a generic request for additional information regarding auxiliary feedwater systems, provided as Enclosure (2) of Reference (1).

In re-sponse to these requests, the following information is provided.

The recommendations of Encles'.re (1) are addressed below, in accordance with the numbering system utilized in Reference (1).

Short ;enn 1.

Recommendation GS-4 Applicable emergency procedures are scheduled to be revised by January 1,1980 to reflect the requirements for transfer to alternate sources of auxiliary feedwater supply for the cases presented in the recommendation.

1502 012 2.

Recommendation GS-5 Emergency procedures are scheduled to ';e revised by January 1, 1980 to contain the informatien required to provide auxiliary feedwater flow from one pump, inde-pendent of any alternating current power source, for at least two hours. Adequate C

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portable lighting and communication are available in the control room for the prescribed manual actions.

3.

Recommandation GS-6 The auxiliary feedwater system procedures and valve lineups are scheduled to be revised by January 1,1980 to require that different operators perform the inde-pendent flow path verifications, if both alignments are completed at the same time.

In other words, one operator will perform the flow path verification for train A, and a different operator will perform the flow path verification for train B.

This level of independence is consistent with the requirements on other safety systems, and has been demonstrated to be adequate to ensure that safety related systems are operable when required.

In addition, a Technical Specification change will be proposed by April 1,1980 to add a surveillance requirement fo-an auxiliary feedwater flow test to be performed af ter a cold shutdown of greater than one month duration.

4.

Recurmendation GS-8 NNECO continues to believe that this recoreendatio-is inappropriate as documented in References (2) and (3).

A detailed response will be provided in a letter from W. G. Counsil to H. Denton, scheduled to be docketed November 29, 1979.

Additional Short Tem Recommendations 1.

The currently installed level instrumentation on the condensate storage tank, consisting of low level alarm and a low-low level alarm in the control room, fulfills the intent of this recommendation.

2.

The significant financial impact associated with this recommendation far exceeds the benefits with respect to reliability verification, in that the auxiliary feedwater pumps have been operated reliably for extended periods at hot standby as a result of normal plant evolutions.

By January 1,1980, operating records will be reviewed to document those periods of operation.

Subsequent to completion of this review, the potential appropriateness of supplemental eadurance tests will be addressed.

3.

NNEC0's response to this recommendation is documented in References (2) and(3).

4.

This recomendation is not applicable, as local manual valve realign-ment is not required for periodic testing.

Additional Long Term Recommendations 1.

NNEC0 continues to believe that this recommendation is inappropriate as documented in References (2) and (3). A detailed response will be pro-vided in a letter from W. G. Counsil to H. Denton, scheduled to be docketed November 29, 1979.

1502 013

2.

NNECO concurs that it is apr

.iriate to eliminate the existing alter-nating current power sourc

.aC) dependency of one auxiliary feedwater (AFW) system pump and its 'ssociated flow path; therefore, this aspect of the recommendation will be implemanted by January 1,1981.

However, NNEC0 does not concur that initiation must be automatic, as noted above.

With regard to Enclosure (2) of Reference (1), P'ECO is committed to respond tu the information requests identified in thmL anclosure.

NNECO is currently in contact with the NSSS vendor, to formulate the work scope and schedule for this endeavor. At the conclusion of these discussions, we will advise the Staff as to the schedule for completion of the effort.

We ti ust you find the above informa' ion responsive +o your requests.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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W'. G. Counsil ~9!4h Vice President 1502 014