ML19241B092

Forwards Category 2 & 3 Regulatory Positions to Be Addressed in Sep.Reg Guide 1.114 Encl

ML19241B092
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	06/11/1979
From:	Ziemann D Office of Nuclear Reactor Regulation
To:	Counsil W CONNECTICUT YANKEE ATOMIC POWER CO.
References
TASK-***, TASK-RR NUDOCS 7907110676
Download: ML19241B092 (7)

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June 11,1979 Docket No. 50-213 Mr. W. G. Counsil, Vice President Nuclear Engineering and Operations Connecticut Yankee Atomic Power Company Post Office Box 270 Har', ford, Connecticut 06101

Dear Mr. Counsil:

RE:

IMPLEMENTATION OF CATEGORY 2 AND 3 REGULATORY GUIDES IN THE SYSTEMATIC EVALUATION PROCRA." - HADDAM NECK PLANT In the Systematic Evaluation Program for your facility we plan to address Regulatory Guides and other staff positions that have been classified as Category 2 or 3 for implementatl9n by our Regulatory Requirements Review Committee.

I Category 2 and Category 3 are defined as follows:

l Category 2:

Further staff consideration of the need for backfitting appears to be required for certain identified items of the re:ulatory position - these individual issues are such that existing plants need to be evaluated to determine their status with regard to these safety issues to determine the need for backfitting.

Category 3:

Clearly backfit.

Existing plants should be evaluated to determine whether identified items of the regulatory position are resolved in accordance with the guide or by some '.quivalent alternative.

For your information, a list of the Category 2 and 3 positions that we currently plan to address is provided in Enclosure 1.

The SEP topics under which these issues will be considered is alsc shown.

A copy of one Category 3 position, Regulatory Guide 1.114, Revision 1, " Guidance on Being Operator at the Control.; of a Nuclear Power Plant", is provided in To complete our evaluation of th:s sper.ific guide you are requested to provide a commitment to meet the recommendations of the guide.

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Mr. W. G. Cour.sil June 11,1979 Please contact the assigned Project Manager for your faciif ty if you have any questions or conimants about these matters.

Sincerely,

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• tvww Dennis L. Ziemaan, hief Operating Reactors Branch #2 Division of Operating Reactors

Enclosures:

1.

List of Ca+egory 2 and 3 Positions 2.

Regulatory Guide 1.114 cc w/anclosures:

See next page i

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I Mr. W. G. Counsil June 11, 1979 l

l cc w/ enclosures:

Day, Berry & Howard l

Counselors at Law One Constitstion Plaza i

Hartford, Connecticut 06103 t

l Superintendent 1

Haddam Neck Ptant j

RFD #1 l

Post Office Box 127E East Hampton, Connecticut 06424 1

Mr. James R. Hiramelwright Nortneast Utilities Service Company l

P. O. Box 270 Hartford, Connecticut 06101 Russell Lit,cary 119 Broad Street.

Middletcwn, Connecticut 06457 K M C, Inc.

L ATTN: Richard E. Schaffstall 1747 Pennsylv::nia Avenue, N. W.

Suite 1050 l

Washington, D. C.

20006 i

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ENCLOSURE 1 CATEGORY 2 AND 3 MATTERS TO BE ADDRESSED IN THE SEP CATEGORY 2 MATTERS Document Murr6e r Revision Date Title Topic RG 1.27 2,

1/76 Ultimate Heat Sint for Nuclear II-3.C Power Plants RG 1.52 1

7/76 Design, Testing, and Maintenance VI-8 Criteria for Engineered-Safety-Feature Atmosphere Cleanup System Air filtration cnd Adsorption Units of Light Water Cooled Nuclear Power Plants (Revision 2 has been published but the changes from Revision.1 to Revision 2 may, but need not, be considered.

RG 1,59 2

8/77 Design Basis Floods for Nuclear 11-3.B

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Pcwer Plants RG 1.63 2

7/78 Ele:tric Penetration Assemblies in III-12 Containment Structures for Light Water Cooled Nuclear Power Plants RG 1.91 1

2/78 Evaluatic, of Explosions Postulated II-l.C to Occur on Transportation Routes Hear E : lear Power Plant Sites RG 1.102 1

9/76 Flood Protection for Nuclear Power II-3.B Plants RG 1.108 1

8/77 Periodic Testing of Diesel VIII-2 Generator Units Used as Onsite Electric Power Systeras at Nuclear Power Plants RG 1.115 1

7/77 Protection Against Low-Trajectory III-4.B Turbine Missiles RG 1.117 1

4/78 Tornado Design Classification III-4.A III-9 RG 1.124 1

1/78 Service Limits and Loading III-11 Combinations for Class 1 Linear Type Component Supports III-9 RG 1.130 0

7/77 Design Limits and Loading Cecbinations 111-11 for Class 1 Plate-and Snell-Type Component Supports

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CATEGORY 2 MATTERS (CONT'D)

Continued Document Mur:6er Revision Date Title Tooic RG 1.137 0

1/78 Fuel Oil Systees for Standby VIII-2 Diesel Generators (Paragraph C.2)

BTP ASB Guidelines for Fire Protection for IX-6 9.5-1 1

Nuclear Power Plants (See In:plemntation Section, Section D)

BTP MTEB 5-7 4/77 Material Selection and Processing V-4 Guidelines for BWR Coolant Pressure Boundary Piping RG 1.141 0

4/78 Cor.tairenent Isolation Provisions VI-4 for Fluid Systems 9

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CATEGORY 3 MATTERS i

Docume nt Numbe r _ Revision Date Title Topic RG 1.E9 1

4/77 Effects of Residual Elements on V-6 Predicted Radiation Damage to Reactor Yessel Materials (Paragraphs C.1 and C.2.

RG 1.101 1

3/77 Emergency Planning for Nuclear XIII-l i

Power Plants RG 1.114 1

11/76 Guidance on Being Operator at the CRS #2 l

Controls of a Nuclear Power Plant RG 1.121 0

8/76 Bases for Plugging Degraded PWR Y-8 Steam Generator Tubes I

RG 1.127 1

3/73 Inspection of Water-Control Structures III-3.C Associated with Nuclear Power Plants RSB S-1 1

1/78 Branch Technical Position:. Design Require VII-3 rents of the Residual Heat Removai System Y-II.B RSB 5-2 0

3/78 Branch Technical Position: Reactor V-6 Coolant System Overpressurization Protection RG 1.97 1

B/77 Instrumentation for Light Water VII-5 Cooled Nuclear Power Plcnts to Assess Plant Conditions During and Following an Accident I

(ParagraphC.3-withadditional l

guidance on paragraph C.3.d to be provided later)

RG 1.55 1

7/78 Maintenance of Water Purity in Y-12.A Boiling Water Reactors c.

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MATTERS THAT ARE NOT TO BE ADDRESSED 1.

Regulatory Guide 1.105 " Instrument Setpoints" - This mattar was included in the SEP Topic VII-1.B and was resolved on the basis of the hUREG-0138 discussion of the topic.

However, DOR generic action on specific instrumentation such as LPRM drift in BWRs is continuing (such action was noted in the NUREG) and these generic reviews may be expanded if the need to do so is identified.

2.

Regulatory Guide 8.8 "Information Relevant to Ensuring That Occupational Radiation Exposure at Nuclear Po..er Stations Will Be As Low As is Reasonably Achievable (Nuclear Power Reactors)" -

This matter is presently being proposed for resolution by DOR /EEB on a generic basis.

Since ALARA issues were not included in the initial SEP scope it would be inappropriate to include this one unique issue now.

3.

Regulatory Guide 1.68.2 " Initial Startup Test Program to Demonstrate Remote Shutdown Capability for Water-Cooled Nuclear Power Plants" -- This matter was determined, by Regulatory Requirements Review Committee, to be applicable to plants in the OL stage of licensing.

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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION Revision 1 I

November 1976 RIG U LATO RY G JD DE OFFICE OF STANDARDS DEVELOPMENT REGULATORY GUIDE 1.114 GUIDANCE ON BEING OPERATOR AT THE CONTROLS OF A NUCLEAR POWER PLANT A. INTRODUCTION and N RC regulatbns; (2) reviewing operating data, including data logt 'ng and review. in order to ensure Paragra ph (L) of s50.54,"Concations of Licenses,"

safe operation of the plant; and (3) being able to of 10 C FR Part 50, " Licensing of.'roduction and manuall3 imtiate engineered safety features during Utilization Facilities," requires that an operator or sarious transient and accidt nt conditions senior operator licensed pursuant to 10 CFR Part 55,

" Operators' Licenses," be present at the controls at in order for the operat 3r at the controls of a all time' during the operation of a facility.' General nuclear power plant to be able to carry out these and Design Criterion 19. " Control Room," of Appendix other responsibilities in a timely fashion, he must give A, " General Design Criteria for Nuclear Power his attention to the condition of the plant at fl times.

Plants." to 10 CFR part 50 requires, in part, that a He must be alert in order to ensure that the plant is control room be prosided from which actions can be operating safely and must be capable of taking action taken to operate the nuclear power unit safely under to present any progress taward a condition that normal conditions and to maintain the nuclear power might be unsafe. This is facilitated by cor. trol room plant in a safe condition under accident curiditions.

design and layout in w nich all controls,instrumenta.

As defir ed m 10 CFR ;50 :(t), the term "controb, tion disp'ns, and alarms required for the safe opera-w hen used with respect to nuclear reactors mearts ap-tion, shutdow n, and cooldown of the unit are readily paratus and mechanisms, the manipulation of which avaliab!c to the operator in the control room.

directly affects the reactisity or power lesel of the C. REGULATORY POSITION reactor. This guide describes a rnethod acceptable to the NRC staff for complymg with the Commission's

1. The operator at the ec ntrols of a nuclear power regulations that require an operator to be present at plant should have an unobstrt.ted view of and access the controls of a nuclear power plant. The Adsisor) to the operational control panels,; including in-Committee on Reactor Safeguards has been con-strumentation displays and alarms, in c rder to be sulted concernin;. t his guide and has concurred in the able to initiate prompt corrective action, w hen neces-regulatory position.

sary, on receipt of any indication (instrurnent move-men r lard of a chaMng conson.

D. DISCUSSION

2. The operator at the controls should not normal-Operating experience nas shown that there is a h leave the area where continuous attention need for guidance with regard to acceptable methods dnclading visual surveillance of safety related annun-of complying with the Commission s requirement for ators and instrumentation) can be given '.o reactor the presence of an operator at the controis of a operating conditions and where he has acess to the facility. The operator at the controls of a nuclear reactor controls. For example, the operator should power piant has many responsibilities, which. include not routinely enter areas behind control panels w here but are not hr.nted to (1) adhering to the plant s technical specifications, plant operating procedures, operanone co, trol pcets are controt panels t.at enaue the operator a the co urots to perfarrn required rnanual safety func-

• Lme incicatc. suhtantne change from previous issue.

i,ons and equpment sursedlance and to rnorater plant condi.

Currem $tnJard T echnn al Sreaficauons require a bcensed nons under normal and acadera condaions Operational control crera'o' ta be present in h en rol room at au times w hde fuel p.snels include instrumertauer for the ren :. reator coolant n ir iterex m y stem contament. and safen.related proce,s u sierm USNRC REGULATORY G'nDES commenu rosa be

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plant performance cannot be monitored. The sure that proper relief o: curs, administrative operator at the controls should not under any cir-procedures should be written to describe what is re-cumstarces lease the surseillance area defined by quired. The administrative procedure should include, regulatory position 3 for any nonemergency reason as a minimum, a definition of proper relief (e.g., what (e g-. to cor.fer with others or for personal reasons) information is required to be passed on and without obtaining a quahfied relief operator at the acknowledged between the two operators).

controls in the esent of an emergency affecting the safe *, at operations, the operator at the controls may

5. A single operator should not assume the momenunly be absent from the defined surveillance oprator-at-the controls responsibility for two or area in order to serify the receipt of an annunciator more nuclear power units at the same time.

ciarm or initiate correctise action, provided he re-mams unhin the confines of the control room.

D. IMPLEMENTATION The purpose of this section is to provide informa-

3. Administrative procedures should be es-tion to license applicants and licensees regarding the tabbsheJ to define and outline (preferably with NRC staff's plans for using this regulatory guide.

sketchey spe:ific areas within the control room where tFe operator at the controls should remain.

This guide reflects current NRC staff practice.

The pro; dures should define the surveillance area Therefore, except in those cases in which the appli-and the areas that may be entered,in the event of an cant or licensee proposes an acceptable alte. native cmergency affecting the safety of operations. by the methed for complying with specified portions of the eperator 't the controls to s erify receipt of an annun-Com mission's regulations, the method described ciator alarm or initiate correctise action.

herein is being and will continue to be used in the esaluation of submittals for operating license or con-

4. Pnor to assuming responsibility for being struction permit applications and the performance of operator at the controls, the relief operator should be licensees until this guide is revised as a result of sug-properly briefed on the plant status. In order to en-gestions from the public or additional staff review.

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