ML19242A781
| ML19242A781 | |
| Person / Time | |
|---|---|
| Site: | 05000471 |
| Issue date: | 07/31/1979 |
| From: | Lydon J BOSTON EDISON CO. |
| To: | Parr O Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0578, RTR-NUREG-578 NUDOCS 7908060238 | |
| Download: ML19242A781 (25) | |
Text
._
BOSTON EDISON COMPANY BOO BOvtsTON STREET B O ST O N. M A5S ACHUSETTS O219 9 ANORt w r. CO R RY
...... .... .... ~ ~' July 31,1979 Director of Nuclear Reactor Regulation Attention: Mr. G. D. Parr, Chief Branch No. 3 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Additional Information Related to Pilgrim Unit 2 (Docket No. 50-471)
Dear Mr. Parr:
At our meeting on July 20, 1979 in Bethesda, Maryland, the NRC defined the basic scope of actions required on the Pilgrim Unit 2 docket to address issues resulting from the Three Mile Island incident. At a subsequent meeting on July 24, 1979, the actions were defined in more detail. These actions were to provide commitnents to comply with the following:
- 1. Recommendations of NUREG-0578, "Tf11-2 LESSONS LEARNED TASK FORCE STATUS REPORT AND SHORT-TERM RECOMMENDATIONS,"
July 19,1979.
- 2. Requirements of IE Bulletin No.79-06B, " Review of OPERA-TIONAL ERRORS AND SYSTEM MISALIGNMENTS IDENTIFIED DURING THE THREE MILE ISLAND INCIDENT," April 14, 1979.
- 3. Requirements of the NRC Staff memo to the Corp.issioners entitled, " ACTION PLAN FOR PROMPTLY IMPROVING JERGENCY PREPAREDNESS," July 24, 1979.
This letter and its attachments confi rm Boston Edison's commitment to comply as appropriate with the above. These requirement, will be incor-porated into the plant design, operating procedures or emergency plan as applicable and described in detail in the FSAR. Additionally, the Applicants will make any changes during the construction phase that are required to pro-vide substantial, additional protection for the public health and safety.
On the basis of the additional information provided in this letter and its attachments, we understacd from the July 20, 1979 meeting that the NRC Staff will proceed to prepare and subm t appropriate documentation of the acceptability or our commitments in support er the scheduled August 27, 1979 ASLB Hearing.
,aI 3J 468
, 1908060)_32
BOSTON EDISON C O M PAN Y Mr. olan D. Parr 2.
Bostori Cdison remains prepared to build Pilgrim Unit 2 as soon as possible.
New England needs Pilgrim Unit 2 to satisfy its need for power ind to re-duce our dependence on fonign oil supplies. We therefore reopectfully mquest your expeditious actions to enable issuance of a Construction Permit.
Very truly yours,
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Commonwealth of Massachus.
County of Suffolk ,
Then personally appeared before me J. M. Lydon, who being duly sworn, did state that he is Senior Vice President of Boston Edison Company, an Applicant herein, that he is duly authorized to execute and file the foregoing letter in the name and on behalf of Boston Edison Company and the other Applicants herein and that the statements in said letter are true to the best of his knowledge and belief.
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Attachments
- 1) 11 Sheets
- 2) 7 Sheets
- 3) 3 Sheets cc: Service List 468 322
1305TO N EDISON COMPANY Distribution Lis
George H. Lewald, Esq. L. G. Cummings, Vice President Repes & Gray Marsh & McLennan, Inc.
225 Franklin Street 1221 Avenue of the Americas Boston, Massachusetts 02110 New York, New York 10020 The Board of Selectmen W. R. Bisson , Vice Presi dent Town of Plymouth Montaup Electric Company 11 Lincoln Street P. O. Box 391 Plymouth, Massachusetts 02360 Fall River, Massachusetts 02722 Robert H. Cuip G. D. Gowdy, Project Encineer Lowenstein, Newman, Reis , Axelrad & Toll Stor.e & Webster Engineering Corp.
1025 Connecti cut Ave. , N.W. P. O. Box 2325 Suite 1214 Boston, Massachusetts 02107 Washington, D. C. 20036 Combustion Engineering, Inc.
Charles Brinkman Manager luJO Prospect Hill Road Conbustion Engii eering, Inc. Windsor, Connecticut 06095 Nuclear Licene a ng Of fi ce At tn : Mr. E. P. Mailman Triangle Towr es Suite A-1 Robert Wanczyk 4853 Cordell Ave. Yankee Atomic Electric Comoany Bethesda, Maryland 20014 Seabrook Nuclear Station 20 Turnpike Road Charles Bardes Westboro, Massachusetts 01581 NELIA The Exchange Thonas C. itewart Farmington Avanut M&M Protec". ion Consultants Farmington, Co aecticut 06032 200 Clarencen Street Boston, Masso;busetts 02116 J. E. Booker Gulf State Utilities Co. Bruce W. McKinnon, Manager P. O. Box 2951 Connuni cy Power Development Dept.
Beaumont, Texas 77704 Mass. Municipal Wholesale Electric Co.
Stony Brook Energy Center John J. Carney Post Office Box 426 Nuclear Energy Property Ludlow, Massachusetts 01056 Insurance Association 85 Woodland Street John L. McLean Hartford, Connecticut 06102 Teledyne Engineering Services 303 Bear Hill Road Dr. Charles Cole Waltham, Massachusetts 02154 Holdsworth Hall - Natural Resources Center Loren K. Stanley Amherst, Massachuse; ts C1002 Nuclear Services Corp.
477 Division Street Les W. Cooley CaTpbell, California 95008 EDS Nuclear 220 Montgomery 5treet San Francisco, California 94104 463 323
BOSTON EDISON COMPANY 2.
Paul Corman William H. Dormer C. T. Maia, Inc.
Mass. Dept. of Public Safety 8th Floor 1010 Commonwealth Avenue 101 Huntington Avenu i Boston, Massachusetts 02215 Boston, Massachusett. 02199 Directorate of Licensing John D. Fassett, President U.S. Nuclear Regulatory Comnission The United Illuminating Co.
Phillips Building 80 Temple Street 7920 Norfolk Avenue New Haven, Connecticut 06506 Bethesda, Maryland 20034 Attn: Emanuel Licitra Mr. Phillip C. Otness, General Mgr.
Mass. Municipal Wholesale Electric Co.
Gerald S. Parker Stcny Brook Energy Center Director , Radiation Control Programs Post Office Box 426 Mass. Dept. of Public Health Ludlow, Massachusetts 01500 Room 835 80 Boylston Street Boston, Massachusetts 02116 Dean P. Ami don Mass. Dept. of Public Works Bechtel Paver Corporation Division of Waterways Post Office Box 3965 100 Nashua Street, Room 529 c/o Central Receiving Boston, Massachusetts 02114 San Francisco, Califormia 94119 Attn: Mr. B. N. Pusheck Mr. Janes B. Muckerheide 755 Boylston Street Gerald E. Anderson , Presi dent Suite 306 New Bedford Gas & Edison Light Co. Boston, Massachusetts 02116 Post Office Box 190 Cambridge, Massachusetts 02139 Ralph M. Wood, Esq.
' ubli c Servi ce Company of N.H.
1000 Elm Street Manchester, New Hampshire 03105 Neil Todreas Nuclear Engineering Dept.
Room 24-109 Mass. Institute of Technology 77 Massachusetts Avenue Cambridge, Massachusetts 02139 Joel Watson Environmental Research & Technology 696 Virginia Road Concord, Massachusetts 01742 Anthony D. Cortese, Commissioner Dept. of Environnental Quality Engrg.
100 Cambridge Street ,
Boston, Massachusetts 02108 468 324
Sh. 1 of 11 Attachment #1 Pilgrim Station Unit 2 Boston Edison Company Docket No. 50-471 The following additional information provides the NRC with the necessary assJrance that Pilgrim Unit 2 will meet the intent of NUREG-0578, "TMI-2 LESSONS LEARNED TASK FORCE STATUS REPORT AND SHORT-TERM RECOMMENDATIONS",
July 19, 1979. While the conmitments to each applicable position are addressed below, the implementation details will be described more fully in the FSAR.
Item 2.1.1 Emergency Power Supply Requirements for the Pressurizer Heaters, Power-Operated Relief and Blcuk Valves, and Pressurizer Level Indicators in PWRs.
Re contenda tion:
Provide redundant emergency power for the minimum number of pressurizer heaters required to maintain natural circulation conditions in the event of loss of offsite power. Also pro-vide emergency power to the control end motive power systems for the power-operated relief valves and associated block valves and to the pressurizer level indication instrument channels.
Response
Redundant emergency power will be provided for the minimum number of pressurizer heaters required to maintain natural circulacion conditic.._ in the event of loss of offsite power. Eme rgency power v il also be provided to the control and motive power systems for thL L.vwer-operated relief valves and associated block valves and to the pressurizer level indication instrument channels.
Item 2.1.2 Performence Testing for BWR and PWR Relief and Safety Valves.
Reconmenda tion :
Commit to provide performance verification by full scale prototypical testing for all relief and safety valves. Test conditions shall in-clude two-phase slug flow and subcooled liquid flow calculated to occur for design basis transients and accidents.
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Sh. 2 of 11
Response
Pilgrim Unit 2 will support the industry efforts to provide per-formance verification by full scale testing for all relief and
- fety valves. The supported test conditions will include two-phase slug flow and subcooled liquid flow calculated to occur for design basis transients and accidents. The verification for Pilgrim Unit 2 will comply witn resolution between the NRC and the industry of the testing requi rements.
Item 2.1.3 Information to Aid Operators in Acc dent Diagnosis and Control.
Reconnendatig1:
Provide in the control room either a reliable, direct position indication for the valves or a reliable flo'.. indication device down-stream of the valves.
Response
A reliable, direct position indication for the valves, a reliable flow indication device downstream of the valves, or an equivalcat alternate method acceptable to the NRC will be used to provide in-dication in the control room.
Recommendation:
Perform analyses and implement procedures and training for prompt recognition of low reactor coolant level and inadequate core cooling using existing reactor instrumentation (flow, temperature, power, etc. ) or short-term modi fications of existing instruments. Describe further measures and provide supporting analyses that will yield more direct indication of low reactor coolant level and inadequate core cooling such as reactor vessel water level instrumentation.
Response
Anaiyses will be performed to establish the information required for prompt recognition of low reactor coolant level and inadequate core
.ooling. Necessary reactor instrumentation will be provided, and the implementation of procedures and operator training will be based on the results of these analyses.
468 326
Sh. 3 of 11 Item 2.1.4 Containment Isolation Provisions for PWRs and BWRs.
Reconron da_ tion :
Provide containment isclation on diverse signal:, ir .n fo rmance with Section 6.2.4 of the Standard Review Plan, review isolation provisions for non-essential systems and revise as necessary, and modify containment isolation designs as necessary to eliminate the potential for inadvertent reopening upon reset of the isolation signal.
Response
Containment isolation will be initiated by diverse signals in con-formance with Section 6.2.4 of the Standard Review Plan. Isclation provisions for non-essential systems will be reviewed and revised as necessary to eliminate the potential for inadvertent reopening upon reset of the isolation signal.
Item 2.1.5 Post-Accident Hydrogen Control Systems for PWR and BWR Containments.
- a. Dedicated Penetrations for External Recombiner or Post-Accident External Purge System.
Recomnendati on :
For plants that have external recombiners or purge systems, provide dedicated penetrations and isolation systems that meet the redor.dancy and single failure requirements of tae Commission regulations.
Modify design as necessary so that these systems are not connected to, or are branch lines of, the large containment purge penetrations.
Response
Pilgrim Unit 2 design will incicde redundant internal recombiners.
Dedicated penetrations and isolation sy tems that meet the re-dundancy and single failure requirements of the Commission regulations will be provided for the containment purge system. The design will be such that systems are not connected to, or are branch lines of, the large containcent purge penetrations.
- b. Inerting BWR Containments Recommendation:
Provide inerting for all Mark I and Mark II BWR containments. This ,
would require changes at Vermont Yankee and Hatch Unit 2 (operating plants), as well as pending OL applicatioas for Mark I and II BWRs.
Response
This is not applicable to Pilgrim Unit 2. --
463 3c., 7
Sh. 4 of 11
- c. Capability to Install Hydrogen Pacon6iner at Each Light Water fluclear Power Plant.
Recommen da tion :
A minority of the Task Force recommends that all operating rea'. tors, which do not already have the capability, be required to provide the capability to add, within a few days af ter an accident, a hydregen recombiner system for post-accident hydrogen control.
Respor,s e:
This is not applicable to Pilgrim Unit 2, since redundant internal recombiners are provided, refer to the response to Item 2.1.5.a above.
Item 2.1.6 Post-Accident Control of Radiation in Systems Outside Con-tainment of PWRs and BWRs.
- a. Integrity of Systems Outside Contaipent Likely to Contain Radioactive Materials (Engineered p.ety Systems and _A_uxiliary bystems)_
Recommendation:
Perform leakage rate tests on systems outside containme, t that process primary cooiant and could contain high ie cl r:di_ active materials.
Develop and implement periodic testing programs and preventive main-tenance programs.
Rr.spons e :
aakage rate tests will be performed on systems outside containment that process primary coolant and could contain high level radioactive mate-ials.
Periodic testing and preventive maintenance programs will be developed and imple,nented accordingF .
- b. Design Review of Plant Shielding oi Spaces for Post Accident Operations Recommenda tion :
Perfonn a design review of the shielding of systems processing primory coolant outside of containment. Determine any areas or equipment that are vital for post-accident occupancy or operation and assure that access and performance will not be unduly impaimd due to radiation fro.. these systems.
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Sh. 5 of 11
Response
e A design review of the shielding of systems processing primary coolant outside of containment will be performed. Any areas or equipment that are vital for post-accident occupancy or operation will be identified. Access and performance will not be unduly impaired due to radiation from these systems.
Item 2.1.7 Improved Auxiliary Feedwater System Reliability
- a. Automatic Initiation of ne Auxiliary Feedwater System Reconmendation :
Provide automatic initiation of all auxiliary feedwater systems. The initiation signals and circuits shall be designed in such a manner that a single failure will not result in the loss of auxiliary feed-water system function. Testability of the initiating signals and circuits sMll be a feature of the design. The initiating signals and circuits shall be powered from the emergency buses. Manual capability to initiate the auxiliary feedwater system from the con-trol room must be retained and must be implemented in such a manner that a single failure in the manual circuits will not result in the loss of system function. The a-c motor-driven pumps and valves in the auxiliary feedsater system must be included in the automatic actuation (simultaneous or sequential) of the leads to the emergency buses. The ce;ign of the automatic initiating signals and circuits must be such tlat their failure will not result in the loss of manual capability to initiate the auxiliary feedwater system from the control Voom.
Response
The Pilgrim Unit 2 existing design provides automatic initiation of the emergency feedwater system. The initiation signals and circuits are designed in such a manner that a single failure will not result in the loss of emergency feedwater system function. Testability of the initiating signals and circuits is a feature of the design.
The initiating signals and circuits are powered from the emergency t;us es . Manual c6pability to initiate tl.e emergency feedwater system from the control room exists in such a manner that a single failure in the manual circuits will not result in the loss of system function.
The a-c motor-driven pumps and valves in the emergency feedwater system are included in the automatic ectuation (simultaneous or sequential) of the loads to the emergency buses. The design of the automatic initiating signals and circuits is such that their failure will not result in the loss of manual capacility to initiate the en.ergency feed-water system from the control room.
468 329
Sh. 6 of 11
- b. Auxiliary Feedwater Flow Indicatior to Steam Generators Recontenda tion :
Provide safety-grade indication in the control room of auxiliary feedwater flow for each steam generator. The flow instrument channels shall be powered from the emergency buses, consistent with satisfying the power diversity requirements for auxiliary feedwater systems.
Response
Safety-grade indication of emergency feedwater flow for each steam generator will be provided in the control room. The flow instrument channels will be powered from the emergency buses, consistent with satisfying the power diversity requirements for emergency feedwater systems.
Item 2.1.8 Instrumentation to Follow the Course of an Accident
- a. Inproved Post-Accident Sampling Capability Re commen da tion :
Resiew and upgrade the capability to obtain samples from the reactor coolant system and containment atmosphere under high radioactivity condi ti ons. Provide the capability for chemical and spectrum analysis of high-level sanples on site.
Re sponse :
The capability to obtain samples from the reactor coolant system and containment atmosphere under high radioactivity conditions will be reviewed and upgraded. The capability for chemical and spectrum analysis of high-level samples will be provided on site.
- b. Increased Range of Radiation Monitors Recommendation:
Provide high range radiation monitors for noble gases in plant effluent lines and a high-range radiation monitor in the containment. Provide instrumentation for monitoring effluent release lines capable of measuring and identifying radiciodine and particulate radioactive effluents under acc' dent conditions.
Response
Pilgrim ' Jolt 2 will support the industry efforts o provide: a) high range radiation monitors for noble gases in plant effluent lines, b) a high-range radiation monitor in the containment, and c) instrumenta-tion for monitoring effluent release lines capable of measuriag and identifying radioiodine and particulate radioactive effluents under accident conditions. The instrumentation for Pilorim Unit 2 will comply with the final resolution between the NKC and the indust - based on sta te-of-the-art capabili ty. ,,n 7 'i L{ b Q sJO
Sh. 7 of 11
- c. Improved In-Plant Iodine Instrumentation Re commendation _:
Provide instrumentation for accurately detennining in-plant air-borne radiciodine cncentrations to minimize the need fc- unnecessary use of respiratory pmtection equipment.
Response
Instrumentation will be provided for determining in-plant airbome radioiodine concentrations to minimize the need for unnecessary use of mspiratory protection equipment. Accuracy will be based on state-of-the-art capability.
Item 2.1.9 Analysis of Design and Off-Normal Transients and Accidents
- a. Recomen dation :
Provide the analysis, emergency procedures, and training to sub-stantially improve operator performance during a small break loss-of-coolant accident.
Response
The analysis, emergency procedures, and training to substantially improve operator performance during a small break loss-of-coolant accident will be provided.
- b. Recommendation :
Provide the analysis, emergency procedures, and training aeeded to assure that the reactor operator can recognize and respond to conditions of inadequate core cooling.
Response
The analysis, emergency procedures, and training needed to assure that the reactor operator can recognize and respond to conditions of in-adequate core cooling will be provided.
- c. Recomendation :
Provide the analysis, emergency procedures, and training to sub-stantially improve operator perfo, ance during transients and accidents, including events that are caused or worsened by inappropriate operator a cti on s .
Response
The analysis, emergency procedures, and training to substantially improve operator perfonMnce during transients and accidents, including events that are caused or worsened by inappropriate operator actions will be provided. __
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Sh. 8 of 11 Item 2.2 Ope rations Item 2.2.1 Improved Reactor Ope,ations Command Function
- a. Shif t Supervisor Responsibilities Recommendation:
Review plant administrative and management procedures. Revise as necessary to assure that reactor operations command and control responsibilities and aulitority are properly defined. Corporate management shall revise and pmmptly issue an operations policy directive that emphasizes the duties, responsibilities, and authority and lines of command of the control room operators, the shift tech-nical advisor, and the person responsible for reactor operations command in the control room (i.e. , the senior reactor operator).
Response
Plant administrative and management procedures will be prepared as necessary to assure that reactor operations command and control responsibilities and authority are properly defined. Corporate management will issue an operations policy directive that emphasizes the duties, responsibilities, and authority and lines of command of the control room operators, the shift technical advisor, and the person responsible for mactor operations command in the control room (i.e. , the senior reactor operator).
- b. Shif t Technical Advisor Recommen da tion :
Provide on shift at each nuclear power plant a qualified person (the shift technical advisor) with a bachelor's degree or equivalent in a science or e1gineering discipline and with specific training in the plant response to off-nomal events and in accident analysis of the plant. Shif t technical advisors shall serve in an advisory capacity to shift supervisors. The licensee shall assign normal duties to the shif t technical advisor that pertain to the engineering aspects of assuring safe operations of the plant, including the re-view and t saluation of operating experience.
Response
Pilgrim Unit 2 will comply wi th the necessary staffing requirements at the time of operating license issuance.
468 332
Sh. 9 of 31
- c. Shif t and Relief Turnover Pr ocedures Recommendation:
Review and revise plant procedures as necessary to assure that a shif t turnover checklist is provided and required to be completed and signed by the on-coming and off-going individuals responsible for command of operations in the control room. Supplemen tary checklists and shift logs should be developed for the entire opera-tions organization, including instrument technicians, auxiliary operators, and maintenance personnel.
Response
Plant procedures will be established as necessary to assure that a shif t turnover checklist is provided and required to be completed and signed by the on-coming and off-going individuals responsible for comnand of operations in the control room. Supplementary check-lists and shift logs will be developed for the entire operations organization, including instrument technicians, auxiliary operators, and main'cenance personnel Item 2.2.2 Improved In-Plant Emergency Procedures and Preparations
- a. Control Room Access Re commen dati on :
Review plant emergency procedures, and revise as necessary to assure that access to the control room under ncrral and accident conditions is limited to those persons necessary to the safe command and control or operations.
Response
Plant emergency procedures will be prepared to assure that access to the control room under normal and accident conditions is limited to those persons necessary to 'he safe commar,d and control or operations.
- b. On_ site Technical Support Center Recoarendation_:
A separate technical support center shall be provided for use by plant management, technical, and engineering support personnel. In an emergency, this center shall be used for assessment of plant status and potencial offsite impact in support of the control room comnar.d and control function. The center should also be used in conjunction with implerentation of onsite and offsite emergency plans, including conmunications with an offsite emerc2ncy response center. Provide 3t the onsite technical support center the as-built drawings of general plant arrangements and piping, instrumentation and electrical systems.,7 k (;b
Sh. 10 of 11 Photographs of as-built system layouts and locations ray be an acceptable nethod of satisfying some of these needs.
fesponse:
A separate technical support center will be provided for use by plant management, technical, and engineering support personnel.
In an emergency, this center will be used for assessment of plant status and potential offsite impact in support of the control room conmand and control function. The center will also be used in conjunction with implementation of onsite and offsite excency plans, including communications with an offsite emergency response cen te r. At the onsite technical support center, the as-built drawings of general plant arrangements and piping, instrumentation and electrical systems will be_provided. Photographs of as-built system layouts and locations may be utilized to satisfy scme of thesc needs.
- c. Orsite Operational Support Center Re commendation Each operating nuclear power plant should establish and maintain a separate onsite operational support center outside the control room.
In the event of ari emergency, shift support personnel (e.g. , auxiliary operators and technicians) other than those required and allowea in the control room ihall report to this center for further orders and a s si gnrent.
Response
A separate onsite operational support center will be establishei and maintained outside the control room. In the event of an emergency, shif t support personnel (e.g. , auxiliary operators and technicians) other than those required and allowed in the control room will report to this center for further orders and assignment.
Item 2.2.3 Revised Limiting Conditions for Operation of Nuclear Power Plants Based Upon Safety System Availability Re commendation :
Pequire that the Technical Specifications for each reactor provi<le that the reacto - be placed in a hot shutdown condition within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and in a cold shutdown condition by the licensee within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of any tine that it is found to be or have been in operation with a complete loss of safety function (e.g., loss of emergency f( edwater, high-pressure ECCS, low-pressure ECCS, containment, emergenc ' power or other prescribed safety function). Require that an assessment of the cause of the 13ss of safety function be made (e.g. , maintenan e, operations error) and that an evaluation of alternative corrective actions be made and documented by the licensee. Require that the senior corporate officer responsible for operation of the facility present the licensee's reconmendation for corrective action and --
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Sh. 11 of 11 evaluation of the alternatives at a public meeting with senior flRC of ficials. Require that the senior f!RC officials issue their decision at that public meeting, or a subsequent public meeting if time is required for staf f evaluation, concerning the a luacy of the changes to improve operational reliability pro-posed iy the utility. Allow the facility to mtu' .1 to power only after t1RC approval of the changes proposed by the licensee.
Response
Pilgrim Unit 2 will participate in the rulemaking procedures and comply with the results of that process.
- r 0 N -)
[ 9
Sh. 1 of 7 Attachment #2 Pilgrim Station Unit 2__
Boston Edi son Company Docket No. 50-471 The following additional information proviJes the NRC with the necessary assurance that Pilgrim Unit 2 will meet the intent of IE Bulletin 79-06B,
" Review of Operational Errors and System Misalignments Identified During the Three Mile Island Incident," April 14, 1979. While the commitments to each applicable position are addressed below, the implementation details will be described more fully in the FSAR. IE Bulletin 79-06B requires action to be taken by licensees of operating Combustion Engineering designed light water reactors. A review of this bulletin has indicated that, although some areas of concern are not immediately applicable to Pilgrim Unit 2 at the Construction Permit stage, it is appropriate to identify and commit to necessary future actions. The following responses address each item of Bulletin 79-06B:
ITEM:
- 1. Review the description of circumstances described in Enclosure 1 of IE Bulletin 79-05 and the preliminary chronology of the TMI-2 3/28/79 accident included in Enclosure 1 to IE Bulletin 79-05A.
- a. This review should be directed toward understanding: (1) the extreme seriousness and consequences of tha simultaneous blocking of both auxiliary feedwater trains at the Three Mile Island Unit 2 plant and other actions taken during the early phases of the accident; (2) the apparent operational errors which led to the eventual core damage; (3) that the potential exists, under certain accident or transient conditions, to have a water level in the pressurizer simultaneously with the reactor vessel not full of water; and (4) the necessity to systematically analyze plant conditions and parameters and take appropriate corrective action.
- b. Operational personnel should be instructed to: (1) not override automatic action of engineered safety features unless continued operation of engineered safety features will resdt in unsafe plant conditions (see Section C2), and (2) not ...A operatior,al decisions based solely on a single plant parameter in i ction when one or more confirmatory indications are available.
- c. All licensed operators and plant management and supervisors with operational responsibilities shall participate in this review and such participation shall be documented in plant records.
L) { 0 b
Sh. 2 of 7 RE'PONSE:
la. These issues and concerns will be incorporated into the training program for the Pilgrim Unit 2 operating staff.
Ib. The operator training program for Pilgrim Unit 2 will .mphasize the key role of the operator in reactor safety and will implement the requirements of item lb.
Ic. Licensed operators and plant management and supervisors with opera-tional responsitilities will participate in the efforts described in la and Ib.
ITEM:
- 2. Paview the actions required by your operating proccdures for coping with transients and accidents, with particular attention to:
- a. Recognition of the possibility of forming voids in the primary coolart system large enough to compromise the core cooling capability, especially r.hural circulation capability.
- b. Operator action required to prevent the fonnation of such voids.
- c. Operator action required to enhance core cooling in the event such voids are fonned. (e.g. , remote venting)
RESPONSE
- 2. Operating procedures for coping with transients and accidents will be developed with particular attention to:
- a. Recognition of the possibility of fonning voids in the primary coolant system large enough to compromise the core cooling capability, especially natural circulation capability.
- b. Operator action required to prevent the formation of s" ' voids.
- c. Operator action required to enhance core cooling in the ever.t such voids are formed. (e.g. , remote venting)
This is also addressed in our responses to Recomendc.tions 2.1.3b and 2.1.9b of NUREG-0578 in Attachment *1.
468 SM?-
Sh. 2 of 7 ITEM:
- 3. Review the containment isolation initiation design and procedures, and prepare and implement all changes necessary to permit containment isolation whether manual ve automatic, of all lines whose isolation does not degrade ner Jed safety features or cooling capability, upon automatic initiation of safety injection.
RESPONSE
- 3. As addressed in our response to Recommendation 2.1.4 of NUREG-0578 in Attachment #1, the Pilgrim Unit 2 design will conform to the con-tainment isolation initiation design requirements _ Implementing procedures and operator training will be provided accordingly.
Il'M:
- 4. For facilities for which the auxiliary feedwater system is not auto-matically initiated, prepare and implement immediately procedures which require the stationing of an individual (with no other assigned con-current duties and in direct and continuous corinunication with the control rocia) to promptly initiate adequate auxiliary feedwater to the steam generator (s) for those transients or accidents the con-sequences of which can be limited by such action.
RESPONSE
- 4. Pilgrim Unit 2 will provide automatic initiation of emergency feed-water as descriued in our response to Recommendation 2,1.7 of NUREG-0578 in Attachmcat #1, therefore this item is not applicable.
ITEM:
- 5. For your facilities, prepare and implement immediately procedures which;
- a. Identify those plant indications (such as valve discharge piping temperature, valve position iridication, or valve discharge relief tank temperatu.e or pressure irdication) which plant operators may utilize to cetemine thct pressurizer power operated relief valve (s) are open, and
- b. Direct the plant operators to manually close the power operated relief block valve (s) when reactor coolant system pressure is redeced to below the set point for normal automatic closure of the power operated relief valve (s) and the valve (s) remain stuck open.
IM8 333
Sh. 4 of 7
RESPONSE
- 5. Procedures will be developed identifying the indications of an open pressuiizer power operated relief valve (PORV) including the use of instrumentation descrioed in our response to Recommendation 2.1.3.a or NUREG-0578 in Attachmen. #1. Pmcedures will be developed to cope with the event of a PORV stt. k oper, .>elow the normal automatic closure setpoint.
ITEM:
- 6. Review the action directed by the operating procedures and training instructions to ensure that:
- a. Operators do not override automatic actions of engineered safety features, unless continued operation of engineered sa.'ety features will result in unsafe plant conditions. For example, if continued operation of engineered safety features would threaten reactor vessel integrity then the HPI should be secured (as noted in b(2) below).
- b. Querating procedures currently, or are revised to, specify that if the high perssure injection (HPC) system has been automatically actuated because of low pressure condition, it must remain in operation until either:
(1) Both low pressure injection (LPI) pumps are in operation and flowing for 20 minutes or longer; at a rate which would assure stable plant behavior; or (2) ine HPI system has been in operation for 20 minutes, and all hot and cold leg temperatures are at least 50 degmes below the saturation temperatum for the existing RCS pressum. If 50 degrees subcooling cannot be maintained af ter HPI cutoff, the HPI shall be reactivated. The degree of subcooling beyond 50 degrees F and the length of time HPI is in operation shall be limited by the pressure /temperr.ture considerations for the vessel integrity.
- c. Operating procedures currently, or are revised to, specify that in the event of HPI initiation with reactor coolant pumps (RCP) operating, at least one RCP shall remain operating in each loop as long as the pump (s) is providing forced flow.
- d. Operators are provided additional information and instructions to not rely upon pressurizer level indication alone, but to also examine pressurizer pressurc and other plant parameter indications in evaluatir.g plant conditions, e.g. , water, in-ventory in the reactor primary system.
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Sh. 5 of 7 RESPONSE :
- 6. a) Procedures will be developed to insum that operators do not override automatic actions of enqineered safety features unless continued operation will result in unsafe plant conditions.
b) The HPSI System will not be secured unless hot and cold leg temperature indications are at least 50 degmes below the saturation temperature for the existing reactor coolant system pressure.
If 50 degrees subcooling cannot be maintained after the HPSI System is secured the HPSI System will be reactivated.
c) Reactor coolant pump operation in the event of safety injection will be based upon maximizing reactor safety, d) The ot Jrator training program will emphasize use of confirmatory indications in the implementation of our response to Item 1.b(2) above.
ITEM:
- 7. Review all safety-related valve positions, positioning requirements and positive controls to assure that va'ves remain positioned (open or closed) in a manner to ensure the proper operation of engineered safety features. Also review related procedures, such as those for maintenance, testing, plant and system startup, and supervisory periodic (e.g. , daily /sh ' ft checks,) surveillance to ensure that such valves are returned to their correct positions following necessary manipulations and are maintained in their proper positions during all operational modes.
RESPONSE
- 7. Safety-related valve positions, positioning requirements and positive centrols will be established such that assurance will be provided that Vdives (including locked vaisas) remain positiened (open or closed) in a manner to ensure the proper operation c' engineered safety features.
Related procedures, such as those for maintenance, testing, plant and system startup, and supervisory period (e.g. , daily /shi'* checks) sur-veillance will be provided to insure that such valves ar e returned to their correct positions following necessary manipulations and are maintained in their proper positions during all operational modes.
ITEM:
- 8. Review your operating nodes and procedures for all systems designed to transfer potentially radioactive gases and liquids out of the primary containn ent to assure that undesired pumping, venting or other releases of radioactive liquids and gases will not occur inadvertently.
468 K0
Sh. 6 of 7 In particular, ensure that och an occurrence would not be caused by the resetting of engineer ' ety features instrumentation. List all such systems and indicate:
- a. Whether 'iterlccks exist to prevent transfer when high radiation indication exists, and
- b. Whether such systems are isolated by the containment isolation signal.
- c. The basis on which continued operability of the above features is assured.
RESPON3E:
- 8. The Pilgrim Unit 2 design and procedures will provide the necessary control to assure that the transfer of radioactive fluids or gases out of containment will not occur inadvertently.
ITEM:
- 9. Review and modify as necessary your maintenance and test procedures to ensure that they require:
- a. Verification, by test or inspection, of the operabili ty of redundant safety-related systems prior to the removal of any safety-related systen from service.
- b. Verification of the operability of all safety-related systems when they are returned to service following maintenance or testing.
- c. Explicit notification of involved reactor operational personnal whenever a safety-related system is removed from and returned to service.
RESPONSE
- 9. Maintenance and test procedures wi' .re verification, by test or inspection, of the operability of redunaant safety-related systems prior to their removal from service, verification of the operability of all s:#ety-related systems whea they are returned to service follcwing maintenance or testing, and the explicit notification of appropriate personnel of the change in status of those safety-related systems.
ITEM:
- 10. Review your prompt reporting procedures for NRC notification to assure that NRC is notified within one hour of the time the reactor is not in a controlled or expected condition of operation. Further, at that time an open continuous communication cnannel shall be established and maintained with NRC.
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Sh. 7 of 7
RESPONSE
- 10. Pilgrim Unit 2 prompt reporting procedures will provide for NRC notification within one t.our and for establishing and maintaining an open communication channel with the NRC.
ITEM:
- 11. Review operating modes and procedures to deal with significant amounts of hydrogen gas that may be generated during a transient or other accident that would either remain inside the primary system or be released to the containment.
RESPONSE :
- 11. Operating modes and procedures fcr dealing with significant amounts of hydrogen gas either inside the primary systei or the containment will be established.
ITEM:
- 12. Propose changes, as required, to those technical specifications which must be mcdified as a result of your implementing the above items.
RESPONSE
- 12. Technical specifications will be prepared and submitted with the FSAR considering the responses given above.
k (30 b ' <' -
- Sh. 1 of 3 Attachment #3 Pilgrim Station Unit 2__
Boston Edi on Company Docket No. 50-471 The following additional information provides the NRC with the necessary assurance that Pilgrim Unit 2 will meet the intent of the " ACTION PLAN FOR PROMPTLv IMPROVING EMERGENCY PREPAREDNESS", July 24, 1979. The implementa-tion details will be described in the Final Safety Analysis Report (FSAR).
The following format addresses the main elements of the NRC Staff effort described in the document referenced above.
(1) Element:
Upgrade licensee emergency plans to satisfy Reguletory Guica 1.101, with special attention to the development of uniform action level criteria based on plant parameters.
(1) Response:
The Pilgrim Unit 2 emergency plan will be based on and will satisfy Regulatory Guide 1.101. Special atter. tion will be given to the developrent of uniform action level criteria based on plant parameters.
(2) Element:
Assure the implementation of the related recommendations of the NPR Lessons Let rr.ed Task Force involving instrun,_ntation to follow the course of ari accident and relate the information provided by this instrumentation to the emer,ency plan action levels. This will in-clude instrumentation for post-accident sampling, high range radio-a ctiilty monitors, and improved in-plant radiciodine instrumentation.
The implementation of the Lessons Learned recommendation on in-strumentation for detection of ir. adequate core cooling will also be factored into the emergency plan action level criteria.
(2) Response:
Commitments in this area have been addressed in the Pilgr Unit 2 responses to NUREG-0578, given in Attachment #1. The implementation of the Lessons Learned recommendation on instrumentation for de-tection of inadequate core cooling will also be factomd into the emergency plan action level criteria. 7
_b 'i '
{h
Sh. 2 of 3 (3) Element:
Detemine that an Emergency Operi.tions Center for Federal, State and local personnel has been established with suitable communications to the plant, and that upgrading of the facility in accordance with the Lessons Learned recommendation for an in-plant technical support center is underway.
(3) Response:
An Emergency Operations Center will be established for Federal, State and local personnel with suitable communications between the plant a !d the Emergency Operations Center. As indicated in the responses to Recommendation 2.2.2.b NUREG-0578 in Attachment #1,an in-plant technicil support center will be provided.
(4) Element:
Assure that improved licensee offsite monitoring capabilities (including additional TLD's or equi"alent) have been provided for all sites.
(4) Response:
Offsite monitoririg capabilities for Pilgrim Unit 2 will comply with the requirements in effect at the operating license stage.
(';) Element:
Assess the relationship of State / local plans to the licensee's and Federal plans so as to assure the capability to take appropriate emergency actions. Assure that this capability will be extended to a estance of 10 miles as soon as practical but not later than January 1, 1981. This item will be performed in coniunction with the Office of State Programs and the Office of Inspection and Enforcement.
(5) Response:
Boston Edison is currently cooperating with the Commonwealth of Massachusetts in its development of an emergency action plen out to a radius of 10 miles from Pilgrim Station. It is our understanding that the Commonwealth of Massachusetts will submit documentation cf this plan to thc NRC to enable implementation prior to 1/1/81.
(6) Element:
Require test exercises of approved Emergency Plans (Federal local, licensees), review plans for such exercises, and par in a limited number of joint exercises. Tests of licensee i will be required to be conducted as soon as practical for all facilities and before reactor startup for new licensees. Exercises of State plans will be performed in conjunction with the concurrence reviews et the Office of State Programs. Joint text exercises involving Federal, State lot al and licensees will be conducted at the rate of about 10 per year, which would result in all sites being exer ised once each five years.
[ (,9 5d
Sh. 3 of 3 (6) Response:
The applicants will participate in test exercises cf approved Emergency Plans (Federal, State, local, licensees). We will participate in reviews of plans for such exercises, and participate joint exercises. We will cooperate in any tests conducted before reactor startup. We will participate in exercises of State plans to be perfonned in conjunction with the concurrence reviews of tha Of fi ce of State Programs.
468 345