ML19242D585
| ML19242D585 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 08/09/1979 |
| From: | Eric Turner HOUSTON LIGHTING & POWER CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19242D579 | List: |
| References | |
| AC-HL-AE-330, NUDOCS 7908150442 | |
| Download: ML19242D585 (21) | |
Text
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'g Houston g h Lighting i & Power Company Ekctrt Tower i PO Box 1700 b_L1 Houston. Texas 77001 August 9, 1979 AC-HL-AE-330 Mr. Harold R. Denton , I trector Office of Nuclear Reactor Regulation United States Nuclear Regulatory Connission Washington, D. C. 20555
Dear Mr. Denton:
Allens Creek Nuclear Generating Station Unit 1 Docket No. 50 h66 As I discussed with Mr. Vassallo, Houston Lighting & Power Company has taken important steps to study the lessons of the Three Mile Island incident which night be relevant to our Allens Creek Nuclear Generating Station ( ACNGS) for which we hope to have a construction permit in 1980.
To assure that HL&P fully understands and responds to the TMI accident we have taken the following actions:
- 1. In April, an internal task force was established to study the areas of design , operations, energency planning and in-house technical support.
- 2. Health Physics personnel worked at the TMI site to assist Metropolitan Edison's recovery efforts.
3 Engineering and operations personnel ha.ve participated in general industry efforts coordinated by EPRI's NSAC, the AIP, and owner's groups.
Of particular importance, our staff has placed heavy emphasis on the following:
- 1. Reconnendations of NUREG-0578, "TMI-2 LESSONS LEAIRNED TASK FORCE STATUS REPORT AND SHORT-TERM RECOMME'iDATIONS ," July 19, 1979,
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Ikx;ston Igiting & IWu Gm1Nny Harold R, Denton August 9, 1979 Page 2
- 2. Requirements of IE Bulletin 79-08, " EVENTS RELEVANT TO LOILING WATEF REACTORS IDENTIFIED DURING THREE MILE ISLAND INCIDENT," April 14, 1979, 3 Requirements of the NRC Staff memo to the Commissioners entitled, " ACTION PLAN FOR PROMPTLY IMPROVING EMERGENCY PREPAREDNESS," July 23, 1979 (SECY-79-h50).
This letter and its attachment represent HL&P cormitments with respect to the requirements identified in these documents.
They will be incorporated into the plant design, operating procedures or emergency plans as appropriate. Those cormitments requiring detailed design work vill be implemented early in the construction phase of the project. All matters related to energency plans or operational procedures, as well as detailed design changes, vill be documented in the FSAR.
ACNGS is urgently required to meet growing load requirements in the mid-1980's. We recognize, however, that, in striving for that goal, we nust study and take into account the latest safety information relating to corstruction and operation of nuclear power plants. That is the purpose of the commitments incorporated in the attachments to this letter.
Very truly yours, 0 %
E. A. Turner Vice President Power Plant Construction
& Technical Services Attachments (3) cc: J. G. Copeland (Baker & Botts)
R. Gordon Gooch (Baker & Botts)
J. R. Newman (Lovenstein, Newman, Reis, Axelrad & Toll)
P. A. Horn Idl Parties
( 33 I. ?b
STATE OF TEXAS COUNTY OF HARRIS ON THIS DAY personally appeared E. A. Turner, who being duly suorn, did state that he is Vice President of Ilouston Lighting 6 Power Company, Applicant herein, that he is duly authorized to execute and file the foregoing letter in the name and on behalf of Houston Lighting & Power Company and that the statements in said letter are true to the best of his knowledge and belief.
SUBSCRIBED AND SWORN TO this day of 1979.
0 Nota'ry Public in and for Harris County, Texas NUEObb
t ALLENS CREEK I;UCLEAR GE'iERATING STATION HOUSTON LIGHTING & POJER COMPANY Docket No. 50-466 NUREG-0578 C0!oiITMENTS The followins information addresses the requirecents of NUREG-0578, "TMI-2 LESSONS LEARNED TASYs FORCE AIiD SHORT-TERM REC 0f01ENDATIONS," (July 19, 1979). Where more detailed engineering or design is necessary, the details of impletenuation will be discussed in the FSAR.
2.1 Desien and Analysis Ite'a 2.1.1 Emer6ency Power Supply Requirements for the Pressurizer heaters, Power-Operated Relief and Block Valves, and Pressurizer Level Indicators in PWRs.
Recounendation:
Provide redundant energency power for the miniuun number of pressurizer heaters required to naintain natural circulation conditions in the event of loss of offsite power. Also provide energency power to the control and native power systems for the icwer-operated relief valves and associated block valves and to the pressuricer level indication instrucent channels.
Response.
Not applicable to BWRs such as ACNGS.
Item 2.1.2 Performance Testin6 for BWR and PWR Relief and Safety Valves.
Recccuendation:
Conuit to provide performance verification by full scale prototypical testing for all relief and safety valves. Test conditions shall include two-phase slug flow and subcooled liquid flow calculated to occur for desi6n basis transients and accidents.
Response
HL&P will support industry efforts to establish the functional perforuance capabilities of PWR and BWR safety and relief valves for norual, transient and accident conditions including two-phase slug and subcooled liquid flow. HL&P cot:aits to incorporating in ACNGS valves verified by the resolution arrived at by ongoin6 indust ry/NRC activities.
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Item 2.1 3 Information to Aid opei. ora in Accident Diagnosis and Control,
Recommenuation:
Provide in the control roca either a reliable, direct position indication for the valves or a reliable flow indication devices downstreau of the valves.
Reuponse:
HL&P reco6nizes this recommendation as part of an effort to provide unambi 6 uous information to allow operators to ascertain the statna of the reactor coolant pressure boundary integrity.
ACNGS will comply with this recoumendation by providing direct position indication or reliable flow indication.
- b. Instrumentation for Detection of Inadequate Core Cooling PWRs and bWRs.
Reconuendation:
Perforu analyses and implement procedures and trainir3 for prompt recognition of low reactor coolant level and inadequate core cooling usin6 existing reactor instrumentation flow.
Response
HL&P recognizes that the purpose of this recommendation is to assist the operator in rapidly determining the status of core cooling. ACNGS will comply with this recommendation by reviewind current instrumer.ta-tion and determine whether further modifications are necessary. In addition the safety analyses, and instrumentation response vill be integrated with the operatlng procedures and training to be cescribed in the FSAR.
Item 2.1.4 Containment Isolation Provisions for PWRs and BWRs.
Recotuendation:
Provide containment isolation on diverse si dnals in conformance with Section 6.2.4 of the Standard Review Plan, review isolation provisions for non-essential systets and revise as necessary, and modify containment isolation designs as necessary to eliminate the potential for inadvertent reopenin6 upon reset of the isolation signal.
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Response
AC!iGS currently complies with SHP 6.2.1 with regard to diverse 4
signals. HL&P will perforr a design review of AC::GS to determine whether corrective measures for non-essential system isolation are nec e s s a ry. AC'!JS final desi6 n will Taeet the requirements of this recommendation to prevent inndvertent valve reopening upon reset of the isolation signal.
Iteu 2.1 5 Post-Accident Hydrogen Control Systems for PWH and BWR Containments.
- a. Dedicated Penetrations for External Recombiner or Post-Accident Externe. Purge System.
Reco:.nendation:
For plants that have external recombiners c.. purge systems, provide dedicated penetrations and isolation systuns that meet the redundancy and aingle failure r2quirements of the Commission regulations. :!od i fy design as necessary so that these systeus are not cannected to, or are branch lines of, the larbe containuer.t purge penetrations.
Response
ACriG3 has 1009 redundant recomb ..ers within containment. "ae backup purde system required by SHP 6.2 5 will L 3 reviewed to assure compliance with redundancy and single failure requirenents for containuent isolation. These systems .till no: be connected to, or are branch lines of, the large contain: cent purge penetrations.
- b. Inerting BWH Containments.
Recommendation,:
Provide inerting for all Mark I and Mark Il Ir4R containments. This would require changes at Vermont Yankee and Hateb Unit 2 fonerating plants), as well as pending OL applications for Mark I ano II BWHt.
Response.
This is nct applicable to AC:!GS since it has a ' ark III contai m aent design,
- c. Capability to Install liyd: agen Reco:abiner at Pach Light Water "uclear Power Plant.
Recommendation A uinori ty of the Task Force recommends that all operating reacttrs, which do not already have the capability, be required to provide tne capability to add, within a few day s af ter an acc ident , a hydrogen recombiner system for post-accident hydrogen control.
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Response
Since ACNGS has redundant recombiners within containment this is not applicable to ACNGS.
Item 2.1.6 Post-Accident Control of Padiation in Systems Outside Containment of PWRs and BWRs.
- a. Inte,;rity of Systems Outside Containment Likely to Can'ain Radioactive Materials (Engineered Safety Systems and Auxiliary Systems).
Reconuendation:
Perform leakage rate tests on systems outside containment that process primary coolant and could contain high level radioactive materials.
Develop and implement a periodic testind program and preventive maintenance programs.
Response
ACNGS will comply with this recommendation. Leakage rate tests will be performed on systems outside containment that could contain highly radioactive fluids. The leakade rate test program and preventive maintenance actions will be described in the FS/dl.
- b. Design Review of Plant Shielding of Spaces for Post-Accident Operations.
Recommendation:
Perform a desid n review of the shielding of systems processing primary 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 impaired due to radiation from these systeus.
Response
The necessary review of shielding of systems processing primary coolant will be perforced. Any areas or equipment that are vital to post-accident occupancy or operation will be identified. Access to these areas will not be unduly impaired due to radiation from these systems.
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Item 2.1 7 Improved Auxiliary Feedwater System Reliability for PWRs.
- a. Automatic Initiation of the Auxiliary Feedvater System.
Recommendation :
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 feedwater system function. Testability of the initiating signals and circuits shall be a feature of the design. The initiating signals and circuits shall be powered from the emergency buses. Manual cap' ility to initiate the auxiliary feedwater system from the control 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 feedwater system must be included in the automatic actuation
( simultaneous or sequential) of the loads to the emergency buses. The design of the automatic initiating signals and circuits cast be suc h that their failure will not result in the loss of manual capability to initiate the auxiliary feedwater system form the control room.
Response
This recctmendation is not applicable tc ACNGS.
- b. Auxiliary Feedvater Flow Indication to Steam Generators.
Recommendation:
Provide safety-grade indication in the control room of auxiliary feedwater flow for each steam generator. The flow instrument channels shall be powered f rom the emergency buses, consistent with satisfyir.g the power di'.ersity requirements for auxiliary feedwater systems.
Response.
Thin recommendation is not applicable to ACNGS.
Item 2.1.8 Instrumentation to Follow t he Course of an Accident.
- a. Improved Post-Accident Sampling Capability .
Recommendation:
Review and upgrade the capability to obtain samples from the reactor coolant system and containment atmosphere under high radioactivity conditions. Provide the capability for chemical and spectrum analysis of high-level samples on site.
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Response
HL&P will conduct a design and operational review of tne reactor coolant and containment atmospheric sampling systems to determine the capability of personnel to promptly obtain a sample under accident conditions without incurring excessive radiation exposure. Necessary changes in design, if any, will be incorporated. A comparable review will be made of the radiological spectrum analysis facilities to determine ability to promptly quantify certain radioisotopes that are indicators of core damage. These facilities will be upgraded as necessary, as will chemical analysis fac ilit ies.
- 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 inst rumentat ion for monitoring effluent release lines capable of measuring and identifying radiciodiae and particulate radioactive effluents under 2ccident conditions.
Response
!!L&P agrees that the ability to monitor high level releases is vital to undermanding the condition of an accident. ACNGS will provide instrument 4 tion and laboratory facilities to accomplish this goal.
Monitors with ranges outlined on pages A-39 and A-40 of NUREG-0578 vill be provided consistent with state-of-art technology.
- c. Improved In-Plant Iodine In s t rument at io n .
Recommendation:
Provide inst rumentat ion for accurately & t rmining in-plant airborne radiciodine concentrations to minimize the need for unnecessary use of respiratory protection equipment.
Response
Accurate determination, of in-plant airborne radioiodine concentra-tion, will be provided by inst rurentation reflecting state-of-the-art technology, and proper training and procedures.
Item 2.1 9 Analysis of Design and Off-Normal Transients and Accidents.
- a. Recommendation:
Provide the analysin, emergency trocedures, and training to substantially inprove operator performance during a small break lo u s-o f-coolant accident.
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- b. Recommendation:
Provide the analysis, emergency procedures, and training needed to assure that the reactor operator can recognize and respond to conditions of inadequate core cooling.
- c. Recommendation:
Provide the analysis, emergency procedures, and training to substantially improve operator performance during transients and accidents, including events that are caused or worsened by inappropriate operator actions.
Response
HL&P recognizes that one of the most important " Lessons Learned" from TMI is to integrate the operator training very closely to realistic transient analyses and instrument response. Much of the effort to accomplish this goal will be gereric in nature with the NRC working with vendors, EPRI and AIF to develop a program. ACNGS will incorporate the results of these efforts by having the analyses put in the form of emergency procedures and training programs. The analyses, emergency procedures and training program outlined in recommendations Ta, 7b and Tc above will be provided.
Item 2.2 Operations Item 2.2.1 Improved Reactor Operations Command Function.
- a. Shift Supervisor Responsibilities.
Recommendation:
Review plant administrative and management procedures. Revise an necessary to assure that reactor operations command and control responsibilities and authority are properly defined. Corporate management shall revise and promptly issue ar 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 reactor operations command in the control room (i.e., the senior reactor operator).
Response
EL&P has reviewed the discussion at pp. A h7 to A-LS of NUREG-0578 (with special regard for the role of highest levels of corporate ranagement) and will assure that adequate administrative and management procedureo are established and implemented in compliance with this recommendation. These procedures will assure that reactor operations command and control responsibilities and authority are properly defined. Corporate management will issue an operations D.uAv 91 (w(n f, r
policy directive that emphasizes the duties, responsibilities, authority and lines of command.
- b. Shift Technical Advisor.
Recommendation:
Provide on shif t at each nuclear power plant a qualified person (the shift technical advisor) with a bachelor's degree or equivalent in a science or engineering discipline and with specific training in the plant response to off-normal events and in accident analysis of the plant. Shift technical advisory shall serve in an advisory capacity to shift supervisors. The licensee shall assign normal duties to the shift technical advisor that pertain to the engineering aspects of assuring safety that pertain to the engineering aspects of assuring safe operations of the plant, including the review and evaluation of operating experience.
Response
The se staffing requirements will be reviewed by HL&P and ACNGS shall be in compliance with such requirements as may be established at the time of operating license issuance.
- c. Shift and Relief Turnover Procedures.
Recommendation:
Review and revise plant procedures as necessary to assure that a shift 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. Supplementary checklists and shift logs should be developed for the entire operations organization, includig instrument technicians, auxiliary operators, and maintenance personnel.
Response
EL&P strongly agrees that formal shift turnover from of f-going to on-going individuals responsible for reactor operations is required.
Procedures for ACNGS will be developed and implemented which ensure that thic turnover will be performed and verified by such checklists as deemed necessary after completion of the review of this rec o mme nda-tion. Amon6 the features to be considered in developing the ACNGS shift and relief turnover procedures for ACNGS will be those on pp.
A-52 to A-5L o f NUREG-0578.
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Item 2.2.2 Improved In-Plant Emergency Procedures and Preparations.
- a. Control Room Access.
Recommendation:
Review plant emer6ency procedures, and revise as necessary to assure that access to the control room under normal and accident conditions is limited to those persons necessary to the safe command and control or operations.
Response
HL&P most strongly a6rees with this recommendation. Control room accees should be limited at all times, but during accident conditions it is tandatory that only these required for safe command and control of reactor operations are permitted access. Procedures for ACNGS will be developed and implemented which limit access to the control room durind normal and accident conditions. These procedures will be developed along the guidelines of the position stated on pg. A-56 of NUREG-0578.
- b. Onsite Technical Support Center.
Recommendation:
A separate technical support center shall be provided for use by plant manageuent, technical, and engineering support personnel. In an emergency, this center shall be used for assessment of plant status and potential offsite impact in support of the control room command and control function. The center should also be used in conjunction with implementation of onsite and offsite emergency plans, including communications with an offsite emergency response center. Provide at the onsite technical support center the as-built drawings of general plant arrangenents and piping, instrumentation and electrical systems.
Photographs of as-built system layouts and locations may be an acceptable method of satisfying some of these needs.
Response; HL&P agrees with the concept of an Onsite Technical Support Center to be utilized as an aid to the person responsible for reactor operations command and control in the control room. ACNGS design will provide en Onsite Technical Support Center, separate from the control room which will contain such drawings, documents, schematics, photographs and such monitorin6 and communications equipment as required to adequately support the reactor operations command and control function. ACNGS procedures will be developed which define the authority and lines of communication of those persons manning this center.
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- c. Onsite Operational Support Center.
Recommendation:
Each operating nuclear power plant should establish and maintain a separate onsite operational support center outside the control room.
In the event of an emergency, shift support personnel (e.g. , auxiliary operators and technicians) other than those required and allowed in the control room shall report to this center for iurther orders and assignment.
Response
ACNGS will provide an Onsite Operational Support Center outside the control room, as a mustering point for operational support personnel.
Item 2.2 3 Revised Limiting Conditions for Opeation of Nuclear Power Plants Based Upon Safety System Availability.
Recommendation:
Require that the Technical Specifications for each reactor provide that the reactor 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 2h hours of any time that it is found to be or to have been in operation with a complete loss of safety function (e.g., loss of emergency feedwater, high-pressure ECCS, low-pressure ECCS, containment, emergency power or other prescribed safety funciton). Require that an assessment of the cause of the loss of safety function be made (e.g. , maintenance, 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 recommendation for corrective action and evaluation of the alternatives at a public meeting with senior NRC officials. Require that the senior NRC officials issue their decision at that public meeting, or a subsequent public meeting if time is required far staff evaluation, concerning the adequacy of the changes to improve operational reliability proposed by the utility. Allow the facility to return to power only after NRC approval of the changes proposed by the licensee.
Resuonse:
As indicated by NUREG-0578, p. A 63, implementation of this sugge stion requires a rule change and certain rulemaking procedures. The effects of such a rule are far-reaching and should receive careful study.
HL&P will participate in any rulemaking on this subject and, of course, comply with any rule which may emerge.
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o-ALLENS CREEK NUCLEAR GENERATING STATION HOUSTON LIGHTING & POWER COMPA'IY Docket No. 50 466 BULLETIN 79-08 CO:"iITMENTS The information which follows addresses HL&P's respcnse to IE Bulletin No. 79-06, " Events Relevant to Boiling Water Reactors Identified During Three Mile Island" (April 14, 1979). Although this document is, at least initially, intended for operations of licensed Boilir.g Water Reactors, HL&P has reviewed it for its applicability at co. struction permit stage. Certain items have been identified, as to which a propriate comuitnents can be cade now. The following responses adaress each item of IE Bulletin 79-06.
- n
- ITEM:
- 1. Review the description of circamatances described in Enclosure 1 of IE Bulletin 79-05 and the pre minary chronology of the TMI-2 3/26/79 accident included in Enclosure 1 to IE Bulletin 79-05A.
- a. This review should be directed sward understanding: (1) the extreme seriousness and consequences of the simultaneous blocking of both trains of a safety systems 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 eventual core damage; and (3) 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 result in unsafe plant conditions (see Section 5a of this bulletin); and (2) not make operational decisions based solely on a single plant parameter indication 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.
Response
One of the responsibilities of our in-house Task Force is to review information concerning TMI including IE Bulletins, NSAC Reports and NUREG s such as 0600. With regard to the NRC recommendations above:
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w la. These catters will be incorporated and stressed in the training pro 6ran for the ACI;GS operatins staff.
lb. Operating personnel vill be instructed as indicated and appropriate procedures will be established to neet the requirement of recounendation lb.
Ic. Uperatin6 personnel, as well as plant mana ers s and supervisors with operatin6 responsibilities will participate in the programs described in la. and lb.
ITEM:
- 2. Heview the containment isolation initiation design and procedures, and prepare and iupleuent all chano es necessary to initiate containment isolation, whether ranual or automatic , of all lines whose isolation does not degrade needed safety features or cooling capability , upon auto:.atic initiation of safety injection.
Respanse:
J. The recouuended review will be conducted for AC:;Gb. This iteu is included in reconuendation 2.1.h of !.UREU-0576. tion-essential systems will te isolated and will r.ot degrade needed safety features or coolin e; capability.
ITE:4:
J. Describe the actions, botn auto:.atic and ranual, nec e s sary for proper functionine of the auxiliary heat removal system (e.g.,liCIC) that are used when the Lain feedwater systeu is not operable. For any uanual action necessary , describe in surzary foru the procedure by which this action is taken in u tinely sense.
Response
J. nC! IGG will review those actions necessary for proper functioning of the auxiliary heat renoval systems. Procedures for the activation of Lnnually initieted actions in a timely ranner will be described in the FUAR for AC;;Ju.
ITEM-
- 4. Describe all uses and types of vessel level indication for both autouatic and .:.anual initiation of safety systems. Describe other redundant instruuentation which the operator night have to give the sale inforLation rebarding plant status. Instruct operators to utilise other available inforration to initiate safety systeus.
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Response
- 4. As discusued in our response concerning Recommendation 2.1 3 and 2.19 of DUEEG 0576 information available to the operator to deteruine the plant status and tne need for muual actions will be reviewed. A description of the instrtuentation (including water level) and how it relates to operator actions will.t2 provided in the FLAH. The operator trainint; prot;rau will assure that operators are trained utilice all available inforLation to initiate unfety systems.
ITEM:
5 Review the action directed by the operatin6 procedures and training instructions to ensure that;
- a. Operators do not override autonatic actions of engineered safety features, unless continued oleration of en6 ineered safety features will result in unuare plant conditions (e.6 veGSel inte ority ) .
- b. Operators are provided additional inforLation and instructions to not rely upon vessel level indication alone for rnnual actions, Lut to also exauine other plant paran.etec indications in evaluatint; plant condition >.
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ba. Procedures will be developea to enuure that operators do not override automatic actions of enoineered safety features unless continued operation will result in unuare conditionu.
Sb. The procedures and uperational trainint; for ACNGS (to be described in o rcater detail with the FbAR suttittal) will streru that operatoru shall take into account other available plant paraueter conditions and not merely rely on venuel level Indication.
1TER O. Review all cafety-related valve positions, positioning requirements and positive controls to assure that valves renain positioned (open or closed) in a Lnnner to ensure the proper operation of engineered safety featureu. nluo review related procedures, such as those for Laintenanc e , testing, plant and cycteu utartup, and supervisory periodic (e.o., daily / chi f t checks,) Jurveillance to ensure that such valves are returned to their correct positions following neceucary Lanipulations and are raintained in their proper positions during all operational :.udes.
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Response
- 6. HL&P will review from a desien viewpoint all safety-related valve positions, position requir,fuentn and controls to assure that valves ret.ain positioned to assure prcper operation of ESFs. Operationrtl procedures will also be developed, to assure that such valves are returned to correct position after beint; coved and are maintained in that position.
1Tue 7 Review your operating nodes and procedures for all systens designed to transfer potentially radioactive gases and liquids out of the priuary containuent to assure that undesired puuping, ventini; or other release of radioactive liquids and gases will not occur inadvertently.
In particular, ensure that such an occurrence would not be caused by the retestino of ent;ineered safety features instrumentation. List all such syste:m and indicate:
- a. Whether interlocks exist to prevent transfer when hie;h radiation indication exists.
- b. Whether such systems are isolated by the containment isolation si6nal.
- c. The basis on which continued operability of tne above features is assured.
Response
7 HLSP will review ACI.G3 operatin s uodes and procedures to assure the inadvertent or undesirable transfer of cadioactive fluids or (;ases outside of containnent will be prevented. The systeus desle;ned to transfer potentially radioactive gases and liquids out of the containuent to oether with the information required by Iteu T. a. , b. ,
and c will be provided in FGAR.
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- d. Review and uodify as necessary your maintenance and test procedures to ensure that t hey require:
- a. Verification, by test or inspecticn, of the operability of redundant safety-related systenu prior to the removal o f any safety-related system f rou service.
- b. Verification of tne operability of all safety-related systens when they ar e returned to service following uaintenance or t e s t in t, .
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- c. 10xplicit notification of involved reactor operational personnel whenever a safety-related system is rea.oved from and returned to service.
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- d. The neceauary administratise controls will be described during the OL eview. Tne controls will be designed to ensure that Laintenance and test procedures address verification of the operability of necessary safety-related systeus and the explicit notification of appropriate personnel of any change in the operational status of those systeus.
1TLM 9 Review your pru:.pt reportint procedures for NhC natification to assure that NEC is notified within one hour of the time the reactor in not in a centrolled or expected condition of 01 eration. Further, at that tile an apen continuous comaunication channel uhall be established and taintained with SRC.
_ Response:
9 Procedt es for this purgoue wili Le described in the Plant Technica.
3;ecifications for nChub uutuitted with the ruAH.
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- 10. heview operating Lodes ana ; roceduret a deal with significant aLounts of hidrogen c an that ;ay be generated durino a transient or other accident that woulu either rennin incide the prinary cynten or be released to I,he containtent.
hesbonse.
- 10. Jbe review W111 Le conducted una operati: o uodes and procedures w111 be described during OL review for dealine with ulgnificant amounts of hy drot e on ac inside the prl::ary cy stem or containment which uay be generated durino a tranulent ar accident.
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- 11. i'ropoce c han o es , au required, to those tecnnical specifications which 1.iu s t be uudified as a result of jour 2tpieLenting the iteau above.
Ite spo n s e :
- 11. All 0; the foregoing i t e!..u vlil be reviewed prior to subuittal of the UL a m. ' ' cation. Technical specifications coring out of this review will _ prepared and submitted durino CL review.
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ALLE:iS CREEh fiUCLEAR GE:JERATI!iG STATION liOUSTON LIGliTING & POWER COMPAIiY Docket No. ';0-466 E..tRGE ICY PLi1J CO:011TMEU'?S Tne Cotuaission's Staff recently subnitted to the Concissioners an "netion Plan for Prouptly Iuproving Euer ency s Preparedness" ( SECY-79-% 0 ,
Ju4 23,1979 ) . inat document outlines inn.iediate steps to laprove licensee preparedness "at all operating power plants and for near teru OLs."
although not applicable by its terms to pending CP applicants HL&P's Task Force on Euero ency Planning has teen evaluating many of the I:ntters uiscucced in SEGY-T9-%0. Althout;h details will be furnishea during the OL review, HL&P, based on its study to date submits the following co:=ents and connaituents with respect to eter eency plans for the IsCNGS:
ITEM:
- 1. Lpgrade licencee energency plans to satisfy Reo ulatory Guice 1.101, with speciai attention to tne deve_lopetent of uniform action lcvel criteria based un p ant paraneters.
Response
- 1. ihe Eter oency Plan for ACN A sulnitted with tr.e Operating License applicatio:. will coLply with the requirenents o: Hegulatory Guide 1.101 as applicable. HL&P will uporade the present Constructicn Peruit-stage Ene r,, . nc y Plan to assure tr.e capability to take protective neasares consistent with lico usatory Guide 1.1U1 out to a dist ance c: 10 miles from the plant site. In all cases, upecial attention will be given to the establishment of uniforu action level criteria appropriate to the ne:ab des 16n.
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- 2. Assure the impleuentation of the related recontendations of the NRR Lessons Learned Task Force involving instrutentation to follow the course of an accident and relate the infortation provided by tnis instrumentation to the emergency plan ection levels. This will include instrutentation for post-accident s anp li n,; , hioh range radioactivity tonitors, and itpraved i:-plant radioidine instrutentation. The iLpleLentation of the lessons learned recoruaendation on instrumentation for detection of inadequate core cooling will also be factored into the energency plan actict level criteria.
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s Hesponse:
- 2. liL&P io couaitted to these des 1cn feature: in Attacht.ent 1. (See responses to Heco::.mendations 2.1 3 b u n j 2.1.6 or SUhhG-0578. ) The inforL2ttion provided by this instrunentation will Le related to the emero ency plan action levels.
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J. IJetermine that an EL.ercency 0 1 erationn Center for rederal, State and local personnel has t;een establlshed with cuitable cot.munications to the plant, and that upgrading or the fac ility in accordance with the Lessonu Lear:.ed reco:. :.endation for un 2nplant technical supi ci t center is underway.
Reuponne:
3 HL&P is ccLaitted to thir reco:: .end'ttion.
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L. nuuure ti.at itpruved licenuee offelte nonitorin o captbilities
( ncluding additicnal 'AJ' u ur eiuivalent) have been previded for all siteu.
heuoonse:
- 4. nUJUL w111 cun. ply witn tni: r e lu i re;..e n t .
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'; . nuceus L:.e relaticn,.ip or Ltate/ local p.ato to the licencee's ani Federal p una co as to assure the capaLility to tac;e up propriate et,ers ency ac t ions. nusure that tuiu capability wlu be exter.de -1 to a distance al 10 .iiea an coon ac 1:ractical but .c t late r than Jc.auary
., 1901. i .it iten will be i. erfor:..ed .c c unJ unc tion wit h t he O f fic e of State Prograus and tne O f ' ic e c Inui ec tion ar d nn furceL ent.
Heuhonse; 5 nm&P in couperatino with ancther utiaty aiplicant in Texas as well as co onizant agencieu of tne atate of Texas at 1 lea r;over "t to duvelop in emergency res;onse pla . J 31 gn e r. to assure t :.e ca p ullity to take protecta Leasureo out to a diutance a: 10 ::.ileu for the plant cite. It in the .ntent o: the part ic ipat r.,, organization s to suboit such a plan before the end of thlu year.
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O. hetiuire test exercices of approve,. ... erg ncy Planc (Federal, State, local, licenuees), review plans f o t' suc h exerc iceu , and participatt in a limited nu:cer of Joint exercies. .eutu uf 1censm ,' will
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a be required to be conducted as soon as practical for all facilities and before reactor startup for the new licenseen. Exerciaen of the State plans will be perforrned in conjunction with the cor.currence reviewc of tne Office of State P rot,r at. s . Joint ten t exerc ises involvin6 Federal, State, local and licensees will be conducted at the rate of about 10 per year, which would result in 'tll siten being exercised once each five years.
hesponse:
O. ACNGS will couply with all require:. ente rebarding t:.e nature and frequency of periodic drills o f e...erc ency plan. Procedurec for thlb purpose will be part of the plan to be suouitted ;.er Ite: 5., above.
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