ML19250A770

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Forwards Response to 790913 Request That Util Implement Requirements of NUREG-0578 Re Followup Actions to TMI-2 Accident.Includes Info Re Emergency Power,Relief & Safety Valve Testing & Instrumentation for Core Cooling
ML19250A770
Person / Time
Site: Maine Yankee
Issue date: 10/18/1979
From: Moody D
Maine Yankee
To: Reid R
Office of Nuclear Reactor Regulation
References
WMY-79-113, NUDOCS 7910240560
Download: ML19250A770 (12)


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ENGINEERING OFFICE WEST 8ORO, MASSACHUS ETTS 01581

%g jg B.3.2.1 WMY 79-113 October 18, 1979 United States Nuclear Regulatory Commission Washington, D. C.

20555 Attention: Office of Nuclear Reactor Regulation Mr. Robert W. Reid, Chief Operating Reactors Branch #4 Division of Operating Reactors

References:

(a) License No. DPR-36 (Docket No. 50-309)

(b) USNRC Letter dated September 13, 1979

Dear Sir:

Subject:

Followup Actions Resulting From the NRC Staff Reviews Regarding the Three Mile Island Unit 2 Accident In your letter, Reference (b), you requested that we submit our commitment to implement the actions contained in NUREG-0578, as modified and/or supplemented by your letter, on the implementation schedules contained in Enclosure 6 of your letter.

The required commitments have been delineated in.the attachment to this letter, along with explanatory notations as to status and anticipated problem areas.

Well defined acceptance criteria for many of the recommendations of NUREG-0578 are needed in order to ensure timely implementation.

The recent clarification meetings and discussions have been of benefit, but others may be necessary to develop adequate acceptance criteria.

These acceptance criteria, when fully developed, may impact implementation schedules due to hardware availability as well as affecting the ability to optimize utilization of scheduled refueling outages for such implementation.

Additionally, our response in implementing several oi the actions contained in NUREG-0578 will be coupled to generic, industry-wide activities.

In these areas schedular commitments and specific requirements may have to be developed between the generic, industry groups and the Commission.

Finally, the inability to secure the increased staff necessary to respond to several action items may act as constraints to prompt resolution, particularly if TMI related Bulletin and Orders continue to escalate.

Thus, we believe a degree of flexibility is necessary in the implementation schedules for good cause shown.

1206 \\\\1 5.6,0 f 7910240

United States Nuclear Regulatory Commission October 18, 1979 Attention: Office of Nuclear Reactor Regulation Page 2 In addition, your letter, Reference (b), required that we provide commitments to implement near-term requirements for improving emergency preparedness on the implementation schedules contained in Enclosure 8 of your letter. Maine Yankee acknowledges the NRC identification of emergency preparedness improvements discussed in Enclosure 7 and their implementation schedule identified in Enclosure 8.

While MY generally commits to accomplishing the improvements implementation schedule identified in those. areas under its control in the time frames specified in Enclosure 8, we are aware of the action recently initiated by the Commission to specifically review overall emergency preparedness on the part of licensee, state, and local emergency preparedness organizations and agencies. This action is under the direction of the Task Force headed by James R. Miller of the NRC staff as presented to us and other Region I licensees on August 20, 1979 in King of Prussia, PA.

Maine Yankee is assessing its existing emergency plans in relation to the various documents and indications of this Task Force and will evaluate the Task Force concerns and address them in a timely manner.

Maine Yankee is aware, however, of the fact that these requirements are apparently not finalized to date and will attempt to keep appraised of modifications as they are made. Final Yankee emergency plan changes will be presented to and discussed with the assigned Task Force Review Team when they visit our plant and review our plans in conjunction with those of the appropriate state and local agencies.

With regard to the establishment of an onsite technical support center, Yankee intends to conform to the positicn set forth in NUREG-0578.

It is our understanding that a clarification of this position is being issued, but we have not received it at the time of writing this letter.

As we understand the clarification, we believe there may be additional requirements and that we may not be able to conform to the additional requirements in all respects, particularly in the physical size requirement and perhaps in staffing requirements.

Within the constraints described above and/or noted in the attachment, it is our intent to meet the requirement implementation schedules set forth in Reference (b).

We trust this information is satisfactory; however, if you have any further questions, please contact us.

Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY w

D. E. Mood Manager of Operations dmp Attachments 1206 1iB

Sheet 1

of 10

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ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment 2.1.1 Emergency Power Supply Complete implementation.

Redundant capability to supply pressurizer heaters from an offaite or emergency power source present1, exists.

Additional procedure development or modifications to existing procedures relative to heater operation, if necessary, will be accomplished by January 1, 1980.

The M.O.V. Block valves on the pressurizer relier lines are presently supplied by an emergency power source.

The Pressurizer solenoid operated relief valve will be connected to an emergency power source during the refueling shutdown which will commence on or about January 15, 1980.

Pressurizer level instrumentation is presently supplied by an emergency power source.

2.1.2 Relief and Safety Valve Submit program descrip-It is presently anticipated that a Testing tion and schedule.

program description and schedule for Relief and Safety Valve testing will be available for submittal on or rs) before January 1, 1980. This schedule C:?

for submittal assumes that the EPRI CJN test program currently under development will be found acceptable,

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and is available.

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Sheet 2

of 10 ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUF ACTIONS

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Sec t.

Abbreviated No.

Title Requirement Implementation Commitment Complete test program.

The schedule for completion of the test program depends upon the progress of the EPRI program.

2.1 3.a Direct Indication of Complete implementation.

Maine Yankee is presently scheduled Valve Position to shutdown for refueling on or about January 15, 1980 for an estimated 5 week period.

It is our intention to complete the installation of an acoustic accelerometer system during that period. This schedule assumes that the equipment necessary for installation will be available in the required time frame.

2.1.3.b Instrumentation for Develop procedures As described in Maine Yankee's Inadequate Core Cooling describe existing inst.

response to I&E Bulletin 79-06B, operating procedures have been reviewed and revised as necessary to:

a.

make the operators aware of the possibility of forming voids in the primary coolant system large enough to compromise core cooling capability, especially during natural circulation.

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Sheet 3

of 10 ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment b.

provide appropriate operator action to prevent the formation of such voids, and

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c.

specify additional operator action necessary to enhance core cooling in the event such voids are formed.

Coupled with the above procedural modifications which have already been accomplished, Maine Yankee will provide a description of its existing instrumentation by January 1, 1980.

New level instrument Methods for the detection of reduced design submitted.

coolant level are presently being investigated by the Owners Groups and Yankee intends to submit a level instrument design by January 1, 1980, provided a satisfactory resolution is developed by this generic approach.

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Sheet 4

of 10 ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment Subcooling instrument in-Maine Yankee is presently evaluating stalled.

proposals on subcooling instruments and related equipment.

Assuming that the equipment selected is available for delivery, Maine Yankee intends to perform the installation during the refueling shutdown which will commence on January 15, 1980.

New level instrument Maine Yankee intends to insball a installed.

suitable device for detection of reduced coolant level, or adapt existing instruments to acc6mplish this purpose by January 1, 1981 depending upon the resolution of the new generic approach.

2.1.4 Diverse Containment Complete implementation.

An Engineering effort is c'ifrently in Isolation progress to provide an Engineering design change which will make automatic, those interim manual actions as described in Maine Yankee's response to I&E Bulletin 79-06B relative to containment isolation actions. Coincident with this engineering effort, MY is waiting to evaluate the recommended Combustion Engineering approach to this item

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which will not be available until

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December 31, 1979 Therefore, Maine Yankee can commit only to the C7s completion of this item on as expedited a schedule as possible.

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Sheet 5

of 10 ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment 2.1.5.a Dedicated H2 Control Description and imple-Maine Yankee will meet schedule.

Penetrations mentation schedule.

Complete installation.

Maine Yankee will meet schedule.

2.1.5.c Review procedures and Maine Yankea does not have recombiners, bases for recombiner use.

Additionally, per Ref. (b) of cover letter, no action is required at this time.

2.1.6.a Systems Integrity for Immediate leak reduction Maine Yankee will implement a leak High Radioactivity program.

reduction program by January 1, 1980.

Preventive maintenance Maine Yankee will establish a pre-program.

ventative maintenance program by January 1, 1980.

2.1.6.b Plant Shielding Review Complete the design Maine Yankee will perform a pre-review.

liminary review of radiation and shielding design by January 1, 1980.

Implement plant modifi-Modifications to plant systems will

cations, be dependent upon the results of the design review. The schedule for completion of the modifications will then be conaistent with any associated constraints imposed by labor and material availability, with the objective of completion of the

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modifications by the January 1,1981 date.

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Sheet 6

of 10 ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sec t.

Abbreviated No.

Title Requirement Implementation Commitment

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2.1.7.a Auto Initiation of Complete implementation An engineering effort is currently Auxiliary Feed of control grade.

in progress which will evaluate various designs for implementation of an automatic auxiliary feed system.

Design Changes will be made as appropriate, on a schedule which is as expeditious as equipment delivery will permit.

Complete implementation

.t is Maine Yankee's intention to of safety grade.

perform the effort described above using safety grade equipment.

2.1.7.b Auxiliary Feed Flow Complete implementation.

Maine Yankee intends to complete Indication the installation of Auxiliary Feed Flow Instruments on the same schedule as described in Item 2.1.7.a IN)

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Sheet 7

of 10 ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment 2.1.8.a Post Accident Sampling Design review complete.

Maine Yankee will complete a review of its capability to obtain the necessary samples by January 1, 1980.

Preparation of revised If the review to be completed in Item procedures.

2.1.8.a-(l) indicates that the capability exists to obtain the desired samples, procedures will then be revised to implement that capability by January 1, 1980.

Implement plant modifi-If it is determined through the review cations.

the sampling capability does not exist, plant modifications kill be engineered which'will give.that capability, in accordance with the January 1, 1981 requested date for completion.

Description of proposed Based upon the estimated completion modification.

of the design review by January 1, 1980 after which appropriate modifications will be planned, Maine Yankee can only commit to submittal of a description of proposed modifications which will be 00]g}g j[737"7g,,

r3 commensurate with those efforts. MY g,

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therefore, commits to submit a

~*'t description of any proposed

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modifications in the earliest time

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frame possibic following finalization f m dification plans.

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Sheet 8

of 10 ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment 2.1.8.b High Range Radiation Installation complete.

Maine Yankee will install noble gas effluent monitors and high range radiation level monitors by January 1, 1981, subject to equipment qualification and availability.

2.1.8.c Monitors Improved Icdine Complete implementation.

Maine Yankee presently has the cape-Instrumentaten bility to determine airborne iodine concentration.

Procedures presently in effect require the use of charcoal for iodine sampling and the ':se of the plants GeLi detector for gamma ray energy spectrum analysis which can discriminate iodine from noble gasses.-

2.1.9 Transient and Accident Complete analysis pro-To accomplish this action item, Maine Analysis cedures, and training in Yankee will utilize generic work areas of:

small break produced by the NSSS vendor in accor-LOCA, inadequate core dance with commitments made between the cooling, accidents and Combustion Engineering Owner's Group transients.

and the Commission.

Implementation of emergency. procedures and initiation of training programs will be accomplished expeditiously, consistent with the intent of Reference (b) of the cover letter.

In addition, within one year of completion of the generic analytical work Maine Yankee will Ps) validate independently the C~?

applicability of the generic C7' guidelines and analyses for the Maine Yankee plant.

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Sheet 9

of 10 ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment Containment Pressure Installation complete.

Maine Yankee will install Monitor a containment pressure monitor of adequate range by January 1, 1981.

Containment Water Level Installation complete.

Maine Yankee will install a containment Monitor water level monitor by January 1, 1981.

Containment Hydrogen Installation complete.

Maine Yankee will install a Monitor hydrogen monitor by January 1, 1981.

RCS Venting Design submitted.

This area is being investigated by the Combustion Engineering owners group at this time. Maine Yankee intends to follow the recommendations made by the owners group.

A venting system design will be submitted by January 1, 1980 provided that this schedule is found to be consistent with the resolution of Owners Group recommendations.

Installation Completed.

The venting system will be installed at the first scheduled outage opportunity after the design is complete and the associated equipment is available.

2.2.1.a Shift Supervisor Complete implementation.

Actions required relative to Shift Responsibilities Supervisors responsibilities will be ps) implemented by January 1, 1980.

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Sheet 10 of 10 ATTACHMENT

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IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment 2.2.1.b Shift Technical Advisor Shift technical advisor Shift Technical Advisor requirements on duty.

will be implemented at Maine Yankee by January 1, 1980.

Complete training.

Procedures and training requirements will be completed by January 1, 1981.

2.2.1.c Shift Turnover Complete implementation.

Maine Yankee will review and revise plant procedures for shift turnover as necessary by January 1, 1980.

2.2.2.a Control Room Access Complete implementation.

Maine Yankee will establish the Control necessary controls to limit access to the control room by January.l, 1980.

2.2.2.b Onsite Technical Establish center.

An onsite Technical Support Center will Support Center be established at Maine Yankee by January 1, 1980.

2.2.2_.c Onsite Operational Complete implementation.

An onsite Operational Support Center Support Center will be established at Maine Yankee by January 1, 1980.

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