ML19250A796

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Commits to Implement Requirements of NUREG-0578 for Followup Actions to TMI-2 Accident.Forwards Description of Commitments,Status of Implementation & Anticipated Problem Areas
ML19250A796
Person / Time
Site: Yankee Rowe
Issue date: 10/18/1979
From: Moody D
YANKEE ATOMIC ELECTRIC CO.
To: Ziemann D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0578, RTR-NUREG-578 WYR-79-118, NUDOCS 7910240611
Download: ML19250A796 (10)


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Telephone 617 366-9011 rt 7t0- 3 9 0-0 73 9 YANKEE ATOMIC ELECTRIC COMPANY Yag0 20 Turnpike Road Westhorough, Massachusetts 01581 mxes s.3.2.1 9

WYR 79-118 October 18, 1979 United States Nuclear Regulatory Consission Washington, D. C.

20555 Attention: Office of Nuclear Reactor Regulation Mr. Dennis L. Ziemann, Chief Operating Reactors Branch #2 Division of Operating Reactors

References:

(a) License No. DPR-3 (Docket No. 50-29)

(b) USNRC Letter to YAEC dated September 13, 1979

Dear Sir:

Subject:

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

The required commitments Lave 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 recommendatiens of NUREG-0578 are needed in order to ensure timely implementaticn.

The recent clarificaticn 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.

Additienally, our response in implementing several of the actfens contained in NUREG-0578 will be coupled to generic, industry-wide activitiee.

Tn 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 tay act as constraints to prompt resolution, particularly if TMI related Eulletins and Orders continue to escalate.

Thus, ve believe a degree of flexibility is necessary in the i=plementation schedules for good cause shown.

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United States Nuclear Regulatory Commission October 18, 1979 Attention: Office of Nuclear Reactor Regulation Page 2 In addition, your le+ter, 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.

Yankee acknowledges the NRC identification of emergency preparedness improvements discussed in Enclosure 7 and their implementation schedule identified in Enclosure 8.

While Yankee generally commits to accomplishing the improvements 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.

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.

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 discusced 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 position 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 s e 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 requirements and 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, YANKEE ATOMIC ELECTRIC COMPANY

.C.

D. E. Mood-Manager of Operations dmp Attachments

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Sheet 1

of 8

ATTACHMENT IMPLEMENTATION OF REOUIREMENTS FOR FOIL,.

TIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment 2.1.1 Dnergency Power Supply Complete implementation.

Redundant capability to supply the

-. s pressurizer heaters from an offsite e from an emergency power source presently crists,, and procedures are available.

The motor operated block valve on the pressurizer relief line will be connected to an emergency power source by January 1, 1980.

The pressurizer solenoid-operated relief valve is already supplied by an emergency d-c power source, and the pressurizer level indication instrument channels are already supplied by the vital bus power source.

2.1.2 Relief and Safety Valve Submit program descrip-YAEC is closely following the EPRI Testing tion and schedule.

program, and presently intends to follow th? industry commitment in regard to this test program.

It is anticipated that the program description and schedule will be available by January 1, 1980.

Complete test program.

The schedule for completion of the rs?

test program depends on the accept-ability and availability of the EPRI C7s program.

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Sheet 2

of 8

ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sec t.

Abbreviated No.

Title Requirement Implementation Commitment 2.1 3.a Direct Indication of Complete implementation.

Yankee Rowe has always had an Valve Position electronic sound surveillance channel in the pressurizer compartment and it provides reliable indication to the operator that there is flow in the discharge pipe. However, Yankee intends to enhance this capability with the installation of an acoustic accelerometer system. When the new equipment is received, it Vill be scheduled for installation.-

2.1 3.b Instrumentation for Develop procedures In response tc I&E Bulletin 79-06A, Inadequate Core Cooling describe existing inst.

Yankee Rete has already reviewed and revised plant procedure:

'J provide a description of the exiatink instrumentation with regard to operator recognition of inadequate core cooling.

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

coolant inventory 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 3

of 8

ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment Subcooling meter in-Yankee Rowe will install a primary stalled.

coolant saturation instrument.

A purchase order has been initiated and engineering design is in progress.

Preliminary engineering has indicated that major modifications to the reactor coolant system are necessary in order to provide the required inputs to the saturation instrument.

Although the instrument will be available, an estimate for the completion of installation cannot be made at this time.

New level instrument Yankee intends to install a suitable installed.

device for detection of reduced coolant level or adapt existing instruments to accomplish this purpose by Janua y 1, 1981, depending on the rcoolution of the generic approach.

2.1.4 Diverse Containment Complete implementation.

Yankee is proceeding with a change to Isolation the design of the containment isolation system which will add a diverse initiation signal (SIAS),

autor.atically isolate all non-essential systems, and require deliberate operator action to reopen rid isolation valves after resetting of gg; the isolation signal. Every effort will be made to implement the design yr, change by January 1, 1980, contingent nJ ur ~ delivery of new equipment and rNJ urther input from Owners Grcups.

Redefinition of essential and non-essential systems will be the product of the review of SEP Topic VI-4, Containment Isolation Systein.

Sheet 4

of 8

ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment 2.1.5.a Dedicated H2 Control Description and imple-Yankee will provide a description Penetrations mentation schedule.

of the change and the implementation schedule by January 1, 1980.

Complete installation.

Yankee will compl'ete implementation of the change by January 1, 1981.

2.1.5.c Recombiners Review procedures and Yankee does not have recombiners.

bases for recombiner use.

Per Reference (b) of the cover letter, no action is required at this time.

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

tion program by January 1,1980.

Preventive maintenance Yankee will establish a preventive program.

maintenance program by January 1, 1980.

2.1.6.b Plant Shielding Review Complete the design Yankee will perform a preliminary review.

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

Implement plant modifi-Modifications to plant systems will ca' ions.

depend upon the results of the design review and also upon the results of other reviews currently being conducted in the SEP review.

Therefore, Yankee intends to factor implementation of shielding

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modifications into the SEP schedule.

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Sheet 5

of 8

ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Ieplementation Commitment 2.1.7.a Auto Initiation of Complete implementation As a result of the SEP safe shut-Auxiliary Feed of control grade.

down review and the post-TMI review, Yankee had decided to install an entirely new auxiliary feedwater system.

A review of accident analyses will be required to determine the mode of automatic initiation. The new system is being designed and the ordering of equipment is imminent.

The new system will be installed and connected to normal plant power svstems on a schedule which is as expeditious as equipment delivery will permit.

The design will include an analysis for steam generator water hammer as required by the NRC letter of September 12, 1979 Complete implementation The new auxiliary feedwater system of safety grade.

will be connected to emergency power sources on a schedule which will allow consideration of all loads requiring emergency powe~ sources as a result of the SEP review, and thus permit optimization of emergency power source capacities.

2.1.7.b Auxiliary Feed Flow Complete implementation.

The new auxiliary feedwater system psy Indication will have feed flow indications

.:D meeting the necessary safety-grade and crs power source requirements.

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eet o

ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Co=mitment 2.1.8.a Post Accident Sampaing Design review complete.

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

Preparation of revised If the review indicates that the plant procedures.

has the capability to obtain the necessary samples, procedures will be revised to implement the capability by January 1, 1980.

Implement plant modifi-if the review indicates that the plant cations.

does not have the capability to obtain the necessary samples, Yankee intends to implement the necessary modifications in conjunction with the SEP schedule.

Description of proposed Any necessary modifications will be modification.

identified when appropriate during the SEP review.

2.1.8.b High Range Radiation Installation complete.

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

2.1.8.c Improved Iodine Complete implementation.

Yankee presently has the capability to Instrumentaton determine airborne iodine concen-ation.

Procedures presently in effect rs3 require the use of charcoal for iodine y

cys sampling and the use of the plant's GeLi detector for gamma ray energy tra spectrum analysis which can FC>

discriminate iodine from noble gases.

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Sheet o

ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment 2.1 9 Transient and Accident Complete analysis pro-To accomplish this action item, Yankee Analysis cedures, and training in Rowe will utilize generic work produced areas of:

small break by the NSSS vendor in accordance with LOCA, inadequate core commitments made between the Westing-cooling, accidents and house Owners' Group and the Commission.

transients.

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 Yankee Rowe will validate independently the applicability of the generic guidelines and analyses for the Yankee Rowe plant.

Containment Pressure Installation complete.

Yankee Rowe will install a containment Monitor pressure monitor by January 1, 1981.

Containment Water Level Installation complete.

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

Containment Hydrogen Installation complete.

Yankee Rowe will install a containment Monitor hydrogen mm.2ttr by January 1, 1981.

RCS Venting Design submitted.

This area is being investigated by the Westinghouse Owners Group and Yankee intends to follow the recommendations Ps) of the Owners Group.

A venting design l?

will be submitted by January 1, 1980, CI' provided this schedule is consistent with the resolution of Owners Group recommendations.

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Sheet 8

of 8

ATTACHMENT IMPLEMENTATION OF REQUIREMENTS FOR FOLLOWUP ACTIONS Sect.

Abbreviated No.

Title Requirement Implementation Commitment Installation complete.

Provided the necessary equipment is available, every effort will be made to meet the scheduled date for installation of the venting system.

2.2.1.a Snift Supervisor Complete implementation.

Actions required in relation to Responsibilities Shift Supervisors responsibilities will be implemented by January 1, 1980.

2.2.1.b Shift Technical Advisor Shift technical advisor Shift technical advisor requirements on duty.

will be implemented by January 1, 1980.

Complete training.

Procedure and training requirements will be implemented by January 1, 1981.

2.2.1.c Shift Turnover Complete implementation.

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

2.2.2.a Control Room Access Complete implementation.

Yankee Rowe will establish the Control necessary controls to limit access to the control room by January 1, 1980.

2.2.2.b Onsite Technical Establish center.

An onsite technical support center will Support Center be established at Yankee Rowe by January 1, 1980.

2.2.2.c Onsite Operational Complete implementation.

An or. site operational support center Support Center will be established at Yankee Rowe by I'3

'x January 1, 1980.

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