ML19250C601
| ML19250C601 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck, Millstone File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 11/21/1979 |
| From: | Counsil W CONNECTICUT YANKEE ATOMIC POWER CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0578 TAC-12365, NUDOCS 7911280444 | |
| Download: ML19250C601 (23) | |
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November 21, 1979 Docket Nos. 50-213 50-245 50-336 Office of Nuclear Reactor Regulation Attn:
Mr. H. Denton, Director U. S. Uuclear Regulatory Commission Washington, D. C.
20555
References:
(1)
D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979.
(2)
W. G. Couns11 letter to D. G. Eisenhut dated October 18, 1979.
(3)
H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979.
Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1 and 2 Discussion of IMI Lessons-Learned Short-Term Requirements In Reference (1), Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) were requested to respond by providing. commitments to comply with each of the requirements of Enclosure 6 of that Reference.
In Reference (2), CYAPCO and NNECO responded with a detailed position for each NUREG-0578 item for each of the three operating units.
In Reference (3), the Staff provided additional clarification for each of these items, and requested further review of the schedular commitments, and a detailed description and justification for any deviation from the Staff requirements. Reference (3) was further supplemented by conference calls with the appropriate NRC project review team.
During these calls, areas requiring further information from CYAPC0/NNECO were identified.
In response to that request, CYAPCO hereby provides Attachment 1, and NNECO hereby provides Attachments 2 and 3 for Millstone Unit No.1 and Millstone Unit No. 2, respectively, to address each of the short-term lessons learned on an item-by-item basis.
It is noted that in the same sense that Reference (3) did not change the intent of Staff requirements of NUREG-0578 and Reference (1),
the attached material does not alter the intent or supersede Reference (2T.
Unparalleled engineering efforts remain in progress in an attempt tc cott with the Staff requirements as they apply to the three operating units.
m 1409 002 7911' 804-4-9 2
, indicated in the Attachnents, CYAPCO and NNECO fully intend to implement the Category A recommendations by January 1,1980 where so stated.
Ibwever,
please recognize that this schedule is quite optimistic considering manpower limitations, hardware availability, etc.
If in any instance full compliance by January 1, 1980 is recognized to be not feasible, the Staff will be notified to that effect promptly.
The above commitment is also applicable to those short-term implementation requirements which were indicated to be effected by the Systematic Evaluation Program (SEP) in Reference (2). The impact of SEP is not felt for any short-term implementation requirement, with the exception of Item 2.1.6.b as outlined in Attachtants 1 and 2.
During one of the above-mentioned conference calls, the Staff stated that their decisions regarding deferral of certain long-term lessons-learned recommendations would not occur until af ter Staff review of the information which will be docketed on or before January 1,1980.
CYAPCO and NNECO endorse this approach; therefore, elaboration of the impact of the SEP on certain long-term requirements is not provided in Attachments 1 and 2, but will be included with the January 1,1980 material. The impact of the SEP can and will be much more succinctly provided once the ongoing design reviews and evaluations are completed. The logic inherent in the above approach is also applicable to Iten 2.1.6 b.
During one of the conference calls, the Staff noted that NNECO had not committed to a schedule for implementation of design changes which may result from the shielding review. As stated during the call and in Reference (2), it is inappropriate to commit to a schedule for completing modifications before such modifications are identified.
A specific concern regarding Item 2.2.2.b, the Onsite Technical Support Center, merits attention at this time. The clarification provided in Reference (3) is, in part, contradictory with the guidance being pecmulgated by the NRC Staff during meetings on Emergency Planning.
In the latter case, the Staff has e: pressed a desire to have two unique support centers, a smaller one (approxi-mately five individuals) in the immediate proximity of the control room, and a much larger one some distance from the control room, outside the security area to allow ready access. This concern was raised during our conference calls, and the Staff agreed to respond with some additional guidance.
This guidance is needed promptly to ensure our efforts are devoted to the proper configuration.
\\4
. With regard to implementation of the short-term requirements, it is first re-emphasized that completion is targeted for January 1, 1980. Recognizing that conditions beyond CYAPCO's and NNECO's control may preclude this, the matter of system reserve generating capacity during the months of January and February,1980, has been investigated with the New England Power Exchange (NEPEX). The outage of any of the three nuclear units during the period of January 1 to February 16, 1980 would reduce the system reliability below the NEPEX prescribed level for adequate system reliability. This projection is based upon currently scheduled outages for NEPEX nuclear and fossil units which cannot be readily moved outside this six-week interval.
Even if all three NU nuclear units remain operational at full power, it is anticipated that heavy use will be made of number six fuel oil for the NEPEX system fossil steam units and number 2 heating oil for internal combustion units which are not normally required.
Pending resolution of the short-term implementation items, acditional details regarding system reserve generating capacity will be provided as required.
With the exception of Item 2.1.7.a, which will be the subject of separate correpondence, CYAPCO and NNECO have addressed each NUREG-0578 requirement, as supplemented by References (1) and (3), on two occasions. Therefore, it is our understanding that your request of Reference (3) is fulfilled.
Our continuing dialogue with the Staff is expected to supplement the Attached material as the inplementation dates approach.
Should any deviations from our implementation program as outlined be identified, the Staff will be so advised promptly.
Very truly yours.
CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY b
NA/I1 Q. G. Counsil l
Vice President Attachments
\\
DOCKET NO. 50-213 ATTAC10iENT 1 HADDAM NECK PLANT FOLLOWUP ACTIONS RESULTING FROM NRC STAFF REVIEWS REGARDING THE THREE MILE ISLAND, UNIT 2 ACCIDENT
) {\\0 h NOVEMBER, 1979
HADDAM NELK PLANT FOLLOWUP ACTIONS RESULTING FROM NRC STAFF REVIEWS REGARDING THE THREE MILE ISLAND, UNIT 2 ACCIDENT Item 2.1.1 CYAPCO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979.
Item 2.1.2 CYAPCO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979.
Item 2.1.3(a)
CYAPCO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979.
Item 2.1.3(b)
CYAPC0 intends to hnplement by January 1,1980 the Catet ory A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979, with the following additional clarifications.
The procedures to be used by an operator to recognize inadequate core cooling using existing instruuentation will be developed and implemented by January 1, 1980.
Item 2.1.4 CYAPCO intends to implement by January 1, 1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear' Power Plants dated October 30, 1979.
Item 2.1.5 jf]} ))h CYAPCO response
._ains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979.
. Item 2.1.6(a)
CYAPCO intends to implement by January 1,1980 the Category A recommendatiods' of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979.
Item 2.1.6(b)
CYAPCO tutends to implement by January 1,1980 the Category A recommendations of NUREs -0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Pl..nts dated Scptember 13, 1979 as clarified by H. R. Denton letter to All Opucating Nuclear Power Plants dated October 30, 1979, with the following additional clarifications.
The design review will not include a review for potential degradation of equip-ment resulting from high radiation. This review cannot be accomplished by January 1,1980 due to the unavailability of required documentation.
This effort continues to be integrated with numerous SEP topics as previously submitted. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979.
Item 2.1. 7 (a)
CYAPC0 continues to conclude that automatic initiation of auxiliary feedwater is unnecessary and not a " lesson learned" from a review of the TMI accident.
This topic was most recently discussed with the NRC Staff during conference calls arranged to clarify the intent of H. R. Denton's letter dated October 30, 1979.
Although these discussions did not result in substantive changes of opinion of either party, areas meriting additional analyses / clarification were identified.
It is currently plar.ned that a docketed submittal, specifically devoted to the topic of automatic initiation of auxiliary feedwater, will be provided to the Staff on or about November 29, 1979.
The intent of this submittal is to explain in detail the basis for CYAPCO's position, and elaborate on the complications associated with implementation of this request by January 1, 1980.
Item 2.1.7(b)
CYAPCO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979.
Item 2.1.8 (a) 1409 007 CYAPC0 intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to AllI 0perating Nuclear Power Plants dated September 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979 with the following additional clarifications.
. Plant design and plant handling and analysis procedures, will be reviewed and modified if possible to allow for the sampling of highly radioactive samples.
Iten 2.1.8(b)
CYAPCO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated Septemb7r 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979, with the following additional clarifications.
CYAPC0 already has procedures in effect for estimating post-accident releases.
These procedures include the following steps:
1.
Use existing effluent monitor response.
2.
If the monitor is off scale, use tables giving predetermined release rates.
These release rates are based on the type of accident and time of accident.
They are based on Reg. Guide assumptions and plant-specific information. Values for noble gases and iodine are given.
3.
Using these release rates and existing meteorological conditions, calculate offsite dose rates and concentrations at specific locations.
4.
Take field measurements at these locations.
5.
If the field measurements vary significantly from the estimates, readjust the release rate estimates.
Item 2.1.8(c)
CYAPCO intends to implement by January 1,1980 the Category A recommendations vf NUREG-L578 as lequired by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979, with the following additional clarifications.
CYAPCO already complies with these requiremen;,as follows:
The Connecticut Yankee Power Facility has several gamma ray spect7omeQers08 40 1.
which may be used for accurately determining airborne iodine concentrations during post-accident conditions. This equipment is capable of identifying and calculating activities for all lodine isotopes of interest (I-131 through I-135).
Identification of other significant isotopes present in the sample is also possible.
2.
The calibration and operation of this equipment for gamma analysis of charcoal filters is specified within station procedures.
Instructions for operation of portable air sampling equipment is also delineated within the station procedures.
. 3.
Station procedures require that the charcoal tilters are analyzed on the gamma ray spectrometers if detectable activity is observed.
The samples will be analyzed off-site (within 30 minutes by car) in the event that backgrour.d levels of radiation cause unacceptably large counting errors which cannot be controlled through the use of ventilation and shielding.
The off-site analyses will utilize gamma energy spectrum analysis for accurate measurement of airborne iodine concentrations.
Iten 2.1.9 CYAPCO response remains unchanged from previous submittal. Reference, W. G. Couns'.1 letter to D. G. Eisenhut dated October 18, 1979.
Additional Instrumentation, Containment Pressure, Containment Water Level and Hydrogen Monitors to Follow the Course of the Accident CYAPCO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979.
Installation of Remotely Operated High Point Vent in Reactor Coolant System CYAPCO intends to implement by January 1,1980 the Category A recommandations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Neclear Power Plants dated Sept ember 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979.
Item 2.2.l(a)
CYAPCO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979.
Item 2.2.l(bl l/f ))} CYAPCO intends to implement this requirement for additions.1 accident assessment capability by adding an additional licensed operator to each shift and upgrading the training of a senior reactor operator on each shif t to include the general technical education, and additiont.1 transient and accident response training requirements as discussed in Enclosure (2) to D. G. Eisenhut's letter of September 13, 1979. The senior reactor operator on each shift designated as the Shif t Technical Advisor would have no assigned line functions while per-forming the Shift Technical Advisor function. The addition of a licensed reactor operator to the control room shif t complement will enable the STA to be detached from controls manipulation and supervision of operators during This provision is considered critical to our intended method of an event. implementation since the primary deficiency noted in the Staff's discussion regarding this alternative was the need for involvement of each of the current shif t complement of three operators in satisfying the demands for prompt control and supervisory actions. Implementation of the STA requirement in
. this way also prevents dilution of command authority during an accident situation which was noted as not desirable in Enclosure (2) to D. G. Eisenhut's letter of September 13, 1979. CYAPC0 feels that this method represents the optimum alt native for implementation of the STA requirement. However, as discussed i. Enclosure (2) referenced above, the completion of the additional general technical education and transient and accident training requirements may take two years or more to fully Dnplement depending on the scope and content of the training requirements as finally established. Therefore, in the interim period while the designated operators are off-shift or off-site receiving the required training, CYAPC0 intends to implement an interim method of providing the additional accident assessment capability. The interim method which CYAPC0 intends to implement by January 1,1980 is to provide immediate on-call assistance to the control room by designated senior personnel from the plant staff available on-site in approximately 30 minutes. The majority of designated individuals will have a Bachelor's Degree in science or engineering and all will have a current Senior Reactor Operator License on the designated unit. These individuals will also receive short-term supplemental training and retraining in plant transient and accident response. As an additional interim measure, CYAPCO will also provide an on-call group of experts with experience and technical backgrounds in the various technical areas important to safety including mechanical, electrical, and fluid systems; reactor physics, chemistry, and metallurgy, This group would consist of individuals from both the plant staff and our Northeast Utilities Service Company (NUSCO) engineering staff. Due to the close geographical proximity of the NUSCO engineering support group, this on-call team of experts will be available on-site within approximately one hour of an event. CYAPCO continues to believe that the long-term and interim measures described above are the most effective means of implementing the required Shif t Technical Advisor coverage. Item 2.2.1(c) CYAPCO response remains unchanged from previous submittal. Paference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Item 2.2.2(a) CYAPCO response remains unchanged from previous submittal. Re e h e, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Item 2.2.2(b) CYAPCO intends to bnplement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979. Additional clarification is required as noted in the cover letter.
% Item 2.2.2(c) CYAPCO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18. 1979. Item 2.2.3 CYAPCO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. 1409 011
DOCKET NO. 50-245 ATTACHMENT 2 MILLSTONE LdCLEAR POWER STATION, UNIT NO.1 FOLLOWUP ACTIONS RESULTING FROM NRC STAFF REVIEWS REGARDING THE THREE MILE ISLAND, UNIT 2 ACCIDENT 1409 012 NOVEMBER, 1979
Millstone Nuclear Power Station Unit 1 Followup Actions Resulting From NRC Staff Reviews Regarding the Three Mile Island, Unit 2 Accident Icem 2.1.1 NNECO response remains unchanged from previous submittal. Reference W. G. Counsil letter to D. G. Eisenhut dated October 18. 1979. Item 2.1.2 The BWR Owners Group is evaluating and formulating a program for testing of the Safety Relief valves. NNECO intends to support the Owners Group effort. Item 2.1.3(a) NNECO intends to implement by January 1, 1980 the Category A recommendations of NUREG-0578 as required by 9. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979. Item 2.1.3(b) NNECO response remains unchanged from previous submittal. Reference W. G. Counsil letter to D. G. Eisenhut dated October 18. 1979. Item 2.1.4 NNECO intends to implement by January 1, 1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979. Item 2.1.5(a, b & c) NNECO response remains uachanged from previous submittal. Reference W. G. Counsil letter to D. G. Eisenhut dated October 18. 1979. Item 2.1.6(a) NNECO intends to implement by January 1, 1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979. 140'). 013 Item 2.1.6(b) NNECO intends to implement by January 1, 1980 the Cat ^qory A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to.11 Operating Nuclear Power Plants dated Scptember 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979 with the following additional clarification.
. The design review will not include a review for potential degradation of equipment resulting from high radiction. This rcview cannot be accomplished by January 1, 1980 due to the unavailability of the required documentation. This effort continues to be integrated with numerous SEP topics as previously submitted. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Iten 2.1.7(a) NNECO response remains unchanged from previous submittal. Reference W. G. Counsil letter to D. G. Eisenhut dated October 18. 1979. Item 2.1.7(b) NNECO response remains unchn..ged from previous submittal. Reference W. G. Counsil letter to D. G. Eisenhut dated October 18. 1979. It en 2.1. 8 (a) NNECO inteads to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979 with the following additional clarifications. Plant design and plant handling and analysis procedures, will be reviewed and modified if possible to allow for the sampling of highly radioactive samples. Item 2.1.8(b) NNECO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979, with the following additional clarifications. NNECO already has procedures in effect for estimating post-accident releases. These procedures include the following steps: 1. Use existing effluent monitor response. 2. If the monitor is off scale, use tables giving pradetermined release rates. These release rates are based on the type of accident and time of accident. They are based on Reg. Guide assumptions and plant-specific information. Values for noble gases and iodine are given. 3. Using these release rates and existing meteorological c anditions, calculate offsite dose rates and concentrations at specific locations. 1409 014 4. Take field measurements at these locations. 5. If the field measurements vary signif *cantly from the estimates, readjuct the release rate estimates.
. Item 2.1 8 (c) NNECO intends to iaplement by January 1,1980 the Category A recc+ aendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 as clarified by H. R. Deaton letter to All Operating Nuclear Power Plants dated October 30, 1979, with the following additional clarifications. NNECG already complies with these requirements as follows: 1. The Millstone Nuclear Power Facility has several gamma ray spectrometers which may be used for accurately determining airborne iodine concentrations during post-accident conditions. This equipment is capable of identifying and calculating activities for all iodine isotopes of interest (I-131 through I-135). Identification of other significant isotopes present in the sample is also possible. 2. The calibration and operation of this equipment for gasama analysis of charcoal filters is specified within station procedures. Instructions for operation of portable air sampling equipment is also delineated within the station procedures. 3. c ation procedures require that the charcoal filters are analyzed on the gaama ray spectrometers if detectable activity is observed. The samples will be analyzed of f-site (within 30 minutes by car) in the event that background levels of radiation cause unacceptably large counting errors which cannot be controlled through the use of ventilation and shielding. The of f-site analyses will utilite gamma energy spectrum analysis for accurate measurement of airborne iodine concentrations. Item 2.1.9 NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Additional Instrumentation, Containment Pressure, Containment Wa'ter Level and Hydrogen Monitors to Follow the Course of the Accident NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Installotion of Remotely Operated High Point Vent in Reactor Coolant System NNECO response remains unchanged from previous submittal. Reference, U. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. e Item 2.2.l(a) i NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Iten 2.2.l(b) NNECO intends to implement this requirement fc. additional accident assessment capability by adding an additional licensed operator to each shift and upgrading the training of a senior reactor operator on each shift to include the general technical education, and additional transient and accident response training requirements as discussed in Enclosure (2) to D. G. Eisenhut's letter of September 13, 1979. The senior reactor operator on each shif t designated as the Shif t Technical Advisor would have no assigned line functions while per-forming the Shift Technical Advisor function. The addition of a licensed reactor operator to the control room shift complement will enable the SIA to be detached from controls manipulation and supervision of operators during This provision is considered critical to our intended method of an event. implementation since the primary deficiency noted in the Staff's discussion regarding this alternative was the need for involvement of each of the current shif t complement of three operators in satisfylt.; the demands for prompt control and supervisory actions. Implementation of the STA requirement in this way also prevents dilution of command authority during an accident situation which was noted as not desirable in Enclosure (2) to D. G. Eisenhut's letter of September 13, 1979. NNECO feels that this method represents the optimum alternative for implementation of the STA requirement. Co-ever, as discussed in Enclosure (2) referenced above, the completion of the additional general technical education and transient and accident training requirements may take two years or more to fully implement depending on the scope and content of the training requirements as finally established. Therefore, in the interim period while the designated operators are off-shif t or off-site receiving the required training, NNECO intends to implement an interim method of providing the additional accident assessment capability. The interim metl 3d which NNECO intends to implement by January 1,1980 is to provide immediate on-call assistance to the control room by designated senior personnel from the plant staff available on-site in approximately 30 minutes. The majority of designated individuals will have a Bachelor's Degree in science or engineering and all will have a current Senior Reactor Operator License on the designated unit. These individuals will also receive short-term supplemental training and retraining in plant transient and accident response. As an additional interim measure, NNECO will also provide an on-call group of experts with experience and technical backgrounds in the various technical areas important to safety including mechanical, electrical, and fluid systems; reactor physics, chemist y, and metallurgy. This group would consist of individuals from both the plant staff and our Northeast Utilities Service Company (NUSCO) engineering staff. Due to the -1nse geographical proximity of the NUSCO engineering support group, this on-call team of experts will be available on-site within approximately one hour of an event. NNECO continues to believe that the long-term and interim measures described above are the most effective means of implementing the required Shif t Technical Advisor coverage. l Item 2.2.1(c) NNECO response remains unchanged from previous submittal. Reference. W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Iten 2.2.2(a) NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Item 2.2.2(b) NNECO intends to Onpl ement by January 1,1980 the Category A recommendations of NUREG-0578 as reqtired by D. G. Eisenhut letter to All Operaf ing Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979. Additional clarification is required as noted in the cover letter. Item 2.2.2(c) NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Item 2.2.3 NNECO response remains unchanged from previous submitr l. Reference, a W. G. Counsil letter to D. G. Eisenhut dated October 8,1979. 1409 017
DOCKET NO. 50-336 ATTACHMENT 3 MILLSTONE NUCLEAR POWER STATION, UNIT NO. 2 FOLLOWUP ACTIONS RESULTING FROM NRC STAFF REVIEWS REGARDING THE THREE MILE ISLAND, UNIT 2 ACCIDENT 1409 018 NOVEMBER, 1979
MILLSTONE NUCLEAR POWER STATION, UNIT No. 2 FOLLOWUP ACTIONS RESULTING FROM NRC STAFF REVIEWS REGARDING THE THREE MILE ISLAND, UNIT 2 ACCIDENT Item 2.1.1 MNECO intends to implement by Janu'ary 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979. Iten 2.1.2 NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Item 2.1.3(a) NNECO intends to Dnplement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhr: letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979. Item 2.1.3 (b) NNECO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979, with the following additional clarifications. The procedures to be used by an operator to recognize inadequate core cooling using existing instrumentation will be developed and implemented by January 1, 1930. Item 2.1.4 NNECO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979. Iten 2.1.5 I NNECO response remains unchanged from previous submittal. Refe fe2ce,L119 W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979.
. It em 2.1. 6 (a) HNECO intends to implement by January 1, 1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton F to All Operating Nuclear Power Plants dated October 30, 1979. Item 2.1.6(b) NNECO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Ops., ring Euclear Power Plants dated September 13, 1979 and as clarified by H. R. venton letter to All Operating Nuclear Power Plants dated October 30, 1979. Item 2.1.7 (a) NNECO continues to conclude that automatic initiation of auxiliary feedwater is unnecessary and not a " lesson learned" from a review of the TMI accident. This topic was most recently discussed with the NRC Staff during conference calls arranged to clarify the intent of H. R. Denton's letter dated October 30, 1979. Although these discussions did not result in substantive changes cf opinfon of either party, areas meriting additional analyses / clarification were identified. It is currently planned that a docketed submittal, specifically devoted to the topic of automatic initiation of auxiliary feedwater, will be provided to the Staff on or about November 29, 1979. The intent of this submittal is to explain in detail the basis for NNECO's position, and elaborate on the complications associated with implementation of this request by January 1, 1980. Item 2.1.7(b) NNECO intends to Laplement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Dentan letter to All Operating Nuclear Power Plants dated October 30, 1979. Iten 2.1.8(a) NNECO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979 with the following additional clarifications. <l } T' O *
. Plant design and plant handling and analysis procedures, will be reviewed and modified if possible to allow for the sampling of highly radioactive samples. I_ tem 2.1.8(b) NNECO intends to bnplement by January 1.1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979, with the following additional clarifications. NNECO already has procedures in effect for estimating post-accident releases. These procedures include the following steps: 1. Use existing effluent monitor response. 2. If the monitor is off scale, use tables giving predetermined release rates. These release rates are based on the type of accident and time of accident. They are based on Reg. Guide assumptions and plant-specific information. Values for noble gases and iodine are given. 3. Using these release rates and existing meteorological conditions, calculate offsite dose rates and concentrations at specific locations. 4. Take field measurements at these locations. 5. If the field measurements vary significantly from the estimates, readjust the release rate estimates. Item 2.1. 8 (c ) NNECO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979, with the following additional clarifications. NNECO already complies with these requirements as follows: 1. The Millstone Nuclear Power Facility has several gamma ray spectrometers which may be used for accurately determining airborne iodine concentrations during post-accident conditions. This equipment is capable of identifying and calculating activities for all iodine isotopes of interest (I-131 through I-135). in the sample is also possible. Identification of other significant isotopes pre yy q7j 1 2. The calibration and operation of this equipment for gamma analysis of charcoal filters is specified within station procedures. Instructions for operation of portable air sampling equipment is also delineated within the station procedures.
. 3. Station procedures require that the charcoal filters are analyzed on the gamma ray spectrometers if detectable activity is observed. The samples will be analyzed off-site (within 30 minutes by car) in the event that background levels of radiation cause unacceptably large counting errors which cannot be controlled through the use of ventilation and shielding. The off-site analyses will utilize gamma energy spectrum analysis for accurate measurement of airborne iodine concentrations. Item 2.1.9 NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Additional Instrumentation, Containment Pressure, Containment Water Level and Hydrogen Monitors to Follow the Course of the Acciderat NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Installation of Remotely Operated High Point Vent in Reactor Coolant Systeo NNECO intends to implement by January 1,1980 the Category A recommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All O'erating Nuclear Power Plants dated October 30, 1979. p Iten 2.2.l(a) NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Item 2.2.l(b) 1409 0'2 t NNECO intends to Lnplement this requirement for additional accident assessment capability by adding an additional licensed operator to each shif t and upgrading the training of a senior reactor operator on each shif t to include the general technical education, and additional transient and accident response training requirements as discussed in Enclosure (2) to D. G. Eisenhut 's letter of September 13, 1979. The senior reactor operator on each shift designated as the Shif t Technical Advisor would have no assigned line functions while per-forming the Shift Technical Advisor function. The addition of a licensed reactor operator to the control room shif t complement will enable the STA to be detached from controls manipulation and supervision of operators during an event. This provision is considered critical to our intended method of implementation since the primary deficiency noted in the Staff's discussion regarding this alternative was the need for involvement of each of the current shif t complement of three operators in satisfying the demands for prompt control and supervisory actions. Implementation of the STA requirement in
- this way also prevents dilution of command authority during an accident situation which was noted as not desirabl. in Enclosure (2) to D. G. Eisenhut's letter of September 13, 1979. NNECO feels that this method represents the optimum alternative for implementation of the STA requirement. However, as discussed in Enclosure (2) referenced above, the completion of the additional general technical education and transient and accident training requirements may take two years or more to fully implement depending on the scope and content of the training requirements as finally established. Therefore, in the interim period while the designated operators are off-shift or off-site receiving the required training, NNECO intends to implement an interim method of providing the additional accident assessment capability. The interim method which NNECO intends to implement by January 1,1980 is to provide immediate on-call assistance to the control room by designated senior personnel from the plant staff available on-site in approximately 30 minutes. The majority of designated individuals will have a Bachelor's Degree in science or engineering and all will have a current Senior Reactor Operator License on the designated unit. These individuals will also receive short-term supplemental training and retraining in plant transient and accident response. As an additional interim measure, NNECO will also provide an on-call group of experts with experience and technical backgrounds in the various technical areas important to safety including mechanical, electrical, and fluid systems; reactor physics, chemistry, and metallurgy. This group would consist of individuals from both the plant staff and our Northeast Utilities Service Company (NUSCO) engineering staff. Due to the close geographical proximity of the NUSCO engineering support group, this on-call team of experts will be available on-site within approximately one hour of an event. NNECO continues to believe that the long-term and interim measurec described above are the most effective means of bnplementing the required Shif t Technical Advisor coverage. Iten 2.2.l(c) NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Item 2.2.2(a) NNEC0 response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Iten 2.2.2(b) 09 023 NNECOintendstoimplementbyJanuary1,1980theCatekoryArecommendations of NUREG-0578 as required by D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979 and as clarified by H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979. Additional clarification is required as noted in the cover letter.
. Item 2.2.2(c) NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. Iten 2.2.3 NNECO response remains unchanged from previous submittal. Reference, W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979. 1409 024}}