ML19257A505

Responds to NRC 790913 TMI Lessons Learned Task Force short- Term Requirements.All short-term Requirements Will Be Implemented by 800101.Implementation Rept Encl

ML19257A505
Person / Time
Site:	Haddam Neck, Millstone  File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	12/31/1979
From:	Counsil W NORTHEAST UTILITIES
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0578, RTR-NUREG-578 TAC-11348, TAC-11561, TAC-12365, TAC-12505, TAC-42846, NUDOCS 8001040498
Download: ML19257A505 (404)

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Dec ember 31, 1979 Docket No s. 50-213 50-245

_50-336 Office of Nuclear Reactor Regulation Attn:

Mr. H. R. Denton, Director U. S. Nuclear Regulatory Commission Washington, D. C.

20555

References:

(1)

IMI-2 Lessons-Learned Task Force Report (Short-Term); NUREG-0578.

(2)

D. G. Eisenhut letter to All Operating Nuclear Power Plants dated September 13, 1979.

(3)

H. R. Denton letter to All Operating Nuclear Power Plants dated October 30, 1979.

(4)

W. G. Counsil letter to D. G. Eisenhut dated October 18, 1979.

(5)

W. G. Counsil letter to H. R. Denton dated November 21, 1979.

(6)

W. G. Counsil letter to J. Hendrie dated November 30, 1979.

(7)

W. G. Counsil letter to H. R. Denton dated December 6,1979; Docket Nos. 50-213 and 50-336.

(8)

W. G. Counsil letter to H. R. Denton dated December 7,1979.

(9)

W. G. Counsil letter to H. R. Denton dated December 7,1979.

(10)

W. G. Counsil letter to H. R. Denton dated December 10, 1979.

(11)

W. G. Counsil letter to H. R. Denton dated December 12, 1979.

(12)

D. L. Ziemann letter to W. G. Counsil dated December 12, 1979; Docket No. 50-213.

(13)

W. G. Counsil letter to H. R. Denton dated December 13, 1979; Docket No. 50-213.

(14)

W. G. Counsil letter to H. R. Denton dated December 14, 1979; Docket No. 50-213.

(15)

W. G. Counsil letter to H. R. Denton dated December 17, 1979; Docket No. 50-245.

(16)

W. G. Counsil letter to H. R. Denton dated December 17, 1979; Docket No. 50-336.

(17)

W. G. Counsil letter to H. R. Denton dated December 17, 1979; Docket No. 50-336.

(18)

W. G. Counsil letter to H. R. Denton dated December 18, 1979; Docket No. 50-213.

(19)

W. G. Counsil letter to H. R. Denton dated December 18, 1979; Docket Nos. 50-213 and 50-336.

(20)

R. W. Reid letter to W. G. Counsil dated December 21, 1979; Docket Nos. 50-213 and 50-336.

(21)

W. G. Counsil letter to R. W. Reid dated January 3,1979.

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(22)

J. J. Shea Summary of November 16, 1979 Phone Conversation to NNECO dated December 3,1979; Docket No. 50-245.

(23)

R. D. Silver Summary of November 19, 1979 Phone Conversation to CYAPCO dated December 3,1979; Docket No. 50-213.

1637 25 8001040 4

e Gentlemen:

Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. 1 and 2 TMI-2 Short-Term Lessons-Learned Implementation In References (1), (2), and (3), Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) were requested to provide responses and commitments regarding the TMI-2 Short-Term Lessons Learned.

Comprehensive responses to each of the items were provided in References (4) and (5), to the extent they were developed et the time of docketing.

The information provided in References (4) and (5) was subsequently clarified, supplemented, or amended by the information provided in References (6), (7), (8), (9), (10), (11), (13),

(14), (17), (18), and (19). The synergistic effect of the above-noted References was summarized in References (15) and (16) for Millstone Unit Nos.1 and 2, wherein NNECO reaf firmed its commitment to comply with all the Category A Short-Term Lessons-Learned requirements by January 1,1980, with the exception of Items 2.1.7.a, Automatic Initiation of Auxiliary Feedwater, and 2.1.9, Transient and Accident Analysis.

NRC Staff confirmation of the appropriateness of the deferral of Item 2.1.7.a was provided in Reference (20). CYAPCO and NNECO acknowledge that Reference (20) responds, in part, to the concerns delincated in Reference (6). Furthermore, References (6), (17), (18), and (19) provide conclusive evidence that implementation of automatic initiation of auxiliary feedwater is being pursued on an expedited basis.

This docketed material is judged to be fully responsive to the requests of References (2),

(3), and (12).

Efforts have been initiated to respond to the extensive requests of Reference (20).

However, it is reiterated that engineering, design, procurement, and supporting analytical efforts have continued despite CYAPCO's and NNECO's continued belief that this effort is unnecessary. At a minimum, sufficient time should be allowed such that automatic initiation can be accompanied by automatic isolation.

The concerns described in Reference (6) remain unanswered; it is respectfully requested that during future communications on this subject, Staff responses to these concerns are made available to CYAPCO and NNECO.

It is important to note that the only reason that a letter similar to Ref erences (15) and (16) was not provided for the Haddam Neck Plant concerned Item 2.1.4, Containment Isolation.

It is CYAPCO's position that the configuration and procedures whiah are in effect regarding containment isolation are adequate to ensure continued, safe operation of the facility. Were the Staff to agree with CYAPCO on this issue, full hnplementation of all the Category A Short-Term Lessons Learned would be achieved at the Haddam Neck Plant by January 1, 1980.

In order to complete fulfillment of References (2) and (3), Attachments (1),

(2), and (3) are provided for the Haddam Neck Plant, Millstone Unit No.1, and Millstone Unit No. 2, respectively.

Each of the Short-Term Lessons Learned are addressed in the Attachments for each unit.

For those instances where previously docketed correspondence provides either a partial or a total response to a given item, the Staff is directed to the appropriate Reference (s).

Unless indicated otherwise in the Attachments, the reference numbers ref er to the docketed documents listed in the forwarding letter.

It is also noted that the concerns identified in Ref erences (22) and (23) have been fully addressed by the attached material.

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' CYAPCO and NNECO have concluded that the attached material is fully responsive to the requests of Ref erences (2) and (3), and that this material is demonstra-tive of the previous statements that implementation of all Category A Short-Term Lessons Learned will be completed by January 1,1980.

It is currently envisioned tha t this document will be the penultimate submittal regarding implementation of the Short-Term Lessons Learned, in that only a response to Reference (2) is required to resolve the docketed Staff concerns.

We trust you find the Attachments responsive to your requests, and that they provide conclusive evidence that unparalleled engineering ef forts have indeed been expended to respond to the concerns resulting from the TMI-2 accident.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTllEAST NUCLEAR ENERGY COMPANY 1

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W. G. Counsil Vice President Attac hments

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-a TMI IMPLEME'iTATION d

Reouirement 2.1.4 Containment Isolation Provisions for PWR's and BWR's The responses to I&E Bulletin 79-08, dated April 23, 1979 and the response to the NRC Staff's request of July,1979, provided on November 15, 1979, responded to the questions raised on Diverse Containment Isolation and the Containment Isolation System.

Since the responses, reviews of all systems penetrating primary containment have been made both generically through the BWR Owners Group and by North-east Utilities.

The results regarding those systems required (essential) and those systems not recuired (non-essential) are identified in tabular form in the section of this report responding to NUREG-0578, item 2.1.6.a.

The generic r:ti:.. ::mplatad through the BWR Owners Group on isolation logic reset identified particular areas for individual utility review as well as providing guidance in those areas which do not require utility action.

Northeast has used the results of the generic review and our own review to assure that no individual valve in the isolation logic will assume an unsafe position en containrient isolation reset.

As a result of this review, modifications to the logic circuits of the following valves have been made to preclude opening of the valves following reset of containment isolation signals:

Cha o,p p or R s,c h Main stean isolation valves (8)

Na # ' # 4 4 yygg Drywell ecuipment and floor drain valves (4)

Drywell and suppression chamber vent valves p( (IN HANDLED ON JMi 3 1980 E. L "yMTE" C0hhER Therefore, Millstone Uni-1 is in full compliance with the January 1,1980 requirements for this item.

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