ML19275A856
| ML19275A856 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 10/17/1979 |
| From: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| 1-109-4, NUDOCS 7910190304 | |
| Download: ML19275A856 (33) | |
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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 UTTLE ROCK, ARKANSAS 72203 (501)371-4422 October 17, 1979 WILLIAM CAVANAUGH lli Vice President Generation & Constnx: tion 1-109-4 2-109-3 Director of Nuclear Reactor Regulation ATTN: Darrell G. Eisenhut, Acting Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Subject:
Arkansas Nuclear One-Units 1& 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPE-6 Lessons Learned Task Force Recommendations (File: 1510, 2-1510)
Gentlemen:
In response to your letter dated September 13, 1979, the following is provided.
We have thoroughly reviewed your letter as well as NUREG-0578. Based on our reviews, we believe, in general, the items set forth in your letter and NUREG-0578 are valid and appropriate to increase the margin of safety at our facili-ties. We address each of these items for both ANO-1 and ANO-2 in the attached detailed discussion.
In some cases our plant specific reviews have developed what we believe to be more effective means of achieving the
' recommendation vice your suggested method.
For a few of the recommended items, it is not possible for us to comply with your recommended schedule based primarily on procurement lead times for certain equipment. For these items,,our best schedules estimate completion dates scat-tered in the January to May 1980 time frame. To accommodate individually each of these modifications as equipment be-comes available, it would be necessary to have several outages during this five month period. We do not believe this repetitive cycling of the plant is in the best interest ? \
of safety. Therefore, we propose two outages for each unit,. g p s
9 1185 344 ,o O
05N MEMBER MiOOLE SOUTH UTtUTIES SYSTEM h
1-109-4 2-10.9-3 Mr. Darrell G. Eisenhut October 17, 1979 one in December 1979 to accommodate all possible items for the January 1980 schedule and another in May 1980 to accommodate the remainder of the items exclusive of the 1981 items. Outages of the two units will be scheduled in series rather than concurrently tc assure adequate availability of power to our customers. As our peak season for power con-sumption is from June to September, it is not desirable to have an outage during that period.
Included in the attached response to your letter is a list of definitions of certain key words and a table showing the implementation schedule for each of the items addressed in the response. All schedules presented are based on the best information available to us at this time, and include con-siderations of design, procurement, installation and testing as applicable. These can be impacted by a number of factors such as delays in equipment delivery and complication of engineering as designs progress. AP&L will utilize every available resource to meet these schedules as presented.
Your consideration of our proposals and appreciation of our detailed reviews and concerns for safe operation of our facilities will be appreciated.
Very t r u ly yo gr.s ,
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William anaugh, I I WC/JTE/aa s
Attachment
ARKANSAS NUCLEAR ONE - UNITS 1 and 2 RESPONSES TO D.
EISENHUT LETTER DATED SEPTEMBER 13, 1979.
Item a The staff will be proposing a new rule on a Limiting Con-dition of Operation to require plant shutdown for certain human or procedural errors, particularly those which are repetitive in nature. As such, no action is required on your part at this time.
Response - ANO-1 and 2 No response required.
Item b At the present time we are delaying efforts regarding proposed rulemaking on both the inerting requirements for Mark I and II BWR containments, and the requirements regarding hydrogen recombiner capability; accordingly, no action is required on your part at this time.
Response ANO-1 Although no response is required, we believe it important to note that ANO-1 does have a dedicated, safety-grade Hydrogen Purge System.
Response ANO-2 Although no response is required, we believe it important to note that ANO-2 has dedicated and safety-grade Hydrogen Recombiners and Hydrogen Purge Systems.
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- Item e The ACRS comments on the shift technical advisor have resulted in our reassessment of the possible means of achieving the two functions which the Task Force intended to provide by this requirement. The two functions are accident assessment and operating experience assessment by people onsite with engineering competence and certain other characteristics. We have concluded that the shift techni-cal advisor concept is the preferable short-term method of supplying these functions. We have also concluded that some flexibility in implementation may yield the desired 1'kb g \?/h
t results if there is management innovation by individual licensees. We have prepared a statement of functional characteristics for the shift technical advisor that will be used by the staff in the review of any alternatives proposed by licensees.
Response - ANO-1 and 2 See response to Section 2.2.1.b of Item f.
Item d Three additional instrumentation requirements for short-term action were developed dur'ng the ACRS review of NUREC-0578. These items relatt to containment pressure, containment water level and containment hydrogen monitors designed to follow the course of an accident.
Response - ANO-1 CONTAINMENT PRtSSURE - ANO-1 currently has three safety grade, qualified containment pressure instrumentation loops, each of which displays a range of 0-65 psia. In addition, we have installed a fourth safety grade, qualified containment pressure instrumentation loop which is recorded over a range of 0-65 psia.
We will install two additional safety grade, qualified pressure instrumentation loops each capable of displaying a range of at least 0 to 192 psia (3 times design pressure of 59 psig) with one channel recorded over the same range.
Our current evaluation indicates that these will be installed by January 1, 1981.
CONTAINMENT WATER LEVEL - ANO-1 currently has installed one non-safety grade containment watar level indicator.
We will install one safety grade, qualified, narrow range level instrumentation loop which indicates in the Centrol Room. We will also install two safety grade, qualified, wide range water level instrumentation loops which indicate in the Control Room, one channel of which will be recorded. The wide range indicators shall have a range capable of indicating, on scale, a level corresponding to at least 500,000 gallons of liquid in the Reactor Building.
Our current evaluation indicates that these will be modified by January 1, 1981.
CONTAINMENT HYDROGEN MONITORS - ANO-1 curren tly has installed 2 safety grade, qualified hydrogen monitors capable of indica-ting from 0 to 5% hydrogen. We will modify these two hydro-4V .
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sen monitors to be capable of monitoring 0 to 10% hydrogen in the Reactor Building. These are qualified and safety grade, and are indicated in the Control Room with one channel recorded.
Our current evaluation indicates that these will be modified by January 1, 1981.
Response - ANO-2 CONTAINMENT PRESSURE - ANO-2 currently has installed four safety grade, qualified containment pressure transmitters four channels of which indicate (in the Control Room) O to 70 psia, one channel of which is recorded over the same range. We will install two additional safety grade, quali-fied containment pressure transmitters capable of indica-tit 3 in the Control Room 0 to 177 psia (3 times design pressure of 54 psig), one channel of which will be recorded over the same range.
Our current evaluation indicates that these will be in-stalled by January 1, 1981.
CONTAINMENT WATER LEVEL - ANO-2 currently has installed two safety grade, qualified, wide range water level indicators (which indicates 46" to 128" above the top of the sump) in the Control Room with one channel recorded. The maximum elevation measured (128") is sufficient to indicate, on scale, a level which corresponds to in excess of 500,000 gellons of liquid in tha containment.
We will modify the instrumentation on both existing channels to provide indication from the top of the sump to at least a level corresponding to 500,000 gallons o .' liquid in the containment.
We will install one safety grade, qualified water level indi-cator (indicating in the Control Room), which indicates the level from the bottom of the sump to the top of the sump.
Our current evaluation indicates that this modification and installation will be completed by January 1, 1981.
CONTAINMENT HYDROGEN MONITORS - ANO-2 currently has in-stalled 2 safety grade, qualified hydrogen monitors cap-able of indicating from 0 to 5% hydrogen. We will modify these two safety grade, qualified, hydrogen monitors to monitor 0 to 10% hydrogen in the Containment Building.
These will indicate in the Control Room over at least the same range and one channel will be recorded.
Our current evaluation indicates that these will be modified by January 1, 19,81.
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4 Item e An additional requirement following issuance of NUREG-0578, which concerned a remotely operable high point vent for gas from the reactor coolant system, was developed.
Response - ANO 1 A generic design effort, to which AP&L is committed, is underway by B&W to provide a functional description of the construction, location, size, and appropriate power suppl" for reactor coolant system high point vents. Appropriate safety analyses considering the effects of such vents are also being pursued. Current schedule indicates this effort should be completed and forwarded to you in May, 1980.
Providing the results of this investigation do not reveal any significant safety issues with regard to installation of such vents, we will install high point vents as appro-priate from these analyses.
Provided the eyaluations are completed as expected, these vents should be installed by January 1, 1981, contingent upon NkC approval and equipment availability.
Response - ANO-2 A generic design effort, to which AP&L is committed, is underway by CE to provide a functional description of the construction, location, size, and appropriate power supply for reactor coolant system high point vents. Appropriate safety analyses considering the effects of such vents are also being pursued. Current schedule indicates that the above items and a concep tual design will be submitted to you for your review by January 1,1980.
Providing the results of this investigation do not reveal any significant safety issues with regard to installation of such vents, we will install high point vents as appro-priate from these analyses.
Provided the evaluations are completed as expected, these vents should be installed by January 1, 1981, contingent upon NRC approval and equipment availablity.
Item f The Lesson. Learned Task Force has compiled a set of errata and clarifying comments for NUREG-0578.
Recommendation 2.1.1 - Emergency Power Supply Requirements for Pressurizer Heaters, Power Operated Relief Valves and Block Valves, and Pressurizer Level Indicators in PWRs.
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Response - ANO-1 PRESSURIZER HEATERS - B&W has determined that 126 Kw of pressurizer heater capacity is necessary within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following a loss of offsite power to assure proper control for natural circulation.
We will provide the capability to power 126 Kw of pres-surizer heater capacity from redundant emergency power sources. The power source alone will be safety grade with appropriate qualified, safety grade interface devices.to isolate the remainder of the nonsafety grade system.
The capability for the safety grade power, appropriate procedures, and training will be completed by Januaryti, 1980.
POWER OPERATED RELIEF VALVES - Currently the ANO-1 PORV is powered from safety grade D.C. power (chanel 1, red) and the block valve is powered from black (nonsafety) A.C.
We will provide safety grade AC motive and control power (channel 2, green) to the PORV block valve. The power source only will be safety grade appropriately isolated with qualified, safety grade interface devices to isolate the safety from the nonsafety grade portions of the system. This will be completed by January 1, 1980.
PRESSURIZER LEVEL INDICATORS - Currently the ANO-1 pres-surizer level indicators are safety grade, qualified, and powered from safety buses. Therefore, we meet this recommendation and no modifications are necessary.
Response - ANO-2 PRESSURIZER HEATERS - CE is performing an evaluation to determine the number of heaters required and the time in which they are required to assure proper control for natu-ral circulation following a Loss of Offsite Power. This evaluation is scheduled to be complete by November 30, 1979.
Currently 300 Kw of pressurizer heaters are powered from safety buses (150 Kw on each bus). These are shed when the Diesel Generators are supplying safety power.
We will provide the capability to reenergize 150 Kw from each safety bus (when the Diesel Generators are supplying safety power) with appropriate procedures and training by January 1, 1980. Should CE's t
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4 evaluation indicate more than 150 Kw 'T required, we will provide that additional capacity as soon as possible but may not be able to complete it by January 1, 1980, due to the schedule of CE's response. Every effort will be made to comply with your January 1, 1980, schedule.
POWER OPERATED RELIEF VALVE - The ANO-2 design does not incorporate a PORV and associated block valve, therefore no modifications are necessary.
PRESSURIZER LEVEL INDICATORS - Currently the ANO-2 pressurizer level indicators are safety grade, quali-fied, redundant, and powered from safety buses. There-fore, we meet this recommendation and that no modifications are necessary.
Recommendation 2.1.2 - Performance Testing for BWR and PWR Relief and Safety Valves.
Response ANO-1 and 2 AP&L is committed to proorams currently underway by B&W and CE to provide i at and support to an industry wide qualification progsam (EPRI). Every effort is being made to support and encourage these programs and to meet your recommended schedule.
Recommendation 2.1.3.a - Direct Indication of Power Operated Relief Valve and Safety Valve Position for PWRs and BWRs.
Response -ANO-1 and 2 We currently have on order acoustic monicoring devices which will provide positive indication ar.d anrunciation of an open valve. These will be installed immediately downstream of the two pressurizer code safeties and the PORV on ANO-1 and immediately downstream of the two pressurizer code safeties (ANO-2 does not have a PORV) on ANO-2.
These devices, procured from B&W,.are the only ones avail-able to our knowledge. They are manufactured from the best available equipment. The preamps are the same type used in the TMI-2 acoustic monitoring system which survived longer than most electrical equipment in the TMI-2 Reactor Building thereby demonstrating a substantial degree of qualification.
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The units have been seismically tested and are single failure proof, testable, and will be supplied safety grade power. They do not, however, have sufficient QA documentation to classify them as safety grade and cannot be classified as qualified.
We are investigating generic qualification of the units and will report the results of our investigation and a schedule for qualification, if feasible, by January 1, 1980.
These devices will not be delivered to AP&L until January 30, 1980. This is the most expedited schedule achiev-able. Due to this constraint, and the fact _ an outage is required, installation will be complate in May 1980.
Recommendation 2.1.3.b - Instrumentation for Detection of Inadequate Core Cooling in BWRs and PWRs.
Response - ANO-1 AP&L is committed to a B&W program which will determine what additional instrumentation, if any, is needed for detection of inadequate core cooling. Due to the 's igni-ficant and thorough scope of this effort, instrument re-quirements, conceptual designs, and generic procedures will be submitted to you by April 1, 1980. This is the most expedited schedule. We will develop appropriate plant specific procedures and provide training within 60 days of completion of this effort.
Every effort will be made to install instrumentation +
determined necessary by the above evaluation by January 1, 1981, subject to equipment availability and NRC reviews.
These modifications, if applicable, will include an unambiguous indication of Reactor Vessel Water Level.
We have ordered two redundant, safety grade, primary coolant saturation meters which will provide, in the Control Room, on-line indication of coolant saturation condition. In the interim, these meters will derive their RCS temperature indication from wide range, non-safety grade temperature inputs. Safety grade, wide range temperature inputs are being designed and equipment and will be delivered in May 1980. The saturation meters will be installed by. January 1,.1980, and upgraded to com-pletely safety grade utilizing the wide range inputs in May 1980.
Response - ANO-2 AP&L is committed to a CE program which will determine what additional instrumentation, if any, is needed for detection of inadequate core cooling. Due to the significant and thorough scope of this e f.f o r t , instrument requirements, conceptual designs, and generic procedures will not be }f)2
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t submitted until March 1, 1980. This is the most expedited schedule. Provided the scope of this effort is not beyond our expectations, we will develop appropriate plant specific procedures and provide training within 60 days of completion of this effort.
Every effort will be made to install instrumentation deter-mined necessary by the above evaluation by January 1, 1981, subject to equipn;nt availability and NRC reviews. These modifications wii.. include an unambiguous indication of Reactor Vessel Water Level.
we have ordered two redundant, safety grade, primary coolant saturation meters which will provide, in the Control Room, on-line indication of coolant saturation condition. In the interim, rhose meters will derive their RCS temperature in-puts from isolated outputs from narrow range, safety grade measurements. Wide range, safety grade temperature inputs will be delivered in May, 1980. This is our most expedited schedule.
The saturation meter will be installed by January 1, 1980, and upgraded to utilize the wide range temperature inputs by May, 1980.
Recommendation 2.1.4 - Containment Isolation Provision for PWRs and BWRs.
Response - ANO-1 Our response to IE Bulletin 79-05A (dated April 16, 1979) identified all essential and non-essential systems and committed to provide diverse containment isolation signals and modifications which we believe will conform to your recommendations. B&W is currently avaluating our proposed modifications to assess their effectiveness.
These modifications require detailed information of internal cabinet wiring which must be supplied by Bailey Meter Company to assure compatibility with existing designs and equipment supplied by them. Although Bailey Meter Company is currently on strike, we are working with B&W to obtain the required in-formation. Presently, we anticipate meeting your schedule of January 1, 1980, however, items such as connectors and wiring which are supplied by Baile3 2ay cause a delay in implementation due to the current strike. Should our schedule status change, you will be promptly notified.
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Response - ANO-2 Our response to IE Bulletin 79-06B (August 16, 1979) identified all essential and non-essential systems and committed to provide certain modifications which we believe will conform to your rec-ommendations. CE is currently evaluating our proposed modifications to assess their effectiveness. We anticipate these modifications will be implemented by January 1, 1980.
Recommendation 2.1.5.a - Dedicated Penetrations for External Recombiners or Post-Accident .arge Systems.
Response - ANO-1 ANO-1 has currently installed redundant, safety grade, and dedicated hydrogen purge systems. Therefore, this recommendation is satisfied by the existing design.
Response -ANO-2 ANO-2 has currently installed redundant, safety gra;e, and dedicated hydrogen purge systems as well as redundant and safety grade in containment hydrogen recombiners.
Therefore, this recommendation is satisfied by the existing design.
Recommendation 2.1.5.b - Inerting BWR Containments Response - ANO-1 and 2 ANO-1 is a B&W PWR design and ANO-2 is a CE PWR design, therefore, this recommendation is not applicable to these units.
Recommendation 2.1.5.c - Capability to Install Hydrogen Recombiner at each Light Water Nuclear Power Plant.
Resoonse - ANO-1 and 2 We are currertly re-evaluating our procedures for use of hydrogen p u r f.e (ANO-1), and hydrogen purge and recombiners (ANO-2) to assess their effectiveness in view of information from TMI-2 and NUREG-0578. These procedures will be modi-fied as appropriate and training provided on the modifica-tions by January 1, 1980. .
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Recommendation 2.1.6.a - Integrity of Systems Outside Containment likely to Contain Radioactive Materials (Engineered Safety Systems and Auxiliary Systems) for PWRs and BWRs.
Response - ANO-1 and 2 AP&L is in the process of developing a program to implement these recommendations. The program is expected to be organized as follows.
- 1. Define all safety and aux 111.~ry systems outside containment which could potentially contain high radioactivity following an accident.
- 2. Define the a c c 2.d e r *. boundaries of each of these systems.
- 3. Perf.orm a visual inspection of each of these systems to identify system features which could provide leakage p a-t h s for radioactive material (i.e. valve packings, flanges, valve bonnets, pump seals, etc.).
- 4. The items identified in 3 above will be reviewed to determine for testability for leakage and for potential design improvements to reduce leakage.
In these cases where testing is impractical, an inspection program will be implemented.
- 5. Test procedures will be prepared to run periodic tests of each system for leakage and to measure leakage where practical. Results of the first test will be reported to NRC.
- 6. Preventative maintenance schedules will be devel-oped for those items having a high potential for leakage based on our operating experience.
- 7. The methods outlined in steps 1, 2, and 3 have begun and are expected to be complete in January 1980. Based on the review (step 4) a schedule will be developed and forwarded to NRC for com-pletion of steps 5 and.6. Step 4 is expected to be completed in March 1980. This is our most expedited schedule.
Recommendation 2.1.6.b - Design Review of Plant Shielding of Spaces for Post-Accident Operations.
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Response - ANO -1 amd 2 A design review of plant shielding in areas that may con-tain radioactive material following an accident is cur-rently underway. Results of this review will be completed and forwarded to you along with any identified feasible design modifications by January 1, 1980. Those modifi-cations will be completed by January 1, 1981, subject to equipment availabi.1'.:y and NRC reviews.
Recommendation 2.1.7.a - Automatic Initiation of the Auxiliary Feedwater System for PWRs.
Response - ANO-1 The IE Bulletins and the Commission's Confirmatory Shutdown Orders for B&W designed plants dealt with improved Auxiliary Feedwater System Reliability. It is our understanding that, since ANO-1 previously addressed these items, this NUREG-0578 item is not applicable to ANO-1 and that no response is required.
Response - ANO-2 The ANO-2 Emergency Feedwater System is designed to meet Branch Technical Position 10-1 Rev. 1. The system is redundant, safety grade, and meets single failure requirements. .
Therefore, our existing system meets this recommendation in-clusive of the long-term item and that no modifications are required.
Recommendation 2.1.7.b - Auxiliary Feeowater Flow Indica-tion to Steam Generators for PWRs.
Response - ANO-1 Currently ANO-1 has non-safety grade flow indication of emergency feedwater flow to the steam generators.
We will, by January 1, 1980, upgrade this indication to provide redundant indication of flow to each steam generator which will derive power from a safety power source with appro-priate qualified, safety grade isolation. We will upgrade this .
indication to full safety grade by January 1, 1981.
Response - ANO-2 The ANO-2 Emergency Feedwater System is designed to meet BTT 10-1 Rev. 1 and as such currently meets this recommendation, Therefore, no modifications are necessary. r
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4 Recommendation 2.1.8.a -
Improved Post-Accident Sampling Capability.
Response - ANO-1 and 2 Currently we are reviewing all appropriate designs and procedures to assure the feasibility of sampling and analyzing reactor coolant and containment atmosphere .
under accident conditions. These reviews will be completed and a report forwarded to you describing the review and recommending corrective actions, as appropriate, by January 1, 1680. The identified corrective actions will be implemented by January 1, 1981, subject to equipment availability and NRC review.
Recommendation 2.1.8.b - Increased Range of Radiation Monitors Response - ANO-1 and 2 Currently ANO-2 has installed two post accident, safety grade, radiation monitors capable of indicating and re-cording to 107 R/hr. However, these monitors are not qualified. They have been involved in a qualification program since 1976 and have yet to meet qualification requirements. Modifications have been made and the monitors are about to begin qualification testing again.
This qualification testing is currently scheduled to be completed by June 1980.
Provided this qualification testing is successful, we will provide two safety grade, qualified monitors in both ANO-;
and ANO-2, with one channel recorded in each unit. This should be provided by January 1, 1981, subject to success of the qualification program and availability of equipment.
We will install noble gas effluent monitoring equipment with an upper range of 105 (ci/cc (Xe-133). Monitors are to be provided for the Radwaste Area Stack, Fuel Handling Arec Stack and the Reactor Building Stack on ANO-1 and for the Fuel Handling Area Vent, Radwaste ,
Area Vect, Containment Purge and the Auxiliary Building Extension Vent on ANO-2. These monitors will be powered from a safety grade source.
We are currently evaluating designs and investigating types and availability of monitors. The best schedule we have been able to obtain supports a delivery date of April 1981.
Due to this delivery problem and the length of ins'talla-tion, these monitors will not be installed until June 1981.
This is our most expedited schedule.
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Capability currently exists to perform spectral analysis of all iodine and particulate filters. Therefore, we currently meet the iodine recommendation.
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- Recommendation 2.1.8.c - Improved In-Plant Iodine In-strumentation.
Response-ANO-1 and 2 Currently we have nine portable air samplers and procedures for obtaining and performing spectral snalyses on these samples. Therefore, we currently satisfy this recommendation.
Recommendation 2.1.9 - Analysis and Design of Off-Normal Transients and Accidents.
- 1. Small Break LOCA analysis and preparation of emergency procedure guidelines.
- 2. Implementation of small break LOCA emer-gency procedure guidelines.
- 3. Analysis of inadequate core cooling and preparation of emergency procedure guide-lines.
- 4. Implementation of emergency procedures and retraining related to inadequate core cooling.
- 5. Analysis of accidents and transients and prep-aration of emergency procedure guidelines.
- 6. Implementation of emergency procedures and retraining related to accidents and transients.
- 7. Analysis of LOFT small break tests.
Response - ANO-1
- 1. The analyses have been performed, emergency pro-cedure guidelines prepared, procedures modi-fied, and training provided.
- 2. E=ergency procedures have been modified and operator ,
training has been provided.
- 3. These anclyses and procedural guidelines are being prepared as our response to IE Bulletin 79-05C Item 5 and will be provided to us by B&W by October 31, 1979.
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- 4. Emergency procedures will be modified and operator training provided based on the results of Item 3 above by January 1, 1980.
5 We are participating in a generic B&W program to address t tis item. As presented to members of the NRC staff in a meeting with the B&W Owner's Group on September 13, 1979, the Abnormal Transient Operating Guidelines (ATOG) Program is an indepth and thorough effort to develop plant specific operational guidelines. These guidelines will in turn be used to develop detailed emergency procedures for a broad spectrum of abnormal transient events.
Due to the detailed nature of the ATOG Program (i.e, use of event trees, safety sequence diagrams, and system auxiliary diagrams), as described in the September 13, 1979 meeting, ANO-1 (the lead plant) will have draft guidelines from B&W by February 22, 1980, and will have final guidelines by March 14, 1980.
- 6. Plant specific procedures and operator training based on the results of Item 5 above will be completed within 3 months of completion of item 5.
- 7. AP&L is committed to a generic B&W program to analyze the LOFT small break tests. As discussed with the staff by the B&W Owners Group in a September 13, 1979, meeting, th : results of this analysis will be available by January 15, 1980. This is currently our most expe-dited schedule based on the scheduled workload of B&W personnel.
Response - ANO-2
- 1. The analyses have been performed, generic emergency proce-dure guidelines prepared and submitted to NRC for review.
- 2. Plant specific emergency procedures will be prepared and implemented within 3 months of NRC approval of the generic guidelines in 1 above.
- 3. These analyses and procedural guidelines are being ,
prepared as our response to IE Bulletin 79-06C Item 5 stated and will be provided by October 31, 1979.
- 4. Emergency procedures will be modified and operator training provided based on the results of Item 3 above by January 1, 1980.
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- 5. AP&L is committed to a generic CE effort to address this item. Due to the inat th nature of this effort it was necessary to separats the effort into two parts.
a) Analyses of all FSAR Chapter 15 events will be completed by February, 1980.
This is our most expedited schedule.
b) Analyses of remaining events will be completed by September, 1980. This is our most expedited schedule.
- 6. Plant specitic procedures and operator training will be completed within 3 months following completion of each Section of Item 5.
- 7. AP&L has committed to a generic CE program to analyze the LOFT small break tests. The results of these analyses will be completed and forwarded to you in December 1979.
Recommendation 2.2.1.a - Shift Supervisor's Responsi-bilities.
Response - ANO-1 and 2 Once per year, the Vice-President, Generation and Construction, will issue a management directive to the personnel primarily responsibile for plant operations and safety, which will emphasize that the primary management responsibility of the shift supervisor is for the safe operation of the plant. This directive will also clearly establish the shift supervisor's command duties under all plant conditions. The first of such directives will be issued on or before January 1, 1980.
Plant procedures are being reviewed and modified, as appro-priate, to assure that the duties, responsibilities, and authority of the shift supervisor and control room opera-tors are properly defined to effect the establishment of a definite line of command and clear delineation of the command decision authority of the shift supervisor in the Control Room relative to other plant management personnel.
Particular emphasis is being placed on the following:
- a. The responsibility and authority of the shift supervisor is to maintain the broadest per-spective of operational conditions affecting the safety of the plant as a matter of highest priority at all times when on duty in the Control Room.
The idea vill be reinforced that the shift super-visor should not become totally involved in any single operation in times of emergency when 15 s s ?c'3 f)b
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- b. The. shift supervisor, until properly relieved, will remain in the Control Room at all times during accident situations to direct the activi-ties of Control Room operators. Persons authori-zed to relieve the shift supervisor shall be specified.
- c. If the' shift supervisor is temporarily absent from the Control Room during routine operations, the Plant Operator who is the lead control room operator will be designaced to assume the Control Room command function. These temporary duties, responsibilities, and authority will be clearly specified.
Training programs for shift supervisors will emphasize and reinforce the responsibility for safe operation and the management function the shift supervisor is to provide for assuring safety.
The administrative duties of the shift supervisor will be reviewed by the Director of Generation Operations. Admini-strative functions that detract from or are subordinate to the management responsibility for assuring the safe operation of the plant will be delegated to other operations per-sonnel not on duty in the Control Room.
Procedures to implement the above will be completed and training provided by January 1, 1980.
- * * * ** * * * * * * * * * * * *
- k * * * * ** * * *
- Recommendation 2.2.1.b - Shift Technical Advisor Response - ANO-1 and 2 Beginning January 1, 1980, AP&L will provide a Shift Technical Advisor at Arkansas Nuclear One available to be called to the Control Room and capable of being in the Control Room within 10 minutes or less upon receiving a call.
This individual will be available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day for each unit except when both units are in a cold shutdown condition.
His primary duty will be to assist the control room operators in
" accident assessment".
The " experience assessment" function, described in Attachment 2 of your September 13, 1979 letter, will be performed by the Arkansas Nuclear One plant staff (plant performance group).
11 Eh5 001 16
Du.ing normal working hours, the Shift Technical Advisor duties will be assigned to a qualified individual on-site who will perform his normal duties provided these duties will allow response to the Control Room in 10 minutes.
Should it be required, his Shift Technical Advisor duties will supercede his normal duties.
We are evaluating your training recommendations for the Shift Technical Advisor as well as participating .
in industry efforts to further define appropriate training and optimize use of this individual. We have not, at this time, completed our evaluation or formalized a training program. We are devoting our maximum efforts to this area in a sincere effort to complete full training of these individuals by January 1, 1981. We will provide you a description of our program and a schedule for completion of training by January 1, 1980.
We believe that this is an effective and efficient method of fulfilling thi.s vital function and that this method meets the intent of this recommendation.
Recommendation 2.2.1.c - Shift and Relief Turnover Proce-dures.
Response - ANO-1 and 2 AP&L is in the process of reviewing and revising, as appropriate, plant procedures for shift and relief turnover. These revised procedures will be consistent with the clarification of this recommendation provided at cur Regional Meeting.
- 1. Procedure (s) will be provided for the oncoming and offgoing control room operators and the oncoming shift supervisor to assure a complete and effective turnover. The following items will be included in the procedure (s):
- a. Assurance that critical plant parameters are within allowable limits;
- b. Assurance of the availability and proper alignment of all systems essential to the prevention and mitigation of operational transients and accidents;
- c. Identification of syste=s and components that are in a degraded mode of operation permitted by the Technical Specifications.
17
For such systems and components, the length of time in the degraded mode will be com-pared with the Technical Specifications action statement;
- 2. Procedure (s) will be provided to assure a com-plete and effective turnover by the offgoing to the oncoming auxiliary operators and technicians.
These procedure (s) will address any equipment under maintenance or test that by themselves could degrade a system critical to the prevention and mitigation of operational transients and accidents or initiate an operational transient; and
- 3. A system will be established to evaluate the effectiveness of the shift and relief turnover procedure (for example, periodic independent verification of system alignments).
The reviews, modified procedures, and training will be completed by January 1, 1980.
Recommendation 2.2.2.a - Control Room Access Response - ANO-1 and 2 AP&L is reviewing'the plant procedures for Control Room access. We will implement procedures whic:. will limit Control Room access during an emergency. These procedures will include the following:
- 1. Administrative procedures that establish the authority and responsibility of the person in charge of the Control Room to limit access.
- 2. Procedures that estublish a clear line of authority and responsibility in the Control Room in the event of an emergency. The line of succession for the person in charge of the Control Room will be established and limited to persons possessing a current senior reactor operator's license. The plan will clearly define the lines of communication and authority for plant manage-ment personnel not in direct command of operations, including these who report to stations outside of the Control Room.
These procedures will be implemented and training provided by January 1, 1980.
1186 003 18
Recommendation 2.2.2.b - On-site Technical Support Center.
Response - ANO-1 and 2 We will, by January 1, 1980, designate an on-site Technical Support Center consistent with the clarification of this recommendatior. provided in our Regional Meeting. That is:
- 1. Close proximity to the Control Room
- 2. Designated as the Engineering and Management Support Center during emergencies.
- 3. Dedicated communications link to the Control Room.
- 4. There will be no capability for plant mani-pulations from the Center.
We have been working for several months on a revised Emer-gency Plan for ,ANO which addresses problem areas identified at TMI-2. Incorporated in this plan is the On-site Techni-cal Support Center. The plan has been finalized in-house and will be transmitted to NRC for review by the NRC Emergency Planning Team. Provided the Emergency Planning Team concurs with our proposal, we will make every effort to implement it by January 1, 1981. However, it does require construction of additional buildings and procurement of substantial equipment which could delay final implementation. We will, however, exercise our best effort as we believe this plan and the support centers therein are essential and meet your recommendations.
Recommendation 2.2.2.c - On-site Operational Support Center.
Response - ANO-1 and 2 We will, by January 1, 1980, designate an On-site Operational Support Center consistent with the clarification of this recommendation provided in our Regional Meeting. That is:
- 1. A designated area separate from the Control Room.
- 2. Set up for Operations Support Personnel.
- 3. Communications with Control Room and On-site Technical Support Center.
- 4. Not necessarily a separate dedicated room or center.
1186 004 19
As discussed in our response to Recommenda, tion 2.2.2.b above, the On-site Operational Support Center is included in our pro-posed revised Emergency Plan and will be implemented consistent with our response to Recommendation 2.2.2.b above.
Recommendation 2.2.3 - Revised Limiting Conditions for Operation of Nuclear Power Plants Based Upon Safety System Availability.
Response - ANO-1 and 2 No response is necessary as per Item a. above.
Near Term Requirements For Improving Emergency Preparedness Item 1 Upgrade licensee emergency plans to satisfy Regulatory Guide 1.101, with special attention to the development of uniform action level criteria based on platt parameters.
Response - ANO-1 and 2 AP&L has been developing the bases for a revision to the ANO E'mergency Plan based on experienc.e from TMI-2. This information will be submitted to our Emergency Pls iewer orior to his plant specific review of AN0's Emergency _an. We have be_a working and will continue to work closely with the NRC Emergency Planning Review Group and will revise the ANO Emergency Plan as appropriate based upon their review and in accordance with the established schedule.
Item 2 Assure the implementation of the related recomtendations of the Lessons Learned Task Force involving instrumentation to follow the course of an accident and relate the information provided by this instrumentation to the emergancy plan action levels. This will include instrumentation far post-accident sampling, high range radioactivity monitors. and improved in-plant radioiodine instrumentation. The implementation of the Lessons Learned Task Force's recommendations on instrumentation for detection of inadequate core cooling will also be factored into the emergency plan action level criteria.
Resoonse - ANO-1 and 2 Instrumentation installed for detection of inadequate core cooling as per our response to Recommendation 2.1.3.b will be factored into the ANO Emergency Plan action level criteria.
20 1186 005
- * * * * * * * * * * * * * * * * * * * * * * * *
- f * * * * *
- Item 3 Determine tha <a emergency operations center for Federal, State end Local paracanel has been established with suitable communica-tions to the plant, and that upgrading of the facility in accordance with the Lessons Learned Task Force's recommendation for an in-plant technical support center is underway.
Response - ANO-1 and 2 An Emergency Operations Center currently exists for Federal, State, Local AP&L personnel. These facilities are in the process of being upgraded, the details of which will be provided in the revised ANO Emergency Plan.
Hardwired and wireless communications with off-site agencies currently exist and are being upgraded as in the above paragraph.
Plans for a Technical Support Center are under development, the details of which will be provided in the revised ANO Emergency Plan.
Item 4 Assure that improved licensee off-site monitoring capabilities (including additional thermoluminescent dosimeters or the equiv-alent) have been provided for all sites.
Response - ANO-1 and 2 Our current off-site monitoring capability consists of 7 TLDs around the site. Our revision to the ANO Emergency Plan will upgrade this capability by the addition of approximately 30 TLDs as well as the capability of aerial surveillance.
Item 5 Assess the relationship of State / Local plans to the licensees' and Federal plans so as to assure the capability to take appropriate emergency actionr. Assure that this <apability will be extended to a distance of ten miles. This item will be performed in conjunction with the Office of State Programs and the Office of Inspection and Enforcement.
Response - ANO-1 and 2 AP&L has worked closely with state and local agencies in the past and has developed an excellent working relationship with these agencies. The State of Arkansas has a " concurred in" state Emergency Plan which currently includes a 10 mile Emergency 1186 006 21
4 Planning Zone. We are working closely with these agencies as we upgrade AN0's Emergency Plan to provide compatibility of the various plans.
Item 6 Require test exercises of approved emergency plans (Federa?.,
State, Local and licensees), review plans for such exerciscs, and participate in a lisited number of j oint exercises. Tests of licensee plans will se required to be conducted as soon as practical for all facilities and before reactor startup for new licensees. Excercise of Statt plans will be performed in conjunction with the cencurrence reviews of the Office of State P r o ,o r a m s . As a preliminary planning bases (sic), assume that joint teet exercises involving Federal, State, Local and licensee will be conducted at the rate of about ten per year, which would result in all sites being exercised once each five years. Revised planning guidance may result from the ongoing rulemaking.
Response - ANO-1 and 2 AP&L currently exercises AN0's Emergency Plan approximately once per year by conducting a test with State, Local, and Federal agencies. This test normally exercises every aspect of the emergency response short of public participation inclusive of actual response to the site with equipment. We will continue to exercise on this same frequency and will revise our testing procedures to testing exercises in-orporating all your recommen-dations at least once every 5 years as deemed appropriate by the Emergency Plan Review Team.
1i86 007 22
IMPLEMENTATION SCHEDULE 1979 OUTAGE December 1979 Outage 2 .1.1 Emergency Power Supplies to Pressurizer Heaters (Units 1 or 2)
Emergency Power to PORV Block Valve (Unit 1).
2.1.3.b Margin to Saturation Meters With Nonsafety Grade Temperature Inputs. (Units 1&2).
2.1.4 Containment Isolatin of ES Actuation (Units 2& 2).
2.1.7.b Add Redu.adant Nonsafety Grade Trains to E"W Flow Indication (Unit 1).
2.1.7.a. Control Grade Auto Initiation of EFW (Unit 1).
May 1980 Outage 2.1.3.a Safety Grade PORV (Unit 1) and Safety Valve Position Indication (Units 1&2).
2.1.3.b Upgrade Temperature Inputs to Tsat Meters to Safety Grade (Units 162).
2.1.7.b Upgrade EFW Flow Instrumentatien to Safety Grade (Unit 1).
December 1980 Outage 2.1.3.b RV Level Indication 2.1.6.b. Plant Shielding Imprevements 2.1.7.a Safety Grade Auto. EFW Initiation 2.1.8.a Post Accident Sampling Systen 2.1.6.b High Range Radiation Monitors Containment Water Level Monitors Containment Hydrogen Monitors RCS Vents 1186 008 23
DEFINITIONS
- 1. Safety Grade - Meets the applicable design basis requirements for " safety grade" which are based on and meet the intent of these positions or revirions to IEEE-279 which are applicable to each unit.
- 2. Qualified - Environmentally qualified to the Design Basis requirements for the appropriate unit as appli-cable.
1186 009 24
1980 1981 Oct flov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Ju Item d - Increase Range of Containment Pressure Indications ANO-1 X ANO-2 X Item d - Increase Range 01 Containment i Water Level Indicators ANO-1 X ANO-2 X Item d ,- Increase Range of Ilydrogen Analyzers ANO-1 X ANO-2 j X Item e - Remotely operable liigh Point vents.
ANO-1 Generic Design X Impl er.icn t ANO-2 Generic nesign X Implement R-2.1.1 - Energency Power PER. Ileaters - ANO-1 X ANO-2 evaluation X implement X POPV- ANO-1 black valve X
- ANO-2 -NA CD P ER . I.evel Indicators O'
ANO-1 NA
(([ ANO-2 NA a
1980 1981 Oct Nov Dec Jan Feb Mar Apr May Jun Jul Auq Sep Oct Nov Dec Jan Feb liar Apr flav Jun R-2.1.2 - Relief Valve Testi .
ANO lip 11 I Scil fiDtJL li ANO lip RI Scil liDill, li R-2.1.3.a - Direct Indication of Relief Valve Position ANO-1 delivered X installed X qualified NOT A VA1 I.A B l .fi ANO-2 delivered X installed X qualified NOT A VAI LAB l.li R-2.1.3.b - Inadequate Core Cooling ANO-1 generic procedures X plant specific proce-dures X instrumentation X ANO-2 generic procedures X plant speci fic procc-dures X instrumentation X Primary Coolant Saturation Meters ANO-1 installed X
- safety grade X
- ANO-2 CC installed X O' wide range X CD I.
1980 1981
~
Oct Nov Der Jan Feb flar Apr flav Jun Jul Auq Sep Oct Nov Dec Jan Feb f4ar Apr flav Jus R-2.1.4 - Containment Isolatic ANO-1 modified X ANO-2
- r. adi fi ed X R-2.1.5.a - Ilydrogen Purge ANO-1 C071 P l.E Tl!D ANO-2 COM P l.E TED R-2.1.5.b - Inerting BWR Containments ANO-1 f. 2 NOT APP I.lC Alli.li R-2.1.5.c - Ilydrogen Recombiners ANO-1 evaluate procc- ,
dures X ANO-2 evaluate procc-dures X R-2.1.6.a - Integrity of Systems ANO-1 f 2 visual inspec-tion X review for improvements X test procedures
-- ^
and preventa- ,
tive mainten-Q ance N t, . AV/ 11. AB LI Os C)
I
1980 1981 -
Oct Nov Dec .lan Feb Mar Apr May Jun Jul Auq Sep Oct Nov Dec .lan Feb Mar Apr May Ju R-2.1.6.b - Plant Shielding ANO-1 f. 2 review X moJifications X R-2.1.7.a - AFW Initiation ANO-1 COM P l.li Tl!
ANO-2 COM Pl.li Tl!
R-2.1.7.b - AFW Flow Indication ANO-1 safety grade X ANO-2 COM Pl.li Tl!
R-2.1.8.a - Post-Accident Sampling ANO-I f 2
-review X modifications X R-2.1.8.h - Radiation Monitors ANO-I f, 2 X R-2.1.8.c - lodine Instrumentation ANO-1 fi2 COM P l.1 Tl!
R-2.1.9 - Off-Normal Transients ANO-1
- 1) COM Pl.I Tli
- 2) COM Pl.1 Tli
- 3) X
- 4) X to 5) generic X Os plant speci fi. X
- 6) X c_D 7) X
1980 1981
- Oct Nov Dec slan Feb Mar Apr May Jun Jul Auq Sep Oct flav Dec Jan Feb Mar Apr May Ju ANO-2
- 1) 3 MON Til FRG HN RC API ROV AI,
- 2) 3 MON Til FR0 MN RC API R0l' A I,
- 3) X
- 4) X
- 5) chapter 15 X other X
- 6) X
- 7) X R-2.2.1.a - Shift Supervisor Respon-sibilities ANO-1 f 2 Management Directive X- YEA RI,Y Prcredures X R-2.2.1.b - Shift Technical Advisor ANO-1 6 2 Interim X Schedule for completion of training X R- 2.2.1.c - Sh i f t Turnover Procedures
- ANO-1 6 2 procedures X R-2.2.2.a - Control Room Access ANO-1 f 2
- procedures X Os C3
1980 1981
- Oct flov Dec Jan Feb Mar Apr May Jun Jul Auq Sep Oct Nov Dec Jan Feb Mar Apr May Jul R-2.2.2.h - Technical Support Center ANO-1 f. 2 Interim X Final X R-2.2.2.c - Operational Support Cent 3r -
ANO-1 f. 2 Interim X Final X R-2.2.3 - Limiting Conditions for Operations ANO-1 f. 2 NOT APP 1,I C Aill.E -
EMERGl!NCY PREPARDNESS Item 1 .teg. Guide 1.101 ANO-1 T, 2 X Item 2 - Action Level Criteria ANO-1 f 2 1:01. l.0W ING C0ftP I. lit 10N 01: Il - 2 . 1.3. b Item 3 - Operations Center ANO-1 f, 2 Interim COM PLl! TI!D
- Final X Os b
, I
1980 1981 *,
Oct flov Dec Jan Feb llar Apr fhy Jun Jul Auq Sep Oct flov Dec Jan Feb !iar Apr ffay Ju Item 4 - Offsite blonitoring ANO-1 6 2 Interim t:0P! l'I.li TliD 1inal X Item 5 - 10 Ptile EPZ ANO-1 f 2 C0tt Pl.E Ti!D Compatibility ANO-1 6 2 existing plans COPI l'I.li TED upgraded plans X Item 6 - Test Exercises ANO-1 6 2 Al'I' ROX IPIA Tlil.Y YliA RI.Y c,s C
Os