ML19296C574
| ML19296C574 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 02/22/1980 |
| From: | Peoples D COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8002260672 | |
| Download: ML19296C574 (12) | |
Text
Commonwealth Edison One First National Pl3za. Chicago. I!! rois Address Reply to: Post Office Box 767 Chicago. lilinois 60690 February 22, 1980 Dr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Zion Station Units 1 and 2 Proposed Interim Actions NRC Docket Nos. 50-295 and 50-304
Dear Dr. Denton:
Per our discussions and understanding with you and members of your staff, Commonwealth Edison Company proposes to take, at Zion Station, the interim actions stated in Appendix A to this letter.
These actions shall be implemented in the indicated time frames after receipt of an NRC con-firmatory order.
'lery truly yours,
- f. h vt
- 1.
D.
L.
Peopl o Director of Nuclear Licensing Attachment.
P%
I
\\
i 2
8002260
.4
4 Appendix A A.
Commonwealth Edison Company shall:
1.
Maintain reactor power level as necessary such that calculated fuel peak clad temperature does not exceed 20500F under large break LOCA conditions per the 10CFR50 Appendix K analysis submitted on October 22, 1979.
2.
Revise plant operating procedures as necessary to require a base load mode type of operation only, without load following, except for power reductions required to mairtain system load and grid stability, for maintenance (e.g., con-tainment entry, main feed pump repairs, etc.) or as required by Technical Specifications.
3.
Conduct a low pressure gross leak test of containment prior to any start up from cold shutdown conditions as indicated in Attachment A.
If other means can be found to verify containment integrity, Commonwealtn Edison may propose such procedures to the Commission for its review and approval.
4.
Maintain at least two senior reactor operators (SR0s), one of whom may be the shift supervisor, in the control room at all times during power operations or hot shutdown, except that the shift supervisor shall be allowed to leave the immediate vicinity of the control room as duties may require, provioed he is available to respond to an emergency by returning to the control room within ten minutes.
The shift or watch supervisor's office is considered part of the control room.
5.
Conduct testing to assure that the LPI/RHR check valves are, in fact, installed correctly and functioning as pressure isolation barriers when the plant is at pressure and producing power.
Verification of valve operability shall be performed prior to plant restart if shutdown at the time of issuance of *
- Order and thereafter whenever RCS pressure has decreat co within 100 psig of RHR system design pressure.
6.
Submit not later than March 1, 1980, the results of a review of possible permanent plant modifications and procedures to further reduce the potential of a severe reactor accident and resultant radiation releases.
7.
Require that all reactor operators and senior reactor operators conduct simulator training and in-plant walk through of the following emergency procedures.
Due to Commonwealth Edison's large operating staff, the in-plant walk-throughs shall be completed prior to the next reactor startup following issuance of the Order, or within sixty
. days of the date of issuance, whichever occurs first.
Those reactor operators and senior reactor operators who have not received simulator training within the past four months on these items shEll be given such simulator training within ninety days of the date of the Order:
a.
Plant or reactor startups to include a range wherein reactivity feedback from nuclear heat addition is noticeable and heat up rate is established b.
Manual control of steam generator level and/or feedwater during <3tartup and shutdown c.
Any significant (10%) power change using manual rod contrcl d.
Loss of Coolant (i) including significant PWR steam generator leaks (ii) inside and outside containment (iii) la:ge and small, including leak rate determination (iv) saturated reactor coolant response (PWR) e.
Loss of core coolant flow / natural circulation f.
Loss of all feedwater (normal and emergency) g.
Station blackout h.
Anticipated Transients Without Scram (ATWS) - failure of control rods to insert i.
Stuck open relief valve on secondary side J.
Intersystem LOCA B.
Commonwealth Edison shall implement the following measures within 30 days of the date of the Order:
1.
A vendor representative will be stationed on site for engineering consultation at Zion Units 1 and 2 on plant operations and maintenance to increase plant safety.
The representative shall be from the NSSS vendor, architect /
engineering or start up engineering firm.
2.
To ensure control room habitability under accident conditions, Commonwealth Edison shall reexamine ventilation intakes, location of potential plant leakage (ingress and egress), and control room filter capabilities, and submit the results of this review to the NRC.
. 3.
Emergency action levels shall be revised to require notification of the NRC for all events in the emergency classes described in NUREG-0610, September, 1979.
4.
Commoe.,
n Edison shall comply with the NRC's " INTERIM POSITI0ts fdR CCNTAINMENT PURGE AND VENT VALVE OPERATION PENDING RESOLUTION OF ISOLATION VALVE OPERABILITY", as contained in the October, 1979, letter to Commonwealth Edison and as indicated in the Commonwealth Edison December, 1979, letter to the NRC.
5.
Plant perconnel shall be trained or retrained in the following areas within thirty days, or prior to startup if required by the Lessons Learned implementation schedule.
Plant personnel shall also be retrained in the following areas within thirty days of the time that there are significant changes to the procedures or requirements applicable to these areas:
Containment and Degraded Core Sampling Degraded Core - Training Emergency Power for Pressurizer Heaters and Decay Heat Removal Containment Isolation Containment Purge / Purge Valve Operation Subcooling Meter Operation Technical Support Center Onsite Operational Support Center Near-Site Emergency Operations Center Emergency Preparedness Plan In-Plant Area Airborne Radiciodine Monitors 6.
Commonwealth Edison shall perform diesel generator testing in accordance with Regulatory Guide 1.108 with a corresponding change in the allowable outage time stipulated in the Limiting Conditions of Operation as follows:
Numbers of CG Failures Test Interval (Days)
Allowable In Prior 100 Tests (R.G. 1.108)
Outaae Time 0 or 1 30 As Is 2
14 As Is 3
7 As Is 4
3 32 hr.
5 3
8 hr.
6 or more 3
None*
- Plant must acnieve hot shutdown within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />
_4_
7.
Requirements regarding reactor operator qualifications shall be revised to incorporate the following for applications submitted after June 1, 1980, except for training classes in session at time of issuance of this Order:
a.
The following experience shall be required for senior operator applicants:
Applicants for senior operator license shall have 4 years of responsible power plant experience.
Responsible power plant experience shall be that obtained as a control room operator (fossil or nuclear),
field operator (nuclear) or as a power plant staff engineer involved in the day-to-day activities of the facility, commeicing with the final year of construction.
A maximum of two years' power plant experience may be fulfilled by academic or related technical training, on a one-for-one time basis.
Two years shall be nuclear power plant experience.
At least six months of the nuclear power plant experience shall be at the plant for which the applicant seeks a license.
b.
The hot training programs shall be modified so that the training concentrates on the responsibilities and functions of the operator, rather than the senior operator.
All individuals who satisfactorily complete this hot training program will be allowed tc apply for an operator license.
At least three months' experience as a licensed operator is necessary before applying for a senior operator license.
c.
The three month consecutive on-the-job training for hot operator applicants shall be as an extra person on shift in the control room.
The hot senior operator applicants will have three months consecutive on-the-job training as an extra person on shift in training.
d.
In addition to the presently approved training programs, all replacement applicants shall participate in simulator training programs.
e.
Training center and facility instructors who teach systems, integratec response, and transient and simulator courses siall demonstrate their competence to the NRC by successful completion of an SRO written examination.
Instructors shall be enrolled in appropriate requalification programs to assure that they are cognizant of current operating history, problems, and changes to procedures and administrative limitations.
f.
In addition to the present operator requalification program requirements, all operator licensees shall
Nb
% participate in periodic retraining and recertification on a full scope simulator representative of Zion Units 1 and 2.
The frequency 3f training will be on an annual basis.
C.
Within 60 days of the cate of the Order, Commonwealth Edison shall:
1.
Review the steady state steam generator operating level to determine the optimum steady state level for the purpose of maximizing dryout time with due consideration for overfilling.
The results of this study shall be provided to the NRC.
2.
Evaluate possible co-impregnation of the charcoal in the plant's air effluent filtration systems with KI and I2 and an amine such as TEDA (triethylene-diamine) to improve the iodine removal capability of these systems.
The results of this review shall be submitted to the NRC.
3.
Evaluate effects on plant systems stability if power is reduced as much as 50%, treating power as a parameter.
(For example, the effects on the feedwater flow automatic control).
4.
Submit a schedule to implement the ATWS instrument modification justified in accordance with the Westinghouse analytical results contained in the letter from T.
M.
Anderson to S. H.
Hanauer in NS-TMA-2182 dated December 30, 1979.
5.
Establish an on-site group whose function shall be to examine plant operating characteristics, NRC bulletins, licensing information service advisories and other appropriate sources which may indicate areas for improving plant safety.
Where useful improvements can be achieved, the group shall also deve.'op and report detailed recommendations for revised procedures, equipment modifications or other improvements to offsite management.
D.
The following measures shall be implemented within 90 days of the date of the Order:
1.
Commonwealth Edison shall establish the on-site emergency preparedness manning levels on each shift as contained in Table 1 attached to this Appendix.
. 2.
Commonwealth Edison shall estaolish a temporary on-site inter-disciplinary review group consisting of, as a minimum, representatives frcm the NSSS vendor, the architect / engineer and the plant maintenance and operations staffs.
This group shall review and concur in all existing plant emergency procedures.
This group shall also review and concur in changes to emergency procedures.
Emergency changes may be approved in accordance with current licensee requirements, but shall be subsequently submitted for approval by the review group.
E.
The following measures shall be completed within 120 days of the date of the Order:
1.
Commonwealth Edison shall examine key plant system vulnerability areas and possible operator dependent areas with the intent of maximizing the reliability in the subject areas.
Specifically, Commonwealth Edison shall:
a.
Verify that the sump for ESF recirculation is free of debris and determine if flow test verification was initially performed.
If not performed, explore means to verify.
Review existing prncedures and training on recirculation alignment and RWST refill.
b.
Review administrative eneck and verification procedures for assuring that the two single failure points (manual) valves in AFWS supply line are in the correct position.
c.
Impose an administrative order requiring expeditious shutdown whenever an independent train of the auxiliary feedwater system and any one of the following are inoperable:
All backup sources of offsite power, one of the two diesel generators supplying power to the other independent train or either of the other trains of the auxiliary feedwater system.
d.
Develop station blackout procedures addressing:
1.
grid dispatcher actions 11.
reactor operator actions 111.
diesel generator repairs e.
Assure that DC-powered lighting is available at the steam-turbine driven auxiliary feedwater pump.
f.
Review causes for, and procedures and operator training required to diminish, the overall number of reactor and main feedwater trips.
. g.
Develop or review procedures to restore main feedwater promptly after a trip and to mitigate the consequences of an ATWS event (e.g.,
emergency boration and CVCS control).
h.
Review administrative controls en the manual valve (s) whose misalignment could fail all ECCS.
2.
A review of control room emergency procedures shall be conducted for the purpose of impr'ving these procedures from a human factors engineering standpoint.
Improvements which can be attained by modifying procedures shall be implemented within the 120 days.
Control room displays shall also be reviewed for the purpose of identifying improvements which will increase the operators' ability to assess plant conditions.
A report will be submitted to describe the improvements recommended and the schedule for their implementation.
F.
Within six months of date of the Order, Commonwealth Edison shall:
1.
Conduct a review of past Licensee Event Reports (LERs) at Zio i Units 1 and 2.
These LERs shall be reviewed to identify design inadequacies (common mode failures, systems interactions, etc.), procedural and training inadequacies, and man-machine / human factor inadequacies.
Recommendations shall be submitted for correction of the base cause of the subject LERs.
Immediate corrections of deficiencies will be made when possible, with the required notifications to be made to the NRC.
2.
Meet meteorclogical acceptance criteria for emergency preparednest contained in Annex 1 to this Appendix, pending necessary equipment deliveries and their installation including computer hardware and software modifications.
During the interim period while modifications are being completed, real time forecasting will be available and provided by a consultant.
3.
Conduct a study to determine and document the method by which its plant complies with current safety rules and regulations, in particular those contained in 10 CFR Parts 20 and 50.
4.
Evaluate the reliability and failure modes of selected systems / components as follows:
a.
Failure Mode Effects Analysis:
Examine the failure modes (random failures and consequences of outages ?.n
. support systems) of the active components on the reactor coolant pressure boundary.
Assess the acceptability of these failure modes.
b.
Implement Fsilure Mode Effects Analysis for minor departures from operating, maintenance and emergency procedures.
c.
Explore ways to improve the reliability of those components with a particularly high failure rate as delineated in NUREG/CR-1205.
5.
Attain full compliance with NRC letters concerning AFWS reliability improvements.
Table 1 STAFFING REQUIREMENTS CECO / ZION STATION FOR NUCLEAR POWER PLANT EMERGENCIES Unit in Addition Position Title Operating Mode Within Major Functional Area Major Tasks or Expertise ('
1 or 2 1 & 2 One Hour Plant Operations and Assessment of Shift Supervisor (SRO) 1 1
2(6)) 3(6) 1(2 1(2 Operational Aspects Shift Foreman (SRO)
)
Control Room Operators Equipment Operator /
Attendant 3
4 Emergency Direction and Control Designated Sr. Official 1(2) 1(2)
(Emergency Coordinator)
Shift Supervisor or
~
designated facility manager Notification / Communication Notify licensee, notify 1(2) 1(2) 1 state local and Federal 1(5) personnel & maintain communication Radiological Accident Assessment Command Center (CC) and Support of Operational Director Senior Manager 1(5)
Accident Assessment (3)
CC Offsite Dose Senior Health Physics 1(5)
Assessment (HP) Expertise Offsite Surveys 4(2)
Onsite (out-of-plant) 2(2)
In-plant surveys Chem /Radchem Sampling Rad / Chem Technicians 2
2 3
Radiochemistry Analysis Chemist 1*
Plant System Engineering, Repair Technical Support Shift Technical Advisor 1(2&7) 1(2&7) and Corrective Actions Core
'l Electrical 1
Mechanical 1
Repair and Corrective Mechanical Maintenance /
Actions Rad Waste Operator 1(2) 1(2) 2 Electrical Maintenance /
Instrument and Control (I&C) Technician 1(2) 1(2) 2
Table 1 (Cont'd.)
Unit in Addition Position Title Operating Mode Within-Major Functional Area Major Tasks or Expertise 1 or 21 & 2 One Heur Protective Actions (In-Plant )
Radiation Protection:
Rad / Chem Technicians 2(2) 2(2) 4
- a. Access Control
- b. RCT Coverage for repair and corrective actions.
- c. Personnel monitoring d'.
Dosimetry Firefighting Fire Brigade Local per Technical Support.
Specit'ica tions Rescue Operations and First-Aid 2(2) 2(2)
Local Support Site Access Control and Security, firefighting Security Personnel All per Personnel Accountability communications, per-Security Plan sonnel accountability Total 10 13 25 Minimum (l) 9 12 Notes:
(1)
The minimum number refers only for the case of shift shortage, caused by a sudden sickness or home emergency.
(2)
May be provided by shift personnel assigned other functions.
(3)
Overall direction of facility response to be assumed by nommand Center director when all centers are fully manned.
Director of minute-to-minute facility operations remains with senior manager in onsite technical support center or control room.
(4)
During the weekdays, management, technical support, health physics, chemist, and maintenance personnel are available on-site.
Command Center function.
One of the control room operators may be provided by the other Zion unit or the center desk.
For a multi-unit site this function may be filled by a Shift Supervisor or Foreman, provided all other qualification requirements are met.
Attachment A Commonwealth Edison shall ensure that there is no gross containment leakage prior to any startup from cold shutdown conditions by performing the following actions:
A.
Ensure that containment penetration and weld channel pressurization system leakage is within Technical Specification limits.
The function of the containment penetration and weld channel pressurization system is to prevent leakage of containment air through penetrations and liner welds under all conditions by supplying air above the containment post accident design pressure to the positive pressure zoned incorporated in the penetration and weld channel design.
The system also provides a means of continuously monitoring the leakage status of the containment.
The containment purge valves and airlock door seals are included in this system.
B.
Perform local leak tests of containment isolation valves not included in the following categories:
1.
Those valves continuously pressurized and monitored for leakage by the penetration pressurization system.
2.
Those valves which, under post-accident containment isolation conditions, are expected to be maintained continually at a pressure equal to or greater than the containment peak accident pressure.
Thi's includes valves under isolation valve seal water and those in systems required for post-accident service if such systems operate at pressures above containment peak accident pressure.
,