ML19318A386
| ML19318A386 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/11/1980 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| TASK-1.A.2.1, TASK-2.B.4, TASK-TM TAC-44188, TAC-44189, TAC-44538, TAC-44539, NUDOCS 8006200460 | |
| Download: ML19318A386 (8) | |
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I Win Electnc rom counur 231 W. MICHIGAN, P.o. BOX 2046 MILWAUKEE WI 53201 June 11,1980 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION Washington, D. C.
20555
Dear Mr. Denf.on:
DOCKET NOS. 50-266 AND 50-301 IMPLEMENTATION OF FIVE ADDITIONAL TMI-2 RELATED REC UIREMENTS POINT BEACH NUCLEAR PLAhT, UNITS 1 AND 2 The attached response addresses specifically each item of the May 7,1980, NRC letter to all operating reactor licensees entitled "Five Additional TMI-2 Related Requirements to [For] Operating Reactors". No reply is given for Item i since the separate correspondence which was to be provided by the NRC has not been received.
Recent verbal comunications with NRC Operating Reactors Branch project management indicates that this item has yet to be issued.
In general, the requirements of the letter, its attachments, and stated references which provide a discussion of each item are unclear and not altogether consistent.
In our response to each item, we have, there-fore, stated our position as completely as possible. We have assumed that implementation of these additional requirements are not meant to impede the completion of previous comitments to meet other THI-2 related NRC requirements.
Very truly yours,
.W UW 4 Y
C. W. Fay, Director Nuclear Power Department Attachments Copy to: NRC Resident Inspector fi Point Beach Nuclear Plant (O37 S
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Attachment DOCKET NOS. 50-266 AND 50-301 IMPLEMENTATION OF FIVE ADDITIONAL TMI-2 RELATED REQUIREMENTS P0INTBEACHNUCLEARPLANT, UNITS 1ANb2 i
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Item 1.A.l.3 Shift Manning No response is given at this time since the separate corres-pondence which was to be provided by the NRC has not been received (see the last sentence cf the third paragraph of the May 7, 1980, D. G. Eisenhut letter). Recent verbal communications with NRC Operating Reactors Branch project management indicates that this item has yet to be issued.
Item 1.A.3.1 Revised Scope and Criteria fer Licensing Examinations Specific sub-sections referenced are those of the March 28, 1980 NRC letter to All Power Reactors Applicants and Licensees titled " Qualification of Reactor Operators" and its Enclosure 1
A.
ELIGIBILITY REQUIREMENTS TO BE ADMINISTERED ON EXAMINATION.
1.
Experience a.
WEPCo applicants for SR0 licenses at Point Beach Nuclear Plant (P8hP) submitted on or after May 1,1980 will meet the expuience requirements stated. Power plant experience acceptable for meeting these requirements is understood to include both nuclear Navy training and operations and experimental reactor training and operations. No mini-mum size or rating for a facility is understood to be required. The experience applicants have gained by academic or tEr.hnical training will be applied to either general power plant or nuclear power plant exp rience as appropriate.
In order not to delay the development of professional degree personnel to SR0 qualification or Technical Advisor qualification, all experience which WEPCo employees gain as part of the PBNP Staff will be applied i
to the requirements. This will include technical support, 1
maintenance, training, and operations experience.
b.
Previously licensed or professional degreed applicants qualified per (a) above will not be required to meet the one year R0 requirement. Licenses held at other power plants or nuclear Navy experience are understood to be applicable in meeting the one year minimum time period. A strict application of this requirement would seriously impede the progress of qualified personnel to Shift Supervisor, Technical Advisor, or training positions of responsibility.
2.
Training a.
WEPCo object %ns to the requirement that SR0 applicants have three months as an extra person on shift were stated on June 4,1980 in a separate letter, C. W. Fay to H. R. Denton. No change in PBNP training is planned pending separate resolution of this item. _
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b.
WEPCo objections to the requirement that R0 applicants have three months as an extra person in the control room were stated on June 4,1980 in a separate letter, C. W. Fay to H. R. Denton. No change in PBNP training is planned pending separate resolution of this item.
c.
As part of the overall WEPCo response to the TMI inci-dent, the PBNP training programs have been reviewed and revised where necessary such that the noted specific training and emphasis is provided. The ongoing, simul-taneous revision and implementation of these and other training programs, such as the new Technical Advisor training required to meet NUREG-0578, will pennit only an interim program package to be submitted by August 1,
- 1980, d.
The PBNP training organization currently has three full-time instructors, one of whom holds a PBNP SR0 license. A fourth full-time and two part-time (Shift Supervisor-SRO) rotated instructors will be added as soon as qualified personnel can be obtained. The Training Engineer (head of Training group) is a college graduate, ex-nuclear Navy R0/EWS, and has held an SR0 elsewhere. A strict interpretation of (1.b) above would be restrictive relative to implementing this requirement. We therefore disagree with the require-ment and its potential burden and impediment to the licensee and to the NRC Operator Licensing process.
In our opinion it is sufficient that only one person of a plant training group be an SRO-licensed person for the plant, as long as that person is in a responsi-ble position to effect training programs and training implementation.
e.
PBNP instructors will participate in appropriate re-qualification programs to assure cognizance of current operating history, problems, and changes to procedures and administrative limits. An initial program descrip-tion is planned for NRC submittal by August 1,1980.
3.
Facility Certifications WEPCo commits t0 certifications complet<id pursuant to Sections 55.10(a) (6) and 55.33 (a) (4) and (5) of 10 CFR 55 being signed, as has been the case in the past, by the highest level of corporate' management for plant operation who has direct knowledge of the applicant's performance.
i This person is the Mans ger-Nuclear Operations Division, resident at PBNP.
B.
NRC-EXAMINATIONS No licensee response is required for this section which 1
states new NRC examination scope..
C.
REQUALIFICATION PROGRAMS 1
WEPCo commits to add instruction in heat transfer, fluid flow, thermodynamics and mitigation of accidents involving a degraded core effective August 1,1980, vs. May 1,1980.
2.
The criteria of requiring a licensed individual to partici-pate in accelerated requalification shall be modified as required.
3.
WEPCo commits to having initial programs modified by August 1,1980, and license applications complying with modified programs by November 1,1980.
D.
LONG RANGE CRITERIA AND/0R REQUIREMENTS No licensee response is required for this section which requires additional NRC staff work and/or rulemaking prior to implementation.
Item 1.C.5 Procedures for Feedback of Operating Experience to Plant Staff Items 1 through 7 represent the requirements of a detailed, proceduralized administrative system, not only for review and dissemination of information, but additionally, td " assure...
personnel become aware of and understand information." If the intent of this section is for the utility to practice methods of reviewing and disseminating material pertinent to the opera-tion or maintenance of their plant's specific design rather than be prescriptive as to implementation, the current review system at PBNP meets these requirements.
WEPCo has realized that this flow of information has always been important to providing a safe and efficient unit.
Due to a licensee requirement to keep abreast of the state-of-the-art methods, PBNP has always employed techniques to accomplish this. These techniques include membership by the utility itself and its personnel in numerous industry committees and organizations, typically in a leadership position.
Copies of LERs through EEI, vendor-bulletins, EPRI studies, utility agreements for information exchange, along with _ numerous other sources of information have always been reviewed by senior supervisors at PBNP and are routed for review to cognizant personnel in a routine manner.
This review and routing includes the Training Engineer, who distributes appropriate information to licensed operators, Technical Advisors, and other operating personnel deemed necessary.
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These existing administrativa techniques shall, however, be reviewed and upgraded if necessary to provide for more effect-ive review and distribution of this material prior to January 1, 1981. The review will be documented and discussed by the Manager's Supervisory Staff for concurrence.
Item II.K.3 Measures to Mitigate Small Break Loss of Coolant Accidents and Loss of Feedwater Accidents The following responses address only the ten items applicable to PWRs and LWRs consistent with the PBNP design.
II.K.3.1 Installation and Testing of Automatic PORV Isolation System.
The current PBNP design includes an automatic system for opening the pressurizer PORVs as described in II.K.3.9 below.
This system ensures that the PORVs will reclose when pressure decreases below the opening setpoint (for either of two inter-locked channels per valve), for valve air supply or other failure, and manual operator action. These features, as well as the direct air operator design and position indication (as contrasted with the pilot operated PORV with indirect position indication inappropriately used in the TMI design) eliminate the need for an automatic closure system for the block valves.
This item will, however, be brought before the Owners' Group of utilities with Westinghouse plants for generic consideration.
WEPCo will then review the results of that investigation for applicability to PBNP.
II. K. 3. 2 PWR Vendor Report on PORV Failure Reduction WEPCo considers this action to be entirely within the scope of the PBNP reactor vendor, Westinghouse Electric Corporation.
This item should proceed directly from the vendor to the NRC as requested by 0wners of Westinghouse supplied reactors with the utility involvement being that of providing PORV operat-ing data as required by the vendor. WEPCo will provide such data if requested by Westinghouse to more clearly define our operating history from current PBNP records.
II.K.3.3 Reporting Safety and Relief Valve Failures and Challenges.
WEPCo will provide the required valve failure and challenge data for the period April 1,1980 through December 31, 1980, as part of the 1980 annual report.
II.K.3.5 Automatic Trip of Reactor Coolant Pumps During LOCA WEPCo has addressed this item generically as part of the Owners' Group evaluation of Westinghouse plants. The results of this evaluation are documented in WCAP-9584, currently under review by the NRC staff. -
II.K.3.9 Proportional Integral Derivative (PID) Controller Modification The power operated relief valve system at Point Beach is identical in each unit and consists of two power operated relief valves, each actuated by two unique and independent channels of pressurizer pressure. Both channels of pressuri-zer pressure must reach a setpoint pressure above nonnal operating pressure before the associated power operated relief valve can be opened. This configuration reduces the number of spurious actuations of the power operated relief valves caused by the PID controller. This is consistent with our understanding of the Westinghouse recommended change referenced.
II.K.3.10 Proposed Anticipatory Trip Modification
-and II. K.3.12 Confirm Existence of Anticipatory Trip Upon
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Turbine Trip A turbine trip will cause a reactor trip to occur via turbine stop valve closure or loss of auto stop oil pressure in each unit at Point Beach. The reactor trip caused bv a turbine trip is bypassed below 50% power as detected by the power range detectors. This configuration is consistant with original plant design and operating setpoint criteria.
II.K.3.17 Report on Outage of ECC Systems WEPCo will provide a report from curre::t plant records detailing outage dates and lengths of outages for all ECC systems, including causes, for the time period January 1,1976 through December 31, 1980 within 60 days after January 1,1981.
g II.K.3.30 Revised Small-Break LOCA Methods to Show Compliance with 10 CFR 50, Appendix K.
WEPCo considers this code development effort to be the responsibility of the PBNP reactor vendor, Westinghouse Electric Corporation. This item should proceed directly from the vendor to the NRC with utility involvement restricted to an evaluation of plant applicability.
II.K.3.31 Plant Specific Calculations to Show Ccmpliance with 10 CFR 50.46.
WEPCo will provide a plant specific analysis for PBNP on a schedule consistent with code development, per II.K.3.30, and NRC review and approval.
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..s Item III.D.3.4 Control Room Habitability The stated purpose of this position is to assure that control room operators will be adequately protected against the effects of accidental releases of toxic and radioactive gases and that the nuclear power plant can be safely operated or shut down under design basis accident conditions in accordance with General Design Criterion 19. Specifically this item requires the licensee to review the control room habitability requirements of, and perform the necessary evaluations to establish conformance with,specified sections of the Standard Review Plan. We note that the safety evalua-tion supporting license amendments 6 and 8 for Point Beach Nuclear Plant Units 1 and 2 dated May 27, 1975 concluded that the control room emergency filtration system at Point Beach Nuclear Plant will perform at a level of efficiency sufficient to limit control ieom doses in accordance with General Design Criterion 19 of Appendix A to 10 CFR Part 50. Nevertheless, WEPCo will conduct the requested re-evaluation and provide the results to the NRC on or before January 1,1981. WEPCo will also provide the information requested in Attachment 1 to this item.
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