ML19343B539
| ML19343B539 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 12/15/1980 |
| From: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| TASK-1.A.1.1, TASK-1.C.5, TASK-1.C.6, TASK-1.D.1, TASK-2.K.2.13, TASK-2.K.3.10, TASK-2.K.3.12, TASK-TM NUDOCS 8012240174 | |
| Download: ML19343B539 (14) | |
Text
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YANKEE ATOMIC El.ECTRIC COMPANY h A-1:.71 Worcester Road, framingham, Massachusetts 01701
, AIU K EE December 15, 1980 United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Darrell G. Eisenhut, Director Division of Licensing
References:
(a)
License No. DPR-3 (Docket No. 50-29)
(b)
USNRC Letter, D. G. Eisenhut to All Licensees of Operating Plants, dated October 31, 1980 l
Sub,4ct:
Post-TMI Requirements-Implementation Date Commitments
Dear Sir:
Reference (b) transmitted all TMI-related items approved for implementation by the Commission as of October 31, 1980.
Included in this document was an itemized listing of existing, revised and new requirements including implementation, review and licensee submittal dates.
Yankee Rowe was requested to reply within forty-five days, documenting our commitment to meet the implementation schedules specified in Enclosure 1 of Reference (b).
Attachment I to this letter provides a commitment to the Implementation Schedule specified in Enclosure 1 of Reference (b).
Where any implementation date cannot be met, we have furnished a revised
(
date, and justification for the delay.
Yankee Rowe does not see the need to propose any interim compensating safety actions.
It should be recognized that the long term commitments made in the attachment to this letter are made under the assumption that no unforeseen difficulties will be encountered in procuring qualified equipment or in l
qualifying equipment already installed.
In addition, it is assumed that the i
NRC requirements for these items will not change and that no new issues will be raised by the NRC which take precedence over these items.
If it becomes apparent that, for any reason, the implementation schedule given for any of these items cannot be met, the NRC will be contacted as soon as possible.
Where Yankee participates in the Westinghouse Owners Group for the resolution of specific action plan items, it should be understood that j
i schedule commitments are derived from the schedule for definition, initiation, and completion of the Owners' Group work which factors in the necessity to review completed work for applicability to Yankee Rowe.
Changes to the Owners' Group schecule of activities may require changes in Yankee's schedule commitments.
8012240 l
17
U.S. Nuclear Regulatory Commission Page 2 Attention:
Darrell G. Eisenhut, Director December 15, 1980
'de trust the information contained in the attachment adequately documents Yankee's intended actions.
If additional clarification of our position is necessary, please contact us as soon as possible in order to allow a timely resolution of any problems. ' be attained.
Very truly yours, YANKEE ATOMIC ELECTRIC COMPA!!Y MY V
L. H. Heider Vice Fresident At tac hme nt COMM0!T4EALTH CF MASSACHUSETTS)
)ss COUNTY OF '40RCESTER
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Then personally appeared before me, L. H. Heider, who, being duly sworn, did state that he is a kice President of Yankee Atomic Electric nompany, that he is duly authorized to execute and file the foregoing request., the name and en the behalf of Yankee Atomic Electric Company, and that the statements therein are true to the best of his knowledge and belief.
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Robert H. Groce Notary Public d',
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Attachment I Yankee Atomic Electric Company Item:
I.A.l.1
Title:
An STA is required on each operating shift at Yankee Rowe in Modes 1-4.
Each STA has a bachelor's degree or equivalent in a scientific or engineering discipline and has received specific training in the response and analysis of the plant for transients and accidents. Each STA has received training in plant design and layout, including the capabilities of instrumentation and controls in the control room. The STA's have been assigned duties that pertain to the engineering aspects of assuring safe operation of the plant, including the review and evaluation of operating experience.
A description of the STA training program, including requalification training will be provided to the NRC by January 1, 1981. A description of our.ong-term STA program will also be providred oy January 1, 1981.
Item:
I.A.l.2
Title:
Shift Supervisor Responsib.lities The requirements of this item havs been implemented by Yankee Rowe as documented in USNRC letter dated April 18, 1980.
This item is complete.
Item:
I.A.l.3
Title:
Shift Manning I
Administrative controls have been established to limit overtime to key plant personnel as described in the USNRC letter dated July 31, 1980. These procedures have been revised to reflect the revised interim criteria for shift staffing.
As discussed in a YAEC letter to USNRC, dated October 27, 1980 (WYR 80-116),
we have revised our license program schedule in order to ensure that all i
staffing requirements of the USNRC letter dated July 31, 1980, for a single unit, will be cet on or before July 1, 1982.
l Item:
I.A.2.1 f
Title:
Immediate Upgrade of Reactor Operator and Senior Reactor Operator l
Training and Qualifications All future applicants for a senior reactor operator (SRO) license will be a licensed operator for one year or will have experience equivalent to one year's experience as a licensed operator as specified in the clarification to this topic in NUREG-0737..,
i Item:
I.A.2.3
Title:
Administration of Training Programs All permanent members of the training staff who teach system integrated responses, transient and simulator ccurses shall hold Senior Reactor Operator (SRO) qualifications and are enrolled in a requalification program.
i Item:
I.A.3.1
Title:
Revise Scope and Criteria for Licensing Examinations Yankee Rowe meets the existing requirements and intends to comply with the further exam requirements by including simulator examinations as part of the licensing examinations as of October 1, 1981. NRC certified instructors at the approved simulator facility will be used for certification for Yankee Rowe operators.
Item:
I.C.1
Title:
Short-Term Accident and Procedures Review The Westinghouse Owner's Group will submit by January 1, 1981, a detailed description of our program to comply with the requirements of Item I.C.l.
The program will identify owner's group previous submittals to the NRC, which we believe will comprise the bulk of the response. Additional effort required to obtain full compliance with this item (with proposed schedules for completion) will also be identified, as discussed with the NRC and Westinghouse on November 12, 1980.
Item:
I.C.2
Title:
Shift & Relief Turnover Procedures The requirements of this item have been implemented by Yankee Rowe as documented in USNRC letter dated April 18, 1980.
l This item is complete.
Item:
I.C.3
Title:
Shift Supervisor Responsibility The requirements on this item have been implemented by Yankee Rowe as documented in USNRC letter dated April 18, 1980.
This item is complete.
Item:
I.C.4
Title:
Control Room Access The requirements of this item have been implemented by Yankee Rowe as documented in USNRC letter dated April 18, 1980.
This item is complete.
Item:
I.C.5
Title:
Procedures for Feedback of Operating Experience to Plant Staff Procedures will be revised, as necessary, to assure that important information on operating experience originating, both within and outside of the organization, is continually provided to operators and other pe sonnel r
and that it is incorporated into plant operating procedures as well as training and retraining programs. Yankee Rowe intends to complete these procedure changes by January 1, 1981.
Item:
I.C.6
Title:
Guidance on Procedures for Verifying Cctreet Performance of Operating Activities Procedures will be reviewed and revised, as necessary, to verify correct implementation of equipment control measures. Yankee Rowe intends to complete these procedure changes by January 1, 1981.
Item:
I.D.1
Title:
Control Room Design Reviews This topic will be addressed upon issuance and review of NUREG-0700.
Item:
I.D.2
Title:
Plant Safety Parameter Display Console The requirement of a Safety Parameter Display System (SPDS) will be reviewed when NUREG-0696 is issued. Yarkee Rowe reserves comtatments until the specific requirements are received and reviewed.
Item:
II.B.1 i
Title:
Reactor Coolant System Vents We have reviewed the NRC position regarding this item and will conform to the design criteria discussed under " Clarification" Sections A and C (Section B cpplies to BWR plants). We will provide the documentation requested by July 1, 1981.
Yankee Rowe intends to accomplish the installation of the reactor coolant
_3_
system vents during the 1981 refueling outage.
This is the only scheduled outage available to meet the July 1, 1982 implementation schedule. Equipment deliveries may not allow the installation to be completed during the 1981 refueling. However, the majority of the work would be accomplished.
The remainder of the work could be completed during the next scheduled outage, or the 1982 refueling, presently projected for late sumner of 1982.
Every effort will be made to meet the implementation date.
Item:
II.B.2
Title:
Design Review of Plant Shielding and Environmental Quilification of Equipment for Spaces / Systems Which May be Used in Post-Accident Operations.
The plant shielding review has been deferred to the SEP program per USNRC letter to YAEC dated April 18, 1980.
Documentation and implementation schedules pertaining to environmental qualification of safety-related electrical equipment are contained in documents other than NUREG-0737 and are therefore not addressed herein.
Item:
II.B.3
Title:
Post-Accident Sampling Capability The plant shielding review has been deferred to the SEP program per USNRC letter to YAEC dated April 18, 1980.
The installation of the reactor coolant sampling system will depend on the results of this review and therefore was included in the SEP review. Please see YAEC letter to USNRC dated May 1, 1980, WYR 80-47.
Yankee Rowe questions the NRC's rationale in requiring chloride monitoring as discussed under " Clarification" Section (2)(c) and (5). Any potential benefits in terms of post-accident monitoring or accident mitigation are not readily obvious to Yankee Rowe. Although we believe that the required analysis could be computed by an offsite laboratory, we question whether the radiation exposure associated with procurement of the sample and subsequent analyses are warranted within the specified timeframe.
Justification of the need for early procurement of post-accident chloride samples, and methods for performing the analysis at reduced exposure, available to the NRC, is requested to enable Yankee Rowe to perform an exposure / benefit ALARA stud.
f Item:
II.B.4
Title:
Training for Mitigating Core Damage Yankee Rowe intends to have a training program developed by January 1, 1981.
This program will teach the use of installed equipment and systems to control or mitigate accidents in which the core is severely damaged. The training program will be initiated by April 1, 1981 with the initial program being completed by October 1, 1981. -
Item:
II.D.1
Title:
Performance Testing of Boiling-Water Reactor and Iretsurized-Water Reactor Relief and Safety Valves (NUREG-0578, Section 2.1.2)
Yankee Atomic, in response to NUREG-0578, indicated that it would be par:icipating in the EPRI Safety and Relief Valve Test Program and would provide program review as well as supply plant specific data for use by the test facility.
Since that time, Yankee Atomic has actively participated in the test program on both the Utility Subcommittee and in the Technical Advisory Group.
Recently it has come to our attention that EPRI has been unable to locate a safety valve for test that is clearly prototypical of the Yankee Rowe safety valves. Despite this difficulty, Yankee will continue to participate in the program on a technical basis.
Since all PWR's for which Yankee Nuclear Services Division provides engineering services are involved in this program, Yankee will be fully able to perform a comparison of the Yankee Rowe relief valve to a prototypical test valve and provide an eva?uation of the operability of that valve which presumably will be shown ti be satisfactory by the testing.
The Yankee Rowe safety and relief valve piping will be evaluated by Yankee for the loads imposed on the piping as compared to the EPRI safety and relief valve test conditions. Following the successful completion of the testing of safety valves, Yankee Rowe will purchase and install new safety valves from a vendor who can supply valves which can be shown to have been certified by an EPRI test valve.
A preliminary evaluation of the adequacy of the safety and relief valves will be submitted by January 1, 1982.
A detailed report for safety and relief valve qualification will be submitted by April 1, 1982.
A detailed discharge piping and support evaluation will be made by July i
l 1, 1982.
With regard to block valves, we feel that the industry effort at this time is properly focused on the safety and relief valve operability and we concur with the industry position of deferring commitment to a detailed test program until the results of the current testing become available.
PWR utilities will not support additional efforts for ATWS valve testing until regulatory issues are resolved. The major EPRI safety and relief valve test facility (CE) is nearing completion and some measures were taken to provide additional test capability beyond the current program requirements. The NRC should recognize that results from the current program are likely to provide most of the information necessary to address ATWS events (i.e., relief capability at high pressure).
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t Item:
II.D.3
Title:
Direct Indication of Relief and Safety Valve Position Reactor coolant system relief and safety valves have been provided with a positive indication in the control room, derived from a reliable indication of flow in.the discharge pipe. The B&W acoustic monitoring system is being qualified to IEEE-323, 344, and 383.
B&W expects to have this qualification 1
completed by the third quarter of 1981.
J Yankee Rowe has proposed a change to the Technical Specifications via letter WYR 80-108, dated September 16, 1980 in response to a USNRC letter dated July 2, 1980.
i Item:
II.E.1.1 i
Title:
Auxiliary Feedwater System Evaluation We understand that the NRC staff will review and evaluate operating plant licensee responses to staff recommendations for improving an AFW system reliability in time to support licensee implementation of both the short-term requirements by July 1, 1981 and long-term requirements by January 1
1982.
Item:
II.E.1.2
Title:
Auxiliary Feedwater System Automatic Initiation and Flow Indication l
Part 1 Auxiliary Fecdwater System Automatic Initiation Automatic init.iation of the Auxiliary Feedwater System is not required at l
Yankee Rowe as discussed in USNRC letter to YAEC dated November 9,1980.
l Part 2 The Auxiliary Flow Indication Instrumentation has been installed at Yankee Rowe. The indication system is environmentally qualified and powered from l
a highly reliable power source.
It is testable and was purchased as safety class material.
1 Supporting documentation, including system design description, will be available for review by the NRC at the plant by April 1, 1981.
i Item:
II.E.3.1 l
i
Title:
Emergency Power Supply for Pressurizer Heaters The requirements for this item have been implemented by Yankee Rowe as i
documented in USNRC letter dated April 18, 1980.
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Yankee Rowe has proposed a change to Technical Specifications via letter WYR 80-108, dated September 16, 1980, in response to your letter dated July 2, 1980.
Item:
II.E.4.1
Title:
Dedicated Hydrogen Penetrations The requirements for dedicated hydrogen penetrations, as discussed in NUREG-0737, have been completed at Yankee Rowe. These modifications were discussed in YAEC letters to USNRC dated December 31, 1979 and April 9, 1980.
The April 9, 1980 submittal included a single failure analysis of the system for containment integrity and the hydrogen control function. This information was discussed in a letter from USNRC to YAEC dated April 18, 1980.
Item:
II.E.4.2
Title:
Containment Isolation Dependability I
Yankee will perform an evaluation to determine what changes to the containment pressure setpoint, if any, would be required to initiate containment isolation for nonessential penetrations. This evaluation is expected to be completed in the first quarter of 1981.
Positions 1, 2, 3 and 4 of this item have been completed as part of NUREG-0578 short-term items. Positions 6 and 7 of this item do not apply to Yankee Rowe as discussed in our letter WYR 79-136 dated November 1, 1979 and accepted by USNRC letter dated October 8, 1930.
Item:
II.F.1
Title:
Additional Accident Monitoring Instrumentation (1) Noble Gas Effluent Monitor Yankee Rowe intends to install high range noble gas effluent monitors on the primary vent stack release path and on each main steam line upstream of the safety valve by January 1, 1982. The vendor engineering details will not be available by January 1,1981, but are currently expected to be available by June 1, 1981.
(2) Sampling and Analysis of Plant Effluents The plant shielding review has been deferred to the SEP program per USNRC letter to YAEC dated April 18, 1980. The installation of plant equipment for monitoring of radioiodine and particulate effluents in accident conditions will depend on the results of this review.
(3) Containment High Range Radiation Monitor Yankee Rowe intends to install a containment high range radiation monitor by January 1, 1982. Final design details of the implementation of the NRC's position and clarifications will be available by July 1, 1981. - - -.-.
(4) Containment Pressure Monitor Yankee Rowe intends to provide a continuous indication of containment pressure in the Control Room by January 1, 1982.
(5) Containment Water Level Monitor Yankee Rowe intends to install a containment water level monitor by January 1, 1982.
(6) Containment Hydrogen Monitor Yankee Rowe intends to int, tall a second hydrogen monitor by January 1, 1982.
Item:
II.F.2
Title:
Instrumentation for Detection of Inadequate Core Cooling The requirements of a saturation monitor have been implemented by Yankee Rowe as documented in USNRC letter dated April 18, 1980.
Yankee Rowe has proposed a change to Technical Specifications via letter WYR 80-108, dated September 16, 1980, in response to your letter dated July 2, 1980.
Our position to provide inadequate core cooling instrumentation has been transmitted previously to the USNRC via YAEC letter WYR 80-60, dated June 4, 1980. Until such time that a new reactor vessel level system or any of the present systems prove to be acceptable for Yankee Rowe, we reserve commitment on any implementation schedule for new equipment.
l Item:
II.G.1
Title:
Emergency Power for Pressurizer Equipment The requirements for this item have been implemented by Yankee Rowe as documented in USNRC letter dated April 18, 1980.
Yankee Rowe has proposed a change to Technical Specifications via letter WYR 80-108, dated September 16, 1980, in response to your letter dated July 2, 1980.
l Item:
II.K.1 l
Title:
I&E Bulletins The USNRC is evaluating Yankee Rowe's response to the applicable bulletins.
Items:
II.K.2.13
Title:
Thermal-Mechanical Report See Item II.K.2.19 Item:
II.K.2.17
Title:
Potential for Voiding in the Reactor Coolant System During Transients The Westinghouse Owner's Group is currently addressing the potential for void formation in the Reactor Coolant System (RCS) during natural circulation cooldown conditions, as described in Westinghouse letter NS-TMA-2298 (T.M.
Anderson, Westinghouse to P.S. Check, NRC). We believe the results of this effort will fully address the NRC requirement for analysis to determine the potential for voiding in the RCS during anticipated transients. A report describing the results of this effort will be provided before January 1, 1982.
Item:
II.K.2.19
Title:
Sequential Auxiliary Feedwater Flow Analysis (The following position applies to Items II.K.2.13 and II.K.2.19)
Yankee Rowe reserves any commitment on the implementation date of these items until we have ample time to review and evaluate a forthcoming proposal and schedule from the Westinghouse Owner's Group.
Item:
II.K.3.1
Title:
Installation and Testing of Automatic Power Operated Relief Valve Isolation System Design of this system will be submitted when and if required by the results of the evaluation undertaken pursuant to Item II.K.3.2.
Item:
II.K.3.2
Title:
Report on Overall Safety Effect of Power-Operated Relief Valve Isolation System The analyses required in this Action Plan Item will be implemented on a generic basis. The report will be reviewed for applicability to Yankee Rowe, and both the report and the documentation of the applicability will be submitted to the NRC staff when it is available from the Westinghouse Owner's Group.
Item:
II.K.3.3
Title:
Reporting SV and R7 Failures and Challenges Yankee Rowe currently reports all failures of safety valves as Reportable Occurrences and will ine.lude any relief valve failures in future LER reports.
Yankee Rowe does not consider an additional annual report of challenges to these valves necersary since these challenges will most probably occur in conjunction with a failure of some other component, and this information would be included with the LER report on the failed component. 1 l
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l Item:
II.K.3.5 s
Title:
Automatic Trip of Reactor Coolant Pumps During a LOCA e
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Yankee Rowe letter, WYR 80-125 dated November 21, 1980, provides the scope and schedule of the program to be pursued in resolving generic ECCS model j
concerns as they apply to Yankee Rowe. Since these activities are related to studies and decisions on automatic tripping of the reactor coolant pumps, the following schedules will apply:
(1) Final selection of a LOCA model which will best meet our needs by February 15, 1981.
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(2) Provide an analysis which addresses the need for automatic RCP trip, with information regarding possible alternatives, and schedules for l
future modifications (if necessary), six months after final selection of LOCA models are to be applied, which is currently proposed for August 15, 1981.
I Item:
II.K.3.9 l
i
Title:
PID Controller I
This item is not applicable to Yankee Rowe since Yankee does not have a o
PID Controller.
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L Item:
II.K.3.10 l
Title:
Proposed Anticipatory Trip Modification I
i This item is not applicable to Yankee Rowe since we have no plans for i
modification.
Item:
II.K.3.ll i
Title:
Justify Use of Certain PORV's t
j This item is not applicable to Yankee Rowe.
Item:
II.K.3.12
Title:
Confirm Existence of Anticipatory Reactor Trip Upon Turbine Trip I
Confirmation of the information described in this section of NUREG-0737 was provided in our letter WYR 80-66, dated June 12, 1980.
Item:
II.K.3.17 I
Title:
Report on Outages of Emergency Core Cooling Systems Licensee Report and Proposed Technical Specification Changes i
Yankee Rowe intends to submit a detailed report of ECCS outage dates, lengths i.
l of outages, and causes of outages for all ECC systems for the past 5 years i
I.
of operation by January 1, 1981.
Item:
II.K.3.25
Title:
Power on Reactor Pump Seals This item is not applicable to Yankee Rowe.
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Item:
II.K.3.30 1
Title:
Revised Small-Break LOCA Methods to Show Compliance with 10CFR Part 50, Appendix K Yankee Rowe letter, WYR 80-125 dated November 21, 1980, describes our program to perform this task.
It is anticipated that this program will be completed by January 1, 1982.
Item:
II.K.3.31
Title:
Plant-Specific Calculations to Show Compliance with 10CFR50.46 i
Yankee Rowe intends to demonstrate compliance with 50.46 using improved
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methodology addressed in Task Item II.K.3.30, applied on a plant specific j
basis within one year after NRC approval of SB-LOCA methods.
Item:
III.A.1.1
Title:
Emergency Preparedness, Short-Term l
This item is complete.
Item:
III.A.1.2
Title:
Upgrade Emergency Support Facilities i
i Yankee Rowe will consider improved facilities upon receipt of detailed requirements from the NRC.
Item:
III.A.2
Title:
Improving Licensee Emergency Preparedness, Long-Term (1) Yankee Rowe shall upgrade its emergency plans by April 1, 1981.
(2) Yankee Rowe is continuing to review the requirements for this item.
At this time we cannot commit to the implementation and schedule requirements of NUREG-0737. We shall provide the NRC with an implementation schedule after ample time to evaluate and determine the impact of NUREG-0654, Rev.1, which we have not rece!.ved to date.
As in all cases, Yankee Rowe fully reserves the right to meet the requirements of NRC's rules by means of acceptable alternatives to i
NRC guidance.
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Item:
III.D.l.1
Title:
Primary Coolant Outside Containment This item is complete.
Item:
III.D.3.3
Title:
Improved In-Plant Iodine Instrumentation Under Accident Conditions By January 1, 1981, Yankee Rowe will have available equipment and associated procedures for accurately determining the airborne iodine concentration, via absorption on charcoal or other media, in areus within the facility where plant personnel may be present during an accident.
Item:
III.D.3.4
Title:
Control Room Habitability Yankee Rowe will perform a control room habitability study in conformance with the guidance provided in Enclosure 4 to your letter dated May 7, 1980.
The results of the control room habitability analysis will be submitted to the NRC by January 1, 1981.
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