ML19345E161
| ML19345E161 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/15/1980 |
| From: | Widner W GEORGIA POWER CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-1.C.5, TASK-1.D.1, TASK-2.K.3.27, TASK-TM NUDOCS 8012230364 | |
| Download: ML19345E161 (9) | |
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,.n-w-a m Ds: ember 15, 1980 Georgia Power
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., wer,,,m.rc vie, Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 ilRC 00CKETS 50-321, 50-366 OPERATING LICENSES DPR-57, tiPF-5 EDWIN I. HATCH NUCLEAR PLANT UNITS 1, 2 COMMITMENTS REGARDING THE ITEMS OF NUREG-0737:
CLARIFICATION OF TMI ACTION PLAN REQUIREMENTS GENTLEMEN:
Pursuant to the conditions of 10 CFR 50.54(f), Georgia Power Company herein submits the confirmation of compliance, with the exceptions and qualifications noted in this letter and its enclosures, requested by Darrell G. Eisenhut's letter of October 31, 1980. The requirements promulgated by that letter, as well as earlier drafts of these requirements, have been the subject of an extensive review by Georgia Power Company, its consultants, and the nuclear industry since their issuance. Our position on each of the items of NUREG-0737 is addressed briefly in.
Georgia Power Company has actively pursued implementation of the requirements which have resulted from the knowledge gained by the study of the TMI 2 accident. We have attempted to be responsible and responsive in our comoliance with both mandated and elective improvements in plant safety.
It is our intention to continue to address all reasonable requirements in a like manner within the limits of existing technology and resource restraints. Many of the requirements of NUREG-0737 are l
complex in nature and have significant, albeit often subtle, plant I
impacts. The complexities of certain proposed solutions and their necessarily l
extended timetables for implementation make an absolute statement of l
compliance impractical and ill-advised at this time. The considerable i -
effort and the numerous revisions required in developing the NUREG-0737 document attest to the difficulty in addressing such issues and schedules for implementation.
We do, however, state our intent to accomplish the implementation of all applicable requirements, as described in Enclosure 1, in their final mutually agreed upon form, per a schedule compatible with that stated in NUREG-0737.
In certain cases, the specific difficulty in meeting the
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required scheduled is cited in Enclosure 1.
Additionally,.some exceptions 8012280 3g
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Georgia Poner d U. S. Nuclecr Regulatory Comission December 15, 1980 Page 2 to the specifics of the NUREG-0737 requirements are noted in Enclosure 1.
A complete statement of exceptions will not be possible until more extensive engineering and analysis have been accomplished. Should such exceptions or necessary variances arise in the future, correspondence will be initiated to infom the NRC of their existence and their impact on schedule, and to request NRC concurrence with their resolution.
Should you have any questions or comments on our efforts in this regard, please contact this office.
Very truly yours,
,'.. ;j W. A. Widner WEB /mb Enclosure xc:
M. Manry R. F. Rogers, III l
l Sworn to and subscribed before me this 15th day of Decenber, 1980.
1 i
Notary Public Nw/ PO!'c. Cwgo, S*Me at Larra V Commiss.cn bpres Sept. 20,1953
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1 ENCLOSURE 1 s
INTENTIONS OF COMPLIANCE FOR NUREG-0737 REOUIREMENTS i
I. A.l.1 - Georgia Power Company (GPC) has had interim Shif t Technical Advisors (STAS) on duty since January 1,1980, as defined in our submittal dated January 25, 1980. STAS, whose training and background meet Technical Specification requirements promulgated by Amendments 79
'i and 18 to the Plant Hatch Unit 1 and Unit 2 licenses, respectively, will be on duty not later than January 1,1981. A description of the current training program which demonstrates conformance with requirements will be submitted by January 1, 1981, along with a description of the long-term STA program.
l I. A.l.2 - GPC has completed implementation of these requirements as they are understood.
I.A.l.3 - GPC met the recommendations of the July 31, 1980, Interim Criteria for Shift Staffing as reported in our letter of October 30, 1980.
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The revised interim criteria, issued in NUREG-0737, are undergoing review. GPC plans to meet the intent of this item, but reserves comitment with respect to specifics of implementation until after cur review is completed. The more restrictive requirement of a 12-i' hour break between all work periods, may result in a more probable necessity of deviation as allowed by subparagraph 2 of I&E Circular No. 80-02 and NUREG-0737, than would the criteria for no more than i
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period required by the original interim criteria.
I. A.2.1 - This item was addressed by previous correspondence dated August 12, 1980, and September 12, 1980, to Paul Collins of the NRC.
I. A.2.3 - GPC Plant Hatch training programs are in compliance with this requirement as it is understood.
I. A.3.1 - GPC has met currently required items as they are understood and intends to meet those portfor.s applicable to plants without simulators i
by the required date of October 31, 1981, within the limits of i
availability of simulator access. An on-site Plant Hatch simulator is presantly on order and under development.
I.C.1
- GPC is a participant in the BWR Owners Group program for development of guidelines for action on transients and accidents.
It is our intention to comply with the schedule as stated in NUREG-0737.
However, it must be recognized that due to the highly complex nature of such a program, in terms of development and training, the assignment of an absolute completion date is not possible.
I.C.2
- GPC Plant Hatch is in compliance 'with the requirements as they are understood.
I.C.3
- See I.C.2 above.
I.C.4
- See I.C.2 above.
I.C.5
- GPC intends to comply with this requirement as it is understood.
WEB /mb 12/15/80 4---.m--
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1 ENCLOSURE 1 INTENTIONS OF COMPLIANCE FOR NUREG-0737 REQUIREMENTS (Continued)
I.C.6_
- GPC intends to comply with the intent of the requirement as it is understood with one known exception at this time. This specific exception is the suggestion that a licensed operator perform the actual tagging or line-ups of systems. A senior reactor operator, normally the Shift Fcteman, develops the system alignment require-ments and authori:es associated tag-out operations. The required physical alignment is the normal duty of a plant equipment operator, who may or may not hold a license. Such an operator is fully qualified to align or verify alignment of any plant system and shall be used for such operations at Plant Hatch.
j I.D.1
- GPC is a participant in the BWR Owners Group Control Room Review program and intends to meet the requirements of this item as under-stood. Complete commitment is reserved until NUREG-0700 has been issued and reviewed.
I.D.2
- GPC plans to meet the intent of this item, but reserves any com-mitment with respect to specifics of implementation or schedule until the issuance and adequate review of NUREG-0696.
II.B.1 - GPC is a participant in the BWR Owners Group efforts toward reso-lution of this item. Currently analyses are underway in support of the use of safety / relief valves (SRVs) as the reactor coolant system vents. GPC intends to meet the requirements of this item as they are understood.
It is believed that the schedule of NUREG-s 0737 can be met, pending acceptable resolution of current questions by analysis.
II.B.2 - GPC has completed an initial shielding analysis and has developed a design to address the results of that analysis. However, the full impact of installation of the designed shielding, when fully evaluated may make such installation undesirable. This point, as well as other outstanding issues in the area of shielding and equipment qualification, must be resolved prior to a commitment to i
meeting the position as stated or the required schedule. This item will be the subject of further correspondence in the future. A commitment to comply with the agreements reached as a result of discussions between GPC and the NRC staff on this question will be made at the conclusion of those discussions.
II.B.3 - GPC intends to meet the requirements of this item as they are understood, and to the extent allowed by ccamercially available equipment. Equipment which will be installed is under develocment and may be subject to as yet unforeseen difficulties in installation and operation. Within the limits imposed by this circumstance, we intend to meet the required schedule.
WE3/mb 12/15/80 Page 2
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ENCLOSURE 1 INTENTICNS OF COMPLIANCE FOR NUREG-0737 RE0VIREMENTS (Continued) 4 1
II.B.4 - GPC has contracted for development of such a training program and intends to meet the requirements, as they are understood, by the required schedule.
II.D.1 - GPC is a participant in the BWR Owners Group SRV Test program and intends to pursue resolution of this item through this generic effort.
II.D.3 - GPC has a SRV Position indication system (both primary and secondary systems) in place. Technical Specifications have been modified to account for these systems. Currently, environmentally qualified pressure switches are scheduled for installation during the Unit 2 refueling outage (now in progress) and the upcoming Unit 1 refueling outage (first quarter in 1981). Switches are due to be shipped by the end of 1930. If available for the outages, they will be installed.
1 II.E.1.1 -Not Applicable.
II.E.1.2 -Not Applicable.
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II.E.3.1 -Not Applicable.
II.E.4.1 -GPC has NRC approved systems for hydrogen control currently installed.
Future requirements as described in SECY-80-399 will be addressed separately when required.
II.E.4.2 -GPC has met or intends to meet the requirements of this item as they are understood with an exception. The vent valves on Unit 1 are presently required to be open for maintenance of the torus /
t drywell pressure differential required under the Mark I containmer program. This exception will be discussed in greater detail in the required January 1, 1981, licensing submittal.
II.F.I - GPC intends to meet the requirements of this iten, as they are understood, to the extent allowed by comercially available equipment.
Equipment which will be installed is under development in some cases and may be subject to as yet unknown difficulties in manu-facture, installation or operation. Two monitors, the containment hydrogen concentration and containment (torus) water level, were previously installed, but will require limited ccmponent replacement l
under the requirements pertaining to I&E Bulletin 79-018.
i WEB /mb 12/15/80-Page 3 l
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ENCLOSURE 1 INTENTIONS OF COMPLIANCE FOR NUREG-0737 REQUIREMENTS (Continued)
II.F.2 - Material has been submitted by the BWR Owners Group in response to this requirement in the General Electric Company NED0 24708 as follows:
o NEDO-247CS Section 3.5.2.1, " Analyses to Demonstrate Adequate Core Cooling (Revised)";
o NED0-24708 Section 3.5.2.3, " Diverse Methods of Detection of Adequate Core Cooling"; and o
NEDO-24703 Section 3.5.2.4, " Justification of Analysis Methods".
Further, certain NRC questions are being addressed by the Owners Group which bear on this question.
As part of the SWR Owners Group, GPC is participating in these generic discussions. The contention of the BWR Owners Group is that due to the nature of the BWR design, presently installed reactor vessel water level instrumentation provide adequate assurance of core cooling. GPC intends to be responsive to the outcome of the results of the generic discussions presently under consideration between the Owners Group and the NRC, as they apply. A full commitment cannot be made, howaver, until that outcome is known.
II.G.1 - Not Applicable.
II. K.1
- No further action required until NRR evaluation of previous sub-mittals is complete.
II.K.2 - Not Applicable.
II. K.3.1, 2,5,7,9,10,11,12,14,19,20,29 - Not Applicable.
II.K.3.3 -GPC intends to meet the requirements of this item as they are understood.
II.K.3.13-GPC is a participant in the BWR Owners Group effort on this item.
Analysis developed by that group is scheduled for submittal per l
NUREG-0737. GPC intends to meet the requirements for modification, l
if any, on a responsible schedule. Full commitment for modifica-tions by July 1,1981, cannot be made until completion of NRC review of that submittal has been accomplished, and modifications, if required, are defined.
II.K.3.15-See II.K.3.13 above.
WEB /mb 12/15/80 Page 4
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i ENCLOSURE 1 INTENTIONS OF CO*tPLIANCE FOR NUREG-0737 REQUIREMENTS (Continued) i II.K.3.16-GPC is a participant in the BWR Owners Group study of possible improvements in the number of challenges and failures of SRVs. A submittal of that study is scheduled in accordance with NUREG-0737.
Comitment to meet the recomendations of that study is reserved j
until they are developed and fully reviewed.
It is the intention of GPC to be responsive in a timely manner to the concerns expressed in this item.
II.K.3.17-GPC intends to comply with the requirements of this item as they i
are understood.
II.K.3.18-GPC is a participant in the BWR Owners Group study of possible improvements in automatic depressurization system operation. A submittal of that study is scheduled in accordance with NUREG-0737.
Commitment to meet the recommendations of that study is reserved i
until they are developed and fully reviewed.
It is the intention of GPC to be responsive in a timely manner to the concerns expressed in this item.
II.K.3.21-GPC is a participant in the BWR Owners Group study of the possible advantages of restart of core spray system and low pressure coolant injection system. A submittal of that study is scheduled in accor-dance with NUREG-0737. Preliminary review of drafts of that study indicate that GPC may wish to take exception to or expand on certain 4
j points of that study. Conuitment to meet recommendations, if any, of that study is reserved until they are more fully developed and i
reviewed.
It is the intention of GPC to be responsive in a timely j
manner to the concerns expressed in this item when they are fully resolved.
II.K.3.22-GPC has verified that procedures exist for manual switching of RCIC i
suction as required.
It is our intention to meet the automatic switching requirements of this item as they are understood.
II.K.3.24-GPC interpets this item to refer to loss of off-sit' AC power only..
l GPC intends to comply with the requirements of this item as they are understood and as noted herein.
II.K.3.25-GPC intends to propose modifications, if required, per the schedule of NUREG-0737.
Commitment to installation of modifications by January 1,1982, is reserved until the potential modifications are more fully developed and understood.
II.K.3.27-GPC intends to comply with the requirements as they are understood.
A submittal of our position will be made by January 1,1981.
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1 ENCLOSURE 1 INTENTIONS OF COMPLIANCE FOR NUREG-0737 REQUIREMENTS (Continued)
II.K.3.28-GPC is a participant in the review of the qualification criteria for ADS accumulators. Pending the outcome of that review and the j
availability of components which may require upgrading, it is our intent to comply with the requirements, as they are understood, and the schedule of NUREG-0737.
II.K.3.30-GPC's letter of November 14, 1980, requested that this item be addressed to General Electric Company by the NRC for resolution.
No further action is planned in this regard until completion of the GE response.
4 j
II.K.3.31-GPC intends to comply with the requirements of this item as they l
are understood.
t II.K.3.40-GPC does not understand the inclusion of item II.D.3.40 in En-closure i to NUREG-0737 and requests clarification.
II.K.3.43-GPC dog not understand the inclusion of item II.K.3.43 in En-closure 1 to f4"EG-0737 and requests clarification.
I II.K.3.44-GPC is a participant in the BWR Owners Group effort in this regard.
A generic submittal is scheduled in accordance with NUREG-0737.
I II.K.3.45-See II.K.3.44 above.
II.K.3.46-GPC Plant Hatch has completed these requirements.
II.K.3.57-GPC Plant Hatch intends to be responsive to this concern. Comi t-i ment is reserved until the implementation schedule is defined.
III. A.l.1-GPC Plant Hatch has completed the requirements of this item as they were understood.
I III. A.1.2-GPC Plant Hatch has completed the interim requirements of this item. We intend to be responsive on a reasonable schedule to the concerns of upgraded emergency support facilities, but reserve all comitment until 1.esuance and thorough review by our staff of NUREG-0696 in its final form.
III.A.2 - GPC is in the process of an extensive effort to meet the require-ments of this item as understood. However, we have found it i
difficult to responsibly address the guidance found in NUREG-0654 Rev. I which was expected in October, 190. 80. We have only j
recently had available a copy of this document and are attempting to comply with the schedule of NUREG-0737. We hereby request an i
extension until February 1,1981, to submit the radiological 1
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ENCLOSURE 1 i
j INTENTIONS OF COMPLIANCE FOR NUREG-0737 REQUIREMENTS (Continued) l III. A.2 (Cont'd) emergency response plan developed under NUREG-0654. Extensions for j
submittal of procedures and implementation of the plan will be the j
subject of future correspondence.
III.D.I.1-GPC has complied with the requirements of this item as they were understood.
III.D.3.3-GPC intends to comply with the requirements of this item as they are understood.
)
III.D.3.4-GPC intends to comoly with the requirements of this item as they are understood. However, we request an extension to February 1, 1981, for :;ubmittal of the results of the review. Extensive analysis has been required due to the question of airborne con-e tamination resulting from assumed MSIV leakage with the large source term defined in NUREG-0737. This analysis, along with the extensive demands made on available engineering resources by current programs in the TMI-related field, makes such an extension highly desirable. Such an extension, if granted, is not expected to impact public health and safety in any significant manner.
J l
l WEB /mb 12/15/80 Page 7
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