ML19351E867
| ML19351E867 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 12/15/1980 |
| From: | Randazza J Maine Yankee |
| To: | Eisenhut D 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-TM WMY-80-162, NUDOCS 8012190469 | |
| Download: ML19351E867 (12) | |
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MAME *19jHAlWEE ' ATORUC POWER COMPARU
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December 15, 1980 (207) 623 3521 WMY-80-162 4
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- g United States Nuclear Requlatory Commission
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Washington, D. C.
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-~'Sy Attention: Darrell G. Eisenhut, Director a
Division of Licensing
References:
(a) License No. DPR-36 (Docket No. 50-309)
(b)
USf!RC Letter, D. G. Eisenhut to All Licensees of Operating Plants, dated October 31, 1980
Subject:
Confirmation of Post-TMI Requirement Implementation Dates
Dear Sir:
Reference (b) transmitted all TMI-related items approved for implementation by the Commission as of October 31, 1980. This document (NUREG-0737) includes an itemized listinc of existina, revised and new requirements including implementation, review and licensee submittal dates. Maine Yankee 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 an implementation date cannot be met, we have furnished a revised date, and justification for the delay.
Maine Yankee has not determined a need for interim compensating safety actions where implementation delays have been proposed.
Please recognize that the long-term commitments made in Attachment I to this letter are subject to delay because of unforseen difficulties that may be encountered in procuring qualified equipment, or in qualifyine equipment already installed, or in additions to leRC requirements for these items.
Also, Maine Yankee is an active participant in the CE-0wners Group for the resolation of specific action plan items.
The schedule commitments are derived frc:n the schedule for definition, initiation, and completion of the Owners' Grcup work which factors in the necessity to review completed work for aoplicability to F.aine Yankee. Changes in the Owners' Group schedule of activities ney require changes in Maine Yankee's schedule commitments.
If it becomes apparent thct, for any reason, the implementation schedule delineated in Attachment I cannot be met, the NRC will be contacted as soon as possible.
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MAINE YANKEE ATOMIC POWER COMPANY PASS p
In considering what actions should be taken to assure enforceability of these commitments, please also consider identifying an appropriate mechanism by which a licensee could justify and implement a schedule change should it become necessary.
We trust the information contained herein is adequate; however, if further clarification is necessary do not hesitate to contact us.
Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY kcuhc._. -
/J. B. Randazza Vice President, Operations RHG/bjp Attachment STATE OF MAINE
)i COUNTYOFKENNEBEC)ss Ther. personally appeared before me, J. B. Randazza, who, being duly sworn, did state that he is a Vice President of Maine Yankee Atomic Power i
Company, that he is duly authorized to execute and file the foregoing request in the name and on the behalf of Maine Yankee Atomic Power Company, and that the statements therein are true to the best of his knowledge and belief.
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ATTACHMENT I I.A.1.1 SHIFT TECHNICAL ADVISOR This item will be completed by January 1, 1981.
I.A.1.2 SHIFT SUPERVISOR RESPONSIBILITIES This item is complete.
I.A.I.3 SHIFT MANNING This item will be met by July 1,1982.
I.A.2.1 IMMEDIATE UPGRADING 0F R0 & SR0 TRAINING AND QUALIFICATION This item is complete.
I.A.2.3 ADMINISTRATION OF TRAINING PROGRAM This item is complete.
I.A.3.1 REVISED SCOPE AND CRITERIA FOR LICENSING EXAMS Maine Yankee meets the existing requirements and intends to comply with further exam requirements.
I.C.1 SHORT-TERM ACCIDENT AND PROCEDURES REVIEW 1.
Maine Yankee has completed the SB-LOCA analyses, and revised operating procedures as necessary.
2a. Maine Yankee is participating with the CE Owners Group in the reanalysis of inadequate core cooling, and accordingly we will be dependent on the Owners Group schedules.
- b. Maine Yankee will have revised operating procedures available by the first refueling outage after January 1,1982.
3a. Maine Yankee has undertaken a program for revision of Operations and Emergency procedures on a plant specific basis. A program description will be submitted by January 31, 1981.
- b. Maine Yankee intends to complete procedure implemen-tation and personnel training by the first refueling outage after January 1,1982.
I.C.2 SHIFT & RELIEF TURNOVER PROCEDURE This item is complete.
I.C.3 SHIFT SUPERVISOR RESPONSIBILITY This item is complete.
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o 1.C.4 CONTROL ROOM ACCESS This item is complete.
I.C.5 PROCEDURES FOR FEEDBACK OF OPERATING EXPERIENCE TO PLANT STAFF Maine Yankee intends to have these procedures im-plemented by January 1, 1981.
I.C.6 VERIFY CORRECT PERFORMANCE OF OPERATING ACTIVITIES Maine Yankee intends to complete these procedure changes by January 1, 1981 I.D.1 CONTROL ROOM DESIGN REVIEWS Maine Yankee will evaluate and determine commitments upon promulgation of NRC requirements.
I.D.2 PLANT SAFETY PARAMETER DISPLAY CONSOLE Maine Yankee will reserve commitments until specific requirements are received.
II.B.1 REACTOR COOLANT SYSTEM VENTS 1.
By July 1,1981, Maine Yankee shall provide a design of the reactor coolant vent system.
2.
Installation of the reactor coolant system vent is scheduled for the 1981 refueling outage, and should therefore meet the July 1982, imple-mentation schedule.
3.
Procedures and supporting analysis for operator use of the vents will be available to the operator by January 1,1982.
l II.B.2 DESIGN REVIEW OF PLANT SHIELDING AND ENVIRONMENTAL QUALIFICATION OF EQUIPMENT FOR SPACES / SYSTEMS WHICH l
MAY BE USED IN POST-ACCIDENT OPERATIONS 1.
Maine Yankee letter WMY-80-147 dated November l
6, 1980 describes the shielding design review including calculated dose rates.
2.
By January 1,1982 all modifications required as a result of the shielding study or appropriate alternatives will be complete.
i l
3.
Documentation and implementation schedules l
pertaining to safety-related electrical equipment are contained in documents other than NUREG-0737 and are therefore not addressed herein.
L.
e 4.
II.B 3 POST-ACCIDENT SAMPLING CAPABILITY Installation of the post-accident sampling system shall be completed by January 1,198?.
Maine Yankee questions the NRC's rational in re-quiring 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 Maine Yankee. Although we believe that the required analysis could be performed by an offsite laboratory we question whether the radiation exposure associated with procurement of the sample and subsequent analyses are warranted within the specified time frau.
Justification of the need for early procurement of post-accident chloride samples, and methods for perfonning the analysis at reduced exposure, are hereby requested to enable Maine Yankee to perform an exposure / benefit ALARA study.
II.B.4 TRAINING FOR MITIGATING CORE DAMAGE Maine Yankee intends to have a training program available for review by 1/1/81, initiated by 4/1/81 and completed by 10/1/81.
II.D.1 PERFORMANCE TESTING OF BOILING WATER REACTOR AND PRESSURIZED-WATER REACTOR RELIEF AND SAFETY VALVES (NUREG-0578,SECTION2.1.2)
As a sponsor of the EPRI PWR Safety and Relief Valve Test Program, Maine Yankee, intends to comply with the requirements of NUREG-0578, item 2.1.2.
By letter dated December 12, 1980, R.C. Youngdahl of Consumers Power Company has provided the current l
PWR Utilities' positions en the program and schedule of NUREG-0737, Item II.D.I., clarifications. Maine l
~ of the Youngdahl letter. Briefly those positions Yankee concurs with the positions and schedules l
are:
A.
Safety and Relief Valves and Piping - The EPRI
" Program Plan for Performance Testing of PWR Safety and Relief Valves".
Revision 1, dated July 1, 1980 does provide a program that satisfies l
the NRC requirements.
Discussion with the NRC staff and their consultants are resolving specific
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detailed issues.
B.
Block Valves - The EPRI Program has not formally l
included the testing of block valves. However, a small number of block valves have been tested l
at the Marshall Steam Station Test Facility.
The PWR Utilities and EPRI cannot provide a
detailed block valve test program until results of the Wyle and CE relief valve tests are available.
Therefore, a block valve test program will not be provided before July, 1981. The PWR 'Jtilities and EPRI believe that the proper operation of the TMI-2, and Crystal River block valves and other operational experience, plus knowledge of the Marshall tests, support a less hurried and more rational approach to block valve testing.
C.
ATWS Testing - PWR Utilities will not support additional efforts for ATWS valve testing until regulatory issues are resolved. The major safety and relief valve test facility (CE) is nearing completion and some measures were taken to provide additional tast 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).
II.D.3 DIRECT INDICATION OF RELIEF-AND SAFETY-VALVE POSITION 1.
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.
2.
Maine Yankee has proposed-a change to the Technical Specifications via letter WMY-80-132, dated September 11, 1980, in response to your letter dated July 2, 1980.
II.E.1.1 AUXILIARY FEEDWATER SYSTEM EVALUATION We understand that the NRC staff will review and evaluate operating plant licensee responses to staff recommendations for improving AFW system reliability in time to support licensee implementation of both the short-tenn requirements by July 1,1981 and long-term requirements by January 1982.
The clarification of this item indicates a simplified reliability analysis using event tree and fault tree logic techniques to determine the potential for AFW system failures has been performed. Maine Yankee has been unable to obtain the event trees and fault trees used in this evaluation. We would appreciate it if the NRC would provide the event tree and fault tree characterizations of the Maine Yankee design together with any other Maine Yankee plant specific information, available from other than Maine Yankee, used in this study.
fl.E.1.2 AUXILIARY FEEDWATER SYSTEM AUTOMATIC INITIATION AND FLOW INDICATION 1.
Auxiliary Feedwater Systt.m Automatic Initiation Maine Yankee has installed an automatic auxiliary feedwater initiation system, which will be upgraded to meet safety grade requirements by July 1,1981.
The finalized design for the automatic initiation of AFWS is not complete and therefore, any possible change to the facility Technical Specifications are being deferred at this time.
2.
Auxiliary Feedwater System Flowrate Indication The Auxiliary Flow Indication Instrumentation has been installed as control grade equipment with the intention of qualifying it to safety grade status.
Maine Yankee will satisfy the safety grade require-ments by July 1,1981, and will provide sufficient documentation to the NRC.
II.E.3.1 EMERGENCY POWER SUPPLY FOR PRESSURIZER HEATERS 1.
The requirements of NUREG-0737 for the item above have been implemented by Maine Yankee as documented in your letter dated April 29, 1980.
2.
By letter WMY-80-132 dated September 11, 1980 Maine Yankee proposed a change to its Technical Specification in accordance with your letter, dated 7/2/80.
II.E.4.1 DEDICATED HYOR0 GEN PENETRATIONS Maine Yankee anticipates the requirements for the dedicated hydrogen penetration of NUREG-0737 will be met by July 1, 1981.
II.E.4.2 CONTAINMENT ISOLATION DEPENDABILITY Maine Yankee will make changes to the containment i
pressure setpoint that will initiate containment isolation for nonessential penetrations, pending the outcome of an evaluation.
If changes are necessary they will be completed by July 1,1981.
In accordance with your letter, dated October 22, 1980, Maine Yankee meets the staff interim position of October 23, 1979. Your letter further stated that upon completion of the long-term review the NRC will provide a Safety Evaluation and request Technical Specification changes if required, therefore we propose no further action at this time.
The containment purge and vent isolation valves presently close on the following control grade high radiation signals:
Auto Closure Signal Mode of Operation 1.
High Containment Gaseous During periods of Activity OR High Pri-On-Line Purging, mary Vent Stack Gaseous Activity.
2.
High Containment Radia-During periods of tion as sensed on shutdown of Refueling either of two contain-Purging.
ment area monitors.
Diverse containment isolation is already addressed in the existing facility Technical Specifications.
i II.F.1 ADDITIONAL ACCIDENT-MONITORING INSTRUMENTATION 1.
Noble Gas Effluent Monitor Maine Yankee intends to install the required noble gas effluent monitors by January 1,1982, i
2.
Sampling and Analysis of Plant Effluents Maine Yankee intends to provide the capability for effluent monitoring of radiciodines via adsorption on charcoal or other media, followed by onsite laboratory analysis by January 1, 1982.
3.
Containment High Range Radiation Monitor Maine Yankee intends to install the required in-containment radiation monitors by January 1, 1982.
4.
Containment Pressure Monitor Maine Yankee intends to provide the required continuous indication of containment pressure in the control room by January 1,1982.
5.
Containment Water Level Since the qualification requirements of Regulatory Guide 1.97 (Rev. 2*) had not been available before NUREG-0737, and equipment presently scheduled for delivery in early 1981 meet the
- requires qualification to IEEE 323-1974
qualification requirements of XEEE 323-1971; this will require ordering new equipment which have lead times of six months or more. Therefore, we plan to install the currently designed equip-ment during the 1981 refueling outage, and upgrade this equipment where necessary to the qualifica-tions of IEEE 323-1974 during the 1982 refueling outage.
6.
Containment Hydrogen Monitors The required contiiluoul indication of hydrogen concentration in the containment atmosphere will be provided in the control room by January 1, 1982.
II.F.2 INSTRUMENTATION FOR DETECTION OF INADEQUATE CORE COOLING Maine Yankee anticipates completion of modifications to provide unambiguous indication of inadequate core cooling by January 1,1982; however, should unforseen problems arise which preclude completion of this modification schedule, the NRC will be notified promptly.
II.G.1 POWER SUPPLIES FOR PRESSURIZER RELIEF VALVES BLOCK VALVES AND LEVEL INDICATION The design implementation for this item is complete.
Maine Yankee has proposed a change to the facility Technical Specifications via letter WMY-80-132, dated September 11, 1980, in response to your letter dated July 2, 1980.
II.K.1 I&E BULLETIN NRC is evaluating Maine Yankee's response to the applicable bulletins.
II.K.2.13 THERMAL-MECHANICAL REPORT II.K.2.17 POTENTIAL FOR V0IDING IN THE REACTOR COOLANT SYSTEM DURING TRANSIENTS, AND II.K.2.19 SEQUENTIAL AUXILIARY FEEDWATER FLOW ANALYSIS (The following position applies to items II.K.2.13,
-II.K.2.17, and II.K.2.19):
Maine Yankee reserves any commitment on the implemen-tation date of these items until we have ample time to rcview and evaluate a forthcoming proposal and schedule from the CE Owners Group.
It is our under-standing that the Owners Group has deferred consideration of these items until early 1981. Therefore, Maine Yankee requests ample time to evaluate and commit to these actions. We expect to be able to provide a letter of comitment for these items by April
1, 1981.
II.K.3.1 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 under-taken pursuant to item II.K.3.2.
II.K.3.2 REPORT ON OVERALL SAFETY EFFECT OF POWER OPERATED RELIEF VALVE (PORV) ISOLATION SYSTEM Maine Yankee is participating in the CE Owner's Group generic evaluation of the probability of failure and necessity for automatic isolation of the PORV's.
It is anticipated that the initial results will be available mid-December 1980 and that plant specific evaluation and inclusion on the Maine Yankee Docket can be accomplished by mid January 1981. A delay of about two aceks is considered necessary to ensure proper review of the Owner's Group results.
II.K.3.3 REPORTING SV AND RV FAILURES AND CHALLENGES Maine Yankee currently reports all failures of safety related safety valves as Reportable Occurrences and will commit to include any relief valve failures in future LER reports.
Maine Yankee does not consider an additional annual report of challenges to these valves necessary 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.
II.K.3.5 AUTOMATIC TRIP 0F REACTOR COOLANT PUMPS DURING A LOCA Maine Yankee letter WMY 80-153 dated November 21, 1980 provides the scope and schedule of the program to be pursued in resolving generic ECCS model concerns as they apply to Maine Yankee. Since these activities are related to studies and decisions on automatic tripping of the reactor coolant pumps we will commit to the following schedules:
Final selection of a LOCA model which will best meet our needs by February 15, 1981.
Provide an analysis which addresses the need for automatic RCP trip, with information re-garding possible alternatives, and schedules for future modifications (if necessary) - six months after final selection of LOCA models are to be applied, which is currently proposed for August 15, 1981.
e II.K.3.17 REPORT ON OUTAGES OF EMERGENCY CORE-C00L1NG SYSTEMS Maine Yankee intends to submit a report on the outages of the ECC System by January 1, 1981.
II.K.3.25 EFFECT OF LOSS OF ALTERNATING CURRENT ON PUMP SEALS Maine Yankee reserves any commitment on the implementa-tion date of this item until we have ample time to review and evaluate a forthcoming proposal and schedule from the CE Owners Group.
It is our under-standing that the Owners Group has deferred considera-tion of this item until early 1981. Therefore, Maine Yankee requests ample time to evaluate and commit to these actions at a later date.
II.K.3.30 REVISED SMALL-BREAK LOCA METHODS TO SHOW COMPLIANCE WITH 10CDR PART 50, APPENDIX K Maine Yankee letter WMY-80-153 dated November 21, 1980 describes our program to perform this task.
It is anticipated that this program will be completed by January 1,1982.
II.K.3.31 PLANT-SPECIFIC CALCULATIONS TO SHOW COMPLIANCE WITH 10CFR50.46 Maine Yankee intends to demonstrate compliance with -
50.46 using the improved methodology addressed in task item II.K.3.30, applied on a plant specific basis within one year after NRC approval of SB-LOCA methods.
III.A.1.1 EMERGENCY PREPARENDESS, SHORT-TERM This item is complete.
(
III.A.1.2 UPGRADE EMERGENCY SUPPORT FACILITIES l
l Maine Yankee will consider improved facilities upon l
receipt of detailed requirements from the NRC.
III.A.2 IMPROVING LICENSSEE EMERGENCY PREPAREDNESS, LONG-TERM 1.
Maine Yankee shall upgrade its emergency plans by April 1, 1981.
2.
Maine Yankee is continuing to review the requirs-ments for this item. At this time we cannot l
commit to the implementation and schedule require-ments of NUREG-0737. We shall provide the NRC with an implementation schedule after ample time to evaluate and determine the impact of l
I
NUREG-0654, Rev. 1, which was first received by Maine Yankee from the KMC coordinating group on emergency planning by letter dated November 26, 1980. As in all cases, Maine Yankee fully reserves the right to meet the requirements of NRC's rules by means of acceptable alternatives to NRC guidance.
III.D.1.1 PRIMARY COOLANT OUTSIDE CONTAINMENT This item is complete.
III.D.3.3.
IMPROVED INPLANT IODINE INSTRUMENTATION UNDER ACCIDENT CONDITIONS By January 1,1981 Maine Yankee will have available equipment and associated procedures for accurately determining the airoorne iodine concentration via absorption on charcoal or other media in areas within the facility where plant personnel may be present during an accident.
III.D.3.4 CONTROL ROOM HABITABILITY Maine Yankee commits to 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. Maine Yankee anticipates that any modifi-cations, should they be necessary, will be completed by January 1,1983.
.