ML20039G738

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Forwards Summary of post-TMI Requirements Unresolved as of 820101 & Estimated Completion Dates.Items Discussed Include II.B.3 Re Post Accident Sampling Capability & II.D.1 Re Relief & Safety Valve Test Requirements
ML20039G738
Person / Time
Site: Maine Yankee
Issue date: 01/15/1982
From: Garrity J
Maine Yankee
To: Clark R
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-***, TASK-TM JHG-82-05, JHG-82-5, MN-82-04, MN-82-4, NUDOCS 8201190071
Download: ML20039G738 (8)


Text

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January 15, 1982 JHG-82-05 MN-82-04 e

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United States Nuclear Regulatory Commission Washington, D. C.

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E.~,isaanternam:ss3 Attention: Office of PAJclear Reactor Regulation

- r=st uwmt et Division of Licensing Operating Peactors Branch #3

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Mr. Robert A. Clark, Chief f$

Peferences:

(a) License No. DPR-36 (Docket No. 50-309)

(b) USNRC letter to MYAPCo dated October 31, 1980

Subject:

Post TMI Ret;uirements - Open Items as of January 1,1982.

Dear Sir:

Enclosed is a summary of the Post TMI Pacuirements which Maine Yankee has not yet fully implemented. This summary includes estimated dates of completion. Any item listed in Reference (b) which is not included in the enclosed summary has beco completed and can be considered closed.

We trust this information is satisfactory.

Sincerely yours, MAINE YANKEE ATOMIC POWER COMPANY John H. Garrity, Senior Director Nuclear Engineering and Licensing JHG/bjp Enclosure Ab 8201190071 820115 POR ADOCK 05000309 hI PDR

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Post TMI Reouirements - Open Items as of January 1,1982 I.A.l.3 Shift Manning NUREG-0737 calls for Maine Yankee to have the following shift staff:

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1 SS (SRO), 1 SRO, 2 RO, 2 A0 by July 1, 1982.

In June of 1981, Maine Yankee provided advance notice to the NRC of possible difficulties in implementirq this shift staffing level by July 1, J982.

It appears at this time, that we will not be able to fully implement this chanrje until at least July 1, 1983.

See: MYAPCo letter to USNRC dated June 25, 1981, FMY-81-96.

I.C.1 Short Term Accidents and Procederes Review See: MYAPCo letter to USNRC dated January 30,1981, R4Y-81-ll.

I.D.1 Control Room Design Review A review committee has been established. A review plan will be submitted by May 1,1982.

I.D.2 Plant Safety Parameter Display Conceptual design work and review of regulatory guidance is proceeding.

II.B.1 Reactor Coolant System Vent There vents are now installed, however tubing stpports need to be added to meet siesmic requirements. These supports will be completed during 1982 refueling outage.

Procedures and supporting analysis will be submitted to the NRC by July 1, 1982.

See MYAPCo letter to USNRC dated July 20, 1981, FMY-81-107.

II.B.2 Shielding and Environmental Qualification Many modifications have been implemented. The following modifications are still open:

a.

II.F.1.6 Containment Hydrogen Monitor - One monitor is operational, but is in a high radiation area, and will have to be moved in order to meet shielding reouirements. This will be done during the 1982 refueling outage. See II.F.1.6 for complete summary, b.

Hot Leg Injection - Alternate shielded system installation is complete and deliberately rendered inoperable pending completion of the seismic analysis which is expected by April 1,1982. The unshielded system remains operable. I 1

c.

II.E.4.1 - Dedicated Hydrogen Penetrations - Maine Yankee will install remote valve stations to meet shielding recuirements. This will be done by Apri' 1,1982. The system remains manually operable.

II.B.3 Post Accident Sampling Capability 1.

Coolant Sampling - This will be completely installed by March 1, 1982. Seismic analysis will be ccmpleted by April 1, 1982.

2.

Containment Atmosphere Sampling - The hydrogen purge system is used to draw o'f a sample. Lab procedures are in place to analyze the sample within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to determine concentration of hydrogen noble gasses, iunines, and cesiums, and~non-volatile gasses. The hydrogen purge system is installed, operational, and isolated pending completion of seismic analysis, which is expected by April 1, 1982.

3.

Chloride Sampling - In accordance with NUREG-0737 item II.B.3 clari'ication paragraph (5), Maine Yankee can complete the eaalysis in 4 days as recuired. This item is complete.

II.D.1 Relief and Safety Valve Test Recuirements Vaine Yankee is participating in the EPRI program to test relief and safety valves. Maine Yankee will make every effor'. to provide the plant specific information as early as possible. Maine (snkee will commit to provide information on or before the following dnc' es:

Plant specific submittal Confirming the adecuacy of safety and relief a.

valves based on licensee / applicant preliminary review of generic program test results. - October 1, 1982.

b.

Plant specific reports for safety and relief valve cualifications. -

January 1, 1983.

c.

Plant specific submittals for safety and relief valve discharge piping and stpport 3 valuations. - July 1, 1983.

See: USNRC Memo "Octeu r 2, 1981 Meeting with EPRI and PWR Utilities to Review Test Results to Date and Proposed Schedule for Completion of Balance of Tests in Response to Item II.D.1, NUREG-0737", dated October 19, 1981.

II.D.3 Valve Position Indication The Valve Monitoring System has been installed and placed in operation.

The only outstanding item is environmental cualification which is expected to be complete by January 1,1983.

II.E.1.1 Auxiliary Feedwater System Evaluetion 1.

Additional Short Term Recommendation -1: Redundant level indicators

- Maine Yankee is awaiting a written technical justification from the NRC on this recommendation.

See: MYAPCo letter to USNF.C dated August 21, 1981, FMY-81-121 i

l 2.

Additional Short Term Recommendation -3:

Safety grade flow l

indication - This system is operational. Maine Yankee is awaiting NRC review which will be provided in a supplement to the SER.

See: USNRC letter to MYAPCo dated April 30, 1981, Arendment 55 3.

Long Term Recommendation GL-1: Safety grade auto initiation - See i

II.E.1.2 for status. Maine Yankee is awaiting NRC review which will l

be provided in a supplement to the SER.

See: USNRC letter to MYAPC0 dated April 30, 1981, Atendment 55.

II.E.12 Auxiliary Feedwater System Auto - Initiation and Flow Indication 1.

Initiation - Safety Grade: The total system logic is now installed and operable. Isolation valves are to be upgraded to safety grade to meet single failure criteria during the 1982 refueling outage.

See: MYAPCo letter to USNRC dated April 28, 1981, FMY-81-67.

II.E.4.1 Dedicated Hydrogen Penetrations Dedicated penetrations exist. Maine Yankee will install remote valve stations to meet shielding requirements of II.B.2 by April 1,1982.

Selsmic analysis which will be completed before April 1,1982.

II.E.4.2 Containment Isolation Dependability In accordance with NUREGWD737, Maine Yankee committed to limit the opening of the 42 inch butterfly valves used for containment purge to 50' open (90o being full open) during containment purging with the reactor systems not in a cold shutdown or refueling mode.

These stops will be installed before the initiation of containment purge with the reactor system not in a cold shutdown or refueling mode.

II.F.1 Accident Mcnitoring 1.

Noble Gas hbnitoring and Main Steam Line Monitoring - This eculpment has been received on site (except acme small parts - tubing fittings,.etc. ).

Eculpment checkcut is proceeding, and installation is scheduled for completion by April 1,1982.

2.

Iodine / Particulate Sanpling - Table II.F.1-2 of NUREG_0737 recuires a permanent solution to the problem of sampling gaseous effluents for radiciodine after an accident.

In previous correspondence (MYAPCo letter to USNRC - FMY-81 dated January 16, 1981), Maine Yankee Atomic Power Company (MYAPCo),

took issue with the design basis shielding envelope. Specifically we presented our arguments for believing the e? sign lodine concentration of 100 uC1/cm3 is too conservative. Seven months after we presented our reason for taking exception to the NRC i

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reouirement, we were informed by the Commission (USNRC letter to MYAPCo datad October 20, 1981) that our arguments had been rejected.

As a result of the latest NRC position and following an assessment by MYAPCo, we intend to comply with the intent of NUREG-0737.

As a result of the NPC response to our position on this subject, engineering efforts have only recently begun to develop a technique for sampling high levels of iodine. Therefore, iodine / particulate sampling capability will be in place by April 1, 1982.

3.

Containment High Range Monitor - This is now installed. The only outstanding item is the Rockbestos cable which may not be environmentally cualified, This will be replaced during the 1982

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rcfueling outage.

4.

Containment Pressure Monitor - The cnly two outstanding items are:

a.

Completion of final seismic analysis for as-built configuration.

This will be completed by April 1, 1982.

Much work was completed during the 1981 refueling outage, however, complete installation was held ut because of eculpment delivery problems.

I b.

Arrival of eauipment necessary to complete installation.

This will be completed by April 1, 1982. This eoulpment has just arrived and will be installed by April 1, 2982.

6.

Containment Hydrogen Monitor - There are three outstanding items:

a.

The seismic analysis will be complete before April 1, 1982.

b.

One monitor is operational but will have to be moved in order to meet II.B.2 shielding reouirements. This will be done during the 1982 refueling outage.

c.

One monitor is available ensite but installation is not yet complete pending piping analysis. Personnel exposure will be i

significantly reduced if installation is completed during an I

outage. Therefore, this will be done during the 1982 refueling i

outage.

II.F.2.

Instrumentation for the Detection of Inadeouate Core Coolirg.

1.

Subcooling Margin Monitor - The upgrade to provide environmentally cualified inputs could not be implemented during the 1981 refueling outage because of procurement difficulties.

It will j

4 be implemented during the 1982 refueling outage. The system as described previously remains operable.

2.

Install Vessel Level Instruments a.

Submittal - A description of this sytem will be sent to the NRC by April 1, 1982. 1

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b.

Implementation.- Much work has been done. W expect to complete install'ation during the 1982 refueling outage.

II.K.2.13 Thermal Mechanical Report See: MYAPCc letter to"USNRC dated December 31, 1981 - FMY-81-189

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II.K.2.17 Potential for Voiding in Reactor Coolant System Curing Transients Maine Yankee has participated in a C-E Owners Ioup program to respond to this item. The C-E Owners Group program analyses have been completed. These analyses demonstrate that if voiding occurs in a Combustion Engineering RCS during anticipated transients, the NRC acceptance criteria for these transients are still met. The documentation of these analysis results is presently being prepareo and is exoected to be submitted by the C-E Owners Group to NRC for review ro later than March 31, 1982.

II.K.3.5 Automatic Trip of Reactor Coolant Pumps during LOCA Maine Yankee will suomit an alternative study by May 3, 1992.

See MYAPCo letter to USNRC dated October 27, 1981 - FMY-18-160..

II.K.3.25 Effect of Lots of AC Power on Pump Seals The CE Owners' Group has determined that the issue is best' pursued on a plant-by-plant basis. During investigation associated with station blackout, generic letter 81-04, we determined that this issue is not a safety concern at Maine Yankee, We will document 06r conclusions and submit a letter report by July 1, 1982.

II.K.3.30 Pevised SB-LOCA Methods to Show Compliance w th 10CFR50, App. K i

Maine Yankee will sutenit Relap 5 model by April 16, 1982.

See MYAPCo letter to USNRC. dated Cecember 16, 1981'- FMY-81-181.

II.K.3.31 Plant Specific Calculations to Show Compliance with 20CFR50.46.

See MYAPCo letter to USNRC dateo Decemr't 15, 1960, WMY-80-162.

III.A.l.2 Upgrade Emergency Support Facilities Our current facilities a's described in the Maine Yankee Emergency Plan -

remain operable.

Maine Yankee is planning to construct a new building on-site which will, among other things, house the Emergency Operaticns Facility and the Technical Support Center. This is expected to be complete by mid 1983. -

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III.A.2

. s Emergency Preparedness The NRC has made several modifications to the implementation schedule for these items. As best we can determine, the present implementation dates for III A.2 items and the source of these modified cates are as follows:

III A.2 ITEM Present Implementation Date Source a.

Install ERF 07-01-82 NRC Regional Meeting Hardward &

Functional Criteria So ftware for Emergency Response Facilities 5/5/81.

b.

ERF Hardware 10-01-82 Eisenhut Letter of and Software fully February 18, 1981, 7'

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operational (Generic Let. 81-10) l c.

Review of Dose 07-01-82 No change Calculation Methodology by Licensee d.

Description of Indefinitely postponed Same as e. above The Class B convers6tions with model NRC Staff.

4.

Class B model Indefinitely postponed fully operational.

It is our understanding, however, that the date for having emergency response facilities operational will again be changed to the first refueling outage after January 1,1983.

In addition, the proposed requirement for the SPDS is to be reviewed by the NRC's Committee on Generic Reauirements, and any proposed inclementation date will, among other things, be based on integration with other emergency response facilities.

With respect to items d. and e., the NRC staff has indicated that while The need for a Class 8 model is being reappraised, additional guidance is 3

forthcoming on the Class A model, as described in Appendix 2 of NUREG-0654, and the proposed operational date is to be consistent with the emergency response facilities.

Maine Yankee's first refueling outage after January 1,1983 is anticipated to be early 1984. We should be able to have the emergency response facilities nardware installed as of that time. Full operational

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capability of the ERF hardward and software should be achieved by mid-1984.

.Committment in this area is, of course, subject to change when the NRC

_ recuirements are finally established with some measure of credibility.

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III.O.~3.4 Control Room Habitability 1

NUREC-0737 recuires modifications to be implemented by January 1,1983.

We will complete the automation of breathing air supply.

See: MYAPCC letter to USNRC dated January 21, 1981, FMY-81-8.

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