ML20040G113
| ML20040G113 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/05/1982 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-***, TASK-TM NUDOCS 8202110278 | |
| Download: ML20040G113 (37) | |
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O Consumers Power n,,o y _,
h lwsclear Licensmg Administrator General Cfficos: 1945 West PamaH Road, Jackson, MI 49201 * (517) 788-1636 February 5, 1982 k
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.n Dennis M Crutchfield, Chief g%pU Operating Reactors Branch No 5 4
4 Nuclear Reactor Regulation 4
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US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - UPDATE OF NUREG-0737, CLARIFICATION OF TMI ACTION PLAN REQUIREMENTS The NRC letter dated October 31, 1980, also identified as NUREG-0737, "Clari-fication of TMI Action Plan Requirements", incorporated into one document all TMI related items approved for implementation by the Commission at that time.
Subsequent NRC letters provided additional explanation or clarification of specific NUREG-0737 items. This total document package provides items to be addressed by Licensees to improve safety at power reactors as a result of lessons learned from the accident at Three Mile Island, Unit 2.
Consumers Power Company's initial response to NUREG-0737 was provided by our letter dated December 19, 1980. That response provided Consumers Power Company's intended actions with respect to the items of NUREG-0737 and super-seded previous submittals on equivalent items from documents such as NUREG-0578, 0626 and 0660 except where specific references were made to previous submittals.
Consumers Power Company's update of our initial NUREG-0737
[
response submitted by our letter dated July 9, 1981 and entitled " Consumers l
Power Company's NUREG-0737 Response - Big Rock Point Nuclear Plant - July 1981 l
Update, provided the status and schedule of our efforts to satisfy the recommendations of NUREG-0737 six months after our initial response.
t By this submittal, entitled " Consumers Power Company's NUREG-0737 Response -
Big Rock Point Nuclear Plant - January 1982 Update", Consumers Power Company j
is submitting our final comprehensive response to NUREG-0737. Henceforth, 3
Consumers Power Company will address any remaining open NUREG-0737 items on a item by item basis. The information contained in this submittal does not supersede our initial response of Dc amber 19, 1980, nor our July 9, 1981
/ 40 update; rather it provides the status and schedule, as of February 4,1982, of Consumers Power Company's efforts to respond to NUREG-0737. Therefore, the format and pagination of this update is such that the updated response to a particular item can be inserted into the December 19, 1980 submittal, oc0182-0020a142 i
8202110278 820205 PDR ADOCK 05000155 P
- Dennis M Crutchfield, Chief 2
Big Rock Point Plant NUREG-0737 Update February 5, 1982
" Consumers Power Company's NUREG-0737 Response - Big Rock Point Nuclear Plant" behind the corresponding item response.
This update is intended to provide Consumers Power Company's latest estimates of how and when various commmitments will be performed; however, unforeseen problems may require modification of these actions and schedules. Such modificatiers to Consumers Power Company's intended actions, where signifi-cant, will be formally submitted.
Please note the following changes included in this update concerning commit-ments identified in Consumers Power Company's letter of July 9, 1981:
1.
The refueling outage at the Big Rock Point Plant, originally scheduled to begin January 1, 1982, has been rescheduled to begin February 6, 1982.
2.
Consumers Power Company proposes to certify all STAS as SR0s and to include an SRO certified STA in the " call-up" of required personnel needed during an emergency condition rather than maintain an SRO certified STA on-shift (Item I.A.1.3).
3.
Consumers Power Company will delegate the responsibility to perform communications / notification activities to a Security Officer who will be designated on each shift (Item I.A.1.3).
4.
Installation of the modified nuclear coolant system vents and submittal of the appropriate Technical Specifications change request will be completed July 1, 1982 rather than March 1, 1982 (Item II.B.1).
5.
Completion of the certification program for the direct indication of relief and safety valve position is now expected by January 1, 1983 rather than January 1, 1982 (Item II.D.3).
NUREG Items I.D.1, CONTROL ROOM DESIGN REVIEWS and I.D.2, PLANT SAFETY PARAMETER DISPLAY CONSOLE, are not included in this submittal but will be updated by a subsequent letter expected to be submitted by March 1, 1982. Due to recent organizational changes at Consumers Power Company, NUREG-0737 Item I.C.5, PROCEDURES FOR FEEDBACK OF OPERATING EXPERIENCE TO PLANT STAFF, is not included in this submittal but will be updated by a subsequent letter expected to be submitted by March 1, 1982.
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.s David J VandeWalle Nuclear Licensing Administrator CC Administrator, Region III, USNRC NRC Resident Inspector-Big Rock Point Attachment oc0182-0020a142
e CONSUMERS POWER COMPANY Big Rock Point Plant NUREG-0737, Clarification of TMI Action Plan Requirements Update of our December 19, 1980 Response to NRC letter, dated October 31, 1980 Docket 50-155 License No DPR-6 At the request of the Commission and pursuant to the Atomic Energy Act of 1954; and the Energy Reorganization Act of 1974, as amended, and the Commission's Rules and Regulations thereunder, Consumers Power Company submits an update of our December 19, 1980 response to NRC letter dated October 31, 1980 (NUREG-0737
" Clarification of TMI Action Plan Requirements").
Consumers Power Company's update is dated February 5, 1982.
CONSUMERS POWER COMPANY
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vu v J W Reynolds, Execut' e Vice President Energy Sul,,ly Sworn and subscribed to before me this 5th day of February 1982 1J Helen I Dempski, Notary /Public Jackson County, Michigan My commission expires December 14, 1983 nu0282-0005bl42
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CONSUMERS POWER COMPANY'S NUREG-0737 RESPONSE BIG ROCK POINT NUCLEAR PLANT JANUARY 1982 UPDATE i
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nu0282-0005a142
m 1C I.A.I.1 SHIFT TECHNICAL ADVISOR 4
' NRC POSITION Each licensee shall provide an on-Shift Technical Advisor to the Shift Supervisor. The Shift Technical Advisor (STA) may serve more than one unit at a multiunit site if qualified to perform the advisor function for the various-units.
i LICENSEE ACTION The current Big Rock Point Technical Specifications, as amended by the NRC on September 3, 1081, requires a Shift Technical Advisor to be part of the minimum shift staff and that STAS.shall have a. bachelor's degree or equivalent. All STAS presently on staff at the. Big Rock Point Plant have a bachelor's degree. Nevertheless, Consumers Power Company is presently in the process of defining bachelors degree equivalency as set forth in draft Regulatory Guide 1.8 rev 2~section 2 ie, a high school degree or its equivalent and one of the following:
a.
four years of formal schooling in science or engineering:
b.
four years of applied experience.at a nuclear facility in the area for which qualification is sought; c.
four years of operational or technical exper tence or training in nuclear power; or d.
any combination of the above totaling four years.
In addition to the above, and as set forth in Consumers Power Company's response to NUREG 0578, Item 2.2.1.b dated March 14,1980, training provided by Consumers Power Company for STA candidates closely approximates INPO draft ~
criteria TQ.7 issued June 1981 for Shift. Technical Advisor Training Consumers Power Company submitted on February ~16, 1981 (updated July:1, 1981 per NRC request) a Technical Specifications change request related to Administrative Controls in which STA requirements were included.
By letter dated February 18, 1981 Consumers Power Company provided a summary of the STA Long-Term Training Program.
DEVIATIONS FROM AND BASIS FOR Recommendations Consumers Power Company proposes to certify all STAS as SR0s. The certifica-tion process would be identical to the training and testing given to those Big Rock Point operators who go on to become licensed SR0s and would be in j
addition to the training that STAS normally receive with the exception that STAS would not take the SRO licensing examination. However, all candidates will be tested by Consumers Power Company as part of the certification process. The testing program will be based on the NRC licensing examination.
A Technical Specification change request will be submitted to the NRC to
. address the STA certification process by March 31, 1982.
l nu0182-0015i142 Updated 1/82
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g 1D I.A.1.1 SHIFT TECHNICAL ADVISOR (Contd)
Schedule Consumers Power Company is initiating the SRO certification process for plant STAS and expects that this first cycle of training and testing will be-complete by October 1,.1982.
The appropriate Technical Specification Change Request will be submitted by March 31, 1982.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated February 16, 1981 2.
Letter from G C Withrow, CP Co, to D M Crutchfield, NRC, dated February 18, 1981 3.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981 4.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated January 11, 1982 5.
Letter from D M Crutchfield, NRC, to D P Hoffman, CP Co, dated September 3, 1981.
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nu0182-0015i142-Updated 1/82
6C I.A.1.3 SHIFT MANNING NRC POSITION This position define shift manning requirements for normal operation.
The letter of July 31, 1980 from D G Eisenhut to all power reactor licensees and applicants sets forth the interim criteria for shift staffing (to be effective pending general criteria that will be the subject of future rulemaking).
Overtime restrictions were also included in the July 31, 1980 letter.
LICENSEE ACTION In response to NRC letter dated November 20, 1981, Consumers Power Company letter dated January 11, 1982 provided our position with respect to:
1.
Two SR0s on-shift 2.
Two HP-Rad / Chem Technicians on-shift 3.
A separate communicator 1.
Two SRO's on-shift As discussed in our updated response to NUREG-0737 Item I.A.1.1, dated January 11, 1982, Consumers Power Company proposes to certify all STAS as SR0s.
The certification process would be identical to the training and testing given to those Big Rock Point operators who go an to become licensed SR0s and would be in addition to the training that STAS normally receive with the exception that STA's would not take the SRO licensing examinations.
Nevertheless, all candidates will be tested by Consumers Power Company as part of the certification process.
Based on the findings of the Operator Action Event Tree evaluation, the results of which will be submitted by March 31, 1982, Consumers Power Company proposes to include an SRO certified STA in the " call-up" of required personnel who can augment the on-shift staff within 60 minutes rather than maintain an SRO certified STA on-shift.
The appropriate Technicial Specifications change request will be submitted with the results of the Operator Action Event Tree evaluation by March 31, 1982.
2.
HP-Rad / Chem Technician On-shift One HP-Rad / Chem Technician is provided on all shifts at Big Rock Point.
Should an emergency situation occur the operations staff, who routinely monitor plant areas prior to entry as part of their normal functions, would be available to assist the HP-Rad / Chem Technician in area monitoring during the initial phases of the emergency.
First aid and rescue activities can be performed by shift personnel, one of which will have a valid first aid certificate. Out-of-plant monitoring and decontamination activities will be carried out by off-site HP-Rad / Chem Technicians.
By utilizing the one on-shift HP-Rad / Chem Technician supplemented by other technicians who will be called in to respond in an emergency, off-site HP-Rad / Chem Technicians, and operations personnel to perform emergency situation activities, all functions listed in NUREG-0654,Section I, naragraphs 7-10, Table B-1 will be adequately manned. A detailed analysis of HP-Rad / Chem Technician actions will be nu0182-0015jl42 Updated 1/82
e 6D 1
I.A.1.3 SHIFT MANNING (Contd) submitted to the NRC by March 31, 1982 as part of the Operator Action Event Tree evaluation.
3.
A separate Communicator
~
Consumers Power Company proposes to delegate the responsibility to perform communications / notification activities to a Security Officer who will be designated on each shift. The designated Security Officer will function in the communicator role until such time as the Site Emergency Director arrives to fulfill that role. A detailed analysis of the Communicator actions will be submitted to the NRC by March 31, 1982 as part of the Operator Action Event Tree evaluation.
DEVIATIONS FROM AND BASIS FOR
~
Recommendations Consumers Power proposes to certify STAS as SR0s and to include an SRO certified STA in the " call-up" of required personnel who can augment the on-
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shift staff within 60 minutes.
The on-shift HP-Rad / Chem Technician, assisted by the operations staff will perform area monitoring, sample collection and' s
analysis, and first aid and rescue activities.
Out-of plant monitoring and decontamination of personnel leaving the plant will be performed by off-site HP-Rad / Chem Technicians with survey monitors and sample equipment obtained from the Charlevoix Emergency Operations Center.
The role of Communicator will be delegated to a Security Officer designated on each shift until the Site Emergency Director arrives to fulfill that role.
Schedule Consumers Power Company is initiating the SRO certification process for STAS
~
and expects that this first cycle of training and testing will be complete by.
October 1, 1982. A Technical Specifications change request addressing the SRO certification of STAS and the inclusion of SR0 certified STAS in the " call-up" of required personnel who can augment the shift staff within 60 minutes will be submitted by March 31, 1982.
Security Officers will be trained and designated as emergency communicators by July 1, 1982.
Detailed analyses of HP-Rad / Chem Technician and Communicator actions will be included in our submittal of the PRA-based Operator Action Event Tree evaluation by March 31, 1982.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 7, 1981 2.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981 nu0182-0015jl42 Updated 1/82 N
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1.A.I.3 SHIFT MANNING (Contd)
LetterhromDhiscrutchfield,NRC,toDPHoffman,CPCo,datedNovember 3.
20,'1981 s
'4! "Let.ter from D P Uoffnan, CP Co, to D M Crutchfield, NRC, dated Jr nuary 11, c1982.
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nu0182-0015j l42 Updated 1/82 4
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j 8A I.A.2.1 IMMEDIATE UPGRADING OF REACTOR OPERATOR AND SENIOR REACTOR OPERATOR 4
TRAINING AND QUALIFICATIONS j
NRC POSITION Effective December 1,1980, an applicant for a Senior Reactor Operator (SRO) license will be required to have been a licensed operator for one year.
LICENSEE ACTION By letter dated November 20, 1981, Consumers Power Company submitted a revision of our RO/SRO Training and Requalification programs to the NRC for their review.
The revised programs incorporate INPO guidelines and NRC requirements.
Consumers Power Company's position with respect to this item remains that our training programs will continue to be modified as necessary to fulfill our needs and to comply with changes to NRC recommendations which may occur in the future.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule Pending NRC review, the revised training and requalification programs will be implemented by March 1, 1982.
REFERENCES
- 1. Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1981 4
- 2. Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated November 20, t
1981 1
i nu0182-0015k142 Updated 1/82
10A I.A.3.1 REVISE SCOPE AND CRITERIA FOR LICENSING EXAMINATIONS -
SIMULATOR EXAMS (ITEM 3)
NRC POSITION Simulator examinations will be included as part of the licensing examination.
LICENSEE ACTION As committed to by Consumers Power Companys letter of December 19, 1980, Consumers Power Company has made arrangements for simulator training and examination for its applicants for Reactor Operator and Senior Reactor Operator licenses.
Consumers Power Company's letter of September 3, 1981 provided a schedule for simulator training and examination at the GE-BWR-Training Center, Morris, Illinois facility.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule None.
REFERENCES 1.
Letter from D PHoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1980 2.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated September 3, 1981 nu0182-0016a142 Updated 1/82
13A I.C.2 SHIFT AND RELIEF TURNOVER PROCEDURES NRC POSITION (NUREG-0578 REQUIREMENT 2.2.1.c)
The licensees shall review and revise as necessary the plant procedure for shift and relief turnover to assure the following:
1.
A checklist shall be provided for the oncoming and offgoing Control Room Operators and the oncoming Shift Supervisor to complete and sign.
The following items, as a minimum, shall be included in the checklist.
a.
Assurance that critical plant parameters are within allowable limits (parameters and allowable limits shall be listed on the checklist).
b.
Assurance of the availability and proper alignment of all systems essential to the prevention and mitigation of operational transients and accidents by a check of the control console.
(What to check and criteria for acceptable status shall be included on the checklist.)
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c.
Identification of systems and components that are in a degraded mode of operation permitted by the Technical Specificati,ons. For such systems and components, the length of time in the degraded mode shall be compared with the Technical Specifications action statement (this shall be recorded as a separate entry on the checklist).
2.
Checklists or logs shall be provided for completion by the offgoing and ongoing auxiliary operators and technicians.
Such checklists or logs shall include any equipment under maintenance or test that by themselves could degrade a system critical to the prevention and mitigation of operational transients and accidents or initiate an operational transient.
(What to check and criteria for acceptable status shall be included on the checklist).
3.
A system shall be established to evaluate the effectiveness of the shift and relief turnover procedure (for example, periodic independent veri-fication of system alignments).
LICENSEE ACTION The position taken by Consumers Power Company with respect to the issues within this item have not changed from the position setforth in our initial response to NUREG-0737 dated December 19, 1980 with the exception of our response to Issue 3.
In this case,the Quality Assurance Department will perform surveillance checks on an annual rather than a semiannual basis as originally proposed.
nu0182-0015p142 Updated 1/82
1LA I.C.2 SHIFT AND RELIEF TURNOVER PROCEDURES (Contd)
DEVIATIONS FROM AND BASIS FOR' Recommendations Since the implementation of semiannual surveillance test T1-08 (Shift Relief Turnover procedure), no findings or observations have been noted in the last three (3) surveillances. To continue the six (6) month surveillance appears to overburden existing manpower resources. Henceforth, Consumers Power Company will perform Shift Relief Turnover surveillance checks on an annual basis.
Schedule None.
REFERENCES Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1980 l
t nu0182-0015p142 Updated 1/82
2h3 II.B.1 REACTOR COOLANT SYSTEM VENTS NRC POSITION Each applicant and licensee shall install reactor coolant system (RCS) and reactor vessel head high point vents remotely operated from the control room.
Although the purpose of the system is to vent noncondensible gases from the RCS which may inhibit core cooling during natural circulation, the vent's must not lead to an unacceptable increase in the probability of a Loss of Coolant Accident (LOCA) or a challenge to containment integrity.
Since these vents form a part of the reactor coolant pressure boundary, the design of the events shall conform to the requirements of Appendix A to 10 CFR Part 50, " General Design Criteria." The vent system shall be designed with sufficient redundancy that assures a log probability of inadvertent or irreversible actuation.
Each licensee shall provide the following information concerning the design i
and operation of the high point vent system:
1.
Submit a description of the design, location, size and power supply for the vent rystem along with results of analyses for Loss of Coolant Accidents initiated by a break in the vent pipe. The results of the analyses should demonstrate compliance with the acceptance criteria of 10 CFR 50.46.
2.
Submit procedures and supporting analysis for operator use of the vents that also include the information available to the operator for initiating or terminating vent usage.
LICENSEE ACTION 1
The design of the reactor coolant system vents has been modified to include drain and flush connections.
Installation of these modified vents and their associated valves is continuing and will be completed by July 1, 1982.
An updated design description, test procedures, operating procedures, including cupporting analysis, and appropriate Technical Specifications change request will be submitted to the NRC by July 1, 1982.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule In concurrence with NRC letter dated September 15, 1981, installation of the modified vents along with the submittal of supporting documentation including design description, test procedures, operating procedures and the appropriate Technical Specifications change request will be completed by July 1,
- 1982, rather than the March 1, 1982 date specified in Consumers Power Company submittal of July 9,1981.
nu0182-0015o142 Updated 1/82
25D II.B.1 REACTOR COOLANT SYSTEM VENTS (Contd)
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981 2.
Letter from D M Crutchfield, NRC, to D P Hoffman, CP Co dated September 15, 1981 nu0182-0015o142 Updated 1/82 l
o 26C II.B.2 DESIGN REVIEW OF PLANT SHIELDING AND ENVIRONMENTAL QUALIFICATION OF EQUIPMENT FOR SPACES / SYSTEMS WHICH MAY BE USED IN POST-ACCIDENT OPERATIONS NRC POSITION With the assumption of a post-accident release of radioactivity equivalent to that described in Regulatory Guides 1.3 and 1.4 (ie. the equivalent of 50% of the core radioiodine, 100% of the core noble gas inventory and 1% of the core solids contained in the primary coolant), each licensee shall perform a radiation and shielding design review of the spaces around systems that may, as a result of an accident, contain highly radioactive materials.
The design review should identify the location of vital areas and equipment, such as the control room, radwaste control stations, emergency power supplies, motor control centers and instrument areas in which personnel occupancy may be unduly limited or safety equipment may be unduly degraded by the radiation fields during post-accident operations of these systems.
LICENSEE ACTION As summarized in our letter dated December 18, 1981, Consumers Power Company has concluded, based on the results of analyzing possible plant personnel exposure to radiation fields resulting from core damage accidents, that all necessary operator actions can be perfu med without exceeding the established dose criterion of 15 mr/hr (30 day average) for continuously inhabited areas or 25 Rem for those operators performing mitigating actions outside the 15 mr/hr areas, including plant ingress and egress. This satisfies 10 CFR 50 Appendix A, General Design Criterion 19.
Consequently, Consumers Power Company has not identified any need for additional shielding of vital areas in which personnel occupancy or action may be unduly limited by radiation fields resulting from postulated accidents involving serious core damage.
DEVIATIONS FROM AND BASIS FOR Recommendations Our letter of December 18, 1981 provided Consumers Power Company's final response to NUREG Item II.B.2.
Schedule None.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981 2.
Letter from T C Bordine, CP Co, to D M Crutchfield, NRC, dated October 21, 1981 l
3.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 18, 1981 nu0182-0015a142 Updated 1/82 l
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II.B.4 TRAINING FOR MITIGATING CORE DAMAGE NRC POSITION Licensees are required to develop a training program to teach the use of installed equipment and systems to control or mitigate accidents in which the core is severely damaged. They must then implement the training program.
LICENSEE ACTION As committed to by our letter dated December 19, 1980, Consumers Power. Company completed the training program described in our December 19, 1980 letter for personnel at the Big Rock Nuclear Plant on September 24, 1981.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule None.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC dated December 19, 1980 l
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i nu0182-0015zl42 Updated 1/82 i
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I LOL II.D.1 PERFORMANCE TESTING OF BOILING WATER REACTOR AND PRESSURIZED WATER REACTOR RELIEF AND SAFETY VALVES (NUREG-0578), SECTION 2.1.2)
NRC POSITION Pressurized water reactor and boiling water reactor licensees and applicants shall conduct testing to qualify the reactor coolant system relief and safety valves under expected operating conditions for design basis transients and accidents.
LICENSEE ACTION By letter dated October 1, 1981, Consumers Power Company provided a summary report of the safety valve test program conducted by Consumers Pcwer Company in cooperation with the Dairyland Power Cooperative using a safety valve from the Lacrosse BWR.
that letter and its enclosure provided the test results and i
showed that the valve operated satisfactorily during the test. The test conditions were selected to simulate expected in-reactor operating conditions.
Acceptance criteria for the safety valve performance test were as follows:
the valve should open, pass the required steam flow, and reclose on demand.
That letter did not include the confirmation that the test results were valid for the Big Rock Point safety valves.
Consumers Power Company expects.that we will be able to submit the required confirmation during the first quarter of 1982. Required adjustments, if any, will be described in that submittal.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule A report providing confirmation that the test results submitted in Consumers Power Company letter of October 1, 1981, are valid for the safety valves at the Big Rock Point Plant, and recommendations concerning required adjustments, if any, will be submitted upon receipt of verification information from the valve supplier (Crosby Valve and Gage Co.).
This information is expected to be available for submittal during the first quarter of 1982.
REFERENCES 1
1.
Letter from T C Bordine, CP Co, to D M Crutchfield, NRC, dated October 1, 1981 nu0182-0015bl42 Updated 1/82
h2A II.D.3 DIRECT INDICATION OF RELIEF AND SAFETY VALVE POSITION NRC POSITION Reactor coolant system relief and safety valves shall be provided with a positive indication in the control room derived from a reliable valve position device or a reliable indication of flow in the discharge pipe.
LICENSEE ACTION Consumers Power Company submitted to the NRC a Technical Specifications change request dated September 25, 1980, supplemented by letters dated March 5, 1981 and September 18, 1981, regarding operability and surveillant requirements for acoustic position monitors.
The NRC, by letter dated October 9, 1981, issued Amendment No 49 to Facility Operating License No DPR-6 for the Big Rock Point Plant approving this Technical Specifications change request.
As noted in Consumers Power Company's letter dated December 19, 1980, Babcock and Wilcox is conducting the equipment certification program for the acoustical safety / relief valve position indicating system. The projected completion date for the final qualification test report is now expected by January 1, 1983, rather than January 1, 1982 as indicated in our letter of December 19, 1980.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule Completion of the acousitical safety / relief valve position indicating system certification program being conducted by Babcock and Wilcox is expected to be completed by January 1, 1983, rather than January 1,1982 as indicated in Consumers Power Company's letter of December 19, 1980.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated September 25, 1980 2.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1980 3.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated March 5, 1981 4.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated September 18, 1981 5.
Letter from D M Crutchfield, NRC, to D P Hoffman, CP Co dated October 9, 1981 nu0182-0015ql42 Updated 1/82
h6C II.E.4.2 MINIMUM CONTAINMENT PRESSURE SETPOINT NRC POSITION 1.
Containment isolation system designs shall comply with the recommendations of Standard Review Plan Section 6.2.4 (ie, that there be diversity in the parameters sensed for the initiation of containment isolation).
?..
All plant personnel shall give careful consideration to the definition of essential and nonessential systems, identify each system determined to be essential, identify each system determined to be nonessential, describe the basis for selection of each essential system, modify their containment isolation designs accordingly, and report the results of the reevaluation to the NRC.
3.
All nonessintial systems shall be automatically isolated by the containment isolation system.
4.
The design of control systems for automatic containment isolation valves shall be such that resetting the isolation signal will not result in the automatic reopening of containment isolation valves. Reopening of containment isolation valves shall require deliberate operator action.
5.
The containment set point pressure that initiates containment isolation for nonessential penetrations must be reduced to the minimum compatible with normal operating conditions.
LICENSEE ACTION Consumers Power Company, by letter dated March 23, 1981, applied for a Technical Specifications change to lower the high containment pressure reactor trip and containment isolation set point from 1.5 psig to - 1.0 psig.
The NRC issued Amendment No 45 to Facililty Operating License No DPR-6 for the Big Rock Nuclear Plant on August 5, 1981 authorizing this change. Accordingly, this update completes our response to NUREG-0737 Item II.E.4.2.
Recommendations None.
Schedule None.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated March 23, 1981 2.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated August 5, 1981 nu0182-0015n142 Updated 1/82
ShB II.F.1. ATTACHMENT 1 - NOBLE GAS EFFLUENT MONITOR NRC POSITION Noble gas effluent monitors shall be installed with an extended range designed to function during accident conditions as well as during normal operating con-4 ditions. Multiple monitors are considered necessary to cover the ranges of interest.
1.
Noble gas effluent monitors with an upper range capac'ty of 10 pCi/cc 5
i (Xe-133) are considered to '>e practical and should be installed in all operating plants.
2.
Noble gas effluent monitoring shall be provided for the total range of concentration extending from normal condition (as low as reasonably achievable (ALARA)) concentrations to a maximum of 10' pCi/cc (Xe-133).
Multiple monitors are considered to be necessary to cover the ranges of interest. The range capacity of individual monitors should overlap by a factor of ten.
LICENSEE ACTION 4
As committed to in Consumers Power Company letter dated July 9, 1981, Consumers Power Company submitted a Technical Specifications change request on October 27, 1981. This change request, revised by Consumers Power Company letter dated December 15, 1981, provided for a Noble Gas Effluent Monitor at the Big Rock' Point Plant.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule Installation of the noble gas effluent monitors may be delayed beyond the date l
indicated in Consumers Power Company's letter dated July 9, 1981 due to delays l'
in the vendor's manufacturing schedule. At this time, delivery is anticipated at the end of February.
Installation will be completed at the earliest time I
after receipt of the equipment and will be consistent with the safe operation of the plant.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981.
2.
Letter from T C Bordine, CP Co, to D M Crutchfield, NRC, dated October 21, 1981.
nu0182-0397a-43-157 Updated 1/82
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ShC II.F.1 ATTACHMENT 1 - NOBLE GAS EFFLUENT MONITOR (Contd) 3.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated October 27, 1981.
4.
Letter from D P Hoffman, CP Co to D M Crutchfield, NRC, dated December 15, 1981.
nu0182-0397a-43-157 Updated 1/82
60B ITEM II.F.1 ATTACHMENT 2 - SAMPLING AND ANALYSIS OF PLANT EFFLUENTS NRC POSITION Because iodine gaseous effluent monitors for the accident condition are not considered to be practical at this time, capability for effluent monitoring of radioiodines for the accident condition shall be provided with sampling conducted by adsorption on charcoal or other media, followed by on-site laboratory analysis.
LICENSEE ACTION As committed to by Consumers Power Company in our letter dated July 9, 1981, Consumers Power Company submitted a Technical Specifications change request on October 27, 1981. This change request, revised by our letter dated December 15, 1981, provides for the sampling and analysis of plant effluents.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule Installation of the equipment associated with this Technical Specifications change remains as indicated in our July 9, 1981 letter which specifies installation by the end of the 1982 refueling outage. This outage is currently scheduled to commence February 6,1982 instead of January 1, 1982.
Since the equipment vendor is anticipating delivery delays, the installation date given above could be delayed.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981 2.
Letter from T C Bordine, CP Co, to D M Crutchfield, NRC, dated October 21, 1981 3.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated October 27, i
1981 4.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 15, 1981 nu0182-0015c142 Updated 1/82
61B ITEM II.F.1 ATTACHMENT 3, CONTAINMENT HIGH-RANGE RADIATION MONITOR NRC POSITION In containment radiation level monitors with a maximum range of 10 rad /h shall be installed. A minimum of two such monitors that are physically separated shall be provided. Monitors shall be developed and qualified to function in an accident environment.
LICENSEE ACTION The external containment high-range radiation monitors, described in Consumers Power Company letter of December 19, 1980, will be installed by the end of the 1982 refueling outage currently scheduled to begin on February 6, 1982 instead of January 1,1982 as specified in our letter of July 9,1981. The appropriate Technical Specifications change request was submitted on December 15, 1981.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule The containment high-range radiation monitor and associated equipment will be installed by the end of the 1982 refueling outage scheduled to begin on February 6, 1982.
REFERENCES 1
1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1980 2.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981 3.
Letter from T C Bordine, CP Co, to D M Crutchfield, NRC, dated October 21, 1981 4.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 15, 1981 I
l l
nu0182-00151142 Updated 1/82 l
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62A II.F.1 ATTACHMENT 4, CONTAINMENT PRESSURE MONITOR NRC POSITION A continuous indication of containment pressure shall be provided in the control room of each operating reactor. Measurement-and indication capability shall include three times the design pressure of the containment for concrete, four times the design pressure for steel and -5 psig for all containments.
LICENSEE ACTION Consumers Power Company has installed the high range containment pressure transmitters and recorders as committed to in our letter of December 19, 1980.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule The appropriate Technical Specifications change request will be submitted by the end of the 1982 refueling outage currently scheduled to begin on February 6, 1982.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1980 2.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981 nu0182-0015u142 Updated 1/82
63B II.F.1 ATTACHMENT 5 - CONTAINMENT WATER LEVEL MONITOR NRC POSITION A continuous indication of containment water level shall be provided in the control room for all plants. A narrow range instrument shall be provided for PWRs and cover the rar.ge from the bottom to the top of the containment sump.
A wide range instrument shall also be provided for PWRs and shall cover the range from the bottom of the containment to the elevation equivalent to a 600,000 gallon capacity.
For BWRs, a wide range instrument shall be provided and cover the range from the bottom to 5 feet above the normal water level of the suppression pool.
LICENSEE ACTION As committed to in our letter dated December 19, 1980, 'onsumers Power Company will modify the existing containment water level monitoring system to provide recordings of measurements.
The equipment for this modification is presently on site at Big Rock Point and the modifications will be completed by the end of the 1982 refueling outage presently scheduled to begin February 6,1982, instead of January 1982 as specified in our letter of July 9,1981. The appropriate Technical Specifications change request will also be submitted by the end of the 1982 refueling outage.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule Plant modifications will be completed and the appropriate Technical Specifications change request will be submitted by the end of the 1982 refueling outage scheduled to begin February 6,1982.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1980 2.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981 nu01oz-0015d142 Updated 1/82
72C II.K.3.14 ISOLATION OF ISOLATION CONDENSERS ON HIGH RADIATION NRC POSITION Isolation condensers have radiation monitors on their vents. These monitors provide alarms in the control room but do not isolate the isolation condenser.
The isolation condensers are currently isolated on a high-radiation signal in the steam line leading to the isolation condensers. The design should be modified such that the. isolation condensers are automatically isolated upon receipt of a high-radiation signal at the vent rather than at the steam line.
The purpose of the _ change is to increase the availability of the isolation condensers as heat sinks.
LICENSEE ACTION The NRC, by letter dated December 15, 1981, indicated that it has completed its review and evaluation of Consumers Power Companys response to Item II.K.3.14.
The NRC concluded that Consumers Power Companys response dated July 9, 1981 is acceptable and that the item is considered resolved.
Notwithstanding the NRC position regarding this item, Consumers Power Company, in our letter dated July 9, 1981, committed to:
1.
examine methods to reduce the probability of a false indication of tube rupture due to shine from the emergency condenser tube bundles, and 2.
investigate additional assurances that fatigue is not a significant contributor to the likelihood of tube bundle failure.
The PRA-based study concerning item 2 above has been completed and will be submitted to the NRC by March 31, 1982.
This study will show that thermal stresses combined with normal operating loads do not appear to contribute to the liklihood of tube bundle failure.
With regard to item 1 above, Consumers Power Company proposes to move the isolation condenser vent radiation monitors two (2) inches away from the condenser vent and to lower the alarm set point in order to prevent a false indication of tube bundle failure due to shine.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule The PRA-based study dealing in part with fatigue induced failures of tubes in the isolation condensers will be submitted to the NRC by March 31, 1982.
nu0182-0015w142 Updated 1/82
i 9
4 72D II.K.3.14 ISOLATION OF ISOLATION CONDENSERS ON HIGH RADIATION (Contd)
REFERENCES 1.
Letter from D P Hof2 man, CP Co, to D M Crutchfield, NRC, dated July 9, 1981
' 2.
Letter from D M Crutchfield, NRC, to D P Hoffman, CP Co, dated December 15, 1981 1
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89A II.K.3.20 LOSS OF SERVICE WATER FOR BIG ROCK POINT NRC POSITION The service water system for Big Rock Point has only one cooling train and is powered from normal alternating current power. The Big Rock Point licensee should verify the acceptability of the consequences of a loss of service water supply to the essential plant components in the event of a loss of off-site power.
LICENSEE ACTION By letter dated June 16, 1981, the NRC concluded that Consumers Power Company's submittal of December 19, 1980 regarding NUREG-0737 Item II.K.3.20 (consequences of a loss of service water to essential plant components in the event of a loss of off-site power) is acceptable except for a loss of cooling to the recirculation pump seals. Loss of service water cooling to the recirculation pump seals is addressed in this update under our response to NUREG-0737 Item II.K.3.25.
DEVIATIONS FROM AND BASIS FOR Recommendations-None.
Schedule None.
REFERENCES i
1.
Letter from D P Hoffman, CP Co to D M Crutchfield, NRC, dated December 19, 1980 2.
Letter from D M Crutchfield, NRC, to D P Hoffman, CP Co, dated June 16, 1981.
nu0182-0015s142 Updated 1/82
l 95C II.K.3.25 EFFECT OF LOSS OF ALTERNATING CURRENT POWER ON PUMP SEALS NRC POSITION The licensees should determine, on a plant specific basis, by analysis or experiment, the consequences of a loss of cooling water to the reactor recirculation pump seal coolers.
The pump seals should be designed to withstand a complete loss of alternating current (AC) power for at least two hours. Adequacy of t?.e seal design should be demonstrated.
LICENSEE ACTION As comultted in Consumers Power Company's letter dated July 9, 1981, Consumers Power 2pany has completed a testing program to demonstrate the adequacy of the elastomer now used in the Big Rock Point recirculation pump seals. The test results showed that the 0-rings maintained a water-tight seal at primary caolant conditions of 1512 (13) psig and_583 (12)F for six hours.
580F is normal operating temperature and thus the highest temperature the seals would experience if cooling were lost.
Six hours was chosen as the test interval because it allows a conservative amount of time for plant cooldown following the loss of seal cooling.
Since the adequacy of the recirculation pump seals to withstand a loss of AC power has been confirmed, this submittal completes our response to NUREG-0737 Item II.K.3.25.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule None.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981 nu0182-0015r142 Updated 1/82 i
l i'
96A II.K.3.27 PROVIDE COMMON REFERENCE LEVEL FOR VESSEL LEVEL INSTRUMENTATION NRC POSITION Different reference points of the various reactor vessel water level instru-ments may cause operator confusion. Therefore, all level instruments should be referenced to the same point. Either the bottom of the vessel or the top of the active fuel are reasonable reference points.
LICENSEE ACTION By letter dated December 19, 1980, Consumers Power Company provided informa-tion that indicated that the steam drum and reactor vessel water levels were referenced to a single level within each component.
By letter dated October 15, 1981, the NRC concluded that action for this item was complete.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule None.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1980 2.
Letter from D M Crutchfield, NRC, to D P Hoffman, CP Co, dated October 15, 1981 l
l 1
l nu0182-0015v142 Updated 1/82 l
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98B II.K.3.29 PERFORMANCE OF ISOLATION CONDENSERS NRC POSITION If natural circulation plays an important role in depressurizing the system (eg, in the use of isolation condensers), then the various modes of two phase flow natural circulation, including noncondensibles, which may play a significant role in plant response following a small break Loss of Coolant Accident (LOCA) should be demonstrated.
LICENSEE ACTION See the updated LICENSEE ACTION for Item II.B.I.
DEVIATIONS FROM AND BASIS FOR Recommendations As noted in Consumers Power Company letters dated December 19, 1980 and July 9, 1981, this item is not applicable to Big Rock Point, except for actions performed as part of Item II.B.1.
Schedule See the updated Schedule for Item II.B.1.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1980.
2.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981.
nu0182-0015t142 Updated 1/82
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99A II.K.3.30 REVISED SMALL BREAK LOSS OF COOLANT ACCIDENT METHODS TO SHOW COMPLIANCE WITH 10 CFR PART 50, APPENDIX X NRC POSITION The analysis methods used by Nuclear Steam Supply System (NSSS) vendors and/or fuel suppliers for small break Loss of Coolant Accident (LOCA) analysis.for compliance with Appendix K to 10 CFR Part 50 should be revised, documented and submitted for NRC approval. The revisions should account for comparisons with experimental data, including data from the LOFT test and Semiscale test facilities.
LICENSEE ACTION As indicated in Consumers Power Company's letter dated December 19, 1980, Consumers Power Company considered that the General Electric Company was the most appropriate party to work with the NRC in resolving concerns with small break LOCA models for BWRs.
By letter dated June 26, 1981, the General-Electric Company provided the NRC with a document that showed that the current GE small break LOCA model satisfies the concerns of NUREG-0626 and is in compliance with 10 CFR Part 50, Appendix K.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule None.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1980 2.
Letter from R H Buchholz, GE, to D C Eisenhut, NRC, dated June 26, 1981 nu-0182-0015y142 Updated 1/82 l
[
100A II.K.3.31 PLANT SPECIFIC CALCULATIONS TO SHOW COMPLIANCE WITH 10 CFR PART 50.46 NRC POSITION Plant specific calculations using NRC approved models for small break Loss of Coolant Accidents (LOCAs) as described in Item II.K.3.30 to show compliance with 10 CFR 50.46 should be submitted for NRC approval by all licensees.
LICENSEE ACTION By letter dated June 26, 1981, the General Electric Company provided documen-tation to the NRC that for operating plants, including Big Rock Point, Item II.K.3.31 is satisfied by existing plant. unique ECCS analysis on file with the NRC.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule None.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 19, 1980 2.
Letter from R H Buchholz, GE, to D G Eisenhut, NRC, dated June 26, 1981 nu0182-0015x142 Updated 1/82
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121C ITEM III.A.I.2 UPGRADE EMERGENCY SUPPORT FACILITIES NRC POSITION Additional clarificat an will be provided in the near future.
LICENSEE ACTION In our letter dated June 1, 1981, Consumers Power Company committed to supply the following information:
1.
Whether or not alternate shutdown panel readouts will be installed in the Control Room.
2.
Review, evaluate and recalculate doses to operators and recommend additional shielding if necessary.
By letter dated December 18, 1981, Consumers Power Company provided our final response, summarized below, to NUREG-0737 Item III.A.1.2.
With respect to Item 1 above, Consumers Power Company has determined that alternate shutdown panel readouts will provide no useful benefit to those in the Technical Support Center.
The actions identified in Item 2 above have been performed.
Analysis by Consumers Power Company indicates that dose rates will not exceed a 30 day average of 15 mr/hr for continuously inhabited areas and that plant personnel exposure would not exceed 25 Rem for those operators performing mitigating actions outside of the 15 mr/hr areas, including plant ingress and egress for postulated accidents.
This satisfies 10 CFR 50 Appendix A, General Design Criterion 19.
As a result, no additional shielding was recommended.
(See LICENSEE ACTION for Item II.B.2.)
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule None.
REFERENCES 1.
Letter from D P Hoffcan, CP Co to D M Crutchfield, NRC, dated June 1, 1981 2.
Letter from D P Hoffman, CP Co, to DM Crutchfield, NRC, dated July 9, 1981 3.
Letter from T C Bordine, CP Co, to D M Crutchfield, NRC, dated October 21, 1981 4.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 18, 1981 nu0182-0015f142 Updated 1/82
122C r *,
III A.2 IMPROVING LICENSEE EMERGENCY PREPAREDNESS - LONG TERM NRC POSITION Each nuclear facility shall upgrade its emergency plans to provide reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.
Specific criteria to meet this requirement are delineated in NUREG-0654 (FEMA-REP-1), " Criteria for Preparation and Evalua-tion of Radiological Emergency Response Plans and Preparation in Support of Nuclear Power Plants."
LICENSEE ACTION As a result of the Emergency Plan Audit recently completed at the Eig Rock Point Plant and as identified via NRC Region III Confirmation of Action letter dated December 14, 1981, Consumers Power Company agreed to provide additional meteorological data using wind speed and direction indicators located on the plant stack at the same level as the isokinetic probe.
By letter dated January 29, 1982, Consumers Power Company provided a description of this system.
Consumers Power Company, by letter dated November 6, 1981, committed to install emergency warning sirens within a 5 mile radius around the Big Rock Point Plant by February 1, 1982.
As confirmed in our letter dated February 4, 1982, installation and testing of the warning sirens has beem completed.
DEVIATIONS FROM AND BASIS FOR Recommendations None.
Schedule Installation of the meteorological equipment discussed above will be completed by May 15, 1982.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated July 9, 1981 2.
Letter from T C Bordine, CP Co, to D M Crutchfield, NRC, dated October 21, 1981 3.
Letter from T C Bordine, CP Co, to D M Crutchfield, NRC, dated November 6, 1981 4.
Letter from J G Keppler, NRC, to R B DeWitt, CP Co, dated December 14, 1981 5.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December 18, 1981 6.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated February 4, 1982.
nu0182-0015gl42 Updated 1/82
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- ** 4 12TB ITEM III.D.3.4 CONTROL ROOM HABITABILITY REQUIREMENTS NRC POSITION In accordance with Task Action Plan Item III.D.3.4 and control room habit-ability, licensees shall assure that control room operators will be adequately protected against the effects of accidental release of toxic and radioactive gases and that the nuclear power plant can be safely operated or shut down under design basis accident conditions (Criterion 19, " Control Room," of Appendix A, " General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50).
LICENSEE ACTION The responses to NUREG-0737 Item II.B.2 and Item III.A.1.2 included in this update and discussed in detail in Consumers Power Company letter dated December 18, 1981, provides Consumers Power Company's assurance that control room operators will be adequately protected against the release of radioactivity and that the plant can be safely operated or brought to a safe shut down condition under postulated design basis accident conditions without exceeding the doses given in 10 CFR 50 Appendix A, General Design Criterion 19.
DEVIATIONS FROM AND BASIS FOR Recommendations Consumers Power Company letter of December 18, 1981 provides our final response.to NUREG-0737 Item III.D.3.4.
The details of this analysis will be included in a forthcoming revision to the Big Rock Point Probabilistic Risk Assessment (PRA) expected to be submitted by March 31, 1982.
Schedule None.
REFERENCES 1.
Letter from D P Hoffman, CP Co, to D M Crtuchfield, NRC, dated July 9, 1981 2.
Letter from D P Hoffman, CP Co, to D M Crutchfield, NRC, dated December.
18, 1981 1
Updated 1/82 nu0182-0015h142
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