ML20041E534
| ML20041E534 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 01/05/1982 |
| From: | Counsil W CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO. |
| To: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20041E528 | List: |
| References | |
| TASK-***, TASK-RR NUDOCS 8203110053 | |
| Download: ML20041E534 (14) | |
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L J, * ',' ; ; U.,7 ' l'.'7 January 5, 1982 Docket Nos. 50-213 50-245 A02136 Mr. William J. Dircks Executive Director for Operations U. S. Nuclear Regulatory Commission Washington, D. C. 20555
References:
(1)
D. G. Eisenhut letter to SEP Plant Licensees, dated January 14, 1981.
(2)
W. G. Counsil letter to D. G. Eisenhut, dated February 27, 1981.
(3)
D. G. Eisenhut letter to All SEP Licensees, dated July 7, 1981.
(4)
W. G. Counsil letter to D. G. Eisenhut, dated y,
July 29, 1981.
F (5)
D. G. Eisenhut letter to W. G. Counsil, dated November 27, 1081, Docket No. 50-213.
(6)
D. G. Eisenhut letter to W. G. Counsil, dated November 27, 1981, Docket No. 50-245.
Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit No. 1
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SEP Redirection and Topic Completion Schedules
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During the latter part of 1980, the Staff and the Systematic Evaluation Program (SEP) licensees initiated discussions regarding a redirection The SEP licensees and the Staff agreed upon the trial use [ (,(*
of the SEP.
of the " lead plant topic" approach, which involved the preparation of a Safety Evaluation Report (SER) by the Staff for a given SEP t
topic on one plant. This SER would then serve as the model for the remaining SEP licensees to p epare Safety Assessment Reports (SARs)
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proposed to licensees in Reference (1). Although the Staff has periodically voiced its criticism of licensee performance during
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the redirected SEP, Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) believe that the progress on the program has been substantial during this period. Regarding the specific performance of CYAPCO and NNECO, it is asserted that every reasonable effort has been made to support the program and that our performance to date is evidence of a sincere commitment to the SEP.
8203110053 020225 PDR ADOCK 05000213 p
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. In References (2) and (4), CYAPCO and NNECO made substantial commit-ments to support the Staff toward completion of the SEP.
CYAPCO and NNECO committed to draft topic assessments to achieve a 60% completion level by June 30, 1981, and to submit all topic assessments prior to the Staff's target dates for the integrated assessment.
CYAPCO and NNECO committed in Reference (2) to submit 31 SARs prior to June 30, 1981 to meet the 60% completion goal. Subsequent to the docketing of Reference (2), the Staf f determined that previously issued license amendments had sufficiently addressed 2 of the topics which CYAPCO and NNECO had committed to draft SARs for; thus our commitment for June 30, 1981 stood at 29 SARs. As of June 30, 1981, lq CYAPCO and NNECO had submitted 30 SARs. Collectively, the 60% target
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completion level was exceeded for the Haddam Neck Plant and Millstone Unit No. 1.
Despite this successful effort, CYAPCO and NNECO received Reference (3), which stated that we had not met our commitment to SEP and that additional resource commitments were required for the Staff to continue with the " lead plant topic" approach.
In response to Reference (3), CYAPCO and NNECO provided Reference (4),
which identified every topic for which CYAPCO or NNECO would draft an SAR and a proposed schedule for submittal.
In an attempt to be responsive to the Staff's preferred topic review schedule, the sub-mittal dates in Reference (4) were determined from Enclosure (2) to Reference (3). However, it was clearly noted in Reference (4) that these submittal dates were a reasonable projection of an achievable schedule and that a number of factors could adversely affect this schedule. Although some SARs were submitted later than the dates given in Reference (4), others were submitted earlier than the schedule indicated.
In general, CYAPCO and NNECO have maintained the Reference (4) schedule and provided SARs tn the Staff in a timely manner.
Despite the substantial progress summarized above, CYAPCO and NNECO received References (5) and_(6), in which the Staff again expressed concern with licensee performance in meeting schedules. CYAPCO and NNECO maintain that References (3) and (6) represent a totally in-accurate and unsubstantiated characterization of our efforts on the SEP. For example, in Reference (5) the Staff states that " Based on overall licensee performance in meeting schedules, we cannot assume that the remaining topic SARs will be completed and submitted as promised." CYAPCO has been unable to determine exactly how "overall licensee performance" relates to CYAPCO's performance.
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CYAPCO and NNECO do not dispute the facts presented in References (5)_
and (6), with minor exceptions; however, we.do object to the critical i,[7p.[ ',gb tone of the letter and the selection of the time frame of reference.
In order to depict an accurate representation of our efforts on the SEP, one must evaluate our effort on the entire redirected program, 4
5 rather than the arbitrarily selected time period from July 1, 1981 "hM p<
to November 13, 1981. Ilowever, CYAPCO's and NNECO's informal ef forts ' 'g, L" /
d to have References (5) and (6) modified to merely statc~ the time b
frame in question were rejected by the Staff. Thus, References (5) d' y and (6) imply that CYAPCO and NNECO have been unsupportive of the redirected SEP since its conception.
It is this characterization which CYAPCO and NNECO dispute. CYAPCO and NNECO representatives present during the December 17, 1981 meeting with yourself and other senior NRC management disputed References (5) and (6) and summarized our accomplishments to date. The primary purpose of this submittal is'to document those statistics. Therefore, CYAPC0~and NNECO are providing the following information. is a listing of all SEP topic commitments, scheduled submittal dates, and actual submittal dates for the Haddam Neck Plant. provides similar information for Millstone Unit No. 1.
Also included in each Attachment is a graph which compares commit-ments vs. actual submittals for each plant. In summary, the tables below show CYAPCO's and NNECO's. cumulative record of providing SARs as scheduled.
Millstone Unit 1 committed submitted June 30, 1981 22 25 113%
December 31, 1981 34 35 103%
lladdam Neck committed submitted June 30, 1981 7
5 71%
December 31, 1981 38 34 89%
As can be clearly seen from the above tables, CYAPCO and NNECO have demonstrated our sincere commitment to completion of the SEP.
In addition to the above efforts, the following resource expenditures and accomplishments should be noted:
o Submittal of 8 SAR addenda o Including consultants, our current manpower loading exceeds 14 professionals full time L_
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o Over $2 million has been expended regarding seismic-related analyses o SEP expenditures (excluding hardware modifications) exceed
$3 million o Extensive seismic anchorage modifications o Other seismic-related modifications to safety-related structures o Participation in three major SEP Owners Group programs regarding seismic issues.
It should be noted that the above accomplishments have been achieved despite the fact that other regulatory issues such as TMI,. Environmental Qualification, and Fire Protection have had a higher priority within both the NRC and -the Utility organizations.
In summary, CYAPCO and NNECO maintain that the References (5) and (6) characterizations are inaccurate and do not represent our actual support to the SEP. CYAPCO and NNECO will continue to support the.
SEP through the integrated assessment as previously indicated. This will be the subject of a meeting between CYAPCO and NNECO and the Staf f in early January.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST. NUCLEAR ENERGY COMPANY M
l W. 'G. Counsil Senior Vice President i
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Docket No. 50-213 lladdam Neck Plant Status of SEP Commitments January, 1982 t
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s Haddam Neck Plant Status of SEP Commitments Submittal Topic No.
Title Commitment Date II-1.A Exclusion Area Authority and 4/30/81 4/27/81 Control II-1.B Population Distribution 4/30/81 8/31/81 II-1.C Potential Hazards or Changes in 4/30/81 6/30/81 Potential Hazards Due to Trans-portation, Institutional, Indus--
trial, and Military Facilities II
".A Hydrologic Description 12/15/81 12/14/81 II-3.B Flooding Potential and Pro-12/15/81 12/14/81 tection Requirements II-3.B.1 Capability to Cope with De-12/15/81 12/14/81 sign Basis Flood II-3.C Ultimate Heat Sink 12/15/81 12/14/81 II-4.D Stability of Slopes 8/31/81 8/31/81 II-4.F Settlement of Foundations 6/30/81 6/22/81 and Buried Equipment III-2 Wind and Tornado Loadings 12/31/81 12/14/81 III-3.A Effects of High Water Level 12/31/81 8/31/81 on Structures III-3.C ISI of Water Control Structures 8/31/81 8/31/81 1
f Ill-4.A Tornado Missiles 8/31/81 8/31/81 III-4.C Internally Generated Missiles 9/30/81 III-4.3 Site Proximity Missiles 6/30/81 6/25/81 III-5.A HELB Inside Containment 9/30/81 III-5.B HELB Outside Containment 8/31/81 10/2/81 III-6 Seismic Design Considerations III-7.D Containment Structural Integrity 4/30/81 4/24/81 Tests VI-1 Organic Material and Post 1/31/82 Accident Chemistry i
lladdam Neck Plant Status of SEP Commitments Submittal Topic No.
Title Commitment Datc VI-10.A Testing of RTS and ESF, Including 6/30/81 Response Time Testing IX-1 Fuel Storage 8/31/81 8/31/81 IX-3 Station Service and Cooling 10/30/81 12/14/81 Water Systems IX-4 Boron Addition System 9/30/81 10/2/81 IX-5 Ventilation System 10/30/81 12/14/81 XV-1 Decrease in Feedwater Temper-9/30/81 9/30/81 ature, Increase in Feedwater Flow, Increase in Steam Flow, and Inadvertent Opening of a Steam Generator Relief or Safety Valve XV-2 Spectrum of Steam System Piping 9/30/81 9/30/.1 Failures Inside and Outside of Containment XV-3 Loss of External Load, Turbine 9/30/81 9/3G/81 Trip, Loss of Condenser Vacuum, Closure of MSIV, and Steam Pres-sure Regulatory Failure XV-4 Loss of Non-Emergency AC Power 9/30/81 9/30/81 to Station Auxiliaries XV-5 Loss of Normal Feedwater Flow 9/30/81 9/30/81 XV-6 Feedwater System Pipe Breaks 9/30/81 9/30/81 Inside and Outside Containment XV-7 Reactor Coolant Pump Rotor Sci-9/30/81 9/30/81 l
zure and Reactor Coolant Pump l
Shaft Break l
XV-8 Control Rod Misoperation 9/30/81 9/30/81 XV-9 Startup of an Inactive Loop or 9/30/81 9/30/81 l
Recirculation Loop At An In-I correct Temperature, and Flow I
Controller Malfunction Causing an Increase in BWR Core Flow Rate l
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Iladdam Neck Plant Status of SEP Commitments Submittal Topic No.
Title Commitment Date XV-10 Chemical and Volume Control Sys-9/30/81 9/30/81 tem Malfunction that Results in a Decrease in Boron Concentration in the Reactor Coolant XV-12 Spectrum of Rod Ejection Accidents 9/30/81 9/30/81 XV-14 Inadvertent Operation of ECCs and 9/30/81 9/30/81 Chemical and Volume Control System Malfunction that increases Reactor Coolant Inventory XV-15 Inadvertent Opening of a PWR Pres-9/30/81 9/30/81 surizer Safety-Relief Valve or a BWR Safety-Relief Valve XV-17 Steam Generator Tube Rupture 9/30/81 XV-19 Loss-Of-Coolant Accidents Re-9/30/81 9/30/81 sulting from Spectrum of Pos-tulated Piping Breaks Within the Reactor Coolant Pressure Boundary
- The seismic re-evaluation program and schedule are thoroughly discassed in the W. G. Counsil letter to D. M. Crutchfield, dated a ac 11, 1981.
- CYAPCO is performing a reanalysis of the Steam Generator Tube Rupture event specifically for SEP. A submittal is scheduled for February, 1982.
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HADDAM NECK PLANT SARs submitted Commitment j
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Docket No. 50-245 Millstone Unit No. 1 Status of SEP Commitments January, 1982 i
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Millstone Unit No. 1 Status of SEP Commitments Submittal Topic No.
Title Commitment Date II-1.A Exclusion Area Authority and 4/30/81 4/27/81 Control II-1.B Population Distribution 4/30/81 5/19/81 II-1.C Potential llazards or Changes 4/30/81 4/29/81 in Potential llazards Due to Transportation, Institutional, Industrial, and Military Faci-111 ties II-2.C Atmospheric Transport and Dif-4/30/81 5/19/81 fussion Characteristics for Accident Analysis II-3.A Ilydrologic Description 6/30/81 6/25/81 II-3.B Flooding Potential and Pro-6/30/81 6/26/81 tection Requirements II-3.B.1 Capability of Operating Plant 6/30/81 6/25/81 to Cope With Design Basis Flooding Conditions II-3.C Safety-Related Water Supply 4/30/81 4/28/81 II-4.D Stability of Slopes 8/31/81 8/31/81 II-4.F Settlement of Foundations and 4/30/81 4/28/81 Buried Equipment III-3.C ISI of Water Control 8/31/81 8/31/81 Structures III-4.A Tornado Missiles 8/31/81 8/31/81 III-4.B Turbine Missiles 9/30/81 8/31/81 III-4.C Internally Generated Missiles 9/30/81 III-4.D Site Proximity Missiles 4/30/81 4/29/81 III-5.A IIELB Inside Containment 9/30/81 III-5.B llELB Outside Containment 8/31/81 12/4/81 IV-2 Reactivity Control Systems 9/30/81 10/28/81
Millstone Unit No. 1 Status of SEP Commitments Submittal Topic No.
Title Commitment Date VI-1 Organic Materials and Post 10/30/81 9/30/81 Accident Chemistry IX-1 Fuel Storage 8/31/81 8/31/81 IX-3 Station Service and Cooling 9/30/81 11/24/81 Water Systems IX-5 Ventilation Systems 9/30/81 11/19/81 XV-1 Decrease in Feedwater Temperature, 6/30/81 6/30/81 Increase in Feedwater Flow, In-crease in Steam Flow, and Inad-vertent Opening of a Steam Gene-rator Relief or Safety Valve XV-3 Loss of External Load, Turbine 6/30/81 6/30/81 Trip, Loss of Condenser Vacuum, Closure of MSIV, and Steam Pressure Regulatory Failure XV-4 Loss of Non-Emergency AC Power 6/30/81 6/30/81 to Station Auxiliaries XV-5 Loss of Normal Feedwater Flow 6/30/81 6/30/81 XV-7 Reactor Coolant Pump Rotor Sei-6/30/81 6/30/81 zure and Reactor Coolant Pump Shaft Break XV-8 Control Rod Misoperation 6/30/81 6/30/81 XV-9 Startup of an Inactive Loop or 6/30/81 6/30/81 Recirculation Loop At An In-correct Temperature, and Flow Controller Malfunction Causing an Increase in BWR Core Flow Rate XV-ll Inadvertent Loading and Oper-6/30/81 ation of a Fuel Assembly in an Improper Position XV-13 Spectrum of Rod Drop Accidents 6/30/81 XV-14 Inadvertent Operation of ECCs and 6/30/81 6/30/81 Chemical and Volume Control System Malfunction that increases Reactor Coolant Inventory
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Millstone Unit No. 1 Status of SEP Commitments Submittal Topic No.
Title Commitment Date XV-15 Inadvertent Opening of a PWR 6/30/81 6/30/81 Pressurizer Safety-Relief Valve or a BWR Safety-Relief Valve XV-16 Radiological Consequences of 6/30/81 6/30/81 Failure of Small Lines Carrying Primary Coolant Out-side Containment 6/30/81 XV-18 Radiological Consequences of Main Steam Line Failure Outside Containment XV-19 Loss-Of-Coolant Accidents 6/30/81 6/30/81 Resulting from Spectrum of Postulated Piping Breaks Within the Reactor Coolant Pressure Boundary XV-20 Radiological Consequences 6/30/81 6/30/81 of Fuel Damaging Accidents
- NNECU did not commit to provide these topic assessments by 6/30/81, however, they were included in the 6/30/81 submittal in order to provide the Staff with one comprehensive DBE document.
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ACKNOWLEDGMENT DATE OF DOCUMENT.
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. *'[M T ' EXECUTIVE DIRECTOR ofecks CTHER:
DESCRIPTION gj LETTE R CMEMO O REPORT C OTHER SPECI AL INSTRUCTIONS OR REMARKS j
Haddaa : tack Plant, Hillstone t!uclear Power Station, Unit Mo.1. SEP Redirection and Topic Coupletton. Schedules I'
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