ML20054E184
| ML20054E184 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, 05000000 |
| Issue date: | 04/16/1982 |
| From: | Counsil W, Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.2.1, TASK-1.A.3.1, TASK-2.B.2, TASK-2.B.3, TASK-2.B.4, TASK-2.E.1.2, TASK-2.E.4.2, TASK-2.F.1, TASK-2.K.3.27, TASK-TM A02375, A2375, GL-82-05, GL-82-5, TAC-42588, TAC-44175, TAC-44525, TAC-44705, TAC-44746, TAC-44935, TAC-45006, TAC-45077, NUDOCS 8204260225 | |
| Download: ML20054E184 (42) | |
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NORTHEAST IFFIEJTIES s
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} ~tEUt[iQ Mr. Darrell G. Eisenhut, Director p
Division of Licensing Office of Nuclear Reactor Regulation 6.
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U. S. Nuclear Regulatory Commission Washington, D.C.
20555
References:
(1)
D. G. Eisenhut letter to All Licensees of Operating Power Reactors, Generic Letter No. 82-05, dated March 17, 1982.
(2)
D. M. Crutchfield letter to W. G. Counsil, dated February 25, 1982.
(3)
R. A. Clark letter to W. G. Counsil, dated February 18, 1982.
(4)
W. G. Counsil letter to D. G. Eisenhut, dated December 31, 1981.
(5)
- n. M. Crutchfield letter to W. G. Counsil, dated November 20, 1981.
(6)
W. G. Counsil letter to D. G. Eisenhut, dated December 31, 1980.
(7)
W. G. Counsil letter to D. M. Crutchfield, dated July 17, 1981.
(8)
D. M. Crutchfield letter to W. G. Counsil, dated August 5, 1981.
(9)
W. G. Counsil letter to D. G. Eisenhut, dated May 20, 1981.
(10)
W. G. Counsil letter to R. A. Clark, dated February 27, 1981.
(11)
D. M. Crutchfield letter to W. G. Counsil, dated July 20, 1981.
(12)
W. G. Counsil letter to D. G. Eisenhut, dated June 10, 1981.
(13)
R. A. Clark letter to W. G. Counsil, dated September 18, 1981.
(14)
D. M. Crutchfield letter to W. G. Counsil, dated December 11, 1981.
(15)
W. G. Counsil letter to D. G. Eisenhut, dated January 31, 1980.
(16)
W. C. Counsil letter to H. R. Denton, dated December 31, 1979.
/
(17)
R. A. Clark letter to W. G. Counsil, dated June 29, 1981, f
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p204260p-%o g,j Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Response to Generic Letter #82-05 Reference (1), Generic Letter No. 82-05, requested that all Licensees of operating power reactors submit information concerning the im-plementation dates for certain post-TMI Action Plan items identified in NUREG-0737. Accordingly, pursuant to 10CFR50.54(f), Connecticut Yankee Atomic Power Company (CYAPCO) as licensee for the Haddam Neck Plant and Northeast Nuclear Energy Company (NNECO) as licensee for Millstone Nuclear Power Station, Unit Nos. 1 and 2, hereby provide the following information.
Attachments 1, 2, and 3 are provided for the Haddam Neck Plant, Millstone Unit No. 1 and Millstone Unit No. 2, respectively, in response to the Reference (1) information request. The first page of each attachment is an index outlining each item of Enclosure 1 to Reference (1) which is applicable to the particular plant. For those items identified as not applicable, no additional information is provided herein.
Included in the attachments for each plant are the completion dates for those items which have been fully implemented. For those items with completion dates which fall after the implementation date specified in NUREG-0737, appropriate justification for continued plant operation for the period beyond the NUREG-0737 implementation schedule has been provided in previous correspondence.
The im-plementation dates for those items which were completed during plant refueling outages are considered to be the dates on which the reactor was taken critical following the refueling outage. The startup dates from the most recent refueling outage for each Plant are as follows:
Haddam Neck Plant November 9, 1981 Millstone Unit No. 1 April 19, 1981 Millstone Unit No. 2 March 11, 1982 Several items listed in Enclosure 1 of Reference (1) require revisions or additions to the Plant Technical Specifications according to the requirements specified in NUREC-0737.
It is CYAPCO's and NNECO's understanding from communications with the NRC Staff that model Technical Specifications will be provided to licensees by the Staff for these items. To date, model Technical Specifications have only been received for Items II.F.1.1 and II.F.1.2.
Application for Technical Specifications will be made for these items upon receipt of guidance from the Staff.
The status of the equipment qualification for those items requiring such will be addressed under separate cover which is currently being prepared. This information will be docketed in response to References (2) and (3). These responses will discuss the qualification status of all equipment installed in accordance with NUREG-0737 at the lladdam Neck Plant, Millstone Unit No. 1 and Millstone Unit No. 2.
As such, we have elected not to duplicate the environmental qualification information in the response for that subset of Action Plan Items identified in Reference (1).
Although not all items identified in Enclosure 1 of Reference (1) have been completed on the schedule identified in NUREG-0737, CYAPCO and NNECO have concluded that continued safe operation is assured with the existing implementation status.
Specific details outlining implementation schedules which differ from the NUREG-0737 schedule,-
as well as the compensatory measures which are in place, are discussed in the attachments.
Where a revised implementation schedule has been identified, information regarding the need for the proposed schedule and the justification for the schedule is provided together. This format is considered appropriate due to the similar nature of Items 2a and 2b of Reference (1).
We trust you find this information responsive to the Reference (1) request.
Very truly yours, 1
CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTilEAST NUCLEAR ENERGY COMPANY W.G.C M W. G. Counsil Senior Vice President 5
U By:
h-#. Opeka Vice President Nuclear Operations 00
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STATE OF CONNECTICUT)
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Berlin
/ dir, /k M COUNTY OF llARTFORD )
Then personally appeared before me J. F. Opoka, who being duly sworn, did state that he is Vice President of Northeast Nuclear Energy Company and Connecticut Yankee Atomic Power Company, Licensees herein, that he
' is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.
J AW/. 0 Nota'rp Public /
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I Docket No. 50-213 IInddam Neck Plant Response to Generic Letter 82-05 Post TM1 Requirements Implementation i
April, 1982
Docket No. 50-213 IInddam Neck Plant INDEX Item Subject I.A.3.1 Simulator Exams II.B.2 Plant Shielding II.B.3 Post Accident Sampling II.B.4 Training for Mitigating Core Damage II.E.1.2 Auxiliary Feedwater Initiation and Flow Indication II.E.4.2 Containment Isolation Dependability, Parts 5 and 7 only II.F.1 Accident Monitoring, Items 1-6 II.K.2.10 Not Applicable II.K.3.15 Not Applicable II.K.3.19 Not Applicable II.K.3.22 Not Applicable 1
II.K.3.24 Not Applicable II.K.3.27 Not Applicable
I.A.3.1 Simulator Exams As requested by NUREC-0737, Item I.A.3.1 and Generic Letter No. 81-29, simulator examinations have been scheduled as part cf the operator license programs at the IInddam Neck Plant since January 1, 1982. As such, this item is complete.
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II.B.2 Plant Shielding In Reference (4), CYAPCO identified the Plant modifications required to facilitate post-accident Operations. These modifications have been rem-pleted as of January 1, 1982. No further act ion is required, j
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j II.B.3 Post Accident Sampling System (PASS)
Item II.B.3 of Reference (1) requires that installation of the final post accident sampling system be completed by January 1, 1982 and that final designs be available for review at that time. CYAPCO reviewed the. existing plant sampling system against the requirements of NUREG-0578 and determined that a dedicated PASS was necessary..This determination was completed in early 1980.
In Reference (12), CYAPCO informed the Staff of its intentions to comply with the inservice date for Item II.B.3 of NUREG-0737; however, the Staff was also apprised of the potential for equipment delivery delays which would preclude completion of this item by January 1, 1982. The original equipment delivery _
date for the Haddam Neck Plant PASS was July, 1981.
Prototype testing and resultant design changes delayed equipment delivery to October, 1981. CYAPCO informed the Staff in Reference (4) that a revised impicmentation date of June 1, 1982 was necessary to complete in-ota11ation, operational testing and debugging of the Haddam Neck Plant PASS.
The hardware installation was complete at the Haddam Neck Plant by April 1, 1982. Currently, operational testing of the system is underway which will be followed by approximately one month of personnel training on the functional system.
An inservice date of June 1, 1982 represents a realistically attainable completion date in which installation, testing and training can be completed.
Interim sampling techniques described in Reference (15) will remain in effect until the PASS is in-stalled and operational.
The present PASS does not include analysis capability for post accident chloride determination. Until recently, i
CYAPCO had not identified suitable equipment to properly-and safely perform this function. Chloride analysis equipment will be procured and installation and training of personnel will be completed by January 1, 1983.
The additional time required to complete this portion i-of the PASS is necessitated by the fact that no suitable equipment was available until recently. The specified completion date of January 1,1983 represents a reasonable schedule by which chloride analysis capability will be available as part of the PASS at the Haddam Neck Plant.
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i Since post-accident cloride analysis is only utilized 4
to detect the ingress of~ seawater or brackish water into the containment from the plant's cooling system, 2
the nature of the need for this capability is secondary to that of the remainder of the PASS. As such, CYAPCO considers the implementation schedule identified herein as reasonable and justified.
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II.B.4 Training for Mitigating Core Damage The training program developed in response to Item II.B.4 of NUREG-0737 was completed at the lladdam Neck Plant by December 29, 1981.
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II.E.1.2 Auxiliary Feedwater Initiation and Flow Indication Installation of a safety grade automatic initiation scheme for the auxiliary feedwater system at the IInddam Neck Plant was complete on November 13, 1981.
The Staff issued a safety evaluation and Technical Specifications for this system in Reference (5).
Safety grade auxiliary feedwater flow indication has been installed at the IIaddam Neck Plant since July 24, 1980.
CYAPCO considers these items complete for the lladdam Neck Plant.
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II.E.4.2 Containment Isolation Dependability Part 5 CYAPCO completed the actions required by Item II.E.4.2.5 of NUREG-0737 and documented the results of the review of the containment isolation setpoint at the Haddam Neck Plant in Reference (6), Additional information to support this position was docketed in Reference (7).
The NRC Staff has issued their Safety Evaluation Report concurring with this position in Reference (8). As such, this item is considered complete as of December 31, 1980.
Part 7 Part 7 of Item II.E.4.2 of NUREG-0737 requires that containment purge and vent valves close on a high radiation signal. CYAPCO's position on this item was docketed in Reference (9).
In the absence of a Staff reply on this matter, CYAPCO concludes that this position is acceptabic and considers this item complete as of July 1, 1981.
II.F.1 Accident Monitoring II.F.1.1 Noble Gas Effluent Monitor II.F.1.2 Sampling and Analysis of Plant Effluent The equipment required to be installed in accordance with Items II.F.1.1 and II.F.1.2 of NUREG-0737 at the lladdam Neck Plant is presently in place and operating under observation. CYAPCO has experienced several complications in the start-up of this system involving component failures.
The equipment vendor service representative has been assisting CYAPCO in the resolution of the start-up problems.
CYAPCO has also experienced difficulties with the calibration procedure supplied by the equipment vendor. Currently, Plant personnel are developing a revised calibration technique that will utilize several gas samples.
In addition, the vendor has developed a new calibration kit.
CYAPCO is evaluating the merits of obtaining the new kit.
Following successful calibration of the high range effluent monitors, personnel training on the equip-ment will commence.
Both the calibration and training efforts will require additional time beyond the completion date specified in Reference (4). CYAPCO intends to complete the implementation of the high range effluent monitor systems at the lladdam Neck Plant by July 1, 1982. The additional three month extension from the Reference (4) im-plementation date is necessitated to ensure correct system operation.
It is noted that the system is currently installed and functional, however, it has not been declared operational due to the complications described above.
Existing procedures for quantifying high level accidental radioactive releases docketed in Reference (16) will remain in effect until the system is fully operational.
II.F.1.3 Containment liigh Range Radiation Monitor This item was complete at the lladdam Neck Plant on January 1, 1982. An update on the status of the environmental qualification of the installed cable will be provided in response to Reference (2).
II.F.1.4 Containment Pressure Monitor This item was completed at the 11addam Neck Plant on November 13, 1981.
II.F.1.5 Containment Water Level Monitor This item was completed at the IIaddam Neck Flant on November 13, 1981.
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II.F.1.6 Containment Hydrogen Monitor Item II.F.1.6 of NUREG-0737 requires licensees to provide continuous indication of hydrogen concentration in the containment atmosphere.
Indication shall be provided in the control room.
Upon issuance of the post-TMI requirement for hydrogen monitoring instrumentation in NUREG-0578, no equipment was available commercially which met the qualification specifications of IEEE 323-1974 and IEEE 344-1975.
CYAPCO identified a commercial grade hydrogen / oxygen analyzer which was judged to be qualifiable to the requirements later specified in item II.F.1.6 of NUREG-0737. CYAPCO purchased the equipment necessary to fulfill the requirements of Item II.F.1.6.
Subsequent testing to verify the environmental quali-fication of the equipment proved less than totally successful.
In addition, material traceability of subcomponents of the analyzers was not maintained during unit fabrication. As the quality of the equipment cannot be assured at this time, CYAPCO cannot accept it for the purpose specified by NUREG-0737. As such, a revised implementation schedule is necessitated.
CYAPCO is currently pursuing a revised qualification program with the hydrogen analyzer vendor in an effort to utilize the existing equipment design.
Upon satisfactory resolution of the qualification program and quality assurance discrepancies, CYAPCO will take receipt of the qualified equipment and complete the installation of the hydrogen monitoring system at the Haddam Neck Plant.
l Safe operation is assured in the interim as manual containment sampling capability exists at the l
Haddam Neck Plant through the Containment Remote l
Particulate Sampler located in the Primary Auxiliary Building (PAB). This capability to sample the con-tainment atmosphere for hydrogen will be available during accidents where radiation levels in the PAB l
are not limiting.
I At this time, it is CYAPCO's intention to continue the qualification effort for the original hydrogen
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analyzer. Upon successful completion of the quali-l fication effort and resolution of the quality assurance l
concerns, CYAPC0 will take receipt of the equipment and affect its installation.
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CYAPCO has demonstrated good faith in its effort to procure the. equipment required by Item II.F.1.6 of NUREG-0737. A deferral of the required inservice date for hydrogen monitoring instrumentation at the Haddam Neck Plant is therefore justified. CYAPCO is t r.rgeting this item for completion by the end of the next refueling-outage, currently scheduled for March, 1983. This schedule, however, is contingent upon successful com~
pletion of the vendor's qualification program. Given the
-severity of previous difficulties with the qualification effort, we do not have a high degree of confidence in this date, but will keep the Staff informed of any major changes to the current schedule.
Docket No. 50-245 Millstone Nuclear Power Station, Unit No. 1 Response to Generic Letter 82-05 Post TMI Requirements Implementation April, 1982
Docket No. 50-245 Millstone Nuclear Power Station, Unit No. 1 INDEX Item Subject I.A.3.1 Simulator Exams II.B.2 Plant Shielding II.B.3 Post Accident Sampling II.B.4 Training for Mitigating Core Damage II.E.1.2 Not Applicable II.E.4.2 Containment Isolation Dependability, Parts 5 and 7 II.F.1 Accident Monitoring - Items 1-6 II.K.2.10 Not Applicable II.K.3.15 Not Applicable II.K.3.19 Not Applicable II.K.3.22 Not Applicable II.K.3.24 Not Applicable II.K.3.27 Common Reference Water Level
II.A.3.1 Simulator Exams As requested by NUREG-0737, Item I.A.3.1 and Generic Letter No. 81-29, simulator examinations have been scheduled as part of the operator license programs at Millstone Unit No. 1 since January 1, 1982. As such, this item is complete.
II.B.2 Design Review of Plant Shielding and Environmental Qualification for Post-Accident Operations As a result of the shielding design review, it was indicated in Reference (4) that plant modifications were necessary to facilitate the addition of water to the torus and to provide an alternate water source for the core spray and containment spray cooling water pumps from a remote location. Plant modification involve the installation of two motor operated valves (MOVs) and one manually operated valve in the cross-tie piping between the condensate storage tank (CST) and the ECCS trains. These valves will permit isolation of the torus and change the suction for the ECCS trains to the CST.
The subject valves will be installed in piping systems that are part of the torus attached piping (TAP) being analyzed per the Long-Term Torus Program.
Plant modifications necessary to install the subject valves will be incorporated into the TAP analyses to assure that such installation will not prohibit us from con-forming with the Acceptance Criteria of Appendix A to NUREG-0661 as required by Operating License No.
Completion of the TAP analyses is presently scheduled for late 1982. Out next scheduled refueling outage is scheduled for September, 1982. Therefore, the TAP analyses will not be completed in sufficient time to allow us to install these valves during the 1982 refueling outage. TAP analyses were originally in-tended to be completed by April, 1982 which would have allowed installation during the September, 1982 outage. Due to the slippage in completion of the TAP analyses, our license has been modified to allow modifications external to the containment (i.e., TAP) to be completed no later than July 1, 1983. However, since the torus must be drained and ECCS isolated during installation of the subject modifications, these valves must be installed during a refueling outage.
If in-stallation of these valves is accomplished prior to completion of the TAP analyses, compliance with our license condition cannot be assured. Therefore, in-stallation of these valves are now scheduled for the 1984 refueling outage.
o Plant modifications needed to assure conformance to the Acceptance Criteria contained in Appendix A to NUREC-0661 will be complete during the September 1982 refueling outage for those modifications inside containment and no later than July 1, 1983 for all remaining modifications.
Accordingly, the intended margins of safety in the contain-ment design will be restored and the functional performance of the containment system will be assured. The purpose of the installation of these additional valves is to allow utilization of the CST as an alternate water supply in the very unlikely situation that the torus does not function as expected during an accident. Thereforo,.
with the extensive modifications being made to the torus to assure its availability under accider.t conditions, it is no longer essential to implement these modifications to comply with the intent of this TMI Action Item.
However, we do believe it is prudent and desirable to have the capability for remote operation of tnese valves and therefore the subject valves are scheduled to be installed during the 1984 refueling outage.
It is our view that this schedule reflects the proper application of our policy of enhancing operational flexibility on a logical and resource-efficient basis recognizing the sequential nature of the analyses and modifications associated with the torus.
II.B.3 Post Accident Sampling System (PASS)
Item II.B.3 of NUREG-0737 requires that installation of the final post accident sampling system (PASS) be com-pleted by January 1, 1982 and that final designs be available for review at that time. NNECO reviewed the existing plant sampling system at Millstone Unit No. 1 against the requirements of NUREG-0578 and determined that a dedicated PASS was necessary. This determination was completed in early 1980.
The original delivery date for the PASS was July 1981, however, prototype testing and resultant design changes delayed the equipment delivery until October, 1981.
Installation efforts commenced in November, 1981, following mobilization of contractors.
NNECO informed the Staff in Reference (4) that a revised implementation date of June 1, 1982 was necessary to complete in-stallation, operational testing and debugging of the Millstone Unit No. 1 PASS.
Hardware installation was completed by April 2, 1982.
Currently, operational testing of the system is under-way which will be followed by approximately one month of personnel training on the functional system. An inservice date of June 1, 1982 represents a realistically attainable date by which installation, testing and training can be completed.
Interim sampling techniques described in Reference (15) will remain in effect until the PASS is installed and operational.
The present PASS does not include analysis capability for post accident chloridt ietermination. Until recently, NNECO had not identified, itable equipment to properly and safely perform this function. Chlo ride analysis equipment will be procured and installation and training of personnel will be completed by January 1, 1983.
Tne additional time required to complete this portion of the PASS is necessitated by the fact that no suitable equipment was available until recently. The specified completion date of January 1, 1983 represents a reasonable schedule by which chloride analysis capability will be available as part ot the PASS at Millstone Unit No. 1.
Since post-accident chloride analysis is only utilized to detect the ingress of seawater or brackish water into the containment from the plant's cooling system, the nature of the need for this capability is secondary to that of the remainder of the PASS. As such, NNECO considers the implementation schedule identified herein as reasonable and justified.
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II.B.4 Training for Mitigating Core Damage In accordance with the schedule requirements of NUREG-0737, the training program developed in response to this item was completed by October 1, 1981.
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II.E.4.2 Containment Isolation Dependability l
Part 5 NNECO completed the actions required by Item II.E.4.2.5
-of NUREG-0737 and documented the results of the review of the containment isolation setpoint at Millstone Unit'No.
1 in Reference (6).
The NRC Staff has issued their Safety Evaluation Report concurring with this position in Reference (11). As such, this item is considered complete as of February 27, 1981.
Part 7 Part 7 of Item II.E.4.2 of NUREG-0737 requires that containment purge and vent valves close on a high radiation signal. NNECO's position on this item was docketed in Reference (9).
In the absence of a Staff reply on this matter, NNECO concludes that this position is acceptable and considers this item complete as of July 1, 1981.
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d II.F.1 Accident Monitoring II.F.1.1 Noble Gas Effluent Monitors II.F.1.2 Sampling and Analysis of Plant Effluent NNECO completed the installation of equipment at Millstone Unit No. 1 in fulfillment of Items II.F.1.1 and.II.F.1.2 of NUREG-0737 by January 1, 1982.
Sub-sequently NNECO identified a serious problem with the preliminary isotopic calibration report regarding i
the monitor's response to isotopes of varying energy.
i Based on the information in this report, the monitor i
would grossly over-estimate any radioactive releases which could be postulated to occur following an accident. As such NNECO has not yet declared the system to be operational.
The equipment vendor is currently acting to resolve the calibration discrepancy. NNECO expects a satisfactory resolution from the vendor by August 1, 1982. Upon
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receipt and review of the vendor's calibration report, NNECO will determine the' acceptability of the monitors response characteristics. An in-service date of September 1, 1982 is hereby specified as that date by which Items II.F.1.1 and II.F.1.2 will 4
be complete for Millstone Unit No. 1.
NNECO maintains a reasonable level of assurance that the installed equipment will be declared operational by September 1, 1982. Acceptance of this equipment for its intended purpose, however, is entirely con-tingent upon the vendor's success at resolving the 1
discrepancy noted above. NNECO has demonstrated good faith in its effort to complete these items on the schedule provided in NUREG-0737 and we are con-l tinuing to expedite this matter.
The existing procedures for. quantifying high level accidental radioactive releases docketed in Reference l
(16) will remain in effect until this system is declared
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operational. This assures the availability of a method i
of determining the magnitude of releases until the final system is declared operational.
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II.F.1.3 Containment Radiation Monitor This item was completed at Millstone Unit No. 1 on July 1, 1981. An update on the status of the en-vironmental qualification of the installed' cable will be provided in response to Reference (2).
II.F.1.4 Containment Pressure Monitor This item was completed at Millstone Unit No. 1 on July 1, 1981.
l II.F.1.5 Containment Water Level Monitor This item was completed at Millstone Unit No. 1 on July 1, 1981.
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II.F.1.6 Containment Hydrogen Monitor Item II.F.1.6 of NUREG-0737 requires licensees to provide continuous indication of hydrogen concentration in the drywell atmosphere.
Indication shall be pro-vided in the control room.
Upon issuance of the post-TMI requirement for hydrogen monitoring instrumentation in NUREG-0578, no equip-ment was available commercially which met the qualification specifications of IEEE 323-1974 and IEEE 344-1975.
NNECO identified a commercial grade hydrogen / oxygen analyzer which was judged to be qualifiable to the i
requirements later specified in Item II.F.1.6 of NUREG-0737. NNECO purchased the equipment necessary to fulfill the requirements of Item II.F.1.6.
Subsequent testing to verify the environmental qualification of the equipment proved less than totally successful.
In addition, material traceability of subcomponents of the analyzer was not maintained during unit fabrication. As the quality of the equipment cannot be assured at this time, NNECO cannot accept it for the purposes specified by NUREC-0737. As such, a revised implementation schedule is necessitated.
i NNECO is currently pursuing a revised qualification program with the hydrogen analyzer vendor in an effort to utilize the existing equipment design. Upon satis-factory resolution of the qualification program and quality assurance discrepancies, NNECO will take receipt of the qualified equipment and complete the installation of the hydrogen monitoring system at Millstone Unit No.
1.
At this time, it is NNECO's intention to continue the qualification effort for the original hydrogen / oxygen analyzer. Upon successful completion of the qualification effort and resolution of the quality assurance concerns, NNECO will take receipt of the equipment and effect its installation.
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procure the equipment required by Item II.F.1.6 of NUREG-0737. A deferral of the required inservice date for hydrogen monitoring instrumentation at Millstone Unit No. 1 is therefore justified. NNECO is targeting this item for completion by March, 1983. This schedule, however, is contingent upon successful completion of the vendor's qualification program. Given the severity of previous difficulties with the qualification effort, we do not have a high degree of confidence in this i
date, but will keep the Staff informed of any major changes to the current schedule.
II.K.3.27 Common Reference Level A common water level reference has been established at Millstone Unit No. 1 as of January ~10, 1982. The NRC issued Amendment No. 80 to Provisional Operating License No. DPR-21 in Reference (14) which consisted of changes to the Technical Specifications to allow establishment of the common water reference level.
As indicated in Reference (14), the NRC Staff considers this item to be complete.
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Docket No. 50-336 Millstone Nuclear Power Station, Unit No. 2 Response to Generic Letter 82-05 Post TMI Requirements Implementation i
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April, 1982
O Docket No.'50-336 f
Millstone Nuclear Power Station, Unit No. 2 INDEX i
Item Subject I.A.3.1 Simulator Exams II.B.2 Plant Shielding II.B.3 Post Accident Sampling II.B.4 Training for Mitigating Core Damage II.E.1.2 Auxiliary Feedwater Initiation and Flow Indication II.E.4.2 Containment Isolation Dependsbility Parts 5 and 7 only II.F.1 Accident Monitoring - Items 1-6 II.K.2.10 Not Applicable II.K.3.15 Not Applicable II.K.3.19 Not Applicable II.K.3.22 Not Applicable II.K.3.24 Not Applicable II.K.3.27 Not Applicable 1
I.A.3.1 Simulator Exams As requested by NUREG-0737, Item I.A.3.1 and Generic Letter No. 81-29, simulator examinations have been scheduled as part of the operator license programs at Millstone Unit No. 2 since January 1, 1982. As such, this item is complete.
II.B.2 Plant Shielding In accordance with Item 2.1.6(b) of NUREG-0578, NNECO conducted reviews at Millstone Unit No. 2 to determine what equipment modifications would facilitate plant recovery following a major accident. NNECO identified that equipment lacking radiation quali-fication as well as those areas where personnel access would be prohibited due to excessive radiation ficids assuming the conservative source terms of NUREG-0578.
The equipment that was determined 4 a be lacking in radiation qualification was reported in Reference (16).
This equipment was replaced by March 15, 1982. As such this aspect of Item II.B.2 of NUREG-0737 is complete as of that date.
NNECO also initially identified in Reference (16) the vital areas and job functions in those areas where personnel access would be prohibited by the radiation fields emanating from systems circulating post accident radioactive materials.
The need for access to the areas identified in Reference (16) has since been re-evaluated and the following post accident operations requiring personnel access to vital areas have been verified as necessary.
1.
Operation of valves C11-440 and CH-340 in the "A" charging pump room.
2.
Operation of valves SI-709 and SI-400 in the piping penetration room.
Operation of valves CH-340, CH-440, SI-709 and SI-400 are necessary for long term boron precipitation control in accordance with procedures approved by the NRC Staff in Reference (17). NNECO has inves-tigated corrective actfons which would alleviate the need for direct access tc these valves and intends to provide remote means of valve operation. NNECO is currently in the process of finalizing its plans for remote valve operation, to ensure that the optimum method is selected. These modifications will be accomplifhed prior to startup from the Cycle 6 refueling outage.
L Continued Plant operation until such time that the modifications discussed above are implemented is based on the conservative nature of the assumptions utilized in the evaluations of this matter. The probability
-of occurrance of'a. design basis loss-of-coolant accident caused by a reactor coolant system break of the size, location, and orientation to necessitate
.use of the boron precipitation control procedureLis extremely remote. Further, if the facility responds to a LOCA in accordance with the assumptions and analyses of Appendix K, the radiological source term would be orders of magnitude less severe than that assumed in the initial evaluation of potential modi-fications associated with TMI Action Plan Item II.B.2 (2.1.6.b).
As such, the radiation levels in the vicinity of the subject valves would be considerably.
less severe.
The postulated phenomenon of boron precipitation causing further degradation of an already degraded core is of sufficiently low safety significance to justify continued operation until startup from the 1983 refueling outage.
The remaining post-accident operator actions identified as Items A1, A2, B1, B2 and D in Reference (16) have been re-evaluated and determined to be unnecessary.
With the approval of the procedure for post-LOCA long term cooling (Reference (17)), the valve manipulations described by Items'A1,'A2,- B1 amd B2 of Reference (16) are not longer required.
f The safety related pumps identified in Item D of Reference (16) are designed for long term post-accident operation. As such, maintenance activities immediately fallowing ~an accident will not be required. Adequate.
oil supplies.are.provided enabling long term post accident operation of all safety related pumps.
Therefore, no equipment modifications are required.
for this item.
II.B.3 Post Accident Sampling System (PASS)
Item II.B.3 of NUREG-0737 requires that installation of the final post accident sampling system be completed by January 1, 1982 and that final designs be available for review at that time. NNECO reviewed the existing plant sampling system against the requirements of NUREG-0578 and determined that a dedicated PASS was necessary. This determination was completed in early 1980.
In Reference (12) NNECO informed the Staff of its in-tentions to comply with the inservice date for Item II.B.3 of NUREG-0737; however, the Staff was also apprised of the potential for equipment delivery delays which would preclude completion of this item by January 1, 1982.
The original equipment delivery date for Millstone Unit No. 2 PASS was July, 1981.
Prototype testing and resultant design changes delayed equipment delivery to October, 1981. NNECO informed the Staff in Reference (4) that a revised implementation date of June 1, 1982 was necessary to complete in-stallation, operational testing and debugging of the Millstone Unit No. 2 PASS.
The hardware installation and testing was completed at Millstone Unit No. 2 a? cf Apell 12, 1982. Personnel training on the runctional system remains to be accom-plished.
An irservice date of June 1,1982 represents a realistically attainable completion date in which installation, testing and training can be completed.
Interim sampling techniques described in Reference (15) will remain in effect until the PASS is in-stalled and operational.
The present PASS does nor include analysis capability for post accident chloride determination. Until l
recently, NNECO had not identified suitable equip-ment to properly and safely perform this function.
Chloride analysis equipment will be procured and in-stallction and training of personnel will be completed by January 1, 1983.
The additional time required to complete this portion of the PASS is necessitated by the fact that no suitable equipment was available until recently.
The specified j
completion date of January 1,1983 represents a reasonable schedule by which chlo ride analysis capability will be availabic as part of the PASS at Millstone Unit No. 2.
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Since. post-accident chloride analysis is only utilized to detect the ingress of seawater or brackish water into the containment from the plant's cooling system, the nature of the need for this capability is secondary to that of the remainder of the PASS. As such, NNECO considers the implementation schedule identified herein as reasonable and justified.
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II.B.4 Training for Mitigating Core Damage g
In accordance with the schedular requirements of NUREC-0737, the training program developed in response to this item was completed by October 1, 1981.
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II.E.1.2 Auxiliary Feedwater Initiation and Flow Indication NNECO completed the installation of.the safety grade automatic initiation scheme for the auxiliary feedwater system at Millstone Unit No. 2 on October 13, 1980.
The safety grade flow indication was installed by August.1, 1981.
NNECO considers these. items to be complete for Millstone Unit No. 2.
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II.E.4.2 Containment Isolation Dependability Part 5 NNECO completed the actions required by. Item II.E.4.2.5 of NUREG-0737 and documented the results of the review of the containment isolation setpoint at Millstone Unit No. 2 in Reference (6). Additional information to support this position was docketed in Reference (10)-
1 The NRC Staff has issued their Safety Evaluation Report concurring with this position in' Reference (13).- As j
such, this item is considered complete as of February 27, 1981.
Part 7 Part 7 of Item II.E.4.2 of NUREG-0737 requires that containment purge and vent valves close on a high radiation signal. NNECO's position on this item was i
docketed in Reference (9).
In the absence of a" Staff reply on this matter, NNECO concludes that this position 4
is acceptable and considers this item complete as of July 1, 1981.
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c-II.F.1 Accident Monitoring II.F.1.1 Noble Gas Effluent Monitors II.F.1.2 Sampling and Analysis of Plant Effluent NNECO completed the installation of equipment at-Millstone Unit No. 2 in fulfillment of Items II.F.1.1 and II.F.1.2 of NUREG-0737 by March 11, 1982.
Sub-sequently, NNECO. identified a serious problem with the preliminary isotopic calibration report regarding-the monitor's response to isotopes of varying energy.
Based on the information in this report, the monitor would grossly over-estimate any radioactive releases which could be postulated to occur following an accident.
As such, NNECO has not yet declared the system to be operational.
The equipment vendor is currently acting to resolve the calibration discrepancy. NNECO expects a favorable response from the vendor by August 1, 1982. Upon receipt and review of the vendor's calibration report, NNECO will determine the acceptability of the monitors 3
response characteristics. An in-service date of September 1, 1982 is hereby specified as that date by which Items II.F.1.1 and II.F.1.2 will be complete for Millstone Unit No. 2.
NNECO maintains a reasonable level.of assurance that the installed equipment will be declared operational by September 1, 1982. Acceptance of this equipment for its intended purpose however, is entirely contingent upon the vendor's success at resolving the discrepancy noted above. NNECO has demonstrated good faith in its effort to complete these items on the schedule provided in NUREG-0737 and we are continuing to expedite this matter.
The existing procedures, docketed in Reference (16),
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accidental radioactive releases will remain in effect until this system is declared operational. This assures the availability of a method of determining the magnitude of releases until the final system is declared operational, i
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II.F.1.3 Containment liigh Range Radiation Monitor This item was cor.pleted at Millstone Unit No. 2 on March 11, 1982. An update on the status of the en-vironmental qualification of the' installed cable will be provided in response to Reference (3).
II.F.1.4 Containment Pressure Monitor This item was completed at' Millstone Unit No. 2 on
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March 11,_1982.
II.F.1.5 Containment Water Level Monitor This item was completed at Millstone Unit No. 2 on March 11, 1982.
II.F.1.6 Containment Ilydrogen Monitor This item was completed at Millstone Unit No. 2 on March 11, 1982.
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