ML20056G228
| ML20056G228 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/18/1993 |
| From: | James Anderson Office of Nuclear Reactor Regulation |
| To: | Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| TAC-M86916, NUDOCS 9309020276 | |
| Download: ML20056G228 (14) | |
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UNITED STATES i{J.-
NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D C. 205S5-0001 August 18, 1993 Docket No. 50-245 i
Mr. John F. Opeka Executive Vice President, Nuclear Connecticut Yankee Atomic Power Company Northeast Nuclear Energy Company Post Office Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
SUBJECT:
REVIEW 0F ISAP SUBMITTAL DATED JUNE 18, 1993 (TAC M86916)
In a letter dated June 18, 1993, Northeast Nuclear Energy Company (NNECO) submitted to.the NRC an updated report on the Millstone Unit No.1 Integrated Safety Assessment Program (ISAP).
In accordance with the Program Plan identified in Amendment No. 56 for Millstone Unit No. 1, the NRC has 60 days from receipt of the letter to state whether or not the staff concurs with NNEC0's positions stated in the report.
The following is the NRC staff's review of NNEC0's ISAP report dated June 18, 1993.
By letter dated December 30, 1992, the NRC staff issued its review of all the ISAP topics. This letter was followed up with a letter dated April 14, 1993, which completed the NRC review of your October 23, 1992, ISAP update report.
The April 14, 1993, NRC letter concluded that of the 133 total ISAP topics (as of October 23, 1992), that 30 should remain open within ISAP, and 103 are resolved.
NNECO's June 18, 1993, ISAP update indicated that 9 new topics have been opened. The NRC staff has reviewed the June 18, 1993, ISAP update and has concluded that of the 142 ISAP topics, 33 topics should remain open within ISAP.
Enclosure I lists all the ISAP topics NNECO considers open and the NRC staff's understanding of them, Enclosure 2 lists the ISAP topics NNECO considers closed but are still under NRC staff review, and Enclosure 3 lists the ISAP topics the NRC staff agrees can be closed out.
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i Mr. John F. Opeka August.18, 1993 Further NRC review of closed ISAP topics, if any, will be performed by inspection or audit. The NRC staff remains available to discuss these issues with you.
Sincerely, Original signed by:
James W. Andersen, Acting Project Manager l
Project Directorate I-4 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation l
Enclosures:
I.
ISAP topics considered open i
by NNECO 2.
ISAP topics NNECO considers closed but are still under staff review I
3.
ISAP topics the staff agrees can be closed cc w/ enclosures:
See next page Distribution:
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t Mr. John F. Opeka August 18, 1993 Further NRC review of closed ISAP topics, if any, will be performed by l
inspection or audit.
The NRC staff remains available to discuss these issues with you.
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Sincerely, b.
ames W. Andersen, Acting Project Manager Project Directorate I-4 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosures:
1.
ISAP topics considered open by NNECO 2.
ISAP topics NNECO considers closed but are still under i
staff review i
3.
ISAP topics the staff agrees can be closed cc w/ enclosures:
See next page i
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Mr. John F. Opeka Millstone Nuclear Power Station Northeast Nuclear Energy Company Unit I cc:
Gerald Garfield, Esquire R. M. Kacich, Director Day, Berry and Howard Nuclear Licensing Counselors at Law Northeast Utilities Service Company City Place Post Office Box 270 Hartford, Connecticut 06103-- 199 Hartford, Connecticut 06141-0270 W. D. Romberg, Vice President J. P. Stetz, Vice President Nuclear Operations Services Haddam Neck Plant Northeast Utilities Service Compar.y Connecticut Yankee Atomic Power Company Post Office Box 270 362 Injun Hollow Road Hartford, Connecticut 06141-0270 East Hampton, Connecticut 06424-3099 Kevin McCarthy, Director Regional Administrator Radiation Control Unit Region I Department of Environmental Protection U.S. Nuclear Regulatory Commission 165 Capitol Building 475 Allendale Road Hartford, Connecticut 06106 King of Prussia, Pennsylvania 19406 Allan Johanson, Assistant Director First Selectmen Office of Policy and Management Town of Waterford Policy Development and Planning Division Hall of Records 80 Washington Street 200 Boston Post Road Hartford, Connecticut 06106 Waterford, Connecticut 06385 S. E. Scace, Vice President P. D. Swetland, Resident Inspector Millstene Nuclear Power Station Millstone Nuclear Power Station Northeast Nuclear Energy Company c/o U.S. Nuclear Regulatory Commission Post Office Box 128 Post Office Box 513 Waterford, Connecticut 06385 Niantic, Connecticut 06357 H. F. Haynes, Nuclear Unit Director G. H. Bouchard, Director Millstone Unit No. I Nuclear Quality Services Northeast Nuclear Energy Company Northeast Utilities Service Company Post Office Box 128 Post Office Box 270 Waterford, Connecticut 06385 Hartford, Connecticut 06141-0270 Nicholas S. Reynolds Winston & Strawn 1400 L Street, NW Washington, DC 20005-3502 i
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ENCLOSURE 1 ISAP TOPICS CONSIDERED OPEN BY NNECO Topic Number Title Comment 1.06 Seismic Qualification By letter dated 9/4/91, the staff stated that of Safety-Related NNEC0's ccamitment to complete the remaining
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l Piping modifications during cycle 14 and 15 refueling l
outages was acceptable and that NNECO should submit any schedule changes to the NRC for review.
r In the ISAP update dated 6/18/93, NNEC0 stated that developments in the area of seismic analytical techniques may provide further bases for resolution. NNECO also stated that the issue would still be resolved by cycle 15. The staff notes the change in resolving this issue and awaits NNECO's submittal outlining the plans.
1.07 Control Room Design All the remaining human engineering discrepancies Review are scheduled to be closed out by the cycle 15 refueling outage.
1.09 Regulatory Guide 1.97 By letter dated 4/24/91, the NRC provided a safety Instrumentation evaluation with a list of open items. NNECO
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addressed these in a letter dated 9/11/91 and in a 1
l letter dated 11/15/91 notified the NRC of 5 additional type A variables. NNEC0 provided further information in submittals dated 3/31/92, 9/8/92, 10/23/92, 7/21/93, and 7/30/93. The NRC is currently reviewing these documents and is awaiting 2 additional NNECO submittals.
1.14 Appendix J -
NNEC0 has scheduled some of the modifications to Modifications be completed during the cycle 14 and 15 refueling outages. NNECO is currently developing a proposal for resolution of the remaining Appendix J issues.
1.43 Water Hammer Changes include the addition of an undervoltage alarm from the vital AC bus as well as an additional DC powered ATWS level indication on the main control board and upgraded procedural guidance. Most of the modifications have been completed and the remainder are scheduled to be completed during the cycle 14 refueling outage.
The NRC staff noted in NNECO's 6/18/93 ISAP update that subtopic 1.43.1, Reactor Vessel Overfill Protection, was proposed for closure. The NRC staff is in the process of reviewing all the Generic Letter (GL) 89-19 responses on a generic basis and, therefore, will not review plant specific issues. The NRC staff will keep this subtopic open until the staff's generic review is completed.
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-1.52 SRV Failure - Setpoint NNECO has_been keeping this topic'open to address Drift recommendations from the'BWR Owners' Group (BWROG)
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which was' addressing this issue. NNEC0 has determined that the most appropriate modification j
for Millstone 1 is to replace three of the i
existing pilot discs. This _ portion of the project -
will be completed during the cycle 14 refueling l
outage. The remaining three discs will be
-i replaced during the cycle'15 refueling outage if l
deemed appropriate (consistent with BWROG
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recommendation to replace the discs in two phases 1
in order to verify performance and effectivenus) j 1.101 Fire Detection System This topic involves certain modifications _to the j
Code Compliance fire detection system to ensure compliance with l
the intent of the National Fire Protection-l Association (NFPA) code. Any modifications which l
will result in a significant change in the scope of the existing project assignment will be evaluated in a future ISAP report.
1.102 Fire Suppression lhis topic involves certain modifications to the System Code Compliance fire suppression system to ensure compliance with_
l the intent of the NFPA code. Any modifications.
which will result in'a significant change in the j
scope of the existing project assignment will be i
evaluated in a future ISAP report.
j 1.104 Pump Flow Rate This topic addressed un evaluation of procuring i
Instrumentation and installing instrumentation necessary to measure' the flowrate of various pumps. The installation of instrumentation to monitor flow through portions of the service water system'is i
scheduled for completion during the cycle 14 i
refueling outage. The remaining pumps are being reviewed as part of NNECO's Inservice Testing (IST) program. NRC letter dated 2/18/93 granted some of NNECO's IST reliefs, requested additional information, and denied some requests. NNECO is currently developing a proposal for resolution of l
the remaining issues.
i 1.106 Station Blackout Modifications to resolve the station blackout l
issue are scheduled for completion during the cycle 14 refueling outage.
In a letter dated j
8/6/92, NNECO informed the staff that the cycle 14 t
outage would be delayed until early 1994.
By i
letter dated 8/25/92 the staff approved this i
revised schedule.
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' I 1.111 Motor Operated Valve NNECO responded to GL 89-10, certifying that
- Testing, detailed programs were being developed to address i
GL 89-10 safety-related motor operated valve testing and j
l surveillance.
By letter dated 5/4/92, NNECO
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j' advised the staff of a change in the program description schedule till 12/31/92.
In a: letter dated 10/22/92, the staff stated that the schedule l
was acceptable, however, NNECO's commitment to meet the schedule requested in the first paragraph of item i (and item k) of GL 89-10 for complet'ng recommended actions a through h of the genoric letter by three refueling outagte after D /28/89 l
(cycle 15), remains unchanged.
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1.112 Service Water System This topic addresses GL 89-13, " Service Water Evaluation, GL 89-13 System Problems Affecting Safety-Related i
Equipment." In a letter dated 4/3/92, NNECO
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provided an update on the implementation of the' five recommended actions. NNEC0 stated that items 1,2,3, and 5 were accomplished on schedule and l
that item 4 is scheduled for the cycle 14 refueling outage.
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1.113 Hardened Wetwell Vent, This project involves installation of a hardened j
GL 89-16 wetwell vent.
In a meeting with the NRC staff on 4/22/93, NNECO presented an alternative' design for j
the hardened vent. Due to the need to complete the associated engineering design, the original l
schedule was changed. However, the installation is still scheduled for the cycle 14 refueling outage.
1.118 Plant Heating Steam This topic involves the modifications necessary System for restoration of the heating steam system. Most of the modifications were completed in the 1991 refueling outage and the remainder were to be completed by the end of 1992. NNECO is reassessing the relative merits of completing the last phase of this project and will inform the staff of the outcome of the assessment. The NRC staff notes the change in schedule.
1.119 Resolution of This topic encompassed NNECO's plant-specific Unresolved Safety response to USI A-46, " Seismic Qualification of i
Issue A-46 Equipment in Operating Plants." NNECO submitted-its response on 9/21/92.
In a letter dated 11/23/92, the staff approved NNECO's schedule for implementation. The seismic evaluation report is scheduled to be completed 180 days following the' completion of the cycle 15 refueling outage.
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. 1.120 Purge and Vent Valve This topic involves providing a new isolation Auto-Closure input signal to the purge and vent system valves for the primary containment on high radiation.
NNECO has committed to do this modification during the cycle 14 refueling outage.
1.122 Split loss-of-Normal By letter dated 9/27/91, the NRC provided its Power Logic position that the Millstone 1 undervoltage protection scheme should be implemented with a split-logic design. NNECO responded on 11/30/92, indicating that this modification would be evaluated in the next ISAP update report.
In the 6/18/93 ISAP update, NNEC0 stated that it plans to implement the modifications associated with this project in the cycle 15 refueling outage.
The NRC staff is currently reviewing the proposed modifications.
1.123 LPCI/CS Pipe NNECO's postaccident analyses indicate that the Temperature torus water temperature could reach temperatures Modifications as high as 207*F following a design basis loss of coolant accident. NNECO initiated an assessment which will analyze the low pressure coolant injection (LPCI) and core spray (CS) piping to ensure that design code stress levels will not be exceeded during postaccident conditions. An ISAP evaluation will be performed upon further definition of the project scope.
1.124 MSIV ASCO Solenoid In September 1989, the NRC notified licensees of a Valve Replacement potential common mode failure with ASCO dual-coil solenoid valves that could impact main steam isolation valve (MSIV) operability. The existing qualified life of the solenoid valves is July 1994. The proposed project is to replace the solenoid valves thus maintaining their compliance with 10 CFR 50.49. Do to the high ISAP ranking and the need to maintain compliance with 10 CFR 50.49, NNEC0 scheduled the modifications for the cycle 14 refueling outage.
1.125 TBSCCW Heat Exchanger NNECO analysis has concluded that the selected Upgrade turbine building secondary closed cooling water (TBSCCW) system heat exchanger is operating at approximately twice the shell side design flow.
This has been the normal system alignment for many years, and no indication of tube damage has been detected. An evaluation has concluded that the heat exchangers are presently operable.
The proposed project to replace the heat exchangers is under evaluation and will be included in a future l
ISAP evaluation.
1.126 BWR Stability Following an instability event at LaSalle Unit 2 in March 1988, the NRC staff, in conjunction with the BWROG and General Electric performed studies related to the event. The NRC staff issued SECY-92-386 on 11/16/92, which conveyed the results of the studies and provided several long-term corrective actions. NNEC0 will evaluate any appropriate hardware modifications within ISAP and schedule the modifications accordingly.
2.06 Condenser Retube This topic addressed the replacement of the existing 70/30 copper-nickel condenser tubes with titanium tubes.
The retubing is scheduled for the cycle 14 refueling outage.
2.103 Battery Charger This topic addressed the replacement of existing Replacement battery chargers with battery-eliminating type, self-regulating chargers. The project is scheduled for the cycle 15 refueling outage.
2.107 Class IE Generator This topic addresses whether sufficient protection Antimotoring exists to prevent damage or degradation in the Protection event any safety-related power source becomes inadvertently powered by its associated bus, when the generator is shut down. The modifications are scheduled to be completed during the cycle 15 refueling outage.
2.108 Generator Antimotoring This topic evaluated the need for supplementary Protection While reverse current protection for the main generator.
Shutdown The modifications are scheduled to be completed during the cycle 15 refueling outage.
e 2.116 Replacement of CU-28 This topic originally involved the replacement of Motor Operator valve CU-2 and its motor-operC ar, and the installation of a motor operated valve (MOV) in the reactor water cleanup inlet piping immediately outside the drywell.
The necessary vent and drain connections for Appendix J testing was also to be installed.
In the 6/18/93 ISAP update, NNECO r
stated that following an improvement in r
maintenance activities associated with these valves and subsequent satisfactory local leak rate testing results, a reassessment of the need to replace this valve was performed. The reassessment concluded that the modifications were not necessary and won't be completed. However, as discussed in the 10/23/93 ISAP update, NNECO determined that replacement of the C0-28 motor operator and cabling could be incorporated into this topic. The title has been changed to reflect this change. The modifications are scheduled for the cycle 14 refueling outage.
2.120 Atmospheric Control This topic addresses a current engineering study System Containment which considers possible modifications to existing Isolation Valves valves or the procurement of new valves to mitigate high valve failure during local leak rate testing. Some modifications have been completed and NNECO has submitted a corrective action plan which addressed future modifications. The modifications do not require significant resources, therefore, NNEC0 will not perform the study and the modifications will be completed during the cycle 14 refueling outage.
2.124 Replacement of IC In response to GL 89-10, " Safety-Related Motor-System Valves Operated Valve Testing and Surveillance." and a subsequent evaluation, NNECO performed an engineering evaluation to demonstrate with reasonable assurance, that safety-related MOVs would operate as intended. The evaluation concluded that all safety-related MOVs (including 1C-1,2,3, and 4) will operate as required.
Subsequent to a recent reassessment, NNEC0 determined that modifications to IC-1,2, and 3 are not necessary and will not be completed. However, in order to increase the reliability and repeatability of IC-4, a NNECO assessment is underway to determine if the motor operator on IC-4 can be replaced with a previously-procured motor operator. Any changes will be included in future ISAP updates. Additionally, the NRC staff notes that valve CU-28 is now being addressed under ISAP topic 2.116.
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2.126 Emergency Service The emergency service water (ESW) and service Water / Service Water water (SW) pump discharge piping in the intake Headers structure is experiencing external corrosion due to salt water exposure. The proposed project is to redesign and replace the ESW and SW pump discharge headers. The modifications are currently scheduled for the cycle 14 refueling i
outage.
2.127 Replacement of LP-The motor operators for these valves are currently 43A/B, LP-44A/B, and not required to be environmentally qualified (EQ).
1C-10 Motor Operators The proposed evaluation involves replacement of the motor operators for the valves with operators that are EQ. This potential modification could provide improvement in the area of high energy line break shutdown methods.
Further developments regarding this topic will be provided in future ISAP reports.
2.128 Low Pressure A Turbine Keyway cracking in the A low pressure (LP) turbine Rotor Replacement rotor has progressed to the extent that inservice inspections of the rotor would have to be performed more frequently than every refueling outage. The proposed project is to replace the shrunk-on disc type A LP rotor with a sclid monoblock rotor. The project is scheduled for the cycle 14 refueling outage.
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ENCLOSURE 2 ISAP TOPICS NNECO CONSIDERS CLOSED BUT ARE STIll UNDER STAFF REVIEW 1.108 Torus Vacuum This topic addressed concerns associated with results of other plant reviews conducted in response to Generic Letter 88-14, " Instrument Air Supply System Problems Affecting Safety-Related Equipment." Unit I containment is configured with two redundant vacuum breaker relief lines from the torus to the reactor building.
Each line has an air-operated butterfly valve and a check valve.
Since the air-operated butterfly valves fail open on a loss of air or AC power, the specific concern relates to their inability to function as the second valve of the two valve containment isolation function. NNECO performed an analysis to determine the maximum possible benefit that could be derived from resolving this issue.
In a letter dated 11/30/90, NNECO stated that the project received a very low score and ranking.
Therefore, NNECO concluded that the project was not warranted and the topic should be closed.
This topic is under staff review and, therefore, should remain open.
1.121 Post Accident Hydrogen This topic had previously been discussed under Monitor topic 1.11.
In a letter dated 6/10/92, NNEC0 submitted its reevaluation for this issue. NNEC0 maintains that no modifications are warranted and that this topic should be closed.
The NRC staff is currently reviewing this issue and, therefore, the topic should remain open.
i ENCLOSURE 3 ISAP TOPICS THE STAFF AGREES CAN BE CLOSED 1.16 10 CFR 50, Appendix R By letter dated 11/6/85 the NRC staff issued an exemption to certain Appendix R requirements, partly based on the licensee's commitment to implement 4 proposed modifications.
In a letter dated 7/31/86, NNECO identified 8 additional items to be included under the scope of this topic.
By letter dated 12/10/86, NNECO submitted its fire protection evaluation entitled "10 CFR 50 Appendix R Compliance Review," which updated NNECO's positions on Appendix R.
In NNECO's ISAP letter dated 8/4/87, NNEC0 stated that all proposed modifications (12 total topics) had been completed or were scheduled to be completed by the end of the 1987 refueling outage (11/9/88 ISAP update reported them completed), except for several aspects of topic 1.16.6 (installation of a water curtain, protecting the turbine building floor supports and protecting the structural steel in the mezzanine area). NNECO concluded that these items are not necessary to comply with Appendix R and referenced the 12/10/86 NNECO letter. Since the remaining aspects of topic 1.16.6 are not necessary to comply with Appendix R, the NRC staff agrees that this topic can be closed.
1.40 Bolting Degradation or In NUREG-1184, the staff made a recommendation for Failure a walk-down checklist to reinforce the need for more frequent visual examinations. NNECO, in a letter dated 9/29/89, committed to evaluate this as a level-of-effort activity if plant-specific concerns arise and, therefore, consider this topic closed.
In NRC Inspection Report 50-245/91-24, dated November 26, 1991, the NRC inspector and NNECO discovered several loose anchor bolts on air handling units which are important to safety. The inspector concluded that the long-term corrective action plan for Millstone 1 anchor bolts was an unresolved item, therefore, the NRC staff considered this topic still open. NNECO has since developed a program to periodically inspect anchor bolts for excessive corrosion during extended outage periods. This unresolved item was closed out in Inspection Report 50-245/93-16, dated 7/22/93 based on the inspector's review.
Therefore, the NRC staff considers this ISAP topic closed.
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1.117 Safety Parameter This topic encompasses the addition of several Display System Upgrade parameters to the safety parameter display system due to the implementation of revised emergency operating procedures, and the improvement of several trending displays. Some work was completed during the 1991 refueling outage and the remainder of the work was completed in April 1993.
Therefore, the NRC staff agrees that this topic can be closed.
1 1.127 Rx Vessel Level Generic Letter 92-04 requested information regarding the adequacy of, and corrective actions for, BWR vessel level instrumentation with respect to the effects of noncondensible gases on system operation. NNECO completed a modification in which a continuous backflush of the condensing chamber reference legs occurs. This modification prevents the buildup of noncondensible gases in the reference leg.
In a letter dated 2/22/93, the NRC staff found the modifications acceptable and, 1
therefore, this topic can be closed.
i 2.106 Diesel Air Start NNEC0 performed a visual boroscope inspection of System Upgrade the air receiver during the 1991 refueling outage.
The inspection revealed minor corrosion which was easily removed. Another inspection is scheduled for the cycle 14 refueling outage.
In the 6/18/93 ISAP update, NNECO stated that this topic will be completed as a routine activity and does not need to be followed as a formal ISAP topic. The NRC staff agrees that this topic can be closed.
2.123 Chemistry Laboratory This topic involves installation of an independent HVAC System heating, ver llating, and air conditioning system for the chesustry laboratory. The project was completed in January 1993. Therefore, the NRC staff agrees that this topic can be closed.