ML20059E808
| ML20059E808 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Haddam Neck, Comanche Peak File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/04/1994 |
| From: | Fox B NORTHEAST UTILITIES SERVICE CO. |
| To: | Rogers K, Selin I, The Chairman NRC COMMISSION (OCM) |
| References | |
| NUDOCS 9401120264 | |
| Download: ML20059E808 (14) | |
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UtilillPS byNleW Nrthudrubdes SentMbuipany P.O Box 270 Hartford, CT 06141-0270 (203) 665-5113 Fax (203) 665-3581 Benwud M. Fox President and Chief Fxecutive Officer January 4, 1994 Chairman Ivan Selin Commissioner Kenneth C. Rogers Commissioner Forrest J. Remick Commissioner E. Gail de Planque U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Chairman and Comissioners:
We appreciate having had the opportunity on December 9, 1993, to brief the Comission on the issues and challenges facing the Northeast Utilities' nuclear organization.
Presentations such as these represent an effective means of comunicating to you the status of both our challenges and accomplishments. We hope that we have-left you with an improved understanding of our continuing efforts in pursuit of operational excellence, along with an appreciation of our commitment to nuclear generation as an integral part of the Northeast Utilities System strategy for meeting future electrical demand.
With respect to the performance objectives of Northeast Utilities, I wish to reiterate the three step strategy for restoration of operational excellence that we outlined during our discussion.
First and foremost, we will vigorously communicate the unconditional expectation that safe and conservative operation is the only number one priority.
Second, we will establish and maintain the most effective organizational structure and staff it with the best individual available for each position.
Third, Northeast Utilities will continue its financial comitment to our nuclear units by assuring that all necessary resources are made available.
A number of questions posed by the Commission during our presentation required additional details to answer fully.
These follow-up details are presented herein as attachments.
, provides a reconciliation, on a major project basis, of the capital program for the Northeast Utilities System (Millstone Station,
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Haddam Neck Plant, and Seabrook Station) for the 1992 - 1995 period. The 4
comparison shows that the current projection of capital expenditures over this period is greater than the total program presented in May 1992, when adjusted for one-time accounting changes.
We have provided additional
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9401120264 940104 PDR ADOCK 05000213 l
P PDR
Page 2 January 4, 1994 project level detail for major project scope changes (i.e., greater than approximately $3 million), and other projects which may be of interest to you.
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- indicates the authorized staffing levels and current projected staffing levels for the nuclear organization within the Northeast Utilities System.
The attachment shows an increase of 290 positions from the " Base" 1992 levels to the Latest Approved 1995 level.
Attachment 3
addresses questions regarding our Integrated Safety Assessment Program and Cost Beneficial Licensing Action experience.
l summarizes our Individual Plant Examination and Individual Plant Examination for External Events status and conclusions.
Again, thank you for the invitation to brief the Commission on these important topics.
We look forward to future opportunities to discuss issues of mutual interest with the Connissioners or Senior Staff as may be appropriate.
Should you require additional information on these or other Northeast Utilities matters, please feel free to contact me directly, or Mr. Richard M. Kacich at (203) 665-3298.
Very truly yours, V
cc:
J. M. Taylor, Executive Direc r for Operations T. T. Martin, Region I Administrator P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 W. J. Raymond, Senior Resident Inspector, Haddam Neck Plant D. H. Jaffe, NRC Project Manager, Millstone Station
ATTACHMENT 1 NU Capital Program Reconciliation As was stated at oJr December 9,1993 meeting, Northeast Utilities (NU) has met and will continue to meet our commitment to provide the capital funding necessary to support safe and reliable nuclear operations.
The following paragraphs and associated graph and table reconcile the changes to the 1992 - 1995 capital projections that have occurred at Millstone Station, the Haddam Neck Plant, and Seabrook Station between May 13, 1992 and December 1, 1993.
Millstone Station The 1992 - 1995 cumulative capital expenditures for Millstone Station have increased by over $51 million. This increase occurred even though there was a large accounting adjustment that " decreased" the 1992 capital expenditures at Millstone St d on.
Because of this adjustment, the Millstone Station capital budget was adjusted downward to reflect $22 million in Millstone Unit No. 2 Steam Generator removal costs.
These costs had been included in the 1992 -
1995 cumulative capital projection provided in May 1992.
The most significant addition to capital since May 1992 has been the new Millstone Site Technical Support Building and associated modifications to the existing North Access Point Building.
These projects increased our current projection by a combined total of nearly $26 million.
In addition, projected 1992 - 1995 Millstone Station capital expenditures increased by an additional
$15 million due to the acceleration of the Millstone Unit No. 3 Moisture Separator Reheater project from the 1997 to the 1995 refueling outage.
Haddam Neck Plant The 1992 - 1995 cumulative capital expenditures for Haddam Neck Plant have j
decreased by $36 million.
There have been three major changes that have i
brought about this reduction.
The first is the elimination of $21 million in surplus capital program contingency funds.
These funds are used to reserve funding in the capital program for as-yet-undefined projects.
In May 1992, the Haddam Neck Plant carried contingency funds for 1992 of $6.7 million.
These funds were not required and the capital budget was subsequently reduced.
In order to reduce the possibility of a similar problem in future years, the capital program at the Haddam Neck Plant reduced or eliminated contingency funds in years 1993 -1995.
Greater emphasis has been placed on defining specific capital projects for the early years in the program.
Contingency funds continue to make up a large portion of the later year capital projections.
Two other contributors to the decrease were the elimination of two projects via the Integrated Safety Assessment Program (ISAP) and deferral of the Safety-Related Piping Support project.
Both the Control Room Habitability and the Tornado Missile Protection projects were cancelled in 1993 because of their marginal benefit to safety, resulting in a combined decrease of )
I
$5.5 million.
The Safety-Related Piping Support project deferral (due to our proposal to provide a more cost-effective alternative resolution) reduced the j
1992 - 1995 program by nearly $4 million.
Egahrpok Station For the period 1992 - 1995, the cumulative capital expenditures for Seabrook Unit I have decreased by about $8 nillion, which includes the Main Plant Computer Replacement project which will be completed with an expected underrun of approximately $2.7 million.
There was an additional large impact from an accounting credit of $8 million received in 1992 for a contractor settlement, i.e., a decr ease in the capital budget which does not represent a decrease in actual spending in capital projects.
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NU Continues to Maintain its Financial Commitment to Nuclear Power Total Capital Expenditures
$ Millions 250-Cumulative Total 1992-95 200
$ Millions 5/13/92 Letter 435 Current Projection 433 150-100-50-0 1992 1993 1994 1995 5/13/92 Letter to NRC Current Projection Note: The current projection includes $100 mi!! ion in 1992 for the replacement of Millstone 2 steam generators and only
$11 million in 1993.
TABLE NOTES 1.
The following table identifies and briefly explains chances in the NU nuclear capital program since the May 13, 1992 letter to the NRC.
2.
The first line titled "May 1992 Program" is the capital program as it was reported to the NRC on May 13, 1992.
Line two is the May 1992 capital projection reduced in 1992 to reflect the Millstone Unit No. 2 Steam Generator removal adjustment and the Seabrook Station contractor settlement.
Line three is the capital program as of December 1,1993.
The " Difference" line identifies the changes which have occurred in the NU capital program between the adjusted May 1992 projection and the current December 1993 projection.
3.
The lower portion of the table is a list of the significant individual project revisions which have contributed to the " Difference" line.
4.
The "Other Project Revisions" line at the bottom of the table is the amount of the " Difference" that has not been explained by the list of significaat projection revisions.
"Other Project Revisions" represents the net impact of less significant increases and decreases on the capital program. -.
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NU CAPITAL PROGRAM RECONCILIATION
( $ MILLIONS )
CAPfTALPROGRAM PROJECTK)NS 1992 1993 1994 1995 92-95 CCMMENTS May 1992 Program 204.8 96.3 70.3 63.1 434.5 As provided to the NRC on May 13,1992 Adjusted May 1992 Program 175.0 96.3 70.3 63.1 404.7 Adjustments for Millstone 2 Steam Generator Removal & Seabrook Contractor Settlement December 1993 Program 148.5 102.0 101.1 81.6 433.2 Difference
-26.5 5.7 30.8 18.5 28.5 PROJECTTITLE Millstone Site New Technical Support Building 11.2 12.4 23.6 New project Millstone Site Warehouse Consolidation 0.2 2.7 0.8 3.7 New project Millstone Site Personal Computers 1.3 1.3 1.3 3.9 Budgeted outside nuclear org. in 1992 Millstone 1 Condenser Retube
-6.7
-6.7 13.4 Refueling Outage delayed from 1993 into 1994 Millstone 1 Low Pressure "A" Turbine Rotor Replace
-2.9
-3.1 6.6 0.6 Refueling Outage delayed from 1993 into 1994 Millstone 1 Relocate Service Water /ESW Suction Heade 1.9 5.4 7.3 New project Millstone 1 Control Room Habitabilty
-3.4
-1.1
-3.9
-8.4 Project eliminated via ISAP Millstone 2 Steam Generator Installation 0.8 10.5 11.3 Capitalization of station support of project Millstone 3 Moisture Separator Reheater Tube Bundle 0.4 4.3 10.4 15.1 Accelerated from '96 '97 Millstone 3 Erosion / Corrosion Refueling Outage 5 0.5 2.7 3.2 New project Haddam Neck Analyze Safety Related Piping Supports
-0.1
-0.8
-2.9
-3.8 Deferred until 96 '97 Haddam Neck Control Room Habitability
-2.5
-1.5
-4.0 Project eliminated via ISAP Haddam Neck Tornado Missile Protection
-0.9
-0.6
-1.5 Project eliminated via ISAP Haddam Neck Spent Fuel Pool Rerad
-4.0
-2.6 3.7
-2.9 Deferred & $2.7 million of budget to removal Haddam Neck Capital Program Contingency
-6.7
-0.3
-7.3
-6.8
-21.1 Specific capital projects defined for '92 '95 Seabrook 1 Main Plant Computer Replacement
-0.7
-2.1 0.1
-2.7 Project will be completed under budget Seabrook 1 Decontamination and I&C Hot Shop
-1.0
-3.0
-4.0 Project cancelled Other Project Revisions
-10.2 L2
-0.5 14.7 fL2 Difference not explained by the above revisions Total Project Revisions
-26.5 5.7 30.8 18.5 28.5
4 ATTACHMENT 2 NU Nuclear Staffing i
Since the December 9, 1991 presentation to the Staff which proposed the
' October 200,"
NU's combined nuclear staffing (including Seabrook) has increased from 3040 to the current level of approximately 3270 employees.
By the end of 1995, the combined nuclear staffing is projected to be 3335 positions, 328 greater than the " Base" level.
As the diagram demonstrates, the Latest Approved is approximately 139 personnel less in the year 1995 than were contained in our 1992 Total projection. This difference of 4 percent in total personnel complement is the 1
result of two factors.
First, the integration of various activities within our Performance Enhancement Program with the aim of eliminating unnecessary redundancies and overlap accounts for an approximate 1 percent reduction. The expectation of such efficiencies was identified to tne NRC in 1992 as a goal, and should have a favorable affect on the company's operational and support capabilities.
The remaining 3 percent is due to a change in accounting for authorized staffing.
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Northeast Utilities Nuclear Staffing 3,500 -
a-si 3,000 -
- n. ;..
2,500 -
l 2,000 -
4 i
1,500
{
1,000 500
/
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i 1992 1993 1994 1995 fdE4?58id Base E5555'M Oct.1991 I IFB)
Latest "200" Additions Approved Additions
-m-_
1992 1993 1994 1995 Base Oct 91 3,045 3,029 3,032 3,007
- 4. 1991 *200" Additions 12/9/91 141 200 208 208 s
PEP Additions 6/4/92 10.2 2.03 2_41i 23.2 Total 3,288 3,438 3,485 3,474 (2)
Latest Approved 12/20/93 3,134 3,270 3,367 3,335 (1)
+ Includes Millstone, Haddam Neck, and Seabrook.
Latest Approved (as of 12/20/93) includes the effects due to Engineering integration.
. Year End staffing levels for 1991 were 3,040 employees, for 1992 were 3,134 employees, and for 1993 were approximately 3,270 employees.
+ (1) This value includes an approximate 3% reduction from (2) due to a change in accounting for authorized staffing.
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ATTACHMENT 3 NU Experience with ISAP and CBLAs Inteorated Safety Assessment Procram (ISAR1 The ISAP has been utilized on the Haddam Neck and Hillstone Unit No. I plants since the mid-1980s.
More recently, the NRC issued license conditions for the Haddam Neck Plant and Hillstone Unit No. I on February 26, 1992 which require these units to each implement an ISAP.
It is our intent to expand ISAP to also include Hillstone Unit Nos. 2 and 3.
Overall integrated assessment was endorsed as a valuable concept for effective and efficient implementation of projects in a letter dated April 5, 1984."'
In this letter, the Staff acknowledged that the ISAP process is an appropriate vehicle for deferring specific actions to levelize workload.
Essentially all significant Haddam Neck Plant and Hillstone Unit No. I plant modifications are evaluated and ranked using the ISAP methodology.
ISAP has proven to be a very valuable prioritization and scheduling tool.
Six-month update reports are provided to the Staff, consistent with the ISAP Program Plan.
The Program Plan for implementation of ISAP includes a threshold concept which can be employed to drop potential plant modifications or topics whose calculated benefits are not commensurate with the cost.
In the past, utilization of the drop threshold was not as successful as originally anticipated.
Recently, however, the Staff has accepted several NU proposals to drop a topic from consideration which had NRC " requirements" associated with it.
In these cases, the full potential of ISAP has been realized.
They include closure of the Control Room Habitability topics (pending issuance of an associated generic letter) for the Haddam Neck Plant and Hillstone Unit No. I without additional modifications.
In another case, for the Haddam Neck Plant, the NRC accepted NU's evaluation that showed little safety benefit for completion of modifications to containment penetrations to comply with GDCs 54 through 57.
Also, for Hillstone Unit No.
1, the Staff accepted NU's evaluation which showed that a single channel hydrogen monitoring system was acceptable and a redundant system need not be installed.
Probabilistic Risk Assessment insights were utilized extensively in these evaluations.
We are pleased that the Staff concurred with our assessments of the relative merits of completing the aforementioned modifications and allowed us to avoid the expenditure of several million dollars for resolution of each of the (1)
D. G. Eisenhut letter to W. G. Counsil, " Expanded Integrated Assessments for Haddam Nech aad Hillstone Unit 1," dated April 5, 1984. i
issues.
We are especially gratified with the Staft's acknowledgement of the 2'
benefits of ISAP in the letter dated September 7, 1993, accepting the Millstone Unit No. I hydrogen monitoring system, wherein it was stated that "The NRC Staff Las accepted NNEC0's position based sn ISAP provisions..."
Cost Beneficial Licensino Actions (CBLAs)
NU is pursuirg CBLA activities as part of a broader initiatin directed towards reduction of regulatory burden. We are engaged in various actlvities, including CBLAs, to review, revise and eliminate regulatory requirements and comitments with littie or no safety benefit.
NU has been selectively active in identifying these requirements and regulatory commitments, and has sought individual relief as appropriate.
We are making significant progress in identifying commitments and burdensome regulatory requirements, and are moving to institutionalize the process of assessing, prioritizing, and implementing identified reduction of regulatory burden initiatives.
Where these issues meet the Staff's criteria for a CBLA, the appropriate submittals will be prepared and identified as such.
For NV, the regulatory burden reduction process is intimately linked with ISAP.
This approach was discussed at length with Mr. L. B. Marsh during his visit to NU in July 1993.
We are encouraged with the NRC's acceptance of our ISAP process and are convinced that ISAP is truly an appropriate vehicle to eliminate regul atory burdens for which the benefit to safety is not commensurate with the associated cost.
Some of our recent successes in the reduction of regulatory burden arena include the ISAP topic closures previously noted. Others include the resolution of the Combustible Gas Control 1stes for Millstone Unit No.1, and the change to a schedular commitment for tw Millstone Unit No. 1 Hardened Wetwell Vent modification to permit pursuit of a less costly alternate design.
We have also requested and been granted license amendments related to local leak rate testing (LLRT) requirements, a trip function LC0 and surveillance requirements, radioactive effluent reports, and fire protection requirements.
In all, a total of approximately 50 items related to NU's reduction of regulatory burden initiative are either completed, in progress, or under internal evaluation.
(2)
J. W. Andersen letter to J. F. Opeka, " Millstone Nuclear Power Station Unit No. 1 - TMI Action Plan Item II.F.1.6, Post-Accident Hydrogen Monitors (TAC No. M83986)," dated September 7, 1993.
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ATTACHMENT 4 NU IPE and IPEEE Status and Conclusions Individual Plant Examination (IPE)
The IPE has been comp'leted and submitted for the Haddam Neck Pl ant,"'
Millstcre Unit Nos.
1, ' 2, a nd 3, "' and Seabrook Station.*'
The Staff l
review for the Millstone Unit No. I submittal was issued on Octcber 5, 1993.*'
This review indicated that although no specific unresolved safety issues or generic safety issues were proposed for resolution, the Staff did agree that drywell steel liner melt-through by molten debris following core melt and RPV failure is a major vulnerability with respect to containment performance. The Staff review of the internal events portion of the Millstone Unit No. 3 IPE/IPEEE was transmitted on May 5,1992,"' and also proposed no specific unresolved safety issues or generic safety issues for resolution.
4 The external events portion (IPEEE) for Hillstone Unit No. 3 is currently being reviewed by the Staff.
The Staff review for the Seabrook Station
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(1)
J. F. Opeka letter to U.S. Nuclear Regulatory Comission, "Haddam Neck Plant - Response to Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities, Sumary Report," dated June 29, 1993.
(2)
J.
F.
Opeka letter to U.S.
Nuclear Regulatory Comission, " Millstone Nuclear Power Station, Unit No. 1 - Response to Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities, Summary Report Submittal," dated March 31, 1992.
(3)
J.
F.
Opeka letter to U.S.
Nuclear Regulatory Comission, " Millstone Nuclear Power Station, Unit No. 2 - Response to Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities, Summary Report," dated December 30, 1993 (4)
E. J. Mroczka letter to U.S. Nuclear Regulatory Comission, " Millstone Nuclear Power Station, Unit No. 3 - Response to Generic Letter 88-20, Individual Plant Examination for Severe Accident Vulnerabilities, Summary Report Submittal," dated August 31, 1990.
(5) 8.
L.
Drawbridge letter to U.S.
Nuclear Regulatory Commission,
" Supplementary Response to Generic Letter 88-20," dated March 1,1991.
(6)
J. W. Andersen letter to J. F. Opeka, " Staff Evaluation of Millstone Nuclear Power Station, Unit 1 Individual Plant Examination (IPE)
Internal Events, Generic Letter 88-20 (TAC No M74432)," dated October 5, 1993.
(7)
V.
L. Rooney letter to J.
F. Opeka, " Staff Evaluation of Millstone 3 Individual Plant Examination (IPE)
Internal Events, GL 88-20 (TAC No. M74434)," dated May 5, 1992. -
submittal was issued on February 28, 1992,"" and the conclusion was that the IPE did not identify any severe accident vulnerabilities associated with either core damage or unusual containment performance.
In general, the results of these studies have identified no significant findings or vulnerabilities.
In large measure, this is because the IPE process was essentially an update of plant-specific PRAs prepared many years earlier as part of the ISAP and living PRA processes.
During the conduct of these prior in-depth PRAs, some of the more significant issues identified and resolved included:
Haddam Neck Plant
- 1 rip charging pumps on loss of semi-vital power to prevent damaging both pumps
- Redesign of ECCS to mitigate loop 2 cold leg SBLOCAs
- Redundant isolation valve installed on letdown line
- Eliminate an identified common mode failure of both emergency diesel generators Hillstone Unit No. 1
- Loss of 120VAC event; modified RPV level indications and alarms, and implemented procedure to mitigate
- LNP contribution to core melt frequency reduced through gas turbine governor replacement and addition of-an electrical cross-tie Millstone Unit No. 3
- Partial stroking of accumulator discharge check valves performed each refueling outage to reduce LBLOCA core melt frequency contribution The IPE for Hillstone Unit No. 2 was submitted to the Staff in a letter dated December 30, 1993, as scheduled.
There were no major vulnerabilities identified, but several recommendations were made and have been implemented to enhance plant safety. These include:
Installation of temperature indicators / alarms in DC switchgear rooms Modification of PORV control logic to prevent inadvertent opening on a spurious high pressurizer pressure signal Include use of valve 2-FW-44 in E0Ps (8)
G. E. Edison letter to T. C. Feigenbaum, " Staff Evaluation of Seabrook Individual Plant Examination (IPE) - Internal Events, Generic Letter 88-20 (TAC No. H74466)," dated February 28, 1992. -
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- Addition of air accumulators for auxiliary feedwater regulating valves Perform sarveillance testing of LPSI check valves However, one remaining potential vulnerability identified in this study is the possibility of a small intersystem LOCA.
This scenario, resulting from a reactor cooling pump thermal barrier tube failure which leads to overpressurization of the RBCCW system, is under active evaluation.
Individual Plant Examination for External Events (IPEEE)
Mlill SCHEDULED COMPLETION Haddam Neck Plant 1994 Hillstone Unit 1 1996 Hillstone Unit 2 1995 i
Hillstone Unit 3 Submitted August 1990"'
5 Seabrook Station Submitted October 1992 '
The Hillstone Unit No. 3 study identified no significant vulnerabilities, but did conclude that fire and seismic events are the external events important to risk.
Replacement of anchor bolts on the diesel generator oil coolers had been implemented to reduce the seismic core melt frequency.
Similarly, it was determined that there are no significant core damage vulnerabilities from external events existing at Seabrook Station.
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(9)
T.
C.
Feigenbaum letter to U.S.
Nuclear Regulatory Commission,
" Supplementary Response to Generic Letter 88-20, Supplement 4,"
dated October 2, 1992.,
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