ML20126H702

Provides Partial Review of Facility Isap Submittal Dtd 921023.NRC Currently in Process of Reviewing 14 of 133 Isap Topics Listed in Submittal

ML20126H702
Person / Time
Site:	Millstone
Issue date:	12/30/1992
From:	Andersen J Office of Nuclear Reactor Regulation
To:	Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO.
References
TAC-M83573, NUDOCS 9301050290
Download: ML20126H702 (26)

Text

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Docket No. 50-245 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

SUBJECT:

REVIEW 0F ISAP SUBMITTAL DATED OCTOBER 23, 1992 (TAC NO. M83573)

In a letter dated October 23, 1992, 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 statad in the report. The following is the NRC staff's review of NNEC0's ISAP report dated October 23, 1992. Since this is the first ISAP submittal after the issuance of Amendment No. 56, the NRC staff has reviewed all of the topics NNECO has proposed for closure in past ISAP submittals.

There are a total of 133 ISAP topics listed in your latest ISAP submittal.

Enclosure 1 lists 36 topics which have been closed out by NRC documents.

NNECO's latest ISAP submittal also stated that 27 topics remain open, these are listed in Enclosure 2. NNECO considers the remaining 70 ISAP topics resolved and thereby closed out. The NRC staff is still in the process of reviewing 14 of these topics, the remaining 56 are discussed in Enclosure 3.

Enclosure 4 lists the remaining topics (14) which the staff is reviewing, i

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, Mr. John F. Opeka December 30, 1992 i further NRC review of closed ISAP topics, if any, will be performed by ins)ection or audit. The NRC staff remains available to discuss these issues witi you.  ;

Sincerely, l l

Original signed i by James W. Andersen, Acting Project Manager-Project Directorate I-4 -

Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation

Enclosures:

1. ISAP Topics Closed Out by NRC Documents

2. ISAP Topics Considered Open by NNEC0

3. NRC Review of ISAP Topics NNECO Proposes for closure 1

4. ISAP Topici. Still Being Reviewed cc w/ enclosures:

See next page i

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-C) l Mr. John F. Opeka Millstone Nuclear Power Station Northeast Nuclear Energy Company Unit 1 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 06103-3499 Hartford, Connecticut 06141-0270 W. D. Romberg, Vice President D. O. Nordquist Nuclear, Operations Services Director of Quality Services Northeast Utilities Service Company Northeast Utilities Service Company Post Office Box 270 Por.t Office Box 270 Hartford, Connecticut 06141-0270 hartford, Connecticut 06141-0270 Kevin McCarthy, Director Regional Administrator Radiation Control Unit Region 1 Department of Environmental Protection U.S. Nuclear Regulatory Commission State Office 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, Nuclear Station Director P. D. Swetland, Resident Inspector Millstone 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 Millstone Unit No. 1 Northeast Nuclear Energy Company Post Office Box 128 Waterford, Connecticut 06385

= Nicholas S. Reynolds Winston & Strawn 1400 L Street, NW-Washington, DC-20005-3502

1 ,

ENCLOSURE 1 LSAP TOPICS CLOSED OUT BY NRC DJ)CUMENTS i

Topic NumbtC lille Comment 1.01 Gas Turbine Generator Start logic NRC SE dated 7/17/91 closed topic Modifications out.

1.02 Tornado Missile Protection NRC SE dated 12/19/91 closed topic out.

1.08 Safety Parameter Display System NRC letter dated 5/3/90 closed topic out.

1.15 FSAR Update NUREG-ll84 stated that topic was resolved.

1.18 ATWS NRC SE dated 10/6/88 closed topic out.

1.20 MOV Interlocks NUREG-ll84 stated that topic was resolved.

1.21 Fault Transfers NRC SE dated 9/3/91 closed topic out.

1.22 Electrical isolation NRC SE dated 9/3/91 closed topic.

out.

1.26 Equipment Classification / Vendor NRC SEs dated 11/24/86 and 8/4/87 Interface (GL 83-28, item 2.1) . closed topic out.

1.27 Post-Maintenance Testing (GL 83- NRC SE dated 2/21/86 closed topic 28, items 3.1.1 and 3.1.2) out.

1.28 Post-Maintenance Testing Technical NRC SE dated 9/3/85 closed topic Specification Changes (GL 83-28, out, items ~3.1.3)

I 1.29 Response to GL 81-34 NUREG-ll84 stated that topic was resolved..

1.30 Post-Trip Review Data and .

NRC SE dated 6/24/86 closed topic l Information (GL 83-28. Item l'.2) out.

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1.31 Equipment Classification / Vendor NRC SE dated 5/3/91 closed topic.

Interface.(GL83-28, item 2.2) out.

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Topic Number lLth Comment 1.32 Post-Maintenance Test Procedures NRC SE dated 2/21/86 closed topic (GL 83-28. Items 3.2.1 and 3.2.2) out.

1.33 Post-Maintenance Testing Technical NRC SE dated 9/3/85 closed topic Specification Changes (GL 83-28, out.

Item 3.2.3) 1.34 Reactor Trip System Testing (GL NRC SE dated 5/31/89 closed topic 83-28, Items 4.5.2 and 4.5.3) out.

1.35 Reactor Trip System Testing (GL NRC SE dated 2/21/86 closed topic 83-28, Item 4.5.1) out.

1.37 Technical Snecification Changes to NRC License Amendment No. 1, dated address 10 CFR 50.72 and 50.73 1/29/87, closed topic out.

1,39 Radiation Protection Plans NUREG-il84 stated that topic was resolved. ,

1.42 Main Steam Lire Leakage Control NUREG-ll84 stated that topic was System resolved.

1,44 Asymmetric Blowdown loads on NUREG-1184 stated that topic was Reactor Systems resolved.

1.45 Systems Interactions NUREG-ll84 stated that topic was resolved,

l. 6 Determination of SRV Pool Dynamic NUREG-ll84 stated that topic was Loads resolved.

1,48 Safety Factor for Penetration X- NRC letter dated 1/19/90 closed 10A -topic out.

1,49 Reactor Vessel Surveillance NUREG-1184 stated that topic was-Program no longer considered-in ISAP.

1.109 IGSCC Countermeasures NRC SE dated 12/14/89 closed topic out..

• 2.13 Turbine Water Induction NUREG-ll84 stated that topic was Modifications no longer considered iniISAP.

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4 Topic

(( umber lLtle Comment 2.14 Evaluation and Implementation of NUREG-ll84 stated that topic was NUREG-0577 resolved.

2.18 Spent fuel Pool Storage License Amendment Nos. 40 and 43, Racks / Transportation Cask dated 11/27/89 and 3/30/90 respectively, closed out this topic. -

2.19 DC System Review NUREG-ll84 stated that topic was no longer considered in ISAP.

2.22 Control Rod Drive System Water NUREG-1184 stated that topic was Hammer Analysis no longer considered in ISAP.

2.26 Reliability Equipment NUREG-llAd. stated that topic was resolved.

2.31 LPCI Lube Oil Cooler Test NUREG-ll84 stated that topic was Frequency resolved.

2.111 (Project Dropped) 2.119 (Topic Deleted) 9 9

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l ENCLOSURE 2 ISAP TOPICS CONSIDERED OPEN BY NNECQ Topic flumber Title Comment 1.06 Seismic Qualification of Safety- By letter dated 9/4/91, the staff Related Piping stated that NNEC0's commitment to complete the remaining modifications during cycle 14 and 15 refueling outages was acceptable. NNEC0 should submit any schedule changes to the NRC for review.

1.07 Control Room Design Review All the remaining human engineering discrepancies (HED) 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 Instrumentation provided a safety evaluation with a list of open items. NNECO addressed these in a letter dated 9/11/91 and in a letter dated 11/15/91 notified the NRC of five additional type A variables. NNECO provided further information in submittals dated 3/31/92, 9/8/92,-and 10/23/92. The NRC is currently reviewing these documents and awaiting a final NNEC0 submittal .

1.14 Appendix J - Modifications NNEC0 has scheduled some of the modifications to 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 vitM AC bus as well' as an additional DC powered ATWS level indication on the main control board and upgraded procedural guidance. The remainder of this project is scheduled to be completed during the cycle 14 refueling outage.

Topic Number Title Comment 1.52 SRV Failure - Setpoint Drift NNEC0 is keeping this topic open to address rer. +?endations from the BWR Owners Grc.p ' ch is currently addressirs ?.nis issue.

1.101 Fire Detection System Code This topic involves certain Compliance modifications to the fire detection system to ensure compliance with the intent of-the National Fire Protection Association (NFPA) code. Any modifications which 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 System Code This topic involves certain Compliance modifications to the fire suppression system to ensure compliance with the intent of the National Fire Protection Association (NFPA) code. Any

-modifications which will result in a significant change in the scope of the existing project assignment will be evaluated in a. future ISAP report.

1.104 Service Water Pump Flow Rate This- topic addressed!an evaluation of Instrumentation procuring and installing' instrumentation necessar, to measure the flowrate of various pumps.- The installation-of instrumentation to monitor flow through portions of the service water system is scheduled-for completion during the cycle 14=

refueling outage. -The remaining pumps are being_ reviewed as part of the licensee's IST program submittal dated 10/30/92.

4 Topic Fumber Title Comment 1.106 Station Blackout Modifications to resolve the station blackout issue are scheduled for completion during the cycle 14 refueling outage. In a letter dated.

8/6/92, NNECO informed the staff.that the cycle 14 outage would be delayed until early 1994 By letter dated

~

8/25/92 the staff approved this revised schedule.

1.111 Motor Operated Valve Testing, NNEC0 responded to GL 89-10, GL 89-10 certifying that. detailed-programs were .

being developed-to address safety-related motor operated valve testing and surveillance. By letter dated 5/4/92, NNECO 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 was . acceptable, however, NNEC0's commitment to meet the schedule requested in the first paragraph of item i (and item k) of. GL :

89-10 for completing recommended actions a through h-of the generic-letter by three refueling outages after-11/28/89, remains unchanged.

1.112 Service Water System Evaluation, This 'opic t addresses GL 89-13, GL 89-13 " Service Water System Problems-Affecting Safety-Related Equipment." ,

In a letter dated 4/3/92, NNECO provided an update on the-implementation of-the five recommended actionI. NNECO stated that items- )

1,2,3, and 5 were accomplished on i schedule and that item 4 is scheduled for the cycle 14 refueling outage.-

1.113 Hardened Wetwell Vent, GL 89-16 This project involves in'stallation of

-a hardened wetwell vent. The >

installation is scheduled for the cycle 14 refueling outage:if an ~ outage of sufficient duration does not occur before then (after February 1993).

4 Topic Number Title Comment 1.117 Safety Parameter Display System This topic encompasses the addition of_'

Upgrade several 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-is scheduled to be completed by the end'of 1992.

1.118 Plant Heating Steam System This topic involves the modifications necessary for restoration of the heating steam syste:n. Most of the modifications were completed in the 1991 refueling outage and the remainder are scheduled to be completed _ by the end of 1992, 1.119 Resolution of Unresolved Safety _This topic encompassed NNEC0's plant-Issue A-46 specific response to USI A-46,

" Seismic Qualification of Equipment in Operating Plants'." NNEC0_ submitted its response on 9/21/92. In a letter dated 11/23/92, the staff approved NNEC0's schedule for implementati_on.

The seismic evaluation. report is scheduled to be completed 180 days following the completion of the cycle

15. refueling outage.

1.120 Purge and Vent Valve Auto- This topic involves providing a new Closure isolation input signal to the purge-and' vent system valves-for the primary-containment on high radiation. NNEC0 has committed to do this modification during the cycle 14 refueling outage.

1.121 ~ Post Accident Hydrogen Monitor This topic had previously been discussed under topic'l.ll. In a _.

_ letter dated 6/10/92, NNEC0 submitted its. reevaluation for this issue.

NNECO niaintains that no modifications are warranted and that this topic should be closed. The NRC staff is-currently reviewing this issue,

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Topic Number Title Comment 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 Replacement This topic addressed the replacement of existing battery chargers with battery-eliminating type, self-regulating chargers. The project is scheduled for the cycle 15 refueling outage.

2.106 Diesel Air Start System Upgrade NNEC0 performed a visual boroscope inspection of 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.

2.107 Class lE' Generator Antimotoring This topic addresses whether Protection sufficient protection exists to prevent damage or degradation in the 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 Protection While Shutdown supplementary reverse current protection for the main generator.

The modifications are scheduled to be completed during the cycle 15 refueling outage.

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l Topic Number Title Comment

-2.116 Replacement of Reactor Water This topic involves the replacement.of.-

Cleanup Valves valve CV-2 and its motor-operator, and-the installation of a MOV in the _

reactor water cleanup inlet-piping immediately outside the drywell. MOV testing. issues pertaining to GL 89-10 must be resolved prior to replacement.

The necessary vent and drain connections for Appendix J testing will also be installed and are scheduled for the cycle 14 refueling outage.-

2.120 Atmospheric Control System This topic addresses a current Containment Isolation Valves engineering study which considers possible modifications.to existing valves or the procurement of new valves to mitigate high valve failure during local leak rate testing. . Some modifications have been completed and NNEC0 has submitted a corrective action plan and exemption request for NRC approval. NNECO is currently-evaluating whether future modifications are necessary. .

2.123 Chemistry Laboratory HVAC System This topic involves installation.of an independent heating, ventilating,.and air conditioning system for the chemistry laboratory. - The project is scheduled.to be completed by the end

-of 1992.

2.124 Replacement of IC System Valves This topic invol.ves the replacement of-and CU-28 valves IC-1,2,3, and 4. Test data collected during the 1991 refueling outage is being reviewed to determine potential work scope changes.

ENCLOSURE 3 B C REVIEW 0F ISAP TOPICS NNECO PROPOSES FOR CLOSURE Iooic 1.04 - RWCU Pressure Interlock This topic involved installing an independent pressure interlock for actuation of the Reactor Water Cleanup (RWCU) system isolation on high pressure. in a letter dated 8/23/85, NNEC0 submitted the PSA summary for this topic which concluded that the decrease in core melt frequency was very small. The staff reviewed the licensee's Probabilistic Safety Assessment (PSA) and concluded that the addition of a second, independent pressure interlock would not alter the probability of a failure to isolate the RWCU line in the case of a failure of the pressure regulating valve. In addition, NNEC0 performed a calculation that demonstrated that if the pressure regulating valve fallad wide open, the large capacity relief valve would have more than enough capacity to discharge the anticipated line flow. In NUREG-ll84, based on the above information, the staff concluded that this topic is resolved. Therefore, the staff considers this topic closed.

Topic 1.05 - Ventilation System Modifications This topic addressed the following two issues: (1) modification of the electrical supp;ies for the feedwater/feedwater coolant injection (FWCI) area coolers so that all six area coolers are automatically sequenced onto a gas turbine-powered bus following a Loss of Normal Power (LNP), and (2) modification to the power supply for the intake structure exhaust fans to allow automatic sequencing of one fan onto a gas turbine bus and the other fan onto a diesel generator bus. In NUREG-ll84, the staff concluded that the priority for implementation of item I was high and item 2 was low. In a letter dated 11/9/88, NNEC0 stated that the item 1 modifications were completed as scheduled during the cycle 11 refueling outage. in the same letter, NNEC0 stated that the operation of the emergency service water system would not be affected even if the fans failed. Therefore, NNEC0 determined that the proposed modifications were of no benefit and that the topic should be closed. Based on the low priority given to this second topic in NUREG-ll84 and the additional information submitted by NNEC0, the staff has concluded that the modification is not warranted. Therefore, this topic is closed.

Topic 1.10 - Emeroency Response Facilities Instrumentation This topic addressed one of the generic requirements of the TMI Action plan, identified in NUREG-0737 Supplement 1. NUREG-0737 Supplement I required that all licensees provide an Emergency Response Facility with appropriate instrumentation. NNEC0 determined that some additional means.of providing real time data to personnel in the Technical Training Center, Emergency Operating Facility, and the Corporate Emergency Operations Center would be beneficial. NNECO completed the physical work and acceptance testing on 1/31/89 and considers this topic resolved. Based on the above, the staff considers this topic closed.

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Topic 1.11 - Post Accident Hydroaen Monitor This topic was part of the generic requirements of the TMI action plan. In response to the requirements of 10 CfR 50.44, NNECO claimed the benefit of the normally inerted atmosphere during reactor operation for its Mark I BWR containment. NNECO installed a single channel hydrogen monitoring system and stated that it could also use the existing post-accident sampling system to monitor hydrogen. In a letter dated 7/31/86, NNEC0 provided additional information on its current systems and stated that the addition of a redundant hydrogen monitor would have negligible impact on public safety. Based on this reasoning, NNECO, in a letter dated 11/9/88, stated that it considered this topic resolved. In a letter dated 2/12/92, the NRC staff found this proposal unacceptable due to the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> timing it takes to obtain a PASS sample. NNEC0 responded in a letter dated 6/10/92 with its current ISAP analysis. The NRC staff is currently reviewing this latest submittal. Since NNECO closed the original ISAP topic out-(1.ll),_it opened a new ISAP topic (1.121) to perform an updated ISAP analysis. Therefore, since this issue is being tracked under ISAP topic 1.121, the NRC staff considers this topic closed.

Topic 1.12 - Control Room Habitability This topic addressed the protection of control room operators against the effects of an accidental release of toxic or radioactive gases such that the plant can be safely shut down under design basis accident conditions. By letter dated 7/9/92, the NRC staff stated that since the NRC is-in the process of issuing a Generic Letter (GL) which encompasses the control room habitability issue, that it was temporarily closing out this_ issue until the GL is issued. Once the GL is issued, the NRC will open a new TAC number and NNECO will open a new ISAP number (if appropriate) to follow this issue.

Therefore, the NRC staff considers this ISAP topic closed.

Toolc 1.13 - BWR Vessel Water Level Instrumentation This topic was part of the generic requirements of the TMI action plan and required licensees to modify or supplement existing equipment to assure accurate indication of vessel water level. In a letter dated 11/9/88, NNECO concluded that in conjunction with the existing feedwater system, the installation of the Safety Parameter Display System (SPDS) satisfactorily addressed this issue. - The SPDS includes indication that would alert operators to reference leg flashing. The drywell temperature upgrade also improves the operator's knowledge of reference leg flashing. -Therefore, NNECO considers this' topic closed. The NRC staff agrees that this topic is closed.

Toolc 1.17 - Replacements of Motor-Ocerated Valves This topic addressed the qualification and/or exemption of 11 Motor Operated Valves (MOVs) that had not been qualified to achieve total compliance with 10 CFR 50.49. The NRC staff granted NNEC0's request for exemptions for 7-af the valves and concluded that the 8th is outside the-scope of equipment required to be environmentally qualified. The remaining 3 valves were qualified by

M NNEC0 during the 1987 refueling outage and, therefore, NNECO considers the topic closed. The NRC staff agrees that this topic is closed.

Tooic 1.19 - Intearated Structural Analysis This topic addressed several Systematic Evaluation Program (SEP) concerns related to the structural integrity of Millstone Unit 1. The last issue was addressed in a NRC letter dated 9/3/92, and the staff indicated that the modifications were acceptable. Therefore, NNECO considers this topic closed.

The NRC staff agrees that this topic is closed.

Tooic 1.24 - Emeraency Power This topic encompassed a review of the Millstone Unit I gas turbine generator (GTG) maintenance program. By letter dated 8/16/84, the NRC staff concluded that the revised maintenance program acceptably resolved this issue, In further discussions with NNEC0, the staff requested that this topic be expanded to further investigate additional preventative maintenance practices that could help reduce the GTG failure rate. In a letter dated 8/4/87, NNEC0 discussed its reliability study (ISAP topic 2.100) and its gas turbine governor control system replacement (ISAP topic 2.112). Based on the initiation of these two topics, NNECO considered this topic closed. The NRC staff agrees that this topic is closed.

Tooic 1.36 - Technical Soecifications Covered by GL 83-36 This topic addressed changes in Technical Specifications to reflect applicable TMI Action Plan Items identified in GL 83-36. By letters dated 1/13/92 and 6/15/92, the staff issued amendments 55 and 57, respectively. The last two issues under this topic were control room habitability and containment hydrogen monitors. Both of these issues are covered under separate ISAP topics (1.12 and 1.121, respectively) and, therefore, NNECO considers this topic closed. The NRC staff agrees that this topic is closed.

Topic 1,38 - Exoand_ Quality Assurance List This topic addressed the NRC's proposal (TMI Action Plan I.F.1) for licensees to expand the Quality Assurance (QA) List. In NUREG-1184, the staff noted that Millstone l's performance was indicative of good QA maintenance and surveillance programs with management support and involvement for both safety related and non-safety related equipment. However, the staff recommended that NNECO cross check their QA list against the equipment in the PSA. In a letter dated 8/4/87, NNEC0 stated that the inherent philosophies behind the modeling in the PSA and the development of the QA list are different and that the cross check is of little or no value. Therefore, NNECO considers this topic closed.

The NRC staff agrees that this topic is closed.

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Tonic 1.41 - Floodina of Comoartments by Backflow This topic addressed the concern that improperly designed drain systems could contribute to equipment damage as a result of backflow. The NRC staff, in NUREG-ll84, concluded that the possibility of damage to equipment from flooding through equipment and floor drain systems is remote. The staff, however, deferred judgment until after an internal flooding study _ was completed by NN:CO. In a letter dated 2/13/87, NNEC0 submitted a probabilistic internal flooding analysis which showed a negligible contribution to core melt frequency. Therefore, the NRC staff considers this topic closed.

Tooic 1.47 - Containment Emeraency Sumo Performance This topic _was initiated to address USI A-43, " Containment Emergency Sump Performance." In NUREG-ll84, the staff stated that Millstone Unit I meets the intent of the safety concerns with the exception of the possibility of blanket type insulation causing reduced flow and possible procedural improvements. -In March of 1988, NNECO completed a study which was undertaken to evaluate the acceptability of fibrous insulation in the drywell with respect-to degradation of long-term Emergency Core Cooling System (ECCS) recirculation.- NNECO concluded that the ECCS pump net positive suction head margin and operability could potentially be-compromised if fibrous insulation migrated in sufficient quantities to the torus and to the low pressure' coolant injection / core spray suction screens. In a letter dated 11/9/88, NNECO summarized the corrective actions which included procedural changes, a technical specification change, and the ECCS suction strainer replacement. In a letter dated 9/29/89, NNEC0 stated that all corrective actions had been completed and, therefore, that this topic was resolved. The NRC_ staff agrees that this topic is closed.

' Topic 1.50 - Isolation Condenser Start-Vo/Makeuo Failures This topic was identified by the NRC staff in NUREG-1184, based on_ the staff's review of the issues raised in the Millstone 1 Probabilistic Safety Study (PSS). In a letter dated 11/9/88, NNEC0 stated that-based on the results of the most recent revision to the PSS and the completion of the long-term cooling study,- the issue is no longer a significant contributor. to the risk of core melt and hence public risk. Therefore, NNECO concluded that there is no justification for continuing this study.and that this topic is-closed. The

.NRC staff agrees-that this-topic is closed.

Tooic 1.51 - Failure to Restore Main Condenser This topic was identified by the NRC staff in NUREG-ll84, based on the staff's review of the issues raised in the Millstone 1 PSS. In a letter dated 11/9/88, NNEC0 stated that based on the results of the most recent revision to the PSS and the completion of the long-term cooling study, the issue is no

r longer a significant contributor to the risk of core melt and hence public risk. Therefore, NNECO concluded that there is no justification for continuing this study and that this topic is closed. The NRC staff agrees that this topic is closed.

Tooic 1.100 - Fire Barrier Penetration Seal Procram Uparade This topic addressed the fire barrier penetration seal program upgrade. By letter dated 9/28/88, NNECO provided a detailed description of the program upgrade initiatives and a schedule for completion. -By letter dated 10/23/92, NNECO informed the staff that the project was completed on schedule and, therefore, NNECO considers this topic closed. The NRC staff agrees that this topic is closed.

looic 1.103 - Standby Gas Treatment System Redundancy .

This topic addressed concerns associated with a deficiency with the Standby Gas Treatment System (SGTS) discovered during the 1987 refueling outage. The system did not fully meet the single failure criteria. In LER No. 87-029-00, dated 8/21/87, and Supplement 1, dated 3/29/89, NNECO committed to modify the system'to correct the single failure problem. In a letter dated 9/29/89, NNEC0 stated that this project was completed during the 1989 refueling outage and, therefore, this topic is closed. The NRC staff agrees that this topic is closed.

Topic 1.105 - Valves LP 15 A/B. 16-A/B. and CU 2/3 This topic addressed the installation of new valve motor oper6 tors in the containment spray system. The project was completed--durig the 1989 refueling outage. Subsequent to the topic evaluation and as a result of an LER and investigation, discussed in detail in a NNEC0 letter dated 4/17/89, NNEC0 decided to replace the motor operators for 1-CU-2/3 with qualified motor operators during the 1989 refueling outage. These motor operators were-also installed on schedule and, therefore, NNECO considers this topic closed. The NRC staff agrees that this topic is closed.

Topic 1.110 - Vital Area-Ventilation I This topic addressed an evaluation of all the vital area ventilation ducting.

This review was completed as a result of an NRC-sponsored regulatory effectiveness review (RER) encompassing the effectiveness of safeguards against radiological sabotage. NNEC0's identified only one penetration that needed modifications during the RER audit. The modification was completed on-schedule and, therefore, NNECO considers the topic closed. The NRC-staff agrees that this topic is closed.

Topic 1.116 - Remote Wide-Ranae Yarways This topic involved the replacement of the wide-range Yarway reactor vessel level transmitters and their associated cables. In a letter dated 1/24/92,

NNECO stated that the modifications were completed during the 1991 refueling outage and, therefore, NNECO considers this topic closed, the NRC staff agrees that this topic is closed.

Tooic 2.03 - process Computer Replacement This topic involves the installation of a new plant process computer. In NUREG-Il84, the staff recommended that the installation be completed on the current schedule because of its importance to related topics, such as topic 1.08, Safety Parameter Display System. In NNEC0's ISAP report dated 11/9/88, NNEC0 stated that the new process computer was installed and operational for start-up of cycle 12 and that this topic should be closed. The NRC staff agrees that this topic should be closed.

lgpic 2.04 - Hiah Steam Flow Setooint Increase This topic encompassed an evaluation of the feasibility of an increase in the MSIV closure setpoint from 120% to 140%. The project would eliminate the need to reduce power for the weekly turbine stop-valve testing, in a letter dated 8/15/85, NNEC0 provided the PSA summary for this topic.~ The staff reviewed the summary and stated that the decrease in_public safety is not outweigFed by the increase in economic performance, in the 8/4/87-lSAP report,'NNECO concluded that no modifications were warranted and that the topic should be closed. The NRC-staff agrees that the topic should be closed.

Igpic 2.05 - Hydroaen Mater Chemistry Study This topic encompassed a study to identify possible modifications to alter the water chemistry at Millstone Unit 1 by injecting hydrogen into feedwater. In the 9/29/89 ISAP report, NNECO stated that they evaluated the viability'of installing a permanent hydrogen water chemistry system, and determined that a permanent modification is not justified. In a letter dated 6/30/92, NNECO submitted a Technical Specification change request to delete all references pertaining to hydrogen water chemistry testing. In a letter dated 9/24/92, the'NRC staff issued Amendment No. 59 which approvou the removal of.the references related to the testing. Therefore, the NRC staff considers this topic closed.

Tuoic 2,07 s Sodium Hvoochlorite System This topic-addressed the concerns surrounding the use and onsite storage of liquid chlorine. Based on NNECO's evaluation, the chlorine tank cars were removed from the site and a permanent sodium hypochlorite system was installed. Therefore,'the NRC staff considers this topic closed.

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Topic 2.09 - Voaradina of P& ids This topic addressed a project to upgrade the piping and instrumentation-diagrams. NNECO completed the upgrade in late 1988 and in the 9/29/89 ISAP report, stated that the P&ID revisions had been verified on file in the control room. Therefore, the NRC staff agrees that this topic is closed.

Tooic 2.10 - Drywell Ventilation System This topic was opened to address drywell temperature concerns. Under this topic, NNECO identified the need to replace the coolingicoils in eight drywell-ventilation units. NNECO installed five of these new coils during the 1985 refueling outage and two during the 1991 refueling outage. The remaining coil was not replaced since it was previously replaced in 1984. Therefore, NNECO.

considered this topic closed. The NRC staff agrees that this topic .is closed.

Topic 2.11 - Stud Tensioners This topic addressed the replacement of the manual vessel-head-stud tensioners with an automated system. In the 1989 refueling outage, NNECO completed'the installation of the automated vessel-head stud tensioner. In the 9/29/89=ISAP report, NNEC0 stated that this topic was considered closed. The NRC staff agrees that this topic is closed.

Topic 2.12 - Reactor Vessel Head Stand Relocation This' topic encompassed relocating the centerline of the reactor _ vessel- head stand to line up with the centerline of the reactor vessel crane and vessel head. In the 9/29/89 ISAP-report, NNEC0 stated that-this project.was.

completed prior to the 12th refueling outage and, .therefore, . should be considered closed. The NRC staff agrees that this topic is closed.

Topic 2.15 - Toraue Switch Evaluation for MOVs This topic was originally initiated to evaluate and respond to I&E Information Notice 84-10, " Motor Operated Valve Torque Switches- Set Below the Manufactures Recommended Value." The topic's scope was expanded in mid-1986 to include considerations and response to I&E' Bulletin 85-03 on icommon mode failures. In

.a letter dated 12/30/87, NNEC0 stated that all work was completed except-for one valve,1-1C-1. In a letter dated'6/28/89, the-NRC staff transmitted GL 89-10 which superseded the recommendations of the earlier Bulletin 85-03. GL 89-10. stated that addressees need not make'any further responses regarding.

Bulletin 85-03 and that any previous test data, remaining to be submitted, should be included in subsequent responses to GL 89-10. ISAP topic 1.111 was opened to respond to GL 89-10 and, therefore, NNECO considered topic 2.15 closed. The NRC staff agrees that since GL 89-10 is included in ISAP topic 1.111, that this topic is closed.

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Tooic 2.16 - Reactor Protection Trio System This topic encompassed (1) replacement of the 120-second automatic depressurization system timer, and (2) removal of two low reactor pressure permissive switches from the ECCS pump start logic to alleviate setpoint drift problems on the reactor protection system. In the ISAP report dated 11/9/88, NNEC0 stated that this topic had been completed prior to the 1987 refueling outage and, therefore, NNECO considered it resolved. The NRC staff agrees that this topic is closed.

Tonic 2.20 - RWCU system Isolation Setooint Reduction This topic involved an evaluation of the feasibility of lowcring the RWCU system isolation setpoint in order to have the RWCU system available for decay heat removal and reactor water clean-up following a reactor scram and as a drain path for vessel level control. NNECO completed the study and determined that the setpoint can be lowered without addition of a leak-detection system on the RWCU system. NNEC0 submitted a Technical Specification change request to lower the setpoint and in a letter dated 7/17/87, the NRC issued a license amendment approving the reduced setpoint. The NRC staff agrees with NNEC0-that this topic is closed.

Topic 2.21 - 480V Load Center Replacement of Oil-Filled Breakers This topic addressed the replacement of the over-current trip devices with solid-state devices. The project was completed during the 1987 refueling outage and, therefore, NNECO considered it resolved. The NRC staff agrees that this topic is closed.

Tonic 2.23 - Instrument. Service and Breathina Air Imorovements This topic addressed upgrading the station air systems at Millstone Unit 1.

All upgrades were completed during the 1989 refueling outage and, therefore, NNECO considers this topic resolved. The NRC staff agrees that this topic is closed.

Tonic 2.25 - Drywell Temoerature Monitorina System This topic addressed the possible modifications to upgrade the drywell temperature monitoring system by installing new temperature sensors. NNEC0 replaced the temperature sensors in the 1987 refueling outage and, therefore, considers this topic resolved. The NRC staff agrees that this topic is closed.

Topic 2.27 - Soare Recirculation Pumo Motor This topic involved rebuilding a damaged recirculation pump motor rotar. In the ISAP report dated 8/4/87, NNEC0 stated that the project would be continued l

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on a level-of-effort basis and-that it would not do an ISAP evaluation for it.

Therefore, NMECO stated that this topic should be considered resolved. The NRC staff agrees that this topic is closed.

Tooic 2.28 - Lono-Term Coolina Study This topic encompassed a study of the long-term cooling capability at Millstone Unit 1.- When the study was initiated, failure of long-term decay heat removal was thought to contribute up to 64% of the core melt frequency.

The study was completed in August of 1987 and concluded that the failure of long-term decay heat removal is no longer a major contributor to total core melt frequency. Therefore, NNECO concluded that no hardware modifications- .

were necessary and that this topic be closed. The NRC staff agrees that this topic is closed.

Topic 2.29 - FWCl Assessment Study This topic addressed a review of the feedwater control system and the FWCI system. In a letter dated 8/4/87, NNEC0 stated that it completed the' study and concluded that the feedwater control system performance in-both the level control mode and feed control mode, as well as FWCI performance, meet the requirements described in the original General Electric documentation and are consistent with the transient and accident analysis._ Therefore,_NNECO considers this topic closed. The NRC staff agrees that this topic is closed.

Topic 2.30 - MSIV Closure Test Frecuency This topic addressed a reduction in the. frequency of the 10% MSIV closure testing from monthly to quarterly testing in conjunction with the Technical Specification 4.7,0.1.C. NNECO is currently evaluating this topic,' and if deemed appropriate, will submit a Technical Specification change request.

Therefore, NNEC0 has determined that this topic does not need to be included as an ISAP item any longer and considers it resolved. The NRC staff agrees that this topic is closed.

Topic 2.32 --primary Containment Pumpback System-This topic involved the installation of a torus to drywell pump-back system.

The pump-back system is designed to take suction from:the torus and-to discharge to the drywell to maintain a minimum 1.0 psi differential pressure by minimizing pntging and venting. NNEC0 evaluated the topic in ISAP and ranked it as a low priority, however, since the project was also a part of the-solution to the larger containment purge and vent issue, NNECO completed the project in the spring of 1988. Therefore the NRC staff considers this topic closed.

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Topic 2.33 - RBCCW Leak Rate Testina This topic addressed the compliance of containment penetrations X-23 and X-24 with the leak rate testing requirements of 10 CFR 50, Appendix J. In a letter dated 5/16/89, NNECO committed to installing a new isolation valve arrangement for penetrations X-23 and X-24. NNECO completed the project during the 1989 refueling outage and considers this topic closed. The NRC staff agrees that this topic is closed.

Tonic 2.100 - Emeroency Gas Turbine Generator Reliability Study This topic involved a study conceraing the reliability of the emergency-gas' turbine generator. NNECO concluded that by replacing the existing electronic devices in the governor system with state of the art microprocessors, the -

unavailability time of the gas turbine generator could be reduced. NNECO opened a new ISAP topic (2.112) to track the replacement, and since this topic dealt with just the study, NNECO considered this topic to be closed.

Therefore, since topic 2.112 was opened to track the gas turbine generator modifications, the NRC staff agrees that this topic is closed.

Tonic 2.101 - Shutdown Coolina Discharoe Valve Reolacement This topic involved the planned replacement of the two motor-operated valves on the discharge side of the shutdown cooling system heat exchangers. -In the 9/29/92 ISAP report, NNECO stated that the project was completed prior to the 1989 refueling outage and, therefore, the topic is closed. The NRC staff agrees that this topic is closed.

Topic 2.102 - Main Transformer Replacement This topic involved the main Millstone Unit 1 generator' step-up (GSU)-

transformer. The GSU transformer failed in. December 1986, at which time the site spare was place in service. This project involved rebuilding and reinstalling the original transformer to replace the backup = transformer. In the 9/29/89-ISAP report, NNEC0 stated that the project'was completed during the 1989 refueling outage and, therefore, NNECO considered this topic - '

resolved. The NRC staff agrees that this topic is closed.

Topic 2.104 - Feedwater Nozzle leakaae Monitorina System This. topic involves the installation of an on-line leakage monitoring system which can be used to justify an extension of the inspection intervals for the feedwater nozzles. The project was completed in August of 1990'and, therefore, NNECO. considers this_ topic closed. The NRC staff agrees that this topic is closed.

Topic 2.105 - 480 V Motor Soft Start This topic involved the installation of three mechanical . clutches on the turbine building exhaust fans to allow the motors to start unloaded and then nave the : load applied gradually. In a letter dated 9/29/89, NNECO stated that it had installed one of the clutches to determine.its feasibility and it

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I proved satisfactory. The remaining two clutches were purchased and will be installed during routine operation. Since the clutches have already been purchased, NNECO considers this topic closed. The NRC staff agrees, that since the remaining clutches have been purchased and will be installed, this topic is closed.

Tooic 2.109 - ECCS Keepfill System This topic was a study to evaluate an independent system to pump water from the torus into the ECCS keepfill lines. In the 11/9/88 ISAP report,-NNECO stated that the result of the study indicated that the proposed system was not cost justified, therefore, the topic should be closed. The NRC staff agrees that the topic is closed.

Topic 2.110 - Head Sorav Line Removal This topic was a study to evaluate the benefits of removing the head spray system. In the ISAP report dated 11/9/88, NNECO stated tha*. the results of the study indicated that no modifications were warranted ano, therefore, that this topic should be closed. The NRC staff agrees that the topic is closed.

Topic 2.112 - Gas Turbine Governor Control System Reolacement As a result of a gas turbine generator study (ISAP Topic 2.100), NNEC0-proposed under this topic a project involving the replacement of the existing electro-mechanical devices in the governor system with." state of the art" microprocessors. In a -letter dated 9/29/89, NNECO stated that this project was completed on schedule during the 1989 refueling outage and,' therefore, NNECO considers this topic closed. The~NRC staff agrees that this topic is closed.

Topic 2.113 - Recirculatia, Pumo Vibration Monitorina This topic addressed the industry work to monitor recirculation pump shaft cracking and its applicability to Millstone Unit 1. NNEC0 concluded that a permanent vibration monitoring system should be added to monitor the recirculation pump. The local indication work was completed during the 1989 refueling outage and the remainder was completed in September 1989. In the ISAP report dated 9/29/89, NNECO stated that based on the above, that this topic is closed. The NRC staff agrees that this topic'is closed.

Tooic 2.114 - RBCCW System Class Boundaries This topic addressed an engineering study to ensure that the reactor building closed cooling water system had adequate class boundary breaks. In the ISAP report dated 11/30/90, NNECO stated that the study concluded that no modifications were required and that the topic should be closed. The NRC-staff agrees that this tcpic is ciosed.

p Topic 2.115 - Reolacement of LPC-4A and 4B Valves This topic involved the replacement of the valves and motor-operators for LPC-4A and B, in an attempt to provide better throttling characteristics for the Emergency Service Water system. The project was completed on schedule during the 1991 refueling outage and, therefore, NNECO considers the topic closed.

lhe NDC staff agrees that this topic is closed.

Tonic 2.117 - Environmental Oualification of IC Local Control Stations This t @ c involved modifications which were required because of environmental qualification concerns that a break in the reactor building may expose local control panels 2254 and 2255 to a harsh environment. The. project was completed during the 1991 refueling outage as scheduled and, therefore, NNECO considers the topic closed. The NRC staff agrees that this topic is closed.

Tonic 2.118 - Replacement of the Normal Station Service Transformer This topic evaluated the benefits of repairing or replacing the normal station service transformer. In the ISAP report dated 4/30/90, NNEC0 stated that the transformer would be repaired, returned to the site, and reinstalled during the next outage of sufficient duration. In the 5/31/91 ISAP report, NNECO stated that the transformer had been repaired during the 1991 refueling outage and this topic was considered closed. The NRC staff agrees that this topic is closed.

Topic 2.121 - Feedwater Venturi Replacement This topic involved modifications which were necessary to replace the two-existing feedwater flow nozzles with two new venturi flow elements. This project was completed during the 1991 refueling outage and, therefore, NNECO considers this topic closed. The NRC staff agrees that this topi_c is closed..

Tooic 2.122 - Reserve Station Service Transformer-Transfer Trio Scheme Replacement This topic encompassed the engineering, procurement and installation _ of a transfer trip scheme for the Millstone Unit I reserve station service-transformer to replace the out-dated system. In the ISAP report dated 5/31/91, NNEC0 stated that this project was completed during the 1991 refueling outage'and that'this topic is considered closed. The NRC staff agrees that-this topic is closed.

Tooic 2.125 -- LpCI Pumo Motor Reolacement This topic involved the replacement of the 1 W D low pressure coolant-injection pump motors with motors .of an % . 4 design. In the ISAP report i dated 10/23/92, NNEC0 stated that the proaca as completed in July 1992, and that this topic was considered closed. The 'OC staff agrees that this topic is closed.  ;

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-y ENCLOSURE 4 ISAP TOPICS STILL-BEING REVIEWED-

-Topic Number lillq 1.03 Containment Isolation - Appendix A Modifications -

1.16 10 CFR 50, Appendix R 1.23/1.25 Grid Separation' Procedures / Degraded Grid Voltage Procedures (TAC No, M60207) 1.40 Bolting Degradation or Failure 1.107 Drywell Spray Flow Indication (TAC No. M51106) 1.108 Torus Vacuum _ Breakers 1.114 Individual Plant Examination, GL _89-20 (TAC No. M74432) 1.115 Reactor Water Level Reference Leg Break, GL 89 .. __.

2.01 LPCI_ Remotely Operated Valves LP-50A and B 2.02_ Drywell Humidity Instrumentation -

2.08 Extraction Steam Piping

- 2.17 4.16 kV, 480 V, and 125-VDC Plant Distribution Protection Study.

2.24 Off-Site Power: Systems g ---- v - m