ML20155A355

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Retracts 880512 Request for Amend to License DPR-61 to Correct ECCS Single Failure Vulnerabilities,Per 880513 Telcon.Nrc Determined Request Did Not Constitute Unreviewed Safety Question & Amend Not Required
ML20155A355
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 05/27/1988
From: Mroczka E
CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8806100032
Download: ML20155A355 (3)


Text

l EM General Offices

HARTFORD, CONNECTICUT 06141-0270 k

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(203) 665-5000 May 27, 1988 Docket No. 50-213 B12933 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Reference:

(1)

E.

J.

Mroczka letter to Document Control Desk (NRC),

"Proposed Amendment to Facility Operating License No.

DPR-61, Technical Specification Revision-ECCS Response,"

dated May 12, 1988.

Gentlemen:

j Haddam Neck Plant Retraction of Proposed License Amendment 1

In Reference (1), Connecticut Yankee Atomic Power Company (CYAPC0) requested issuance of a license amendment for the Haddam Neck Plant.

The amendment was requested in order to comply with 10CFR50.59(c) which requires that a license amendment application be submitted when a proposed change to the facility involves an unreviewed safety question (USQ).

qYgC0 had conservatively 1

interpreted 10CFR50.59 such that the proposed change constituted a USQ.

The NRC Staff, in a telephone conversation on May 13, 1988, informed CYAPC0 i

after reviewing the proposed change described in the May 12 letter (Reference (1)), that the Staff had determined that the change did not I

constitute an unreviewed safety question.

As a result, no license amendment was necessary.

The corresponding hardware modification (which has j

subsequently been implemented) did not necessitate a change in technical specifications.

The May 12 letter proposed o minor technical specification change as a practical method of complying with the 10CFR50.59(c) requirement to submit a license amendment request pursuant to 10CFR50.90.

(1) The purpose of the change to the facility is to correct ECCS single failure vulnerabilities.

Specifically, the change involves trippino the charging pumps automatically on a safety injection actuation signti (SIAS).

The charging pumps are not required for the injection phase of a LOCA event at Haddam Neck.

Prior to this change, the charging pumps tripped with a coincident SIAS and loss of normal porer (LNP).

The change results in the charging pumps being tripped on an SIAS regardless of the availability of off-site power.

8806100032 880527 l

l PDR ADOCK 0500 3

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U.S. Nuclear Regulatory Commission B12933/Pago 2 May 27, 1988 Consistent with the conversation with the NRC on May 13, 1988, CYAPC0 hereby retracts the request for the license amendment of Reference (1).

The proposed technical specification change in Attachment 3 of Reference (1) also proposed a change to the basis of the core cooling systems technical specification.

That request remains valid.

CYAPC0 requests that the NRC Staff issue the change in the basis of the technical specification at your earliest convenience.

Summary of Corrective Actions for the ECCS Sinale Failure Vulnerabilities The following is a summary of the actions CYAPC0 has taken (or will be taking) to address ECCS single failure vulnerabiliti These actions have been discussedineithertheMay12orMay13,1988g)lettersorduringmeetings with the NRC on May 10, 1988 in the NRC offices or on May 17,1988 in the Northeast Utilities offices.

(1) Safety-related motor operated valve (MOV) starter circuit mechanical interlocks have been tested.

Any interlocks requiring replacement were replaced.

A 10CFR21 evaluation on the potential generic implications of the failure of the MOV due to the mechanical interlock is in progress.

(2) An interim solution involving the automatic tripping of the charging pumps on a SIAS has been implemented.

This change eliminates the single failure vulnerabilities that were identified in the charging system.

(3) The need for an improved solution to the charging system vulnerabilities (for example, a redundant valve for CH MOV-257 and automatic opening of BA-MOV-32 on an SIAS) will be explored for the

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1989 refueling outage.

The ISAP process and the Integrated Implementation Schedule will govern this process to integrate this issue into other ECCS m'difications and to confirm that the optimum solution will be implemented.

(4) CYAPC0 has completed a single failure analysis (3) of the ECCS mechanical components and has satisfactorily dispositioned all items identified as potential single failure vulnerabilities.

(2) See the E. J. Mroczka letter to Document Control Desk (NRC) "Haddam Neck Pl ant, Information Regarding ECCS Single Failure Analysis,"

dated May 13, 1988.

(3) Details of this evaluation were discussed at a meeting with the Staff in our office on May 17, 1988.

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I U.S. Nuclear Regulatory Commission B12933/Page 3 May 27, 1988 (5) After plant startup, a single failure analysis of the ECCS, including related electrical and air

systems,

'4111 be performed.

The scope and schedule for completion of this analysis is under developwnt and will be come nicateo to the Staff.

Similar to the work completed before

startup, exemptions previously issued or deviations from current criteria docunented as acceptable via the SEP process or other regulatory documentation are not invalidated.

(6) A report on the results of the single failure analysis work will be submitted to the NRC after the completion of the above single failure analysis work.

If you have any questions, please contact us.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY M

E.7/Nroc~zRA Ser(for Vice Pr(e/

sident cc:

W. T. Russell, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant i

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