View source for B13307, Responds to Generic Ltr 89-06, Task Action Plan Item I.D.2 - SPDS - 10CFR50.54(f). SPDS for Plants Meet Applicable Requirements of Suppl 1 to NUREG-0737 & Consistent W/ Majority of Positions Provided in NUREG-1342

{{Adams
| number = ML20247E475
| issue date = 07/21/1989
| title = Responds to Generic Ltr 89-06, Task Action Plan Item I.D.2 - SPDS - 10CFR50.54(f). SPDS for Plants Meet Applicable Requirements of Suppl 1 to NUREG-0737 & Consistent W/ Majority of Positions Provided in NUREG-1342
| author name = Mrocaka E, Mroczka E
| author affiliation = CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000000, 05000213, 05000245, 05000336
| license number = 
| contact person = 
| case reference number = RTR-NUREG-0737, RTR-NUREG-1342, RTR-NUREG-737, TASK-1.D.2, TASK-TM
| document report number = B13307, GL-89-06, GL-89-6, NUDOCS 8907260188
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 8
| project = 
| stage = Other
}}

=Text=
{{#Wiki_filter:'
r       s 4
NORTHEAST UTILITIES                                          o.n.n.,O = ... somen sir  .e.riin.ce,n.ci,cui 1          "Y'     N''''I'EUII                                   P.O. BOX 270
                                            ' 1",,7,CC.,,,                                    HARTFORD. CONNECTICUT 06141-0270 k    k  J  [ oar [.a[ast.ucauie aucow.
                                        .                                                     (203) 665-5000 July 21, 1989 Docket Nos. 50-213 50-245 50-336 B13307 Re: Generic Letter 89-06 U.S. Nuclear Regulatory Commi.:sion Attention: Document Control Desk Washington, DC 20555 Gentlemen:
Haddam Neck Plant Millstone Nuclear Power Station, Unit Nos. I and 2 Generic letter 89-06 On April 12, 1989, the NRC Staff issued Generic Letter 89-06, "Ta Plan Item I.D.2--Safety Parameter Display System--10CFR50.54(f).'gAction                   This Generic Letter requested a response within 90 days of the date of the Generic Letter. Since Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) did not receive this Generic Letter until May 12, 1989, the NRC Staff was contacted to request an extension for the submittal of our response                         1989. This request was formally docketed on July 12,1989,(2yntil July 21,at the request of the Staff.
                            . Generic Letter 80-06 generally discusses the results of the Staff's evaluation of the implementation of safety parameter display systems (SPDSs) by various licensees / applicants.      Enclosed with the Generic Letter is NUREG-1342,                 "A Status Report Regarding Industry Implementation of Safety Parameter Display Systems," dated April 1989. NUREG-1342 describes methods used by some I
(1)   J. G. Partlow letter to All Licensees of Operating Plants, Applicants for Operating Licenses, and Holders of Construction Permits, " Task Action Plan Item I.D.2--Safety Parameter Display System -10CFR50.54(f)--(Generic Letter 89-06)," dated April 12, 1989.
(2)   E, J. Mroczka letter to U.S.       Nuclear Regulatory Commission,             " Generic Letter 89-06," dated July 12, 1989.
A003 8907260188 890721 DR   ADOCK 0500

l
               +
              - U.S. Nuclear Regulatory Commission B13307/Page 2 July 21, 1989 l
licensees / applicants .to implement SPDS in a manner found acceptable by the NRC Staff. Additionally, NUREG-1342 documents design features that the NRC Staff has found unacceptable and gives the Staff's reasons for finding them unacceptable.
Generic' Letter 89-06 specifically states that the information in NUREG-1342 does not constitute new requirements and that the Supplement I to NUREG-0737 establishes SPDS requirements. We commend the NRC's effort to document- the                 l acceptability to the Staff of various licensees'/ applicants' implementation of
,              the SPDS criteria found in Supplement I to NUREG-0737.      Whenever NRC require-L              ments are general . in nature, as is the case with SPDS provisions found in Supplement I to NUREG-0737, it may be beneficial to licensees to be aware of more detailed NRC guidance regarding potential acceptable means of meeting the more general requirements. It is our understanding, however, that the infor-mation contained in NUREG-1342 constitutes one of several means of meeting the SPDS provisions found in Supplement I to NUREG-0737. Accordingly, not meeting precisely the NRC positions contained in the informational NUREG-1342 does not imply that a licensee does not comply with the more general SPDS provisions found in Supplement I to NUREG-0737.
As requested in Generic Letter 89-06, we have reviewed the SPDSs for the Haddam Neck Plant and Millstone Unit .Nos. I and 2 taking into account the information in NUREG-1342.          (Generic Letter 39-06 specifically excludes Millstone Unit No. 3 from consideration.) We have also completed the check-list contained in the Generic Letter for these three plants. As explained below, we believe the SPDSs for the subject plants meet the applicable requirements of Supplement I to NUREG-0737.       We do not, however, agree with the characterization in Generic Letter 89-06 that Supplement I to NUREG-0737 establishes the "legel requirements" for SPDS. It is our understanding that the provisions of Supplement I to NUREG-0737 are not in themselves legally binding requirements.
Besides those provisions of Supplement I to NUREG-0737 contained in NRC regulations (e.g.,10CFR50, Appendix E), the only aspects of Supplement I to NUREG-0737 which are legally binding are those contained in the various confirmatory orders the NRC issued on this subject which confirm previously docketed commitments.       If we did not commit to a certain aspect of Supple-ment I to NUREG-0737, or if a commitment was not confirmed in the subject orders, the provisions of Supplement I to NUREG-0737 are not legally binding.
The following statement taken from Section 1 of Supplement I to NUREG-0737 h particularly illustrative of this interpretation:
It is . . . not intended that either the guidance documents or the                    l fundamental requirements are to be considered to be legal require-ments at this time.
With respect to the implementation of SPDSs at the Haddam Neck Plant and                    }
Millstone Unit Nos. I and 2, significant correspondence has been previousiy submitted to the NRC Staff identifying the means by which the provisions of l
1 1

 .+                                                                                                                               j l
U.S. Nuclear Regulatory Commission                                                                                    i B13307/Page 3 July 21,1989 i
Supplement I to NUREG-0737 would be met.             In addition, this docketed informa-                              !
tion has been reviewed by the Staff.                  Where additional information was required to be submitted to support Staff review of our SPDSs, such informa-tion was previously provided. In the case of the Haddam Neck Plant, the Staff's review of our dgeted information resulted in the issuance of an                                                ,
{{letter dated|date=October 21, 1988|text=October 21, 1988 letter}}                 which documented the Staff's conclusions that                                  '
CYAPCO had met.all of its commitments for the implementation of the SPDS and                                          1 that the Staff review of the SPDS was complete. In a similar fashion, Staff review of docketed correspondence led to the issuance of for the Millstone Unit No. 2 SPDS on February 12,1987.I4 Safety                                      A moreEvaluation detailed history of past correspondence between CYAPC0, NNECO, and the NRC can be found                                         .
in Attachment 1.                                                                                                       !
Based upon the information referenced in Attachment I and, in particular, the SPDS Safety Analysis Reports (SARs) for each plant which specifically identi-                                         i fied the means by which we intended to comply with the provisions of Supple-                                          '
ment 1 of NUREG-0737, CYAPC0 and NNEC0, on behalf of the Haddam Neck Plant and Millstone Unit Nos. I and                2, respectively, hereby certify pursuant to                                  ;
10CFR50.54(f) and the Generic Letter 89-06 request that our SPDSs meet the applicable requirements of Supplement I to NUREG-0737. This certification does not imply that our SPDSs fully meet all the positions contained in NUREG-1342.           Although we have reviewed our SPDSs in response to Generic letter 89-06 and conclude that they are consistent with the majority of the positions provided in NUREG-1342, given the fact that the NRC states that NUREG-1342 does not contain new requirements, we believe the previously docketed information remains sufficient to establish compliance with the applicable requirements of Supplement I to NUREG-0737.
With respect to the above certification, we note that changes to our SPDSs may be implemented without NRC approval pursuant to 10CFR50.59. Although we certainly intend to fully compe with the applicable requirements of Supple-ment I to NUREG-0737, changes to our SPDSs that do not affect legally binding requi.+ements, as defined above, can be made fully consistent with the require-ments of 10CFR50.59.
(3)          A. B. Wang letter to E. J. Mroczka, " Implementation of Safety Parameter Display System (TAC No. 51245)," dated October 21, 1988.
1 (4)          D. H. Jaffe letter to E. J. Mroczka, dated February 12, 1987.
i

U.S. Nuclear Regulatory Commission                                                     }
B13307/Page 4                                                                          I July 21,- 1989
{
Should you have any questions on the above information, please contact us.
Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY h.d. O h E. J. Mroczka
                                                                                     ~
Senior Vice President By:   C. F. Sears Vice President cc:        W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 A. B. Wang, NRC Project Manager, Haddam Neck Plant W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 J. T. Shedlosky, Senior Resident Inspector, Haddam Neck Plant STATE OF CONNECTICUT)
                                                ) ss. Berlin COUNTY OF HARTFORD )
Then personally appeared before me, C. F. Sears, who being duly sworn, did state that he is Vice President of Northeast Nuclear Energy Company and Connecticut Yankee Atomic Power Company, Licensees herein, that he is author-ized to execute and file the foregoing information in the name and on behalf cf the Licensees herein, and that the statements contained in said information are true and correct to the best of his knowledge and belief.
iAM CYYi Notafy Public bkevm

Docket Nos. 50-213 50-245 50-336 B.13307 l
l Attachment 1 Haddam Neck Plant Millstone fluclear Power Station, Unit Nos. I and 2 History of Past Correspondence on SPDSs l
l July 1989 I
__--___-_______A

p U.S. Nuclear Regulatory Commission B13307/ Attachment 1/Page 1 July 21, 1989 History of Past Correspondence on SPDSs Haddam Neck Plant l
CYAPC0 submitted on May 13, 1980,II) the SPDS Safety-Analysis Report (SAR) and committed to implement (including operator training) the SPDS as defined in the SAR, within 6 months from the start of Cycle 15 or by March 25 whichever was later. In an order issued by the NRC on July 2, 1986,12f 988,                                                                    the NRC Staff acknowledged that an SAR and an implementation plan had been submit-i ted on May 13, 1986, and confirmed that the SPDS would be fully operational on March 25, 1988. The dated August 12,1986.g Staff                                                                clarified In this        the letter, theconfirmatory Staff establishedorder  in a that   letter the SPDS was to be fully operational within 6 months from the start of Cycle 15 or by March 25, 1988, whichever was later.
On September 24,1986,I4) the NRC responded to our SAR for the SPDS at the Haddam Neck Plant.                                                              The Staff   performed   a preliminary        review and conclug that additional information                                                             would   be necessary.            On December 15, 1986, information. In a letter dated CYAPC0 submittN5,1988, October                                                                        CYAPC06}he     requested informed  the NRC additional Staff that the SPDS was declared fully operational on July 18,                                                                   1988, in accordance with the SAR and (1)  J. F. Opeka letter to C. I. Grimes, " Supplement I to NUREG-0737, Safety Parameter Display System, Safety Analysis Report, ISAP Topic No.1.20,'
dated May 13, 1986.
(2)  C. I. Grimes letter to J. F. Opeka, " Order Confirming Licensee Commitments on Emergency Response Capability (Generic Letter 82-33, NUREG-0737)," dated July 2, 1986.
(3)  C. I. Grimes letter to J. F. Opeka,                                                                   " Correction to Order Confirming Licensee                                                              Commitments   on    Emergency      Response       Capability (Generic Letter 82-33, NUREG-0737," dated August 12, 1986.
(4)  F. M. Akstulewicz letter to J. F. Opeka, " Safety Parameter Display Report (ISAP Topic No. 1.20)," dated September 24, 1986.
(5)  E. J. Mroczka letter to C. I. Grimes, '' Safety Parameter Display System, ISAP Topic No. 1.20," dated December 15, 1986.
(6)  E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, "Supplemert I to NUREG-0737, Safety Parameter Display System (TAC No. 51245)," dated October 5, 1988.
1

i-   .
J
                ~
1                                                                                                                              l' U.S. Nuclear Regulatory Commission l                 813307/ Attachment 1/Page 2
;                 July 21, 1989 confirmatory order. In a {{letter dated|date=October 21, 1988|text=letter dated October 21, 1988}},(7) the NRC Staff documented their conclusion that CYAPC0 had met all of its commitments for the implementation of the SPDS and that the NRC Staff review of the SPDS was l                 complete.
Millstone Unit No. 1 On April 9, 1987,(8) NNECO, on behalf of Millstone Unit No.1, submitted the SPDS SAR.       In addition, a commitment was made to implement (including operator training) the SPDS as defined in the SAR within 6 months following the start of  Cyg 12 or by February 15, 1988, whichever was later. On September 16, 19,87,        the NRC Staff responded to our submittal concerning the Millstone Unit No. I SPDS. The Staff requested that additional information                              rovided so that the review could be completed.            On November 25, 1987                               NNEC0 respondedtothatrequestandsubmittedadditioginformationtosupportthe Staff's review of the SPDS.       On August 24, 1988,    NNEC0 documented that the SPDS at Millstone Unit No. I was declared fully operational on February 8, 1988, in accordance with the SAR and schedule previously submitted to the Staff.
Millstone Unit No. 2 NNECO submitted on March 25, 1985(I2) the SPDS SAR and committed to implement (including operator training) the SPDS as actined in the SAR prior to the start of Cycle 8 or by March 25, 1987, wnichever was later. In an order (7)    A. B. Wang letter to E. J. Mroczka, " Implementation of Safety Parameter Display System (TAC No. 51245)," dated October 21, 1988.
(8)    E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, " Supplement I to NUREG-0737, Safety Parameter Display System, Safety Analysis Report,"
dated April 9, 1987.
(9)    M. L. Boyle letter to E. J. Mroczka, " Safety Parameter Display System--Request for Additional Information," dated September 16, 1987.                              '
(10) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, " Supplement I to NUREG-0737, Safety Parameter Display System, Additional Information,"
dated November 25, 1987.
(11) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, " Supplement I to NUREG-0737, Safety Parameter Display System (ISAP Topic No.1.08),"
dated August 24, 1988.
(12) W. G. Counsil letter to J. R. Miller, " Supplement I to NUREG-0737, Safety Parameter Display System, Safety Analysis Report," dated March 25, 1985.

      '. A
     .c.;
              ~
i            U.S. Nuclear Regulatocy Commission B13307/ Attachment 1/Page 3
              ' July 21, 1989 issued by: the NRC ' Staff on July 27,1985,(13) the Staff acknowledged that an SAR and an implementation plan had been submitted on March 25, 1985, and confirced that the SPOS would be fully operational prior to the start Cycle 8 or by March 25, 1987, whichever was later. On February 11,1986, zig                     i, the NRC Staff requested that NNEC0 provide additional information on the SPDS.
              .In  accordance dated   July 31, 1986.       with ig) request, NNEC0 provided the information in a letter As a result of telephone conversations with the
,               Staff, NNEC0 elected to conduct additional testing of one of the types of                       d isolation devices used in the SPDS. The testing an                              results were described in a letter to the Staff dated October 24,1986.qige On February 12, 1987,III) the NRC Staff issued a safety evaluation for the Millstone Unit No. 2 SPDS. It was concluded that no serious safety questions were posed by the proposed SPDS                 and g'prefore the implementation of the SPDS could continue. On June 1, 1987,I                      NNEC0 documented that the SPDS at Millstone Unit No. 2 was declared fully operational on March 24,                          1987.
Included in this letter were our comments on the NRC. Staff's safety evaluation dated February 12, 1987. In respongg)to our {{letter dated|date=June 1, 1987|text=June 1, 1987 letter}}, the NRC Staff responded on June 18, 1987,                        nnting that our comments on the        1 February 12, 1987 safety evaluation did not change the Staff conclusion that no serious safety questions are posed by the proposed SPDS.
(13) E. J. Butcher letter to J. F. Opeka, " Order Modifying License Confirming Additional Licensee Commitments on Emergency Response Capability (Supplement I to NUREG-0737)," dated July 27, 19 3 .
(14) A. C. Thadani letter to J. F. Opeka, dated February 11, 1986.
l
;               (15) J. F. Opeka letter to A. C. Thadani, " Safety Parameter Display System,"
dated July 31, 1986.
(16) J. F. Opeka letter .to A. C. Thadani, " Safety Parameter Display System,"
dated October 24, 1986.
(17) D. H. Jaffe letter to E. J. Mroczka, dated February 12, 1987.
(18) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, " Supplement I to NUREG-0737, Safety Parameter Display System," dated June 1, 1987.
l (19) D. H. Jaffe letter to E. J. Mroczka, "flillstone Unit No. 2 SPDS (TAC                      l No. 51257)," dated June 18, 1987.
                                                                                                                !}}