ML17272A787

Informs NRC of Followup Actions Taken Re TMI-2 Lessons Learned Task Force Recommendations.Util Has Joined GE Owners Group.Bwr Action Items Will Be Implemented Prior to Receipt of OL & Changes to FSAR in Accordance W/Review Schedule

ML17272A787
Person / Time
Site:	Columbia
Issue date:	01/14/1980
From:	Renberger D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0578, RTR-NUREG-578 GO2-80-13, NUDOCS 8001220524
Download: ML17272A787 (14)

Text

Ht GULATOHY INFORMATION DISTRIBUTION SYSTEM (HIDS)ACCESSION NBH: 8001220520 DOC~DATE~80/01/10 NOTARIZED:

NO l.ACIL:b0 397 APPSS Nuc lear Projects Unit 2F Washington Publ ic Powe AOTH~NAME AUTHOR AFF ILLATION HEN8ERGERFD,I

~Washington PubliC Power Supply System At CTF',NAME Ht;"CIPItNT AFFILIATION OENTOAFH~RE Office of Nuclear Reactor Regulation SUBJE,CT: Informs NHC of followup actions taken re TMI 2 Lessons Learned flask Force recommendations, Util has joined GE owners group.BAA action items will be implemented piior to receipt of OL 8 chehoes to FEAR in'ccordence

'w/revIe'w schedule, DISTRIBUTION CODE: 80018 COPIES RECEIVED:LTR 4 kNCL g SI/E: TITLE: PEAR/FSAR ATADTS 0'nd Relsted Correspondence NOTES: P~AC i'ON: INTEHNAI.:

PIES TH ENCL i i 0 1 1 2 i 1 i i i i 0 1 1 1 1 i 0 1 0 2 2 1 0 RECIPIENT CO It)CODE/NAMt LT 05 P~o~~g g, BC 0 FILE 06 09 tsEOSC I EN BH 1i MECH ENG&A 13 MATL ENts BH i 6 ANAL'YSIS OH 18 AUX bYS BA 20 I L C SYS BH 22 AO SIri'ZCA 27 E,FFL f A l'lb 29 KiHK)<GOO AO f'L'ANT SYS AD SITE ANLYSIS HYDROeeMETtOH BH OSLO'ECIPIENT ID CODE/NAME AD~02 NRC PDH 08 OPERA LIC BR 10 GAB 12 STHUC ENG BR 15 AEAC'SYS BH 17 CORE PILAF 8H CONTAIN BY 8 ROARS SYS BR 26 ACCDNT AALYS 28 HAD ASMT HH AD FOR ENG AD lfEAC SAFETY DIRECT0H NRA MPA COPIES LTTH tBCL i 0 hXTF HNAI.0 03 LPDH 30 ACRS 1 1 10 10 OQ NSIC 1 1 ILA'p~&Q~R%PS W8 FO&BQ~WI 8 Lmp'S Qg gn'OTAL NUMBER OF COP I tS Ht:QUIHEO 0 L t'TR~ENCI.

1 A ll k Washington Public Power'Supply System A JOINT OPERATING AGENCY p.0.Box 958 3000 Gco, wxsHitcoroN War R<csaANo, WAswsoro~99352 PHONc (509)375-5000 Docket No.50-397 January 14, 1980 G02-80-13 U.S.Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C.20556 Attention:

Harold R.Denton, Director

Subject:

WPPSS NUCLEAR PROJECT NO.2 FOLLOW-UP ACTION REGARDING THE THREE MILE UNIT 2 ACCIDENT

References:

(1)T.D.Keenan to H.R.Denton dated October 1, 1979 (2)WPPSS letter to H.R.Denton dated August 8, 1979

Subject:

Intermediate BWR Plant Owners Group (3)D.B.Vassallo letter to All Pending Operating License Applicants dated September 27, 1979

Dear Mr.Denton:

The purpose of this letter is to inform you of the actions we are taking to respond to the NRC staff review regarding the Three Mile Island-2 accident.As you are aware, we have been successful in our efforts to join the General Electric Operating Plant Owners Group as indicated in Reference 1.We have been participating in the Owners Group since August and will utilize the Owners Group activities in the same manner as the original members in responding to the Reference 3 letter and the NRR Bulletins 8 Orders Task Group.Therefore, the need for the Intermediate BWR Plant Owners Group, discussed in Reference 2, no longer exists and it has been disbanded.

Accordingly, NRC review effort unique to the Inter-mediate BWR Plants wi 11 generally not be required.This will save time and effort both on your part and ours.'$))goo>>~0 T

Mr.H.R.Denton Page 2 In response to your request in Reference 3 that we begin implementation of the actions contained in NUREG-0578 and its supplements, we have pre-pared Attachment 1 which basically endorses the BWR Owners Group res-ponses.For those items where plant unique differences exist, we have added clarifications.

Our current schedule is to implement these action items prior to receipt of o'ur operating license with changes to our FSAR being submitted in accordance with review schedule requirements.

With regard to our actions in the areas of Emergency Planning and Preparedness and Improvements in Operator Training, we are proceeding in accordance with the intent of the guidelines provided in Enclosures 7, 8 and 9 of Reference 3.Revisions to our Emergency Plan and Training Program are currently underway and will be submitted in accordance with established review schedule requirements prior to receipt of our operating license.In keeping with your proposal of Reference 3 to become involved in the activities of the NRR Bulletins&Orders Task Group, we are participating in the preparation of a supplement to the General Electric report NEDO-24708.To this end, we are working with the other Owners formerly in the Intermediate BWR Plant Owners Group (Detroit Edison Company (Fermi-2), Mississippi Power and Light Company (Grand Gulf-1/2), and Pennsylvania Power and Light (Susquehanna-1/2))and GE to provide a supplement that includes these plants in the NEDO report.This supplement is currently being prepared and will be submi tted in early 1980.Responses to Inspection and Enforcement Bulletin No.79-08 as well as plant unique data requested by the B.SO.Task Group will also be submitted by letter in early 1980.The information provided in the supplement to NEDO-24708 and our own response to ISE Bulletin No.79-08 plus plant unique data will provide you with the same information for WNP-2 as has been submitted for the original GE Operating Plant Owners Group.With similar submittals being made by Detroit Edison Company (Fermi-2), Mississippi Power and Light Company (Grand Gulf-1/2)and Pennsylvania Power and Light (Susquehanna-1/2)you will have similar information in the same format for all GE Operating BWR's and BWR's with pending Operating Licenses.This provides an opportunity for you to review WNP-2 and the other intermediate BWR plants in the same manner and using the same resources that are reviewing the information submitted by the original Owners Group members.We believe this approach to be of mutual benefit in most efficiently utilizing available resources.

We strongly urge you to proceed accordingly.

Mr.H.R.Denton Page 3 In addition to the above activities, we have reviewed your TMI-2 Lessons Learned Task Force Final Report NUREG-0585) and the President's Commission Report (Kemeny Report)and are actively pursuing some of the recommeda-tions therein.Very truly yours, DLR:DLG:cd attachments D.L.RENBERGER Assistant Director Technology cc: JJ Verderber-B8R, NY HR Canter-BSR, NY FA MacLean-GE, San Jose NS Reynolds-Debevoise 8 Liberman, D.C.ND Lewis-EFFSEC, Olympia, WA JR Lewis-BPA, Richland, WA L.Rubenstein-NRC, D.C.D.Lynch-NRC, D.C.PK Bingham-GE, San Jose PW Marriott-GE, San Jose JS Bitel-Commonwealth Edison JP Morin-L.I.Lighting Co.TD Keenan-VT Yankee Nuclear Power Corp.WF Colbert-Detroit Edison N.Curtis-Pennsylvania Power 5 Light L.Dale-Mississippi Power and Light KK Chitkara-Cincinnati Gas and Electric Co.

I tW~>>

ATTACHMENT 1 WASHINGTON PUBLIC POWER SUPPLY SYSTEM UNIT 2 (DOCKET NO.50-397)COMMITMENTS TO MEET RE UIREMENTS OF NUREG-0578 This attachment contains commitments by Washington Public Power Supply System Unit 2 to the requirements set forth in NUREG-0578 and items (a)through (f)of Mr.D.B.Vassallo letter of September 27, 1979.Because of our acti ve involvement in the BWR Owners Group and the sub-sequent review of the Owners Group positions on NUREG-0578 items by the NRC, we have chosen the Owners Group positions as the means of responding to Mr.D.B.Vassallo's letter of September 27, 1979.For reference purposes, a copy of the BWR Owners Group positions as trans-mittedd by Mr.T.D.Keenan's letters on the subject to Mr.D.G.Eisenhut dated October 17, 1979, and November 15, 1979, are enclosed as part of this attachment.

NUREG-0578 Item 2.1.1 Emer enc Power Su lies WNP-2 concurs with the BWR Owners Group position with the following clarification:

The air-operated solenoid valves, which provide a long-term source of air to the air-operated ADS valves, are connected to emergency power.NUREG-0578 Item 2.1.2: Performance Testin for Relief and Safet Valves WNP-2 concurs with the BWR Owners Group position with the exception that S/RV performance testing in the"Alternate Shutdown" mode will be performed.

In addition, it should be noted that we are aware of the NRC's rejection of the Owners Group position, and our own response to that rejection will be handled through the BWR Owners Group.NUREG-0578 Item 2.1.3a Direct Indication of S RV Valve Position The implementation criteria provided by the Owners Group is modified by WNP-2 to include an evaluation of alternative approaches.

The position indication system shall be designed to the appropriate environment.

As a backup method of position indication, WNP-2 will use the existing discharge pipe thermocouples.

NUREG-0578 Item 2.1.3b Instrumentation for Inade uate Core Coolin WNP-2 concurs with the BWR Owners Group.position and will implement these requirements accordingly.

NUREG-0578 Item 2.1.4 Containment Isolation Provisions for PWR's and BWR's WNP-2 concurs with the BWR Owners Group position and will implement these requirements accordingly.

I 1' NUREG-0578 Item 2.1.5a Dedicated H dro en Control Penetrations WNP-2 has permanently installed redundant post-LOCA Hydrogen recombiners that meet the requirement of GDC 54 and 56.NUREG-0578 Item 2.1.5b Inertin BWR Containments Since this item has been deferred by the NRC, it will not be addressed.

NUREG-0578 Item 2.1.5c Installin H dro en Recombiners in LWR's WNP-2 has a post-LOCA Hydrogen recombiner system, and it is currently being reviewed for access requirements during its intended use todetermine if additional shielding or other design changes are required.NUREG-0578 Item 2.1.6a S stems Inte rit for Hi h Radioactivit WNP-2 concurs with the BWR Owners Group posi tion and will implement these requirements accordingly.

NUREG-0578 Item 2.1.6b Plant Shieldin Review WNP-2 concurs with the BWR Owners Group position and will implement these requirements accordingly.

NUREG-0578 Item 2.1.7a Auto Initiation of Auxiliar Feedwater This item is not applicable to BWR's.NUREG-0578 Item 2.1.7b Auxiliar Feedwater Flow Indication This item is not applicable to BWR's.NUREG-0578 Item 2.1.8a Im roved Post-Accident Sam lin Ca abilit WNP-2 concurs in principle with the BWR Owners Group position;however, because we are not confined by the same time limitations, we are still in the review stage and are not able to commit to any specific design changes at this time.We are, however, actively pursuing a course of action that will satisfy the NRC position on this item.NUREG-0578 Item 2.1.8b Increased Ran e of Radiation Monitors WNP-2 concurs with the BWR Owners Group position and will implement these requi,rements accordingly.

NUREG-0578 Item 2.1.8c Im roved In lant Iodine Instrumentation WNP-2 concurs with the BWR Owners Group position and will implement these requirements accordingly.

l I P k NUREG-0578 Item 2.1.9 Transient and Accident Anal ses WNP-2 concurs with the BWR Owners Group position and will implement these requirements accordingly.

NUREG-0578 Item 2.2.1a Shift Su ervisor's Res onsibilities WNP-2.concurs with the BWR Owners Group posi tion and will implement these requirements accordingly.

NUREG-0578 Item 2.2.lb Shift Technical Advisor WNP-2 concurs with the BWR Owners Group position;however, it should be noted that we are aware of the NRC's rejection of the BWR Owners Group position, and our own response to that rejection will be handled through the BWR Owners Group.NUREG-0578 Item 2.2.lc Shift Turnover Procedures WNP-2 concurs with the BWR Owners Group position and will implement these requirements accordingly.

NUREG-0578 Item 2.2.2a Control Room Access Control WNP-2 concurs with the BWR Owners Group position and will implement these requirements accordingly.

NUREG-0578 Item 2.2.2b On-site Technical Su ort Center Because of the different time schedule for WNP-2, we have not yet determined how we will meet the NRC's position on this item.We are actively pursuing it;however, and will have a complete position established in early 1980 that will support the requirements of the NRC.NUREG-0578 Item 2.2.2c On-site 0 eration Su ort Center WNP-2 concurs with the BWR Owners Group position and will implement these requirements accordingly.

NUREG-0578 Item 2.2.3 Revised Limitin Conditions for 0 erations Since this item has been deferred by the NRC, it will not be addressed.

ACRS Items--Containment Pressure, Water Level, and H dro en Monitors WNP-2 concurs with the BWR Owners Group position and will implement these requirements accordingly.

H.R.Oenton Item-Reactor Coolant S stems Ventin WNP-2 concurs with the BWR Owners Group position and will implement these requirements accordingly.

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