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REGULATORY INFQHHATION DISTRIB
ACCESSION N8R:8408280001 , DuC ~ DATE: 84/08/24FACIL:50-410 Nine
Mile Point Nuclear Station/
AUTH,l'JAt!E AUTHOR AFF ILIATIONMANGANiona 05000410
n items. Info will be
ENCL I .SIZE:gRelated Correspondence
05000410
RECIPIENTIO CODE/NAMF
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INTERNAL: ADi~>/LFJHBIE F ILEIF/DEPER/IRB
35NRR/OE/AEABNRrt/DE/EHEBNRR/OE/GB =28NRR/DE/t'ITEB 17NRR/OE/SGEB
25NRR/OHFS/LMB 32NRR/OL/SSPBNRR/OS I/ASBNRR/OSI/CSB 09hRR/DSI/t1ETB
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EXTERNAL: ACRS " 41DMB/OSS (AMDTS)LPOR 03NSIC '5
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13NRR/OE/i'1E8 18NRR/DE/SAG
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10NRR/DSI/ICSB 16NRR/OS I/PSB 19NRR/OSI/RSB 23RGN1
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TOTAL NUMBER OF COPIES REQUIRE.D: LTTR 55 ENCl 47
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Y NIAGARAU MOHAWK
NIAGARA MOHAWKPOWER CORPORATION/300 ERIE BOULEVARDWEST,
SYRACUSE, N.Y. 13202/TELEPHONE (315) 474-1511
August 24, 1984(NMP2L 0142)
Mr. A. Schwencer, ChiefLicensing Branch No. 2U.S. Nuclear
Regulatory CommissionWashington, DC 20555
Re: Nine Mile'oint Unit 2Docket No.-50-410
Dear Mr. Schwencer:
Enclosed for your use and information are the Nine Mile Point
Unit 2responses to the Nuclear Regulatory Commission's Safety
Evaluation Report openitems. This information has been previously
disc'ussed with your staff and issubmitted to aid your review of
the Unit 2 license application for theresolution of these open
items. This information includes Safety EvaluationReport open items
19, 51-3, 56, 58, 89, 104, 105, 123, 124, 125, 129, 130,154, 155,
157, 158, 159, 160, 161, 167, 170, 171, 172, 173, 175 and 186 .
The enclosed will be included in the next Final Safety Analysis
ReportAmendment.
Very truly yours,
NLR:jaEnclosurexc: Project File (2)
C. V. ManganVice President
Nuclear Engineering 5 Licensing
840828000 1 840824PDR ADQCK 05000410E PDR
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UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSION
In the Matter of'iagaraMohawk Power Corporation )
(Nine Mile Point Onit 2))'ocket No. 50-410AFFIDAVIT
C. V. Mangan, being duly sworn, states that he is Vice President
of NiagaraMohawk Power Corporation; that he is authorized on the
part of saidCorporation to sign and file with the Nuclear
Regulatory Commission thedocuments attached hereto; and that all
such documents are true and correct tothe best of his knowledge,
information and belief.
Subscribed and sworn to before me,' Notary Public in and for the
State of NewYork and County of , this A+~ day of ~~'~ 1984.
Notary Public in and forounty, New York
" My Commission expires:
FRANCES A VAN AUKEH}4tart 9ohllc In tho Siar ~ ol tin~
YorhQsahllnI ln Ononrlao ~ Co. No. lS22181
My Coeraicchas Saolroc March 20, 19
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modes is presented in Tables 3. 5-15 and 3. 5-16. It can
beobserved that the overall probability of damage by
turbinemissiles is 1.803 x 10 7/yr for Unit 2 if the probability
ofturbine failure rate of 1.0 x 10 '/yr recommended by the NRCis
used. These results are within the acceptance value of10 ~/yr as
outlined in Standard Review Plan 2.2.3, but areslightly higher than
the acceptable criteria specified inRegulatory Guide 1.115. These
calculated figures areconservative. Therefore, overall probability
forunacceptable damage by turbine missiles for Unit 2,
whenestimated on a more realistic basis, is much lower, and
isconsidered acceptable. A Turb ne System Maintenance Program based
onthe Mariufacturer's. (GE) recommendations and calculations of
missilegeneration probabilities will be developed within 3 years of
obtaining anoperating license.
3.5.1.3.4 Turbine Overspeed ProtectionDesi n Bases
Safet Desi n Basis The turbine-generator overspeed protec-tion
controls are not reguired to effect or support the safeshutdown of
the reactor or to.perform in the operation ofreactor safety
features.Power Generation Desi n; Basis The turbine generator
'on-trols are designed to prevent overspeed that may result froma
turbine generator trip or a large reduction in load. Themechanical
overspeed trip is set at about 110 percent ofrated turbine spee9.
The electrical or backup overspeedtrip is set at about 112 percent
of rated turbine speed.These set points will prevent the r'otor
from exceeding themaximum transient speed of 120 percent (design
overspeed) ofrated turbine speed.
Turbine speed is normally controlled by an
electrohydrauliccontrol (EHC) system. The speed control unit of the
EHCsystem (Figure 3. 5-1) produces a speed/acceleration errorsignal
that is determined by comparing the desired speedwith the actual
turbine speed at steady-. state conditions, orthe desired
acceleration with the actual acceleration duringstartup. When the
speed reference signal is increased in astep, the acceleration
control will take over and acceleratethe turbine at the selected
rate up to the new speedreference, at which point the speed control
willautomatically take control. Upon decrease of the
speedreference, the turbine will coast down with the valvesclosed.
The valves will reopen only when the new set speedhas been reached.
There is no deceleration limit. Duringnormal operation at rated
speed, the speed error signal isessentially zero, regardless of the
load.
3.5-15
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NINE HILE POINT UNIT 2
SPR NO. 51 3
In the staff's review of the HPCS diesel generator, it is not
clear thatthe check valve upstream of the air receiver tank is.
qualified againstwell established leakage criteria following a
seismic event. Theapplicant should amend the FSAR to clarify how
sufficient air capacityis assured to start the HPCS,diesel
generator immediately after aseismic event.
RESPONSE
This response has been incorporated into revised section 9. 5.
6. 2. 2
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0 ~Nine Mile Point Unit 2 CESAR
special fittings are designed, manufactured, and inspectedin
accordance with the guidelines and requirements of ANSIStandard
B3L. l, ASME Section VIII, or DEMA standards. Theseengine-
skid-mounted starting ai r piping and associatedcomponents are
over-designed (subjected to low workingstresses) for the
application, which results in highoperational reliability. The
design of the engine mountedstarting air piping and components to
the cited designphilosophy and standards is considered equivalent
to asys" em designed to ASME Section I II, Class 3 requirementsw'h
regard to system functional operability and
inservicereliability:Sufficient air capacity to start the HPCS
diesel generator immediatelyfollowing a seismic event is assured by
qualification of all piping andall components, including the check
valve upstream of the air receivertank, to Seismic Category I
requir ements. The air receiver 'tanks arecharged to provide the
necessary afr for starting the engine.When the air tank pressure e
drops below a pr eset 'valve, the aircompressors operate to
recharge their respective tank to the fullycharged condition.No
Division I I I diesel generator (DG) control functions aresupplied
by the air sta ting system or any other air systemto cont ol
emergency t".ip functions and/or diesel generatoroperation, except
engine cranking.
9.5.6.3 Inst umentation and ControlInstruments and
controlsmanual cont ol of each stasystem. The cont ols fo"in the
associated dieselmonitors descr'bed belo~room. The cont ol logic
is
a.e provided for automatic andndby d'sel generator starting
eacn starting system are locatedgenerator control rqom. The
are locat d in the main controlsnown on =igure 9.5-41:
Oae ationEach diesel gene a"o. a' compressor is
s~artecautoma='call.y when the associated ai" receiver pressure
islow and stops automat cal' when the a' pressu e is ..o mal.Each
a' compressor can be control'ed manually.
Alarms are provided in t~e main con"=ol room for eachstandby
diesel generator s" a="'ng sys-'em 'nope able and eachstandby
diesel gene a"or s"ar"'ng system trouble.9. 5. 6. 4 Test'g and
Inspect'nThe stancby diesel gene ator star='ng system is
designedpermit pe iodic inspect'on ar.d testing of the components
andsystems. Start'ng system capability is tested dur'ngpreope
at'onal test'ng of the diesel generator. Eilters ardstrainers are
checked for "'earl'ness dur'ng rou"'neinspection and testing.
Blowdown valves are openecperiodically to blow moisture out of the
air receivers.Continued integrity of the starting system is
assured
9. 5- "-
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Nine
Macle
Porn" Un t 2 FSAR
QUEST ION F271. 10
Zdentify if there are any safety-related deep draft pumps inthe
plant.RESPONSE
The only safety-related deep draft pumps'tilized in theUnit 2
design are three residual heat removal pumps, one lowpressure core
spray pump, and one high pressure core spraypump.
NRC letter dated December 8, 1983 requested
additional.information on methods used to qualify long-term
operabilityof deep draft pumps.The following is a description of
the method used:
Operability MethodsI,ong-term operability has been considered.
'in theemergency core cooling system. (ECCS) pump design.The ECCS
pumps ' ffectiveness is evaluated byacceptance, qualification, and
in-plant testing.Operability is assured by functional
andsurveillance tests, preventive maintenance, andvibration
monitoring as described below.
Functional 'Zesting and Surveillance
Each deep draft pump is scheduled to befunctionally tested in
accordance withSection XI of the ASME Boiler and PressureVessel
Code, which currently recpxires testingat least once each 31
calendar days.
Pump'nletpressure, cLifferential pressure, flowrate, motor
vibration, and motor bearingtemperature measurements wi1.1 be
taken.Engineering analyses are performed to identifychanges or pump
performance trends that may beindicative. of off-normal operating
conditions.Functional testing and surveillancerequirements are
specified in NMP2 TechnicalSpecifications, surveillance proWchrres,
andinservice inspection (XSI) programs.
b. Preventive Maintenance Program
Preventive maintenance and surveillancetesting are scheduled at.
periodic intervals.
QSR F271.10-1.
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Scheduled preventive maintenance consists ofobtaining megger
(resistance) readings of themotor windings, lubricating critical
rotatingcomponents, plus general cleaning andinspection of rotating
electrical equipment atperiodic intervals specified in
preventivemaintenance procedures. Inspection„overhaul,alignment,
and impeller lift adjustments willbe scheduled as the ISI program
test resultsindicate.
C. Vibration Monitoring Program
As part of the NMP2 plant IS I programs,vibration measurem'ents
wi1 l be taken inaccordance with'Section XI of the ASME'oilerand
Pressure Vessel Code, which currentlyrequires monitoring, every 31
days. Inaddition, vibration data bases will beestablished during
the preoperationaL/startuptesting phase and will be used for
comparisonpurposes during later .surveillance testing.Journal
bearing wear and shaft whip can bededuced from motor vibration
increases. Thedata will be evaluated on a scheduled basis topredict
potential bearing and journal failuresand establish replacement
schedules. Datawill be available onsite for inspection.
Vibration should be limited to .3 in/sec. velocity peak-to-peak
over allmeasured frequencies as measured by an LSD 360 or
equivalent equipnent, whenthe motor and punp are operated as a'nit,
over the normal design range ofcr ssure and flow. This limit is
based on normal oper ation. Higher mmentaryincr eases may be
acceptable during starting oi at shut off. This limit is notbased
on what the equipnent can withstand. The equipnent danage threshold
ishi+er: close to .020 irch-, mcmentary and not sustained. Any
sustainedv'br ation. over .3 in/sec may cause excessive bearing
wear.
2. Background
ECCS Pump Design,
The ECCS pumps used at NMP2 are manufacturedby Byron Jackson
(BJ) Pumps.. Each ECCS pumpis supplied with a casing or suction
barrel.These pumps are- not installed in a wet sump;These deep
draft, pumps, due to their relativeshortness, demonstrate fewer of
the problemsassociated with longer pumps. The longestECCS pump in.
service at the NMP2 plant is24 ft long. The rigidity of the pump
assemblyis 'nhanced by the use of seismic ringsbetween the pump
assembly and the barrel.
The hydraulic design has been developed overthe last 40 years of
experience in manyapplications. The; pumps use a doubLe
suctionfirst stage to provide stability over a. wide
Q&R F271.10-2
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range of flows. Column frequencies are wellremoved from the pump
speed.The barrels are relatively large in diameter,thereby
providing low velocities around thepump inlets. The suction barrels
includeseismic restraints (spoke configuration) whichact as flow
straighteners to suppress vortexformation. All pumps are provided
with highprecision, k'eyed sleeve-type couplings.The ECCS pumps
contain design . features topreclude failure of the impellers,
impellerstaking, shafts, bear'ngs, wear rings,couplings, and
stuffing boxes. The designincludes safety factors ( loading
criteria)based on the expected pressures, temperatures,.and
loadings defined in the designspecification. Lateral restraints
areincluded in the pump to control deflections.Tolerances assuring
alignment of the shaft andpumping elements are verified by
designcalculations. Motor shaft deflections withintolerance are
predicted in a static seismicanalysis and, are verified by a
qualificationtest of a similar motor. A dynamic analysisof the pump
and motor is performed todetermine resonances and predict
loadingsthroughout the pump and motor.
ECCS Pump TestingTests are performed on each pump delivered. The
testsinclude head versus flow, NPSH, and vibration monitoring.The
assembled pumps are checked for porper assembly andlow friction by
hand turning (rotating) the shaft. Eachpump is run for a total of
100 hours during testing. Aqualification test of a similar pump
motor was oerformed.This data provides qualification of the NMP2
pumps motorsby a similarity analysis.
Q&R F271. 10- 3
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!.'.ng .'.~g l.e Po> nt Jn' 2 CESAR
O'UEL SYSTEM DESIGN
The fuel system design for Unit 2 is identical to thatreviewed
and approved for GESSAR II {Reference 1). Methodsand criteria used
to evaluate fuel system performance arealso identical to those used
for GESSAR II. The results ofthe NRC review of Section 4.2 of
GESSAR II documented inReferences 2 and 3 are therefore applicable
to Unit 2.
The Nine Hile Point Unit 2 post irradiation fuel
surveillanceprogram for GE designed and manufactured fuel
assemblies is theprogram proposed by GE (References g through 8).
This programhas been,previousIy approved as satisfying SRP Section
4.2.II.D'.3
4. 2-1
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4. 2. 1 References
1. General Electric Standard Sa ety Analysis Report, DocketNo.
50-447.
2. Safety Evaluation Report Related to the Final DesignApproval
of the GESSAR II BWR/6 Nuclear Island Design,NUREG-0979, April
1983.
3. Safety Evaluation Report Related to the Final DesignApproval
of the GESSAR II BWR/6 Nuclear Island Design,NUREG-0979 (Supplement
No. 1), July 19B3.
(4) J. S. Charnley (GE) to C. H. Berlinger, (HRC),.
"Post-Irradiation. Fuel Surveillance Program", Hovember 23,
1983.
(5) L. S. Rubenstein (HRC) to R. L. Gridley
(GE),"Post-Irradiation Fuel Surveillance"., January 18, 1984.
f
(co) J. S. Charnley (GE) to L. S. Rubenstein (HRC), "FuelSurveil
lance Progr am", February 29, 1984..
(7) J. S. Charnley (GE) to L. S. Rubenstein (HRC),
"AdditionalOetails Regarding Fuel Surve'illance Program", Hay
25>1984.
{8) L. S. Rubenstein (HRC) to R. L. Gridley (GE), "Acceptanceof
GE Proposed Fuel Surveillance Program," June 27, 1984.
4. 2-2,
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Nine Mile Point Unit 2 FSAR
9A. 3. 2 Administrative Procedures and. Controls
ADMINISTRATIVE CONTROL'S
Procedures similiar to those presently in effect at Nine
MileUnit 81 are being developed for Unit II and will comply withBTP
CMEB 9.5-1, Section C.2 Items A through O. 'heseprocedures will be
under the control of the supervisor fireprotection nuclear and
co-approval by the required supervisors.The administrative controls
for fire protection, consist of thefire protection organization,
the fires brig'ade Itraining, thecontrols over combustibles and
ignition source,'the prefire plansand procedures for fighting
fires, surveillance and maintenanceof fire protection features,and
quality assurance.9A.3.3 Fire Brigade
A fire brigade of five members has been established atUnit 2. A
Nuclear Fire Chief and four nuclear fire fightersare assigned
rotating shifts with fire, rescue, and firstaid responsibilities.
In addition, these people performinstructions and tests on the fire
systems and equipment asrequired. All members shall have knowledge
„. in. safetyrelated systems, as. this is a required module in the
fixebrigade training programs. The ability to- pass. an
annualphysical examination and agility test is required
foremployment in the fire department. Brigade members
reportdirectly to the Supervisor of Fire Protection-Nuclear or
hisassistant.Personal protective equipment such as turnout coats,
boots,gloves, and helmets are provided for brigade members.
Inaddition approved self-contained breathing apparatus isprovided.
Complete sets of equipment are stored in aminimum of ten locations
throughout the plant.An approved breathing air-compressor is
presently in use forSCBA bottle refilling, in addition a bottle
cascade systemis available.Fire brigade members will be trained as
outlined in APN-10P(Nuclear Fire Fighter and Nuclear 'ire Chief
Training) .This training program is intended to ensure that the
Brigade-Leader and at least two members shall have
sufficienttraining and a knowledge of plant safety-related systems
tounderstand the effects of fire and fire suppression on
safeshutdown capability.Technical training for nuclear fire
fighters and nuclearfire chiefs shall consist of classroom sessions
and in-plantinspections showing site specifics covering the
subjects asoutlined. in APN-10P.Station. practical training for
nuclear fire fighters andnucleax'ire chiefs shall consist of
on-the.-job training,fire drills, training exercises and
demonstrations, lecture
9A..3-31
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Nine Nile Point Unit 2 5'SAR
QUESTION E460. 18 ( 11. 4)
Provide the NMP2 Process Control Program establishing a setof
process parameters and boundary conditions within whichreasonable
assuranc'e can be given that solidification willbe complete with
essentially zero-Cree liquid based on therecommended WFC-VRS,
Topical Report process parameters. Yourprocess control program
should include administrative and/orplant operating. procedures to
meet waste form structuralstability requireme'nts set forth in
Section 61.56 of10CPR61.
RESPONSE
The process control program is not yet available. Generictests
have been run on their process using their ownmethodology which
indicate the stability requirements of10CFR61 will be met by the
NMP2 system.The vendor of the VRS system is preparing a program
based onthe requirements of 10CFR61, the NRC' final waste
clas-sification and waste form technical position papers
concern-ipg stability requirements for solidified waste states
thatgeneric information from topical reports using actual
orsimulated waste can be used to qualify a process
controlprogram.
Tests, will be performed based on the analytical standardsset
forth. by the NRC. Test information will be collected toestablish a
complete program prior to making the VRS systemoperational.The
process control program is expected to be available bythe second
quarter of ]g85.
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Nine Mile Point Unit 2 FSAR
QUESTION E460.19 (11.4)'I
Section 20.311 of 10CFR20 requires that any licensee
whotransfers radioactive waste to a land disposal facility
mustclassify the waste according to Section 61.55 of
10CFR61.Provide a compliance program to assure proper
classificationof waste in accordance with guidance provided in
Low-LevelWaste Licensing Branch Technical Position on
RadioactiveWaste Classification, Rev. 0, dated May
1983.RESPONSE
Radioactive waste shipments are classif ied according toSection
61. 55 o f 10CFR61 by a combination of directmeasurements 'and
scaling factors. Direct measurements aremade of the significant
gamma-emitting nuclides, grossalpha, and water content of each
batch of waste shipments.Scaling factors, initially developed from
industry data andsubsequently from actual measurements on composite
samplesof waste batches, are used to quantify nuclides not
directlymeasured. The factors will be redeveloped when
significantchanges are observed in various process streams and on
aperiodic basis.
Specifically, the following is used to quantify the
nuclideslisted in Tables 1 and 2 of Section 61.55 for each
radioac-t'ive waste stream:
Co-60, Cs-137, and other gamma-emitting nuclides withsufficient
yield - By direct gamma ray spectroscopy.Ni-63, Sr-90, Tc-99, and
I-129 - By scaling to nuclidesdirectly measured.Transuranics,
Pu-241, and Cm-242 - By scaling to grossalpha, directly
measured.H-3 - By scaling to water content.C-14, Ni-63, and Nb-94
in activated metal - Byphysical calculations based on exposure.
Procedures. will be developed by March 1985 for classification
of wasteshipments from Unit 2. Training procedures will be
developed andtraining will be provided prior to use of the
procedures.
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None Hiie Point Unit 2 FSAR
QUESTION F471.21 (SRP 13. 1)
(a) Figure 13. 1-9 shows that the health physics. andchemistry
functions at, NMP-2 are not separated into aHealth Physics Section
and Chemistry Section supervisedby a Health Physics Supervisor and
a ChemistrySupervisor as recommended by our positions inSection 1
I.A. 1 of NUREG-0731. The organisation andFigure 13.1-9 should be
revised to reflect separatesupervision of these distinct functional
areas..
(b). The applicant should provide qualifications in the form'f a
resume for the Superintendent, Chemistry andRadiation Management
(RPM) to demonstrate that the RPMmeets the requirements of
Regulatory Guide 1.8,"Personnel Selection and Training."
(c) The applicant should commit to using the criteria ofANSI 3.
1, December 1979, in selecting the individualtemporarily filling
the RPM' position as outlined inNUREG-073 1 .
(d) The applicant should commit to t ain health
physicstechnicians in acco rdanc e with the criteria'fANSI/ANS 3.
1-1978, which requires one year of relatedtechnical t aining and
two years of experience, orANSI 18. 1, which also r equires such
training andexperience. Additionally, radiochemistry and
radiationprotect/on are separate specialties each requ3.ring
twoyears of working experience, as indicated in ANSI 18.1.The
applicant should commit to provide experiencedtechnicians with
appropriate qualifications ancL two~years of experience in each
specialty, chemistry andradiation protection, or should separate
the functionsinto two distinct specialties in accordance 'ithANSI
18. 1.
(e) To comply wi'th the criteria of NUREG-0654, Table B-l andthe
II.A.d(2) of NUREG-073 1, the applicant should committo have at
least one "ANSI 18. 1 qualified health physics
. technician on the site at all times.RESPONSE
See rev. sed Chapter 13..
Q&R F471.21;1
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Nine Mile Point Unit 2 FSAR
TABt'.E 13.l-3 (Cont)
Su ervisor Com uter 0 erations and Maintenance Nuclear
This supervisor is responsible for the proper operation ofthe
station process computer, the security computers, thedocument
control computer, the outage management andscheduling computer,
site applications on the Niagara Mohawksystem computers and the
operation and maintenance of thevarious mini and micro computers
used on the site forprocess and results applications.Su ervisor
Technical Su ort NuclearThe Supervisor Technical Support Nuclear is
in charge of thecoordination of the activities of the General Site
TechnicalSupport Staff. This staff is composed of
technicalassistants of diverse training and exp'erience, who
areassigned on special projects within the TechnicalDepartment.
Supervisor Fire Protection Nuclear
The Supervisor Fire Protection Nuclear performs generalplanning,
testing, inspection and overseeing of the stati'onfire protection
functional activities'eriodic testing ofthe systems and portable
equipment is performed by shift.fire brigade personnel or
technicians under. the direction ofthe Shift Supervisor or
Supervisor Fire Protection.Su erintendent Chemistr and Radiation
Mana ement
The Superintendent Chemistry and Radiation Management
isresponsible for the chemistry, radiochemistry,
radiationprotection and emergency planning requirements of
thestations(He is the "Radiation Protection Manager" defined in
ANSI 18.1-1978).He also coordinates the chemical'ndradiochemical
aspects of the effluent and environmentalmonitoring to ensure the
maintenance of site criteria.Under his direction are the Supervisor
Chemistry andRadiation Protection, Supervisor Radiological Support,
andthe Environmental Coordinator.
Su ervisor Chemistr and Radiation Protection
The Supervisor Chemistry and Radiation Protection has
directresponsibility for the Radiochemistry and RadiationProtection
Technicians and for the operation of theChemistry and
Radiochemistry laboratory, radiationprotection program, and
radiological monitoring'quipment.
2 of 7
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Nine Mile Point Unit 2 CESAR
TABIE 13.1-3 (Cont)
(When he temporarily fills the ("Radiation Protection Manager"
)Superintendent Chemistry and Radiation Management position, heis
qualified to ANS 3.1 Draft 1979)Under his direction are the Unit
Radiation ProtectionSupervisor, Unit Chemistry Supervisor, and
SupervisorInstrument Support.
Su ervisor Radiolo ical Sup ortThe Supervisor Radiol'ogical
Support has the responsibilityof assisting the Superintendent
Chemistry and RadiationManagement in providing technical and -
administrativeguidance in the areas of Emexgency Planning,
ALARA,Radiological Engineering, Respiratory Protection,
andDosimetry (He is an individual who can temporarily fill the
("RadiationProtection Manager" ) Superintendent Chemistry and
Radiation Management'sposition and is qualified to Section 4.4.4 of
ANS 3.1 Draft 1979).Under his direction is a technical support
staff to provide
technical guidance in the above areas.Unit Radiation Protection
Su ervisorUnder the general direction of the Chemistry and
RadiationProtection Supervisor, 'his supervisor is responsible
forproviding technical and administrative guidance in the areaof
radiation protection and for managing and controllingpersonnel
exposures to radiation and radioactive materials.A Technical
Specialist is assigned to assist thissupervisor.
Unit Chemistr Su ervisorUnder the general direction of the
Chemistry and RadiationProtection Supervisor, this supervisor is
responsible forproviding technical and administrative guidance in
the areaof Chemistry and for managing and controlling
radioactiveand chemical effluents. A Technical Specialist is
assignedto assist this supervisor.Su ervisor Instrument Su ortUnder
the general direction of the Chemistry and RadiationProtection
Supervisor, this supervisor is responsible for aprogram to assure
that all counting room and radiationprotection instrumentation, as
well as sealed sources, areproperly inventoried and maintained. A
Technical Specialistis assigned to assist this supervisor.AI,ARA
Coordinator
Under the general direction of the Supervisor
RadiologicalSupport, this supervisor is responsible for developing
andmaintaining a formal AMA progx am to assure that the
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Nine Nile Point Unit 2 ESAR
TABI.E 13. 1-3 {Cont)
Radwaste 0 erations Su ervisorThe Radwaste Operations
Supervisor, under the generaldirection of the Supervisor
Operations, is responsible forcoordinating the sa fe and e fficient
conduct of wasteoperations. He schedules and coordinates waste
shipmentsand supervises the packing of radioactive waste
asnecessary. He directs and supervises the work of
operatorsassigned to duties in the waste facility.
AssistantSupervisors Radwaste Operations are assigned, as
required.
.Radiolo ical En ineerUnder the general direction .of the
Supervisor RadiologicalSupport, this supervisor is responsible for
providing highlyspecialired technical advice and assistance in 'the
area ofradiological. engineering.Emer enc Coordinator
This supervisor has responsibility for maintaining andmodifying
the Emergency PLan and Procedures as required, formaintaining the
Emergency Plan Monitoring equipment and forthe scheduling,
operation and analysis of drills and otherexercises of , the
Emergency Plan and Procedures. Anassistant emergency coordinator is
assigned., to assist thissupervisor.
Envi ronmenta 1 Protection CoordinatorThis supervisor is
responsible for coordination of theenvironmental programs
associated with the Nine Mile PointSite and operated by
contractors, and also for environmentalmonitoring conducted by site
personnel.
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TABIE 13.,1-4 (Cont)
TitleTraining SpecialistNuclear
Emergency Coordinator
Supervisor Chemistryand Radiation Protection
Unit Radiation ProtectionSupervisor
Unit: Chemistry Supervisor
Supervisor InstrumentSupport
Supervisor RadiologicalSupport
Section ofANSI N18.1-1978
No. Site . Containing
16 NA
NA
4.4.3or'.4.4
„
4
4.4.3
4.7.2
4.6. 1~
Dosimetry Coordinator
At&RA Coordinator
Radiation Protection Technicians As Needed
4.7.2
4. 7.2
4.5.2
Chemistry 8 Radiochemistry Technicians
Environmental ProtectionCoordinator
Respiratory ProtectionCoordinator
Radiological Engineer
Assistant StationShift Supervisor NuclearStation ShiftSupervisor
Nuclear
Chief Shift OperatorNuclear AuxiliaryOperator E
As Heeded
16
16
12
4.5.2
4. 7.2
4. 7.2
4. 7.2
~4.3. 1
4.3. 1
4.3. 1
4.3. 1
* When one of these individuals temporarily fills the position
of SuperintendentChemistry and Radiation Management this individual
will meet the qualificationsof Section 4.4.4 of ANS 3el Draft
1979.
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13.2.16 Shift Technica1 Advisor Training
The Shift Technical Advisor (STA) attends the training program
forSenior Reactor Operators (SRO). The SRO program meets the
requirementsof NUREG 0737 Appendix C. For a comparison of the SRO
program and therequirements for STA training in NURER 0737 Appendix
C see Tahle 13.2-2.
13.2.17 Applicable NRC Documentation
The following NRC documents are applicable to training:10CFR50
Kicensing of Production E Utilization
Facilities10CFRSO
10CFR55
10CFR55
10CFR55.33
NUREG-0094
NUREG-0737
10CFR71
RegulatoryGuide 1.8
Appendix R Fire Protection Program forNuclear Power Facilities
Operating Priorto January 1, 1979
Operator license
Appendix A Requalification Program ForE,icensed Operators
Appendix E Renewal of EicensesTechnical Specifications 6. 4.
1
NRC Eicensing Operating Guide
Clarification of TMI Action PlanRequirements
Packaging of Radioactive Material forTransport
Personnel Selection and Training
USNRC fetter Harold Denton to all power reactorapplicants and
licensees. Subject-qualifications of reactor operators,dated March
28, 1980.
The 'above-listed regulatory guidance has been addressed inthe
training program and implementing procedures.
13.2-56
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CHAPTER 13
LIST OF FIGURES
FigureNumber Title13. 1-1
13.1-1a
13. 1-2
13.1-3
13.1-4
13. 1-5
13.1-5a
13. 1»5b
13. 1-6
13. 1-7
13.1-8
13.1-9
13.2-113.2-213. 4-1
13. 5-1
NMPC CORPORATE UPPER MANAGEMENT ORGANIZATIONAND FUNCTION
NMPC UPPER MANAGEMENT NUCLEAR ORGANI7ATXnN
NMPC NUCLEAR AND SECURITY ORGANIZATION
NUCLEAR GENERATION ORGANIZATION
NUCf EAR ENGINEERING ORGANIZATION
UNIT 2 SITE ORGANIZATION CHART - PRODUCTION
PERSONNEL ASSIGNED DURING PREOPERATIONALTESTING AND STARTUP
TESTING
TOTAL SITE STAFFING FQR UNITS 1 AND 2
UNIT 2 SITE ORGANIZATION CHART - MAINTENANCE
TECHNICAL ORGANIZATION
UNIT 2 SITE ORGANIZATION CHART - TRAINING
CHEMISTRY AND RADIATIQNPROTECTION ORGANIZATION
OPERATOR TRAINING SCHEDULESRO PROGRAM COMPARISON TO NUREG-0737
APPENOIX CSAFETY REVIEW AND AUDIT OF OPERATIONSORGANIZATION
"AT THE CONTROLS" MAIN CONTROL ROOM
13-viii
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Section
13.2.12.413 ~ 2. 12.513. 2. 12. 613.2. 13
13.2.13.113.2.14
13. 2. 14. 113.2.14.21'3.2.14.3
13.2. 1513.2. 15. 113.2.1613.2.1713.3
13. 413. 4. 113.4.213.4.2.113.4.2.213. 4. 3
13.513.5. 113.5. 1. 1
13.5. 1.213.5.1.313.5.1.313 '.1.313.5.1.313.5.1.3
.1
.2
.3~ 4
13.5. 1.313. S. 1. 313.5. 1.313.5. 1.313.5.2
.4.1
.5
.6e7
13.5 ~ 2. 113.5.2. 1. 1
Nine Mile Point Unit 2 FSAR
CHAPTER 13
TABLE OF CONTENTS (Cont)
TitleRecordsOther Station EmployeesFire Protection StaffReserve
Fire Brigade Trainingand Retraining (APN-10E)Training
ProgramTraining of Nonlicensed Personnel(APN-10C)Professional
PersonnelQuality Control PersonnelQuality Control Duties ofStation
PersonnelTraining Program RecordsRecordsShift Technical Advisor
TrainingApplicable NRC DocUmentationEMERGENCY PLAN
OPERATION REVIEW AND AUDITAdministrative ControlsSafety Review
and Audit of OperationsSite Operations Review CommitteeSafety
Review and Audit BoardAudit Program
PLANT PROCEDURESAdministrative ProceduresConformance with
RegulatoryGuide 1.33Preparation of ProceduresAdministxative
ProceduresStanding Operating OrdersSpecial Operating
OrdersEcgxipment Control ProceduresControl of Maintenance
andModificationModification Procedure ObjectivesMaster Surveillance
Testing ScheduleProcedures for LogbookTemporary PxoceduresOperating
and MaintenanceProceduresControl Room. Operating ProceduresGeneral
Plant and System OperatingProcedures
Pacae
13.2-49c13.2-49c13.2-49d
13 . 2-5313.2-53
13.2-5413.2-5413.2-55
13.2-5513.2-5513.2-5513.2-5613.2-5613. 3-1
13. 4-113. 4-113. 4-113. 4-113.4-213.4-3
13 . 5-3.13. 5-1
13.5-113. 5-113.5-213.5-213.5»313.5-3
13. 5-313. 5-313. 5-3a13. 5-3a13. 5-4
13.5-413. 5-4
13.5-4
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TABLE 13.2-2
SRO PROGRAM COMPARISON TO NUREG"0737
APPENDIX C
NUREG-0737, Appendix C SRO PROGRAM
6.2 Applied Pundamentals(120 hxs)Plant Specific Rx
TechnologyChemistry 4 Corrosion ControlI5CPlant MaterialsPlant
Thermal Cycle
Reactor TheorySimulator WeekPlant Systems TxainingPlant Systems
TrainingThexmodynamics
80 hours~ 8 hours40 hours
4 hours40 hours
172 hours
6. 3 Man'agement/Supervisory Skills(40
houx's)LeadershipInterpersonal CommunicationMotivation of
PersonnelProblem 5 Decisional AnalysisStressHuman BehaviorCommand
Responsibilities 4
Lxmf.ts
Admin Procedures,Controls 4 Limitations(Leadership
Training)(Procedural Training)
24 hours
16 hours
40 houx's
6.4 Plant Systems (200 hours) Plant Systems Training 200
hours
6.$ Administrative Controls(80 hours) Simulatox Training
Admin Procedures, Controlsand Limitations
25 hours40 hours
65 ours
6.6 General Operating Procedures(30 hours) Simulator Training 30
hours.
6. 7 Tx ansientlAccident Analysis(30 hours)
Simulatox Training 30 hours
6.8 Simulator Training Simulator Training 120 hours
* This table is typical of each training class,, however, the
actual hours mayvary by + 20 percent based upon the qualifications
and experience of thetraining class.
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F.S.A.R. Changes to Chapter 13.2
13.2.1.2 Administration of Training Pr ograms
All instructors teaching the licensed training and
retrainingprograms in the subjects of systems, integrated
responses. transientsand simulator courses shall demonstrate senior
reactor operatorqualifications and be enrolled in appropriate
requalification programs.Other members of the permanent or
non-permanent training staff, who areresponsible for teaching
technical subjects, such as reactor theory,heat transfer, fluid
mechanics, thermodynamics, health physics,chemistry and
instrumentation are exempt from the senior reactoroperator
criteria. Guest lecturers who are considered subject matterexperts,
who are to be used on a limited basis, are also exempt fromthe
Senior Reactor Operator Criterion but shall be monitored by
aqualified instructor.
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NINE MILE POINT UNIT 2 RESPONSE TO TMI REQUIREMENTS
I.A.1. 1 SHIFT TECHNICAL ADVISOR
FSAR Cross.'Reference
Sections 13.1, 13.2.2
NUREG-0737 Position
Each licensee shall provide an on-shift Technical Advisor tothe
Shift Supervisor. The Shift Technical Advisor (STA) mayserve more
than one unit at a multiunit site if qualified toperform the
advisor function for the various units.
The STA shall have a bachelor's degree or equivalent in
ascientific or engineering discipline and have receivedspecific
training in the response and analysi:s of the plantfor transients
and accidents. The STA shall also receivetraining in plant design
and layout, including thecapabilities of instrumentation and
controls'n the controlroom. The licensee shall assign normal duties
to the STAsthat pertain to the engineering aspects of assuring
safeoperations of the plant, including the review and evaluationof
operating experience.
The need for the STA p'osition may be eliminated if
thequalifications of the Shift Supervisors and Senior Operatorshave
been upgraded and . the man-machine interface in thecontrol room
has been acceptably upgraded. However, untillong-term improvements
are attained, the need for an STAprogram will continue.The NRC
staff will establish the detailed elements of theacademic and
training requirements of the STA at a laterdate. The level of
upgrading required for licensedoperating personnel and the
man-machine interface in thecontrol room acceptable for eliminating
the need of an STAwill also be determined at a later date. Until
theserequirements for eliminating the STA position have
beenestablished, the staff continues to require that an STA
beavailable for duty on each operating shift when a plant isbeing
operated in Modes 1-3 for a BWR. At other times, anSTA is not
required to be on duty.Since the accident at TMI several efforts
have been made toestablish, for the long term, the minimum level
ofexperience, education, and training for STAs. These
effortsinclude work on the revision to ANS-3.1, work by the
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Institute of Nuclear Power Operations (INPO), and internalstaff
efforts.INPO has made available a document entitled Nuclear
PowerPlant Shift Technical Advisor.--Recommendations for
PositionDescription, Qualifications, Education and Training. A
copyof Revision 0 of this document, dated April 30, 1980,
isattached as a supplement to this task. Sections 5 and 6 ofthe
INPO document describe the education, training, andexperience
requirements for STAs. The NRC staff finds thatthe descriptions as
set forth in Sections 5 and 6 ofRevision 0 to the INPO document are
an acceptable approachfor the selection and training of personnel
to staff the STApositions. The INPO document'provides 'interim
guidance fora utility in planning its STA program over the long
term.Applicants for operating licenses shall provide adescription
of their STA training program and their plansfor requalification
training on a schedule consistent withthe NRC licensing review
schedule. This description shallindicate the level of training
attained by STAs anddemonstrate conformance wi'th the qualification
and trainingrequirements.
Applicants for- operating licenses shall provide adescription of
the long-term STA program, includingqualification, selection
criteria, training plans, andplans, if any, for the eventual
phase-out of the STA programon a schedule consistent with the NRC
licensing reviewschedule.
Nine Mile Point Unit 2 Position
The STA qualifications are shown on Table 13.1-4 and include a
bachelor'degree or equivalent in a scientific or engineering
descipline. Trainingrequirements are discussed in Section 13.2, and
include soecific trainingin plant design and arrangement, and the
capabilities of the instrumentsand controls in the control room.
The STA's review and evaluate operatingexperience reports,
including engineering'spects of assuring safesperations. During
off-normal events, he provides the Station ShiftSupervisor with and
assessment of station conditions and advises actionsto terminate or
mitigate the consequences of off-normal conditions.During this time
he shall perform no duties unrelated to assessment.or
diagnosis.
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E.C.3 SHEET SUPERVISOR RESPONSEBEEETY
FSAR Cross Reference
Sections 13.1, 13.5.1
NUREG-0737 Position
The 'ighest level of corporate management of each licenseee,>
gshall issue and periodically reissue a management directivethat
emphasizes the pximary management responsibility of theShift
Supervisor for safe operation of the plant under allconditions on
his shift and that clearly establishes hiscommand duties.Plant
procedures shall be reviewed to assure that the
'duties, responsibilities, and authority of the Shift'Supervisor
and Control Room Operators are properly definedto effect the
establishment of a definite Line of commandand clear delineation of
the command decision authority ofthe Shift Supervisor in the
contxol room relative to otherplant management pex sonnel.
Particular emphasis shall beplaced on the following:
The responsibility and . authority of the ShiftSupervisor shall
be to maintain, the broadestperspective of operational conditions
affecting thesafety of the plant as a matter of highest priorityat
all times when on duty in the control room. Theidea shall be
reinforced that the Shift Supervisorshould not become totally
involved in any singleoperation in times of emergency when
multipleoperations are required in the contxol room.
.2- The - Shift. Supervisor, until properly relieved ofduty,
shall remain in the control room at all timesduring accident
situations to direct the activitiesof Control Room Operators.
Persons authorized torelieve the Shift Supervisor shall be
specified.
3. Ef the„Shift Supervisor is temporarily absent fromthe
control. room during routine operations, a leadControl Room
Operator shall be designated to assumethe control zoom command
function. These temporaryduties, responsibilities, and the
authority shallbe clearly specified.
Training programs. for Shift Supervisors shall emphasize
andreinforce the responsibility for, safe operation and the
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Nine Mile Point Unit 2 FSAR
management function the Shift Supervisor is to provide
forassuring safety.
The administrative duties of the Shift Supervisor shall
bereviewed by the senior officer of each utility responsiblefor
plant operations. Administrative functions that detractfrom or are
subordinate to the management responsibility forassuring the safe
operation of the plant shall be delegatedto other operations
personnel not on duty in the control.room.
The following table clarifies this position:SHIFT SUPERVISOR
RESPONSIBIK,ITY (2.2.1.a)
NUREG-0578 .PositionPosition No. Clarification
Highest level of corporatemanagement (1)
V. P. for operations
Periodically reissue (1)
Management direction (1)
Annual reinforcementof company policyFormal documentationof shi
ft personnel,all plant management,copy to IE region
Properly defined (2.0)
Until properly relieved (2.8)
Temporari.ly absent (2.C)
Control room defined (2.C)
Defined in writing ina plant procedureFormal trans fer
ofauthority, valid SROIicense, Recorded inplant log
Any absence
Includes shift super-visor office adjacentto the control
room
Designated (2.C)
Clearly specified
In administrativeprocedures
Defined in administra-tive procedures
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NUREG-0578 PositionPosition No. Clarification
SRO training
Administrative duties (4)
Administrative dutiesreviewed (4)
Specified in ANS 3.1(Draft) Section 5.2.1.S
= Not affecting plantsafety
On same interval asreinforcement: i.e.,annual. by V. P.
foroperation
Nine Mile Point Unit 2 Position
The response to this task is contained in I.A.1.2.Refer to Task
I.A.1.2„ position statement for response toE. C. 3'.
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I.A.1.2 SHIFT SUPERVISOR RESPQNSIBIIITIESFSAR Cross
Reference
Sections 13.1, 13.5.1
NUREG-0737 Position
The highest level of corporate management of each licenseeshall
issue and periodically reissue a management directivethat
emphasizes the primary management responsibility of theShift
Supervisor for safe operation of the plant under allconditions on
his shift and that clearly establishes hiscommand duties.Plant
procedures shall be reviewed to assure that theduties,
responsibilities, and . authori ty of the ShiftSupervisor and
Control Room Operators are properly definedto effect the
establishment of a definite line of commandand c1ear delineation of
the command decision authority ofthe Shift Supervisor in the
control room relative to otherplant management personnel.
Particular emphasis shall beplaced on the following:
The responsibi lity and authority of the ShiftSupervisor shall
be to maintain the broadestperspective of operational conditions
affecting thesafety of the plant as a matter of highest priorityat
all times when on duty in the control room. Theidea shall, be
reinforced that the Shift Supervisorshould not become totally
involved in any singleoperation in times of emergency when
multipleoperations are required in the control room.
2. The Shift'upervisor, until properly relieved,shall remain in
the control room at all timesduring accident situations to direct
the activitiesof Control Room- Operators. Persons authorized
torelieve the Shift Supervisor sha'1 be specified..
3. If the Shift Supervisor is temporarily absent fromthe control
room during routine operations, a leadcontrol room operator shall
be designated to assumethe control room command function. These
temporaryduties, responsibilities, and authorities shall beclearly
specified.
Training programs for Shift Supervisors shall emphasize
andreinforce the responsibility for saf e operation and the
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management function of the Shift Supe visor is to proridefor
assuring safety.The administrative duties of the Shift Supervisor
shall bereviewed by the senior officer of each utility
responsiblefor plant operations. Administrative functions that
detractfrom or are subordinate to the management responsibility
forassuring the safe operation of the plant shall be delegatedto
other operations personneL not on duty in the controlroom.
The fo 1 lowingposition.
table provides clarification to the above
SHIFT SUPERVISOR RESPONSIBILITY (2.2.1.a)NUREG-0578 Position
Position No. ClarificationHighest. level of corporatemanagement
(1)
Periodically reissue (1)
V. PE for operations
Annual reinforcementof company policy
Management direction (1) Formal documentation ofshift personnel,
all .plant management,copy to IE region
Properly defined (2.0)
Until properly relieved (2.B)
Temporarily absent (2.C)
Control room defined (2.C)
Defined in writing ina plant procedureFormal transfer
ofauthority, valid SROLicense, recordedin plant logAny absence
Includes shift super-visor office adjacentto control room
Designated (2.C) In administrativeprocedures
Clearly specified (Z.C) Defined in administ a-tive
procedures
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NUREG-OS78 PositionPosition No. Clarification
SRO training ( 3 )
Administrative duties (4)
Administrative duties.reviewed. (4.) +
Specified in ANS 3.1(Draft) Section,5.2.1.8
Not affecting plantsafety
On same interval asreinforcement: i.e.,annual by V. P.
foroperations
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NINE NILE POINT UNIT 2 POSITION
Prior to fuel loading and annually thereafter, the Vice
President-NuclearGeneration shall issue a management directive that
emphasizes. the primarymanagement responsibility of the Station
Shift Supervisor (SSS) for safeoperation of the plant under all
conditions on his shift and clearlyestablishes his command
duties.
Plant procedures are written to assure that the duties,
responsibilities andauthority of the SSS and other licensed control
room operators are properlydefined to effect the chain of
command.
In the future, administrative duties of the SSS will be reviewed
annuallyafter fuel load by the Vice President-Nuclear Generation to
ensure that suchfunctions don't detract from safe plant
operation.
/
SSS RESPONSIBiLITIES
The Station Shift Supervisor is in charge of all operations on
his assignedshift. Under the general direction of the Supervisor
Operations Nuclear, hi.s
'unctionincludes direction of shift activities, authorization of
equipmentreleases for maintenance, ensuring that the plant is
operated safely andwithin the license and technical specifications
and ensuring that plantoperations are conducted in accordance with
approved procedures. As. overallsupervisor of operations for his
shift, the Station Shift Supervisor shouldavoid becoming personally
involved in the manipulative tasks or details ofoperati'on of any
one portion of the plant so that he may retain acomprehensive
perspective of general station conditions at all times. In
anemergency situation, however, should the Shift Supervisor choose
to performmanipulative functions to ensure that the plant is in a
safe condition, he.shall coordinate his actions with the Chief
Shift Operator. Whenever hedetermines that the safety of the
reactor is in immediate joepardy or whenoperating parameters
exceed'ny of the reactor protection circuit setpointsand automatic
shutdown should, but does not occur, he has the responsibilityand
the authority to order shutdown of the reactor or to personally
effect theshutdown.
The Shift Supervisor shall hold an NRC senior reactor operator
l.icense. Heshall be continuously present at the plant for the
duration of his assignedshift until properly relieved by the
oncoming Shift Supervisor". It is hisresponsibility to provide
direction for returning the reactor to powerfollowing a trip or an
unscheduled power reduction.
Ouring (normal operations) periods when the SSS is out of the
control room, hedesignates another SRO the control room command
function, as specified byadministrative procedures.
Ouring emergencies, accidents or incidents requiring special
procedures, theShift Supervisor shall remain continuously in the
control room until relievedby the oncoming shift supervisor or a
senior licensed operator designated bythe Supervisot Operations or
higher authority. From the control room, heshall continuously
assess the condition of the station and provide generaldirection
for all operating actions.
„Tr aining programs for SROs reinforce the responsibility for
safe operation andthe management function of the control room
supervisor to assure safety.
SSS administrative duties have been reviewed, and many of the
administrativefunctions have been assigned to other personnel.
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I.B.1.2 INDEPENDENT SAFETY ENGINEERING GROUPFSAR Cross
Reference
Sections 13.1.1, 13.4
NUREG-0737 Position
Each applicant for an operating license shall establish anonsite
independent safety engineering group (ISEG) toperform independent
reviews. of plant operations.The principal function of the ISEG is
to examine plantoperating characteristics, NRC issuances,
LicensingInformation Service advisories, and other
appropriatesources of plant design and operating experience
informationthat may indicate areas for improving plant safety.
TheISEG is to perform independent review and audits of
plantactivities, including maintenance, modifications,operational
problems, and operational analysis and to aid inthe establishment
of programmatic . requirements for plantactivities. Nhere useful
improvements can be achieved, itis expected that this group will
develop and presentdetailed recommendations to corporate management
for such.things as revised procedures or equipment
modifications.
Another function of the ISEG is to. maintain surveillance
ofplant operations and maintenance activities 'o provideindependent
verification that these activities are performedcorrectly and that
human errors are, reduced as far aspracticable. ISEG will then be
in a positi.on to adviseutility management on the overall quality
and safety ofoperations. ISEG need not perform detailed audits of
plantoperations and shall not be responsible for signofffunctions
such that it becomes involved in the operatingorganization.The new
ISEG shall not replace the plant operations reviewcommittee (PORC)
and the utility's independent review andaudit group as . specified
by current staff quidelines(Standard Review Plan, Regulatory Guide
1.33, StandardTechnical Specifications). ~ Rather, it is an
additionalindependent group of a minimum of five dedicated,
full-timeengineers, located onsite but reporting offsite to
acorporate official who holds a high level,technically-oriented
position that is not in the managementchain for power production.
The ISEG will increase theavailable technical expertise located
onsite and willprovide continuing, systematic, and independent
assessmentof -plant activities. Integrating the Shift Technical
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Nine Mile Point Unit 2 FSAR
Advisors (STAs) into the ISEG in some way would be desirablein
that't could enhance the group's contact with theknowledge of
day-to-day plant operations to provideadditional expertise.
However, the STA on shift isnecessarily a member of the operating
staff and cannot beindependent of it.It is expected that the ISEG
may interface with the qualityassurance (QA) cjrganization, but
preferably should not be anintegral part of~ the QA
organization.The functions of the ISEG require daily contact 'with
theoperating personnel and continued access to plant facilitiesand
records. The ISEG review functions can therefore bestbe carried out
by a group physically located onsite;However, for utilities with
multiple sites, it may bepossible to perform portions of the
independent safetyassessment function in a centralized location for
all theutility's plants. In such cases, an onsite group still
isrequired, but it may be slightly smaller than would be thecase if
it were performing the entire independent safetyassessment
function. Such cases will be reviewed on acase-by-case basis.
At this time, the requirement for establishing an ISEG isbeing
applied only to applicants for operating licenses inaccordance with
Task I.B. 1.2. The staff intends to reviewthis, activity in about a
year to determine its effectivenessand to see whether changes are
required. Applicability to
„operating plants will be considered in, implementinglong-'term
improvements in organization and management foroperating plants
(Task I.B. 1 ~ 1) .Nine Mile Point Unit 2 Position
An onsite ISEG will be established to perform independent
reviews of plantoperation. The principal function of the ISEG is to
examine plant operatingcharacteristics, various NRC and industry
licensing and service advisories,and recommend ones for improving
plant operations or safety. The ISEG willperform independent review
of plant activities, including maintenance,modifications,
operational concerns, and operational analysis and
makerecommendations to the Supervisor Technical Support Nuclear.
The SupervisorTechnical Support Nuclear (or his designee) will
present to OperationsAssessment Committee (OAC) and/or the
Technical Superintendent the results ofanalysis including (when
useful improvements can be achieved) detailedrecommendations such
as revised procedures or equipment modifications.Presentations to
SORC are provided by the Operations Assessment Committeedescribed
in Section 13.4.
The ISEG will observe plant operations and maintenance
activities to'etermine that these activities are being performed
properly and providewritten recommendations (when useful
improvements can be achieved). The ISEGdoes not perform detailed
(gA type) audits, and are not responsible forsignoff functions
associated with daily operational activities. The ISEG
isindependent of SORC and SRAB but may make recommendations to
these groups.
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The ISEG is a total of ten dedicated full-time engineers,
assigned onsiteto Unit 1 and Unit 2, and report to the Supervisor
Technical Support Nuclear.The Supervisor Technical Support Nuclear
reports to the SuperintendentTechnical Services Nuclear and then
reports to the Technical Superintendentwho is responsible for all
technical support on site.
Although the Technical Department reports to the General
SuperintendentNuclear Generation (who is responsible for
operations), the TechnicalDepartment is independent from the direct
operational supervision of the plantthat resides with the Station
Superintendent. Additionally, the TechnicalDepartment has recourse
to resolve safety concerns by addressing such concernsto either the
SRAB or the Vice President Nuclear Engineering and Licensing.
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TECHNICALORGANIZATION
NIAGARA MOHAWK POWER CORPORATIONNINE MILE POINT-UNIT 2FINAL
SAFETY ANALYSIS REPORT
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Nine Mile Point Unit 2 FSAR
I.C".2 SHRIFT AND RELIEF TURNER PROCEDURES
FSAR Cross Reference
Section 13.5.1
NUREG-0737 Position
The licensees shall review and" revise as necessary the
plantprocedure for shift and relief turnover to - assure
thefollowing:
A checklist shall be provided for the oncoming andoffgoing.
Control Room Gperators and the oncomingShift Supervisor to compLete
and sign. ThefoLLowing items., as a minimum, shaLL be included
inthe checklist:a. Assurance that critical plant parameters are
within 'llowable limits (parameters andaLlowable limits shall be
listed . on. thechecklist).
b.
Co
Assurance of t@e availability and properalignment of all,
systems essential to theprevention and mitigation of
operationaltransients and accidents by a check of thecontrol
console (what to check and criteriafor acceptable status. shall be
included in thechecklist) .Zdentifica&oi"of." systems and,
components thatare in) a. degraded- 'made of .operation
permittedby.'he- Technical Specifications. For suchsystems and
components, the length of time inthe "'degraded mode. shall be
compared..with, theTechnical Specifications action statement(this
shalL be recorded as a separate entry onthe checklist)'.
Checklists. or logs. shaLL be provided for completionby the
offgoing ancL-ongoing auxiliary operators andtechnicians. Such
checklists or logs shall includeany equipment under maintenance or
test'hat byitself could. degrade. a system critical to
theprevention and mitigation of operational transientsand accidents
or initiate an'perational transient(what.to check and criteria for
acceptable statusshaLL be included on the. checklist).
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Nine Mile Point Unit 2 E'SAR
3. A system 'shall be established to evaluate theeffectiveness
of the shift -.and relief turnover,procedure.
Nine Nile Point Unit 2 Position
The'nit 2 (shift relief turnover) procedures 'will include:
l. A checklist providing for the oncoming and offgoing Control
Room Operatorsand the- oncoming. Shift Supervisor to complete and
sign. The followingitems, as a minimum, shall be included in.the
checklist:
a.
b.
Assurance that critical plant parameters are within allowable
limits(parameters and allowable limits shall. be listed on the
checklist).
Assurance of the availability and proper alignment of all
systemsessential to the prevention and mitigation of operational
transientsand accidents by a check of the control console (what to
check andcriteria for acceptable status shall be included, in the
checklist).
c. Identification of systems and components that are in a off
normal orout of service mode of operation permitted by the
TechnicalSpecifications. For such systems and,components, the
length of timein. the off'normal or out of service mode shall be
compared with theTechnical Specifictions action statement;(if any).
(This shall berecorded as a separate entry on the checklist.)
2. Checklists or logs shall be provided for completion by the
offgoing andongoing operators. Such checklists or logs shall
include any equipmentunder maintenance or test that by itself could
degrade a system criticalto the prevention and mitigation of
operational transients and accidentsor initiate an operational
transients and accidents or initiate anoperational transient (what
to check and criteria for acceptable statusshall be included on the
checklist).
3. A system shall be established to evaluate the effectiveness
of the shiftand relief turnover procedure.
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Nine Nile Point Unit 2 FSAR
E.C.4 CONTROE ROON ACCESS
FSAR Cross Reference
Section 13.5.3.
NUREG-0737 Position
The licensee shall make provisions for limiting access tothe
control room to those individuals responsibl'e for thedirect
operation of the nuclear power plant (e.g.,Operations Supervisor,
Shift Supervisor, and Control RoomOperators}, to technical advisors
who may be requested orrecpxired to support. the operation, and to
predesignated NRCpersonnel. Provisions shall include the
following:
1. , Develop and implement an administrative
procedurethat:establishes . the authority and responsibilityof the
person in charge of the control room to
. limit access, andDevelop and implement procedures that
establish aclear 1'ne of authority and responsibility in
the.control room in the event of an emergency. Theline of
succession for the person in charge of thecont ol room 'hall 'be
established and limited topersons possessing a current senior
reactoroperator's license. The plan shall clearly definethe
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Nxne Nx].e Poxnt Unxt 2 FSAR
I.C.S PROCEDURES FOR FEEDBACK OF OPERATING EXPERIENCETO PLANT
STAFF
FSAR Cross Reference
Section 13.5.1
NUREG-0737 Position
In accordance with Task Z.C.S, Procedures for Feedback
ofOperating Experience to Plant Staff (NUREG-.0660), eachapp
canlicant for an operating license shall prepare proceduresto
assure that operating information pertinent to plansafety
originating both within and outsf de the utilityorganization is
continually supplied to operators and otherpersonneersonnel and is
incorporated into training and retrainingprograms. These procedures
shall:
1. Clearly identi'fy organizational 'esponsibilitiesfor review
of operating experience, the feedbackof'ertinentinformation to
operators and other
personnel, and the incorporation of suchinformation into
training and retraining programs;
2. Identify the administrative and technical reviewsteps
necessary in translating recommendations bythe operating experiehce
assessment group intoplant actions (e.g., changes to
procedures,6perating orders);
3.
S.
Identify the recipients of various categories ofinformation from
operating experience (i.e.,supervisory. personnel, st.ft technical
advisors,oper'ators, maintenance personnel, health,
physicstechnicians) or otherwise provide means throughwhich such
information can be raadil.y related tothe gob functions of the
recipients;Provide means to assure that affected personnelbecome
aware. of and understand information ofsufficient importance that
..it should not wait -foremphasis through routin'e training and
retrainingprograms g
Assur e that plant personnel. do not. routinely'receive
extraneous and unimportant'nformation onoperating experience in
such volume that it wouldobscure priority information or otherwise.
detractfrom overall job performance and proficiency;
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Nine Mile Point Unit 2 FSAR
6. Provide suitable checks to assure that conflictingor
contradictory information is hot conveyed tooperators and other
personnel until resolution. isreached; and,
7. Provide periodic internal audit to assure that thefeedback
program functions effectiveLy at alllevels.
Each utility shall carry out an operating experienceassessment
function that viLL involve utility personnelhaving collective
competence in all areas important to plantsafety. In connection
vith this assessment function, it isimportant that procedures exist
to assure that importantinformation on operating experience
originating both withinand outside the organization is continualLy
provided tooperators and other, personnel and,:that it is
incorporatedinto plant operating procedures aad'training and
retrainingprograms.
Those involved in the assessment of operatiag experiencevill
review information from a variety of sources. Theseinclude
operating information from the licensee's ownplant(s), publications
such as ZE Bulletins, Circulars, andNotices, and pertinent NRC or
industrial assessmeats ofoperating experience. Ia some cases,
information may be ofsufficient importance that it must. be dealt
with promptly(through instructions, changes to operating and
emergencyprocedures, i/suance of special precautions, etc) and
mustbe handled in such a manner to assure that operationsmanagement
personnel would be directly involved in theprocess. In many other
cases, however, importantinformation vill'ecome available which
should be brought tothe atteation of operators and other persoanel.
for theirgeneral information to assure continued saf e
plantoperation.
Since the total volume of information handled by theassessment
group may be, Large, it is important thatass'urance be provided
that high priority matters are dealtwith promptly and that
discrimination is used, in thefeedback of other information so that
personnel are notdeluged with uaimportant and extraneous
information. to thedetriment of their overall proficiency- It is
important.also, that technical reviews be conducted to
precludepremature dissemination of conflicting or contradictoryinfo
rmation.
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Nine Mile Point Unit 2 CESAR
Nine ile Point Unit 2 PositionUnit 2 will utilize Administrative
Procedures and Training Procedures to
implement the feedback of operating experience to plant staff.
The procedures:1. Clearly identify organizational responsibi lities
for review of
operating experience, the feedback of pertinent information
tooperators, and other personnel, and the incorporation of
suchinformation in training and requalification training programs
(forexample see Section 13.2.4.1.1 item 9).
2. Identify the administrative and technical review steps
necessary intranslating recommendations by the Operations
Assessment Coneitteeinto plant actions (e.g. changes to procedures,
operating orders).Section 13.4 and l. 10 provide information on the
OperationsAssessment Committee.
3. Identify the recipients of various .categories of information
fromoper ating experience (i.e. shift or supervisor, personnel)"
orotherwise provides means through which such information can
bereadily. related to the job functions of the recipients (for
examplesee Section 13.2.4.1.3).
4. Provide means to assure that affected personnel become aware
of andunderstand information of sufficient importance that it
should notwait for emphasis through routine training and retraining
or standingorders or night orders (for example required reading
assignments aremade on an ongoing basis to address this
concern).
5. Assure that plant personnel do not routinely receive
extraneousinformation on operating experiences in such volume that
it couldobscure priority information.
6. Provide suitable checks to assure correct information is
conveyed tooperators and other personnel.
7. Provide periodic audits to assure that the feedback program
functionseffectively (for example Training Audits).
Operating experience assessment is performed by the Technical
SupportGroup, the Operations Assessment Coranittee and SORC as
described inAdministrative Procedures on an ongoing basis. The
individuals involvedreview information from a variety of sources
such as, IE Bulletins, IEInformation Notices, IMPO, reports, LER's,
and vendor information letters suchas SILS.
The feedback system provides for early notification of
significantinformation to operating personnel and management. The
evaluation process,specifically the Operations Assessment Committee
meeting, provides assurance
:.that the information is correct and that unimportant and
extraneousinformation does not impact overall proficiency.
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NINE HILE POINT UNIT 2
SER NO. 1675.2.2
. We require the applicant to discuss in detail the analytical
method usedto determine the number of the AOS SRVs. This method
should'considerthe most limiting events and satisfy a single
failure criterion.
RESPONSE
In a LOCA analysis, a particular AOS flow rate is required to
bring thevessel pressure down in a prescribed time to allow the
operation of lowpressure core cooling following the postulated
failure of HPCS. Thisrequired flow rate determines the number of
AOS valves. Based on
':generic BWR calculations including that of Hanford, 7 AOS
valves arerequired for NHP2. This number will be confirmed by NHP2
.unique ECCSanalysis.
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SER QUESTION 170:
The LOCA analyses reported in the FSAR were for a lead plant
representative ofHHP-2. The applicant has committed to perform
plant-specific LOCA analyses ina later amendment to the FSAR before
fuelloading. The NRC staff will report the results of its review of
the plant-specific analyses in a supplement to this report.
SER QUESTION 171:
The staff requires the appl,icant to provide calculated maximum
total hydrogengeneration from the chemical reaction of the cladding
with water orsteam for the most limiting LOCA case.
RESPONSE:
Information for SER items 170 and 171 will be provided by April
1985.
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NINE MILE POINT UNIT 2
SER NO. 172
Single active component failures and operator errors are
considered in thetransient analysis of moderate frequency. The most
limiting transient event isa feedwater controller failure with
maximum demand with the failure of turbinebypass. The change in CPR
is, about 0.27 for an fnitial HCPR of 1.24 whichresults in
violation of MCPR safety limit of 1.06. The applicant has
statedthat this transient event is one of only 2 to 3 seconds
duration: no
fuel'ailurewould be expected. The staff requires, that the
applicant demonstratehow they meet a small fraction of 10 CFR 100
criteria violating OL MCPR limit.The applicant should also
demonstrate the method used to identify this eventwhen all moderate
frequency transients combined with single failure/operatorerror are
considered in the evaluation.
RESPONSE
As stated in the response to guestion 440.41, for
moderate-frequency events in. Chapter 15, the i'nclusion of any
additional single failure or operator errorwould shift the events
to infrequent or limiting fault category which has lessstringent
safety criteria.
Resporises to questions 440.41 and 440.43 have identified
that:
The worst additional single failure/operator error. is the
postulatedfailure of turbine bypass, and
2) Among all moderate".frequency transients coupled with turbine
bypassfailure, the most limiting event is feedwater controller
failure withmaximum demand.
P
In this scenario, the final.CPR would violate the.l.06 safety
limit for aduration of 2 to 3 seconds.':Consequently, about.2X of
fuel rods will undergoboiling transition for 2 to 3 seconds with
corresponding peak;clad temperatures(PCT)below 1600 F. Since
boiling transition would have to last for much longertnan 30
seconds before PCT approaches the safety limit of 2200 F, no
fuelfailure or radiological release is expected. Therefore, the
requirement ofmeeting "a small'raction of 10CFR100 limit" is
satisified.
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NINE MILE POINT UNIT 2
SER. NO. 173
The applicant was asked to justify that operation with partial
feedwaterheating to extend the cycle beyond the normal end of cycle
condition would notresult in a more limiting change in minimum
critical power ratio than thatobtained using, the assumption of
normal feedwater heating. The applicant, .indicated that analyses
will be provided before operation in this mode if adecision is made
to operate in this mode. Until such analyses are provided thestaff
will condition the license to prohibit operation in this mode.
RESPONSE
Operating with reduced feedwater temperature after rated end of
cycle is notthe design basis of the plant safety analysis. Although
it is expected thatcurrent Chapter 15 analyses will bound this
operation under a derated feedwaterheating condition, Niagara
Mohawk will submit additional'analysis to accompanythe request for
this mode of operation. This commitment has been made inresponse to
question 440.46.
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OPEN ISSUE 175
II.K.3.18 Modification of ADS Lo ic
NMPC is currently evaluating this item. The staff will
require'.thatNMP2 should specify which option they are planning to
implement.Either Option 2 or 4 is acceptable to the staff.
RESPONSE
Nine Mile Point Unit 2 will implement Option 2. FSAR Section
1.10will be revised to address this commitment.
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Nine Mile Point Unit 2 FSAR
Exem tion Justi ficati on (10CFR50 'Appendix J., Part I I I, A.
l. d)1. Systems that are required to maintain the plant 'n
a safe condition during the test shall be operablein their
normal mode and need not be vented.
2. Systems that are normally filled wi th water andoperating
under post accident conditions need notbe vented.
The control rod drive and hydraulic control for the
reactorrecirculation flow control valves'will not,be vented
duringthe ILRT as justified by Notes 1'7 and 26 of Table
6.2-56,respectively.The test method utilized is the absolute
method, as described in8N-TOP-l, Rev. 1, 1972. Values of primary
containment atmospheredry-bulb temperature, dew point temperature
(vapor pressure), andpressure are used in the leakage rate
calculations.
The primary containment leakage monitoring system (LMS)provides
means for monitoring the primary 'containment pres-sure during
ILRT. Two independent, pressure sensing lines,each equipped with a
quartz. digital type 'bsolute pressuremanometer, are provided in
LMS system. One extra quartzmanometer is provided as a
not-installed spare(Figure 6.2-73).
Eighteen temperature elements and six humidity analyzers
areprovided in. the primary containment atmosphere monitoringsystem
(CMS) to monitor dry-bulb and dew point temperatures,respectively
(Figure 6.2-71).
The test procedure, test equipment and facilities, period of
testing,and verification of leak test accuracy follow the
recommendations ofgN-TOP-1, Rev. 1, 1972.
Acceptance criteriaChapter 16.
for a Type A tests are descr'bed in
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Nine Mile Point Unit 2 FSAR
6 2.6.3 Primary Containment Isolation Valve Leakage RateTests
(Type C Tests)
Primary con ainment nment isolation valve leakage rate tests
willbe performed by local pressurization in accordance with the
" requirements of Appendix J to 10CFR50. The pressure will be
applied inthe same direction as it would be applied when the valve
is required anddocumented that the results from the test for a
pressure applied in theopposite direction will provide equivalent
or more conservative results.Each valve to be tested'ill be closed
by normal operation, without anypreliminary exercisinq or
adjustment. Table 6.2-56 lists all primarycontainment isolation
valves on pipelines penetrating the primarycontainment.
The test pressures and acceptance criteria for the
primarycontainment isolation valve leakage rate tests are given
inTable 6.2-60.
6.2.6.4 Additional Requirements
The combined leakage rate forall penetrations and valves subject
toType B and C tests will be in accordance with 10CFR50 App'endix
J.
II
6.2.6.5 Scheduling and Reporting of Periodic Tests
The periodic leakage test schedule is given in Chapter 16.
6.2.6.6 Special Testing Requirementsh
The reactor building will be tested as required by Chapter
16.
A peroperational high pressure drywell bypass leakage test will
beperformed once prior to fuel load to determine the bypass leakage
fromthe drywell into the suppression chamber. The containment will
besubjected to the maximum design pressure differential of 25 psi
betweenthe drywell and suppression chamber.
The test pressures and acceptance criteria for the drywell
bypassleakage tests are given in Table 6.2-61.
6.2-88
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