BVY-93-084, Responds to Insp Rept 50-271/93-12 on 930604 Re Unresolved Items Identified in Sections 3.2 & 3.3

Responds to Insp Rept 50-271/93-12 on 930604 Re Unresolved Items Identified in Sections 3.2 & 3.3

ML20056E102
Person / Time
Site:	Vermont Yankee
Issue date:	08/13/1993
From:	Reid D VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-93-084, BVY-93-84, NUDOCS 9308200006
Download: ML20056E102 (2)

Text

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i i l VERMONT YANKEE j NUCLEAR POWER CORPORATION Ferry Road. Brattleboro. VT 05301-7002

( ), ENGINEERING OFFICE .

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5B0 MAIN STREET . l

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BOLTON. MA 01740 -

(508)779-671i August 13,1993 BW 93-084 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

References:

a) License No. DPR 28 (Docket No. 50-271) b) Letter, USNRC to WNPC, " Emergency Operating Procedure inspection (Inspection Report No. 50-271/93-12)", dated 6/4/93

Subject:

Response to inspection Report 93-12

Dear Sir:

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This letter is written in response to Reference b), which was an Emergency Operating Procedure . j inspection conducted by Ms. Tracy E. Walker and other members of your office on May 11 and May ,

12,1993. i I

As noted in the accompanying attachment, we have addressed each of the unresolved items identiiled -  !

in sections 3.2 and 3.3 of the inspection report.

It is our intent to correct procedures OP-2124, " Residual Heat Removal System" and OP-0109, " Plant  !

l Restoration", by September 1993. Updating the Procedure Generation Package, Appendix F. "PSTG l to OE Differences (DIFF-2)", will be completed by February 1994. l We believe that the actions proposed are responsive to your concerns; however, should you have any  !

further questions, please do not hesitate to contact us.  :

i Sincerely, j Vermont Yankee Nuglear, wer Corporation Donald A. Reid b

j Vice President, Operations l

CC: USNRC Region 1 Administrator l USNRC Resident inspector - WNPS USNRC Project Manager - WNPS l

9308200006 930813 i l

PDR ADOCK'05000271 Of j O[ }

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o ATTACHMENT A Inspection Report Section 3.2 The concerns stated in this section of the inspection report address weaknesses in the implementation of OP 2124, " Residual Heat Removal System", in that the procedure allows but does not direct the operator to inject LPCI through the RHR heat exchangers. Further, some operators indicated they would not inject through the heat exchangers based on current training. ,

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RESPONSE

To address this concern, OP 2124 will be revised by September 1993 to require that LPCI Injection l be routed through the RHR heat exchangers as soon as conditions permit. Operators will be instructed on the basis for this procedure change, and future simulator scenarios will reinforce the need to  ;

implement this requirement. These efforts will ensure that the intent of the Plant Specific Technical '

Guideline (PSTG) will be met. That is, to promote rapid removal of decay heat from the primary containment, thus minimizing suppression pool heatup and prolonging the availability of the ,

suppression pool as a heat sink. l inspwtlon Report Section 3.3 This section primarily addresses concerns that the existing Vermont Yankee Emergency Operating Procedures (EOPs) do not provide for concurrent parameter control and prioritization of action paths for RPV Control. Specific weaknesses in the PSTG and OP 0109 regarding depressurizing the reactor are included.

RESPONSE

We have reviewed OE 3100 and the available options to ensure prompt allowance for concurrent parameter control, but do not believe that a change in this procedure would enhance this aspect of our i implementation of the accident mitigation strategy. Although OE 3100 is a series evolution, it remains l our belief that situations requiring concurrent parameter control would be rapidly recognized by the '

operators, and that entry into OE 3101 would not be delayed. The operators are trained to monitor plant response to key parameters (ie, reactor power, pressure, level) and if the observed parameter deviates from expected limits, OE 3100 directs the operator to take manual control. If these operator i actions are unsuccessful, the operator is directed to enter the appropriate section(s) of OE 3101, "RPV Control Procedure". Based on our review, we believe that no further changes to OE 3100 are required, however, the PSTG will be revised by February 1994 to document this difference from the BWROG EPG's.

To address other specific concerns contained in this section, the PSTG will be revised by February 1994 to indicate that direction to depressurize the reactor in accordance with PSTG step RC/P-3 is provided in OE 3100 via direction to enter procedure OP-0109, " Plant Restoration". OP 0109 will be I revised by September 1993 to require initiation of reactor depressurization in accordance with PSTG step RC/P-3 as the first step of this procedure. OP 0109 will also be revised to eliminate the requirement that water level be restored to below 177" prior to commencement of depressurization.

Operator training will continne to emphasize the importance of operators monitoring key parameters and prioritizing rf sponse actions as appropriate.