IR 05000271/1993012
| ML20057F351 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/06/1993 |
| From: | Bettenhausen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Reid D VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| NUDOCS 9310150174 | |
| Preceding documents: |
|
| Download: ML20057F351 (2) | |
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Docket No. 50-271 Mr. Donald Vice President, Operations Vermont Yankee Nuclear Power Corporation RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301
Dear Mr. Reid:
l SUBJECT: INSPECTION REPORT NO. 50-271/93-12 This refers to your August 13, 1993, correspondence, in response to our June 4,1993, letter.
Thank you for informing us of the corrective actions documented in your letter. These -
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actions will be examined during a future inspection.of your licensed program. It appears that.
you have adequately addressed our concerns related to implementation of the RPV Control Guideline.. We are particularly interested in reviewing your justification of differences from the BWR Owners' Group Emergency Procedure Guidelines.
Your cooperation with us is appreciated.
Sincerely, l
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Operations Branch Division of Reactor Safety i
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e IVERMONT YANKEE NUCLEAR POWER CORPORATION
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,. -k Ferry Road, Brattleboro, VT 05301-700?
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ENGINEERING OFFICE
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$80 MAIN STREET BOLTON MA 01740
(508) 779-6711
August 13,1993 BVY 93-084 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 References:
a)
Ucense No. DPR-28 (Docket No. 50-271)
b)
Letter, USNRC to VYNPC, " Emergency Operating Procedure Inspection (Inspection Report No. 50-271/93-12)", dated 6/4/93 Subject: Response to inspection Report 93-12
Dear Sir:
This letter is written in response to Reference b), which was an Emergency Operating Procedure inspection conducted by Ms. Tracy E. Walker and other members of your office on May 11 and May 12,1993.
As noted in the accompanying attachment, we have addressed each of the unresolved items identified j
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-C109, " Plant Restoration", by September 1993. Updating the Procedure Generatlon Package, Appendix F. "PSTG to OE Differences (DIFF 2)", will be completed by February 1994.
We believe that the actions proposed are responsive to your concerns; however, should you have any j
further questions, please do not hesitate to contact us.
Sincerely, Vermont Yankee Nu lear P wer Corporation bt Q Donald Vice President, Operations CC:
USNRC Region't Administrator:
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USNRC Resident inspector - VYNPS USNRC Project Manager - VYNPS b
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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 tha 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.
RESPONSE To address this concern, OP 2124 will be revise'd by September 1993 to require that LPCI injection 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 P! ant Specific Technical
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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. __
Inspection 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 evailable 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
!mplementation of the accident mitigation strategy. Although OE 390 is a series evolution, it remains our belief that situations requiring concurrent parameter control vould be rapidly recognized by the eparators, and that entry into OE 3101 would not be delayed.1 ; operators are trained to monitor plant response to key parameters (ie, reactor power, pressure, le vel) and if the observed parameter deviates from expected limits, OE 3100 directs the operator to take manual control. If these operator 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 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 tc below 177" prior to commencement of depressurization.
Operator 'Mning will continue to emphasize the importance of operators monitoring key parameters and prioritizing response actions as appropriate.
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