IR 05000271/1997201
| ML20212G515 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 10/28/1997 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Lochbaum D UNION OF CONCERNED SCIENTISTS |
| Shared Package | |
| ML20212G518 | List: |
| References | |
| 50-271-97-201, NUDOCS 9711060214 | |
| Download: ML20212G515 (7) | |
Text
October 28, 1997
SUBJECT:
VERMONT YANKEE DESIGN INSPECTION REPORT NO. 50-271/97 201
Dear Mr. Lochbaum:
Your letter dated September 15,1997, commented on the subject report of the NRC design
Inspection at Vermont Yankee (VY) snd the licensee's response to the NRC's request for
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information pursuant to 10 CFR 50.54(f) regarding adequacy and availability of design bases information. Enclosed are responses to your comments.
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The staff agrees that several significant regulatory issues resulted from the VY design inspection.-
The report transmittalletter requested the licensee to evaluate the issues and provide a written response concoming its plans to complete the corrective actions required to resolve the inspection open items. The staff intends to follow-up on the results of the inspection and the licensee's response to determine whether further regulatory action is needed. As stated in the inspection report transmittallatter, any enforcement action resulting from the inspection will be handled separately by Region 1.
I trust this reply responds to your concems.
Sincerely, l Original signed byl Samuel J. Collins, Director Office of Nuclear Reactor Regwation Docket i 9. 50 271 Mfli,T NRC ME CEW M G
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9711060214 971028
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PDR ADOCK 05000271
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Mr. David Mr. Peter LaPorte Director ATTN: James Muckerheide cc:
Massachusetts Emergency Management Ager.;y Regional Administrator, Region 1 400 Worcester Rd.
U. S. Nuclear Regulatory Commission P.O. Box 1496 475 Allendale Road King of Prussia, PA 19406 Framingham, MA 01701 0317 Mr. David R. Lewis Mr. Raymond N. McCandless Shaw Pittman, Potts & Trowbridge Vermont Division of Occupational 2300 N Street, N.W.
and Radiological Health Administration Building Washington, DC 20037 1128 Montpper,VT 05602 Mr. Richard P. Sedano, Commissiener Mr. J. J. Duffy Vermont Department of Public Service Licensing Engineer 120 State Street 3rd Fluor Montpelier,VT 05602 Vermont Yankee Nuclear Power Corporation Public Service Board 580 Main Street Bolton, MA 01740 1398 State of Vermont 120 State Street Montpeller,VT 05602 Mr. Robert J. Wanczyk Director of Safety and Regulatory Affairs Chairman, Board of Selectmen Town of Vernon Vermont Yankee Nuclear Power Corp.
P.O. Box 116
'185 Old Feny Road Brattleboro, VT 053f11 Vemon, VT 05354 0116 Mr. Richard E. McCullough Mr. Ross B. Barkhurst, President Operating Experience Coorriinator Vermont Yankee Nuclear Power Corporation Vermont Yankee Nuclear Power Station P.O. Box 157 185 Old Ferry Road Govemor Hunt Road Brattleboro, VT 05301 Vernon, VT 05354 Mr. Gregory A. Maret, Plant Manager-G. Dana Bisbee, Esq.
Vermont Yankee Nuclear Power Station P.O. Box 157 Deputy Attomey General 33 Capitol Street Governor Hunt Road Vernon,VT 05354
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Concord, NH 03301 6937 Ms. Deborah B. Katz Resident inspector Box 83 Vermont Yankee Nuclear Power Station Shellbume Falls, MA 01370 U.S. Nuclear Regulatory Commission P.O. Box 176 Vemon, VT 05354 Mr, Jonathan M. BlocP Esq.
Main Street P.O. Box 566 Chief, Safety Unit Putney, VY 05346-0506 Office of the Attomey General One Ashburton Place,19th Floor Boston, MA 02108 Vermont Yankee Nuclear Po ver Station Regional Administrator, Region i U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
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RESPONSES TO THE UNION OF CONCERRED SCIENTISTS COMMENTS (1)
ISSVE The report transmittalletter stated that *Ove all, the design engineers of the Yankee Atomic Electric Company, who provided engineering services to Vermont Yankee (VY),
had excellent knowledge and capabilities." The letter also stated that " Based on the understanding of your current design bases efforts, the team concluded that it was unlikely that you would have uncovered some of the issues identified in this repott." The Union of Concemed Scientists'(UCS's ) letter stated that these conclusions seem contradictory since a licensee supported by an excellunt engineering organization would be able to uncover virtually every safety issue.
RESPONSE The statement regarding excellent knowledge and capabilities of desigt. angineert referred to the level and detail of the engineers' responses to the inspection team's questions. As discussed below, the statement concerning the likelihood of the licensee uncovering some of the issues identified in the report referred to the depth of the Design Bases Documentation (DBD) validation process, and not to the engineers.
(2)
ISSUE The Us S letter stated that "The majority of the team's findings are symptomatic of programmatic weaknesses. Thus, it is more reasonable to suspect that comparable (
problems exist in other safety systems at this plant than it is to assume that these are isolated events."
RESPONSE The inspection report transmittalletter states that "as with all Nhc inspections, we expect that your staff will evaluate the applicability of the results and specific lindings of this inspection to other systems and components throughout the plant." For each of the 29 open inspection items listed in Appendix A of the inspection report, NRC will perform a follow-up inspection. The inspection will cover both the specific corrective action (s), and, where applicable, the licensee's action (s) regarding the extent of similar conditions throughout the plant. The follow-up inspections will therefore enable the staff to identify findings that are symptomatic of programmatic weaknesses and evaluate the licensee's corrective actions.
(3)
(SSUE
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The inspection report transmittalletter stated the following: " Based on the understanding of your current design bases efforts, the team conc!uded that it was unlikely that you would have uncovered some of the issues identified in this report. Based on the conversatior, at the exit meeting, we understand that your staff will be re-examining your design bases program. Region Iintends to review this issue when they inspect the findings in this report."
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The UCS letter stated that the above NRC determination, coming after the licensee responded under oath to the 50.54(f) request, would seemingly leave the NRC staff consistent with the design bases. UCS regnsted that the NR and adequacy of design bases information. inspection findings are cons RESPONSE The licensee's 50.54(f) response (page 46) stated the following:
assessments, and inspections plus our 50.54(f) response specific evaluations of"Our revie for improvement have been identified, there is reasonable bases. The Design Bases Documentation DBD Program des
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being implemented to strengthen this assur(ance.)"
At this time, the NRC finds no inconsistency between the a.bove licensee statement and the inspection findings because the statement refers to " reasonable assurance" and th fact that the DBD program is being implemented to s*fathen this assurance. At the inspection exit meeting, NRC discussed the scope of the DBD Program with VY and Yankee Atomic representatives. At that time, the VY DBD Program was stillin the Development Phase and had not entered the Validation Phase. The validation proc was to be based on Safety System Functional inspection (SSFI) techniques, similar to the NRC design inspection, and was to focus on the functionality of the system as related to team and the licensee's DBD validation process, we understo discussions that VY's program would not necessarily require the verification o' all that VY would have uncovered some of the issues identified in conclusion was prospective because the DBD Validation Phase had not yet been implemented. Nonetheless, there was mutual recognition by both the NRC and the findings. As indicated in the report transm nal 'etter, the lico Region I intends to review this issue, and its relationship to the licensee's 50.54(f)
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response, in follow-up inspections.
(4)
ISSUE The UCS letter referred to Section E1.3.3.2d (pa0e 23) o' the inspection report rega
- a residual heat removal / low-pressure coolant injection (RHRlLPCI) ficw instrument that had a loop uncertainty of +6.1% and.5.6% of scale (20,000 gpm). The UCS letter stated that "If this uncertainty is applicable to the flow instrument used for testing LPCI flow for this uncertainty when conducting the required LPCI flow refueling outage."
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3-RESPONSE The flow instrument referred to in Section E1.3.3.2d is the flow indicator, not the flow recorder. The flow recorder is used to moriit.,r LPCI flow during surveillance testing cf the LPCI pumps. Section E1.1.2.2c of the inspection report refers to calculation VYC g37, Revs. O and 1. This calculation used a nonennservative LPCi flow rate, and a flow instrument uncertainty valve that was larger than that of the flow recorder. However, the combined effect of the incorrect inputs to the loss of coolant accident analysis results was minimal.-
(5)
ISSUE The UCS letter expressed a concem that the failure of a single pressure regulator would prevent service water flow to both emergency diesel generator (EDG) trains.
RESPONSE The design of the air supply system for control of servic6 water to each EDG train included two non.afety related pressure regulators, one for the service water flow control
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valve and one for the flow controller. The statement in the inspection report implying that the failure of a non safety related pressure regulator could potentially disable both trains of EDGs was incorrectly worded. The team's concern was that the pressure regulators could experience a common mode failure (because the regulators were non safety-i related) resulting in the potential fallwe of both EDGs. The licensee replaced all the
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pressure regulators w'th regulators that were qualified relying on the commercial dedication process.
(6)
ISSUE The UCS letter noted that the inspection team identified a problem with ! adequate minimum flow protection for the RHR pumps, and stated that this unresoi *ed problem has considerable safety significance.
RESPONSR As with all open items for tlus inspection and as indicated in (2) above, the NRC will address the licensee's corrective actions in follow-up inspections. Any enforcement resulting from this inspection will be addressed separately by Region 1.
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Distribution For Yellow ticket 0970144
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Dated: Rciober 28.1997 DecketSie Moriginalmooming).
PUBLl0 PECB R/F (w/ incoming)
SCollins FMiragalia RZimmerman BSheron JRoe WTravers DMatthews OGC MThadani MBoyle (Email only MLB4)
NRR Mailroom (YT 0970144 w/ incoming) (012/G/18)
MClark KJabbour Jlsom DNorkin PDl1 R/F CHehl, RI l
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ORIGINAL DUE DT: 10/10/97 TICKET NO: 0970144 DOC DT: 09/15/97 NRR RCVD DATE: 09/19/97 A.
LOCHBAUM. UCS i
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TO:
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COLLINS FOR SIGNATURE OF :
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DESC:
ROUTING:
VERMONT YANKEE DESIGN INSPECTION REPORT COLLINS NO. 50-271/97-201 MIRAGLIA ZIMMERMAN SHERON ROE TRAVERS BOHRER ASSIGNED TO CONTACT:
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