ML19210D621
| ML19210D621 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/20/1979 |
| From: | Moody D VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0578, RTR-NUREG-578 WVY-79-130, NUDOCS 7911270400 | |
| Download: ML19210D621 (8) | |
Text
,
s VERMONT Y AN KEE NUCLEAR POWER CORPOR ATION SEVENTY SEVEN GROVE STREET B.3 2.1 RUTLAND. VERMONT 05701 November 20, 1979
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ENGINEERING OFFICE TURNPIKE RO AD WESTDORO. M ASS ACHUSETTS 01581
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United States Nuclear Regulatory Commission Washington, D. C.
20555 Attention:
Office of Nuclear Reactor Regulation
!!r. Harold Denton, Director
References:
(a) License No. DPR-28 (Docket No. 50-271)
(b) 'JSNRC Letter to YAEC dated October as, 1979 (c) YAEC Letter to USNRC dated October 18, 1979 (d) USNRC Letter to YAEC dated September 13, 1979
Dear Sir:
Subject:
Followup Actions Resulting from the NRC Staff Review Regarding The Three Mile Island Unit 2 Accident This letter is in response to your letter, Reference (b).
Our initial response with regard to our followup actions, Reference (c), was based on your letter of September 13, 1979 (Reference (d)) and our perception'of the clarifications provided at the regional and topical meetings that we attended.
A revised version of Enclosure 1 of Reference (b) is enclosed which addresses several deficiencies that have been identified la our initial response to Reference (d) as well as updated commitments relative to BVR Owner's Group Positiens; however, we have not assessed any expansion to the scope of these requirements which may be implied by Enclosure 1 of Reference (b) and reiterate that our current schedule is based on our understanding of your letter of September 13, 1979 Our schedule for completing each of the followup requirements is firm.
In the event of a delay in any of our implementation commitments, we will inform you of the degree of completion by January 1,1980, including a detailed justification for the delay.
We trust this information is satisfactory; however, if you have any further questions, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CCRPORATION D. E. Moody Manager of Operations 3z99 070 DEM/dmp Enclosure 7 9112 7 0 eF oco
Page l' Rev. 1 ATTACHMENT Items labeled A will be implemented by 1/1/80.
Items labeled B will be implemented by 1/1/81.
Section Abbreviated Implementation Number Title Requirement Requirement Commitment / Notes 2.1.1 1:me rnency Power Supply Complete Implementation A
Vermont Yankee meets the intent of Requirement this recommendation. The power operated reactor vessel safety / relief valves are powered from emergency sources.
Redundant valves are provided.
No block valves are or will be provided because this would be detrimental to safety. Vessel level instruments are powered from emergency sources.
2.1.2 Relief and Safety Valve Submit program description A
The program description and schedule
.T.stinn and schedule will be provided by the BWR Owners Group by January 1, 1980.
Complete test program By July 1981 It is expected that the testing will be complete by July 1981.
2.1.3.a Direct Indication of Complete implementation A
Relief Valves During the Sept-Valve Pos it io n Oct. 1979 refueling outage changes were implemented at Vermont Yankee to facilitate / permit the installation during power operation of pressure instrumentation to sense safety / relief valve operation.
A purchase order was issued to Cencral Electric in Sept. for the required components.
Despite our
_,a attempts to expedite delivery of the si) needed hardware, current information
'l3 indicates it will not be available for implementation by Jan. 1, 1980.
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We intend to install the remaining pressure instrumentation as soon as possible following receipt.
Page 1 Rev. 1 Section Abbreviated Implementation Number
___ Title Requirement Requirement Commitment / Notes Safety Valves: We firmly believe that the alternative proposed by the BWR Owner's Group is viable and provides adequate indication of a stuck open safety valve. However, in light of your recent letter, Eisenhut to Keenan, dated 11/13/79 which documents the NRC's refusal of the high drywell pressure option we will re-evaluate the need for installing additional equipment.
Concurrently we will initiate efforts to design, procure and install any equipment deemed necessary during the 1980 refueling outage.
2.1.3.b 1:.t rument ation for Develop procedures and A
Vermont Yankee will meet the intent of Ia.dequate Core Cooling describe existing inst.
this recommendation.
Existing instrumentation and procedures have-New level instrument A
already been described in responses design submitted to Bulletin 79-08.
The need for adequate core cooling instrumentation Subcooling meter installed A
of a new design is being reviewed generically by the EWR Owners Group
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New level instrument B
and the reactor vendor. Vermont s;)
installed Yankee expects to concur with the findings of these groups.
<!J coolant systems operate at saturated
d temperatures, consequently a rs) sub-cooling meter is of no value and will not be installed.
2.1.4 Di rso Containment Co,nple t? implementation A
Vermont Yankee intends to comply with I
lat-ion the intent of this recommendation.
Changes will be made to automatic containment isolation valve logic as required following receipt of equipment.
Page 3 Rev. 1 Sec tion Abbreviated Implementation
~
Numbe~
Title Requirement Requirement Commitment / Notes 2.1.5.a t raiccaed H2 Control Description and A
Vermont Yankee meets the intent Pene t ra t io ns implementation schedule of this recommendation regarding single failure criteria.
In addition Complete installation B
connections already exist on the CAD system which could be used for additional H2 control penetrations.
2.1.5.c Reconbiners Review procedures and A
The requirement for recombiners bas baaet for reevmbiner use been placed in abeyance.
2.1 6.a Sestems Integrity f,;
Immediate leak A
Vermont Yankee intends to meet this Hi,,h Radioactivity reduction program recommendation. A review of systems will be conducted with the purpose of Preventive malatenance A
identifying methods of minimizing program Icakage of radioactive fluids.
In addition, a preventative maintenance program will be implemented. We endorse the BWR Owners Group position on this matter.
2.1.6.b P1 an Sh ielding Keview Complete the design A
Vermont Yaakee intends to meet this review re comme nd a t io n.
A preliminary shielding review will be conducted Inplement plcnt B
with the objective of defining modi ficatio ns required systems and shielding requirements to enable operation and maintenance of these required systems.
Modifications to plant systems will be dependent upon the results of the design review. The schedule for
>4 completion of the modifications will
'I) then be consistant with any
'3 associated constraints imposed by 7) labor and material availability, with sa the objective of completion of the tfa modifications by the January 1, 1981 date.
We endorse the BWR Owners Group position on this matter.
Page 4 Rev. 1 Section Abbreviated Implementation Number
__ Title Requirement Requirement Commitment / Notes 2.1.7.a Auto Ini t iation of Complete implementation A
This NUREG 0578 position does not Auxiliary Feed of control grade pertain to BWRs.
Complete implementation B
of safety grade 2.1.7.b Auxiliary Feed Flow Complete implementation A
This NUREG 0578 position does not l oilicat ion pertain to BWRs.
2.1.8.a Post Acc ident Sampling Design review complete A
Vermont Yankee will complete a review of its capability to obtain the Preparation of revised A
necessary samples by January 1, 1980.
procedures Implement Plant B
If the review to be complete in Item modifications 2.1.8a-(1) indicates that the capability exists to obtain the desired sampl?= procedures will Description of proposed A
then be revised to implement that modification capability by January 1, 1980.
If it is determine through the review the sampling capability does not exist, plant modifications will be engineered which will give that
'4 capability, in accordance with the
'43 January 1, 1981 requested date for
'3 completion.
C~3 Vermont Yankee will submit a sa
_m.
description of the proposed modifications by January 1, 1980.
2.1.8.b
"' gh Range Radiation Installation complete B
Vermont Yankee will install extended initors range noble gas effluent monitors and high range containment radiation monitors by January 1, 1981, subject to instrument qualification and availability. We endorse the BWR Owners Group position on this item.
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Page 5 Rev. 1 Se ct ion Abbreviated Implementation Number
__, Title Requirement Requirement Commitment / Notes Quantifying Radioactive A
Vermont Yankee will have a method of Releases quantifying radioactivity releases should the existing effluent instrumentation go offscale available for review by the NRC Emergency Plan Review Team.
2.1.8.c Improved Iodine Complete implementation A
Vermont Yankee presently has the i ns t rume nt a tion capability to determine airborne iodine concentrations.
Proc edures presently in effect require the use of charcoal for iodine sampling and the use of plant's GeLi detector for gamma ray energy spectrum analysis which can discriminate iodine from noble gases. We endorse the BWR Owners Group position on this item.
2.1.9 Transieat and Complete analysis To accomplish this action item, Acc ident Analysis procedures, and training in Vermont Yankee will utilize geleric areas of:
small break LOCA, work produced by the NSSS vendor in inadequate core cooling accordance with commitments made acc ident s and transients between the BWR Owners' Group, and the Commission.
Implementation of emergency procedures and initiation of training programs will be accomplished expeditiously, consistent with the intent of
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Reference (b) of the cover lette.r.
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In addition, within one year or sg3 completion of the generic analytical work, Vermont Yankee will validate independently the applicability of 7-J the generic guidelines and analyses LJ' for the Vermont Yankee plant.
Page-6 Rev.[1 Section Abbreviated Implementation Number Title Requirement Requirement Commitment / Notes Containment Pressure Installation complete B
Vermont Yankee will meet the intent o Monitor these recommendations.
Containment pressure, level, and hydrogen containment Water Installation complete B
monitoring equipment will be in Level Monitor service by the scheduled date.
Additional discussion on these items is presented in the BWR Owners Group b
positions.
Containment flydrogen Installation complete g
B Monitor RCS Venting Design submitted A
Installation complete B
VY meets the intent of this g
recomme ndat io n.
The details are c-ra discussed in the BWR Owners Group Q
pos it ion on this item. There are 4 SRV's located on the main steam lines which are safety grade and are operable individually or collectively from the control room.
In addition the vessel head is vented to one g
e steam line and vent valves, operable e
from the main control room, are provided which vent to the drywell.
O Venting occurs also with operation N
of the RCIC or llPCI turbine.
CN NOTE: On i h.4 101 lowing items Vermont Yankee specifically endorses the BWR Owners Group positions and will use them as guideline-Ior impi. mentation.
2.2.1.a shitt Supervisor Complete implementation A
Vermont Yankee will meet this I: sponsibilities recommendation.
Procedures defining SS responsibilities will be in effect on schedule.
2.2.1.b Shift Technical Advisor Shift technical advisor A
Vermont Yankee will augment the on duty current staff with a shift technical advisor on duty by, January 1, 1980
Page.7 Rev. 1 Se c tion Abbreviated Implementation Number
___ Title Requirement Requirement Commitment / Notes Complete Training B
Vermont Yankee will implement the necessary procedures and complete the training of the shift technical advisor by January 1, 1981.
2.2.1.c Shift Turnover Complete implementation A
Vermont Yankee will meet this Proce<hnes recomme nda t io n.
Procedures defining the requirements for shift turnover will be in effect on schedule.
2.2.2.a Control Room Access Complete implementation A
Vermont Yankee will meet the intent o control this recommendation.
Procedures U!9 controlling access to the control
@((j) room will be in effect on schedule.
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2.2.2.b, on:ite Technical Establish center A
Vermont Yankee will meet the 7
Support Center intent of this recommendation. A technical support center will be C==D designated on site and appropriate E535) equipment made available.
fhj Description of the permanent center Egi;,
will be submitted by January 1, 1980.
==
C=E'p 2.2.2.c on: ire ope ra t ional Complete implementation A
Vermont Yankee will meet the intent o
=3
'io ppo r t Center this recommendation. An operational b ='
support center will be established on the site and will be provided with appropriate equipment.
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