ML19256G465

Advises That 800101 Date for Compliance w/NUREG-0578 Not Feasible.Equipment Delivery,Design Review,Safety Evaluation & Outage Schedule Will Result in Completion During Wk of 800216.Schedule & Ltr Re Requested Outage Encl

ML19256G465
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	12/14/1979
From:	Moody D VERMONT YANKEE NUCLEAR POWER CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0578, RTR-NUREG-578 WVY-79-142, NUDOCS 7912310341
Download: ML19256G465 (6)

Text

i .

VERMONT YAN KEE3UCLEAR POWER CORPORATION SEVENTY SEVEN GROVE STREET ***

WVY 79-142 RurtAso, VERMONT 05701 D

REPLY TO:

ENGINEERING OFFICE December 14, 1979 TuRNeixE Roao WESTBoRo. M ASSACHUSETTS 01581 TELEPHONE 417 364-9011 Mr. Harold, R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20014

Enclosures:

(1) NUREG-0578 Criteria Development and Vermont Yankee Implementation Schedule (2) Letter J. D. Cochran to T. D. Keenan discussing Vermont Yankee Shutdown

References:

(1) Letter, D. E. Moody to H. Denton, dated November 20, 1979 (2) Letter, Max W. Carbon to Commissioner Peter Bradford discussing Implementation Schedules

Subject:

Schedule for Implementation of NUREG-0578 Recommendations

Dear Mr. Denton:

In accordance with our statement in Reference (1), this letter will inform you of our intentions concerning the implementation of those NUREG-0578 items wherein compliance with the January 1,1980 implementation date is not feasible, specifically, recommendations 2.1.3A and 2.1.4. Equipment delivery, design review, safety evaluation and outage schedule will result in completions of the implementation during the week of February 16, 1979. A shutdown is necessary to permit installation of the hardware associated with both of the above NUREG-0578 items. Verbal notification of this situation was '

provided to Mr. Verrelli of your staff and Vern Rooney, the Vermont Yankee project manager, on December 3,1979 A detailed schedule of our efforts is provided as Enclosure (1). It documents Vermont Yankee efforts to: (1) define acceptable solutions, (2) provide designs, (3) review the designs for adverse interaction with other safety related systems, (4) locate and order the equipment and (5) install equipment.

With regard to recommendation 2.1 3A, Direct Indication of Relief and Safety Valves, Vermont Yankee opted to use pressure switches in the discharge piping of the four relief valves for position indication, and containment pressure response as position indication for the two safety valves. To this end, the following was done:

(1) Pressure switches were ordered from General Electric in Septecber with deltvery promised by mid-December.

1661 217 p 7012310 3Hl

United States Nuclear Regulatory Commission December 14, 1979 Attention: Mr. Harold R. Denton Page 2 (2) The required piping modifications were completed during the fall refueling shutdown.

(3) Conduit and cable installation was begun.

These indicators are expected to be in service by January 1,1980.

Containment pressure response as a suitable long-term technique for providing indication of safety valve position was rejected by your staff in November. As a result of this decision:

(1) Engineering review of possible alternatives was begun resulting in the choice of acoustic monitoring for safety valve position indication.

(2) Vendor review was conducted and purchase orders issued to Babcock &

Wilcox on the basis of qualified equipment and an expedited delivery date of February 1,1980.

(3) Installation procedures are being prepared.

(4) Scheduled outage was requested via Vermont Electric Power Company (VELCO) for one week immediately following delivery of the last hardware shipment. This time period was not available as discussed in Enclosure (2). The first available time period was February 16 through 23, 1980 and this date has been officially scheduled for a Vermont Yankee outage to implement NUREG-0578 requirements.

Vermont Electric Power Company (VELCO) is the agent for the electric power companies in Vermont and represents them with the New England Power Exchange (NEPEX). This organization is responsible for maintaining adequate power for the New England area and to schedule plant operation to maintain adequate power reserves. '

Regarding NUREG-0578 recommend:a. ion 2.1.4, Containment Isolation Provision, Vermont Yankee endorsed the position statement provided by the BWR Owner's Group. This position committed to instituting administrative controls by January 1,1980 to prevent containment is'slation valves from reopening when the isolation signal was removed, coupled with logic modifications to be completed by January 1, 1981.

The BWR Owner's Group position in this matter was found unacceptable by your staff and logic modification was required by January 1,1980. As a result, the following steps have been taken:

(1) A new detailed design change was made on an expedited basis.

1661 218

United States Nuclear Regulatory Commission December 14, 1979 Attention: Mr. Harold R. Denton Page 3 i

(2) Hardware for this modification was placed on order immediately. An expedited delivery date of December 7 was achieved through discussion with the vendor.

(3) Preparation of installation procedures was begun. Consideration was given to installation of components already available.

Vermont Yankee endorses the position of the Advisory Committee on Reactor Safeguards, Reference (2), which states that unnecessary plant shutdowns should be avoided to limit the number of transients. In addition, the effect on power availability in the State of Vermont of an earlier shutdown discussed in Enclosure (2), in our judgement, indicates that Vermont Yankee should be permitted to operate until the presently scheduled outage of February 16 to complete implementation of the remaining NUREG items. The implementation of administrative procedures in regard to containment logic reset as previously discussed, coupled with the existence of containment pressure as an indication of open safety valves leads us to conclude that there is adequate assurance of continuing safe operation of the plant until the scheduled outage of February 16.

We trust you concur in our position on these matters. Should you require additional information or if you desire additional clarification of our position and our intentions on these matters, please contact us.

Sincerely, VERMONT YANKEE NUCLEAR POWER CORPORATION S.t%4 D. E. Moody Manager of Operations DEM/dmp #

Enclosures 1661 219

.. C osure

. 12/7/79 NUREC-0578 CRITERIA DEVELOPMENT AND VERMONT YANKEE IMPLLNENTATION SCHEDULE BEYOND 1/1/80 EVENT DATE (1) Ac c id e n t a t Th ree H il e Is 13 nd . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 / 2 8 / 7 9

) (2) BWR Owne r s ' G roup f o rme d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 / 2 8 / 7 9 (3) NUREC-0578 TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations published..................................................................... 7/79 (4) NRC (Harold Denton) Clarification meeting with all utilities on NUREC-0578. . . . . . . . . . . . . . . . . . . 8/1/ 79 (5) Harold Denton's memorandum to the Commission on " Resumption of Licensing Reviews for Nuclear Power Plants" (added requirements.for containment monitoring and RCS venting).... 8/20/79 (6) BWR Owners' Group meeting with the NRC Staff to review the BWR-6 and an early review of NUREC-0578 positions, specifically valve testing............................................. 8/21/79 (7) NUREC-0578 issued to all utilities requiring response within 30 days...................... .. 9/13/79 (8) All Owner Croups meeting with the NRC staff to present informally essentially all positions relative to NUREC-0578. Specially included safety and relief valve testing and position indication. (Cenerally favorable response for BWR.).......................................... 9/20/79 (9) Ve rmon t Yank e e scheduled f all outa ge. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 / 2 2 thru 11/ 3 (10) NRC Regional meetings nationwide - Owners' Group positions were discussed.................... 9/24/79 (11) Vermont Yankee ordered pressure switch for " Direct Indication of Valves:

NUREG- 05 7 8 I t e m 2.1. 3. a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 / 2 4 / 7 9 (12) Conceptual design for direct indication of valves, Phase I, issued for safety reviev......... 9/27/79 (13) NRC Topical Mee tings (3 days) - Bethesda , Md. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10/10 thru 10/12 (14) Formal submittal of Owners' Croup positions on NUREC-0578 items (a request was made for review and comment s within 2 wee ks ) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10/17/ 79 (15) Response to Denton's 9/13/79 letter due (30 day letter)...................................... 10/18/79 (16) Conceptual design issued for safety review regarding containment logic. ... ... . .. .... .. .. . . .. .10/24/79

• (17) Completion of piping work in drywell for NUREC-0578 Item 2.1.3.a. (see Item 9 above)......... 10/30/79 (18) Denton's clarification letter issued requiring response within 15 days....................... 10/30/79 (19) Reevaluation of containment logic conceptual design, new design issued for safety review.....11/9/79 (20) Eisenhut issues letter to Owners' Group rejecting several of their positions and requesting compliance and response along with utility response to Denton's 10/30/79 letter. Advance copy received by telecopy 11/9/79. Received letter 11/19/79. Specifically rejected ,

(1) SRV Testing, (2) Containment Logic Position and (3) Safety Valve Position Indication.....11/14/79 (21) Design and evaluation o f s a fety valve indica tion op tions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11/14 thr 11/28 (22) Response to Denton's 10/30/79 letter due along with utility reevaluation response to Eisenhut's 11/14 / 7 9 1 e t t e r. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11/ 2 0 / 7 9 (23) Requested scheduled outage from NEPEX for week ending 2/9/80 (Rcquest danicd). .... .. . ..... ...11/27 (24) Ordered hardware for sa fety valve indica tion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11/29/79 (25) Orde red hardwa re for containment isolation logic modifica tion. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11/29/79 (26) Detailed " Containment Isolation Logic" design complete....................................... 12/1/79 (27) Hardwa re for Containment Isola tion Mod ificat ion due. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12/ 7/ 79 '

(28) Safety Relief Valve Pressure Switches due.....................................................12/10/79 (29) Remaining equipment for safety relief valve modification due.. .............................. 12/10/79 (30) Scheduled completion of saf ety relie f valve modificat ion. . . . . . . . . . . . . . . ..................... 12/31/79 (31) Hardware for safety valve indication arriva1.............. ..................... .. .... .... 7/1/80 (32) Scheduled outage.................................................

.. . .. . ........ ....... 2/16 thru 2/23/80 (33) Scheduled completion of modification for direct indication of safety valves. .

NUR EC-O S 78 Pos i t ion 2.1. 3. a . . . . . . . . . . . . . . . . .. .. .... .. . .... ..... .. . .. . .. . 2/23/80 (34) Scheduled completion of modification of containment isolation. NUREC-0578 Position 2.1.4.. .. 2/23/80

_ ._ . . 1661 220

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Vermont Yankee Nuclear Power Corporation

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Subject:

Request For Scheduled shutdown Of Verunnt Yankee For e

ua NUREG-0578 Modifications

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Dear Mr. Keenan:

M This letter confir=s the verbal co:=::unications resarding the

$ subject request and the reason- for selection of an alternate date.

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" On November 27, 1979 you contacted Villian B. Dunn, Jr. of this office, in my absence, to request a scheduled outage of Vermont Yankee a

f for the week ending Saturday, February 9,19SO, (that is, to cost off-line at 0001 on Saturday, February 2, .1980 and to return to full load d

ys by 0600 on Honday, February 11, 1980). Stated purpose of the requested Vermont Yankee outage was to install endifications (requiring plant D shutdown) in co=pliance with hTdEG-0578. Mr. Villiam Dunn ic=ediately Jj relayed your request to me at Westborough, hassachusetts End I, in turn,

,g promptly submitted the request to Robert Dunn, who is the Generation

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.._ _. Cocedinator for Rhoda Island-Iastern Massachusetts-Vermont Energy l$F[ Control r*wer (EEEVEC).

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d M! Mr. Embert Dunn, working with the NEPEI staff and the NEP00L E Maintenance Schadn11ng Task Force, reported back to me on Nove:ber 28,

[3 1979 chne the vermont Yankee requested scheduled outage date could not

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be accepted (see explanation below) and listed the following alternate M dates, in order of pool preference, which were acceptable within the g

=.y REPOOL re14Mife7 rW14~= and procedmes-fd h k anding March 15, 1930

@p h k ending March 8, 1S80 Ih Baek endtwr Wrch 1,1930 g- Seek id+vy h m 23, 1980

>#j Q ne regnested vaek ending February 9,1950 was 2:naccepnable to the h pool be-r se -W-4 "g of the Ver=s:mr Y r- k- octage during that weer

@ vould have vdn1=*d 'E?EI C>erati=g Procedure So. 5 - Pit Ou ages. This

[ procedure establishes criteria and guides for requesting, evaluatin5,

( It pr=vides fer

4_ P, DDIroving and classifying generator t=it eutages.

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f i Hr. Thor.ss D. Keenan h

Director of Operations & Engineering W Page 2 N December 12, 1979 Ed y,t h, sufficient operating reserve while considering transsission reliability and unit availability for planned as well as unplanned outages. The

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$ intent of the procedure is to insure that sufficie:.t generating unit Q capability is availabic vithin the pool to supply the projected 1 cad M and required operating reserve, while also recognizing that there vill d be scene amune of unscheduled or forced generator outages. The " allow-ance for unscheduled outager" which is used in the scheduling process is

&@ based on the average a=ount of unscheduled outages that actually occurred during the time of the week day peak loads for the last twelve =enths.

L NEPOOL e.xperienced an oc erage arouse of unscheduled generator outages

@ of 2800 W during the 12 months preceding the start of preparation of the f% 1980 annual overhaul schedule, and it was this value that was utili:ed in d '

considering the vermont Yankee request for scheduled outage.

December 1,1979 the "allevance for unscheduled outages" used in the (As of

@$ NEP00L scheduling process was raised to 3000 W, based on the = ore recent

$4 unfavorable experience.) Even with Ver:ent Yankee on-line and operating y at full load during the week ending February 9,1980, the projected P capability al.lovance for unscheduled outages is less than 3200 W. If

[ Vernant Yankee were to be scheduled down for the week ending February 9, 1980 the projected capability allevance for unscheduled outages vould drop 9 to less than 2700 W. This vould clearly be unacceptable under the bj established guidelines. Please note that use of the 12 month average M

y experience.is not a conservative assu=ption. Please also note that it was necessary to manually shed a portion of customer load in the RDr.*EC k

i area twice last su=cer in order to prevent a collapse of the bulk power system. As a result of these two disturbancas, NEPEX Operating Procedure y No. 5 is being revised and consideration is being given to the use of a ,

g sore conservative cethod for deter-ining an allowance for unscheduled Q M' generating unit outages. -

On Novex6er 28, 1979, 1 contacted Mr. John Beck to inform him that th h

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the requested outage for Ver:ent Ys**e during the week ending February 9, 1980 was unacceptable to the pool and that the four alternate dates t.ich g were acceptable to the pool, had been suggested. Mr. Beck decided to 3g request the week ending February 23, 1930, since it was the earliest'veek in 1980 which could acco=odate the Vernent Yankee scheduled outage. This yd revised request was relayed to the pool and was accepted. Ver=ont Yankee LM is currently scheduled to co:e off-line at 0001 on Saturday, February 16, yy 1980 and to be back at full load by 0600 on Manday, February 25,19S0.

g W If you have any questions regarding this catter, please do not hesitate OE to contact either me or Mr. V1111a= H. Denn, Jr.

i 1661 222 15.. Very truly yours, p? -

J. Denny Cochran 3,3 JDC:1c Assistant Vice President

. _ . _ _ _ . _ _ . . _ . . _ - _ _ _ _ _ . . , _ - - _ . . _ _ _ _ . . _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ . _ . _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ , _ .