ML19305B752
| ML19305B752 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/14/1980 |
| From: | Conway W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| WVY-80-43, NUDOCS 8003200254 | |
| Download: ML19305B752 (4) | |
Text
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V ERSIONT Y AN KEE NUCLEAR POWER COR POR ATION O
't SEVENTY SEVEN GROVE STREET KUTLAND, Vi?RMONT 05701 WY 80-43 REPLY TO:
ENGINEERING OFFICE TURNPIKE RO AO WEST 00RO. M ASS ACHUSET1 $ C S S B t TELEPHONE 617 366 9011 Pbrch 14, 1980 B.3 2.i United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Office of Nuclear Reactor Regulation Thomas A. Ippolito, Chief Operating Reactors Branch #3 Div.ision of Operating Reactors
References:
(a) License No. DPR-28 (Docket No. 50-271)
(b) USNRC Letter to R. L. Smith from T. A. Ippolito dated February 20, 1980, subject:
Supplemental Safety Evaluation Report
Dear Sir:
Subject:
Supplemental Safety Evaluation Report Refercnce (b) above requested that we inform you of our commitment or non commitment to the Staff Positions expressed in Sections 3 3 and 3.6 of the Supplemental Safety Evaluation.
It also indicated that there would be an expected implementation date of November 1, 1980 for any commitments made in response to those Staff Positions.
It is our feeling that the proposed date is unacceptable for the type of changes required by your Staff Positions, and we propose the following dates.
For those commitments regarding changes in procedures and training requirements, we propose a date of December 31, 1980. For those commitments requiring system modifications or new systems, we propose a date of the end of the 1981 refueling.
All commitments that we make in this letter are based upon those dates.
We feel that to attempt to impose a date of November 1, 1980 based upon the issuance at some future time of a proposed rule which may contain many positions and conditions that are completely arbitrary and without basis, and which may be contested vigorously by the nuclear industry, is without merit.
8003200 2.5 4 g
d
' U.S. Nuclear Regulatory Commission March 14, 1980 Attention:
Mr. Thomas A. Ippolito Page 2 Our training cycle started on January 1 of 1980. The type of training can be changed during the current year, bet it will be at least December of 1980 before the changes in the cycle atch up with all members of the fire brigade.
The systems modifications will require design time and will require that the plant be shutdown for an extensive time for any work done inside the Primary Containment. The next scheoaled block of time for this type of work which fits into a reasonable design and procurement schedule is during the refueling outage that begins in October of 1981.
Based upon the above discussion and schedule, our commitments in response to the Staff Positions expressed in the Supplemental Safety Evaluation are as follows:
33 Primary Containment Analysis Based upon a careful reading of the Staff Positions, it is our understanding that our four proposed modifications:
1 A means for early detection of oil fires inside the containment, 2.
A collection system for small oil leaks from each reactor recirculation pump motor, 3
Fixed (manual) suppressions for oil fires at each reactor recirculation pump motor (density of 0 3 gpm/sq. ft.),
4.
Replacement of all combustible " armor flex" insulation with non-combustible insulation, are unacceptable with the exception of the replacement of the combustible insulation with non-combustible insulation.
We, therefore, withdraw our commitment to the first three proposed modifications and propose the following:
1.
We will provide stand pipes and hose stations outside the drywell with adequate lengths of hose to reach any location of concentrated combustibles inside the drywell with an effective hose stream.
2.
Because the balance of the requirements expressed in your position are new ones with respect to the seismic qualification of any new modifications in the Primary Containment, we require more time than the 20 days allowed by your letter to study the alternatives before making a commitment to provide one or another. We expect to be able to provide you with either (1) a commitment to one of your alternatives or, (2) our own proposed alternative by June 1, 1980.
U.S. Nuclear Regulatory Commission March 14, 1980 a
' I Attention:
Mr. Thomas A. Ippolito Page 3 We wish to point out, however, that no matter what our commitment is in terms of a new system, we take issue with the requirement that the system should be designed to withstand an SSE. All the primary safety systems in the plant are designed to withstand a seismic Category I event, therefore, any new installation will be designed and installed to the same criterion.
3.6 Administrative Controls We have reviewed the five staff concerns and positions expressed in this section. Our commitments are listed below:
1.
Training of fire brigade support personnel.
We will commit to the preferred staff position attached as to your letter, Reference (b).
2.
Fire Brigade Drill Frequency We do not intend to commit to the NRC requiremente on drilling as expressed in the letter, Reference (b). We continue to feel that our position on drills provides adequate practice to fire brigade members. We point out that your position requires each individual member of the fire brigade to participate in at least two drills per year. Our position requires the same number of drills for the majority of the fire brigade.
It is only the support personnel who will be required to attend only one, and in all probability they will in fact attend more than one.
3 Controls to be used for Untreated Wood This concern is not expanded upon in your letter so we cannot address it directly. However, we wish to point out that in our letter of September 10, 1979, WVY 79-98, we said the following:
Fire Retardant Wood Vermont Yankee has established controls on the use of wood in areas of high combustible loading and in areas where a significant fire hazard exists and the occurrence of a fire would present a serious threat to the safe shutdown of the Plant (Fire Control Areas). When wood is brought into these areas, it will be:
a.
Fire retardant or, b.
Painted with a fire retardant coating, or c.
Wrapped in fire retardant material.
=
U.S. Nuclear Regulatory Commission March 14, 1980 i
Attention:
Mr. Thomas A. Ippolito Page 4 We felt that this responded to the staff concerns expressed at that time. Without further indication from you as to why it did not, we cannot make any further commitment.
4.
The Assignment of the Shift Supervisor as the Fire Brigade Leader We will agree to the conditions stated by the NRC staff for use of the Shift Supervisor as Fire Brigade Leader; and we will (1) commit that the Shift Supervisor (s) responsibilities for the overall operation and safety of the plant will not conflict, in any way, with the esponsiblilities of an "on the scene" Fire Brigade Leader during a fire emergency; (2) provide assurance that the Supervisory Control Room operator assigned to supervise the control room in the absence of the Shift Supervisor is equally qualified to do so, and meets the requirements of "American National Standard for Selection and Training of Nuclear Power Plant Personnel;" N 18.1-1971 (we wish to point out that this is our present commitment for all oparating plant staff) and (3) assure an approved procedure is svailable which clearly defines the Supervisory Control Room Operator's duties and responsiblilites in assuming the postion of Shift Supervisor.
5.
Control of Ignition Sources in Safety Related Areas To resolve this staff concern; we will commit to the preparation and institution of administrative controls to assure that all safety related areas and areas hazardous to safety related equipment are protected from fire damage or loss resulting from work involving ignition sources such as welding, cutting, grinding or open flame work.
We trust that the above commitments respond adequately to the NRC staff concerns. Upon receipt of your agreement, we will begin implementation of the commitments.
If you have any further comments or questions, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION
_ NMa/w/d W. F. Conway Manager of Operations EAS/sec l
_ _