ML19310A437
| ML19310A437 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/11/1980 |
| From: | Heider L VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Eisenhut D NRC COMMISSION (OCM), Office of Nuclear Reactor Regulation |
| References | |
| WVY-80-87, NUDOCS 8006170548 | |
| Download: ML19310A437 (6) | |
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VERMONT YAN KEE NUCLEAR POWER CORPORATION SEVENTY SEVEN GROVE STREET RUTLAND. VERMONT 05701 h
8b-87 REPLY TO:
ENGINEERING OFFICE TURNPIKE ROAD
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WESTBORO, M ASSACHUSETTS 01581 t
TELEPHONE 617-366-9011 June 11,1980 i
United States Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Darrell G. Eisenhut, Director Division of Licensing
References:
(a) License No. DPR-28 (Docket No. 50-271)
(b) USNRC Letter to All Operating Reactor Licensees dated May 7, 1980 (c) TMI-2 Action Plan; SECY-80-230 (d)
" Generic Evaluation of Feedwater Transients and Small Break Loss of Coolant Accidents in GE-designed Operating Plants and Near-term Operating Applications," NUREG-0626, dated January, 1980 (e) Letter, S. J. Stark (GE), to C. O. Thomas (NRC), "
Prospective Safety Evaluation Report Requirements for BWR's,"
December 7, 1979
Subject:
Five Additional TMI-2 Related Requirements To Operating Reactors
Dear Sir:
Reference (b) transmitted five items from the NRC's TMI Action Plan that were felt to be applicable to operating reactors. Vermont Yankee was requested to. reply within 30 days stating our commitment to meet these additional items and their associated schedules.
The attachment to this letter provides a tabule.On by item of the twenty-three requirements specified in Reference (b) and our specific plans to address each one. Vermont Yankee recognizes its obligation to respond to NRC requests for information and it is our intention to be fully responsive in t;his regard. However, we trust that the NRC staff recognizes that Vermont Yankee, as the licensee, bears the full weight of responsibility for the safe dperation of this facility. In this regard we feel that an absolute, final commitment to the entire set of requirements and schedules contained in Reference (b) cannot be madc at this time.
As recommended in Item B.15 of Reference (d) we propose to perform an independent, plant specific assessment of some items prior to implementation to assure ourselves that the individual and collective impact of these requirements will not compromise system reliability and safety.
p) 800617 0 6g
I, United Statc2 Nuclocr R;gulctory Commicsion June 11,1980 Attn: Darrell G. Eis;nhut, Dir;ctor Paga 2 W
Following a comprehensive review of the requirements, we may wish to discuss with the NRC staff alternatives to strict adherence to some of the requirements and schedules. Such alternatives may include: 1) modifications other than those suggested by the requirement but which offer equal or better safety improvements; 2) design and test of hardware modifications on a single typical plant followed by implementation on remaining plants; or 3) exception to some recommendations whose implementation is believed unnecessary (see, for example, BWR Owners' Group positions in Reference (e)). Thus, we believe that a' degree of flexibility may be necessary on your part in relation to the implementation schedules and requirements if good cause can be shown.
Vermont Yankee's commitments for action concerning the requirements of Reference (b) are contained in the attached pages.
If additional clarification of our position is necessary, do not hesitate to contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION YY L. H. Heider Vice President S
Item Title.
Requirement Schrdule Commitment /boten.
I.A.l.3 Shift Hanning 8/1/80 The NRC'a positita Cnd 7/1/82 clarification has not been received; VY will make the required response 30 days after receipt of the " separate correspondence" referenced 'in the NRC.
5/7/80 Letter.
IA.3 1 Revise Scope and Criteria NRC Examinations (Ref. USNRC Letter to For Licensing Examinations All Power Reactor Applicants and Licencees; 5/1/80 VY intends to comply with
., page 4) this requirement.
I.C.5 Feedback of Operating Licensee to implement actions VY plans to meet the Experience and submit documentation of method 1/1/81 intent of this require-for staff review sent.
II.K.3 3 Reporting Safety and Relief A. Failures of relier had safety VY intends to comply with Valve Failures and valves to close shculd be this requirement.
Challenges reported to the NRC 4/1/80 B. Challenges to relier and Documentation of SV and safety valves should be SRV future challenges will documented in the annual report be included in the next 10CFR50.59 report.
II.K.3 13 Separation of HPCI & RCIC Licensee to provide results of 10/1/80 This item is being evalu-System Initiation Levels evaluation to staff.
ated by the BWR Owner's Group and reactor vendor. We anticipate endorsing their position. The results of our evaluation will be
'j submitted to the NRC sta ff.
j Documentation of any If justified by analysis licensee 4/1/81 modifications found ll to implenent actions and submit necessary and schedule documentation of the methr4 for for their implementa -
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staff review.
tion will be provided
'i for staff review.
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Item Titl*
Requirem nt Schedul' Commitment /Not*m II.K.3 15 HPCI & RCIC Breik Detection Licens3e to irplement 1/1/81
. Sea Iten II.K.3 13.
Logic" actions and submit documentation of the method for staff review.
II.K.3 16 Reduction of Challenges &
Licensee to provide results of 1/1/81 See Ites II.E.3 13.
Failures of Relief Valves evaluation to staff.
Licensee to document proposed changes 1/1/82 for staff approval.
First or Second Licensee to implement modifications Refueling Outage Following
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Staff Approval II.K.3.17 Report on Outage of ECC.
Licensee to provide results of 1/1/81 VY intends to comply Systems evaluation to staff, with this requirement.
II.K.3 18 Modification of ADS Logic Licensee to provide results of 1/1/81 See Ites II.K.3 13 evaluation to staff.
Licensee to document proposed 1/1/82 changes for staff review.
First or Second Licensee to implement modif1;ations Refueling Outage Following Staff Approval 1
II.K.3 21 Restart of CS & LPCI on Lxcensee to document proposed 1/1/81 See Ites II.K.3 13 Low Level changes for staff approial.
First or Second ii Licensee to laplement modifications Refueling Outage Following l
Staff Approval i
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II.K.3.22 Autunatic Switchover Licensee to implement actions Precedures VY intends to evaluate of Rt.,IC Systes Suction and submit documentation of 1/1/81 this position along the method for staff review.
Design 1/1/82 with Ites II.K.3 13; the results will be submitted to the staff for review. Procedural changes will be made in the prescribed time frame.
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Iten Title Requirement Schedul9 Commitment /NotM II.K.3 24 Spac3 Cooling for Lic:r. sos to irplement tctions 1/1/82 See Ital II.K.3.13
'HPCI & RCIC and submit documentation of method for staff review.
II.K.3 25 Loss of AC Power on Licensee to provide results 1/1/82 See Ites II.K.3 13.
Pump Seals of evaluaeion to staff.
II.K.3 27 Common Reference for Vessel Licensee to implement actions 10/1/80 VY Intends to address Level Instrumentation and submit documentation of this requirement by the the method for staff review.
required date.
II.K.3 28 Qualification of Licensee to provide results of 1/1/82 VY intends to address Accumulators on ADS Valves evaluation to staff.
this ites by the required date.
II.K.3 29 Performance of Isolation Licensee to provide results of 4/1/81 VY does not have an Condensors with evaluation to staff.
1 solation condenser.
Non-Condensables II.K.3 30 small Break LOCA Methods Licensee to submit analysis 1/1/82 VY intends to comply with j
Compliance with model for staff approval.
this requirement.
Appendix K i
6 II.K.3 31 Plant Specific Licensee to provide results of 1/1/83, or VY intends to comply with
.j Calculations - Compliance evaluation to staff.
1 year after this requirement.
with 10CFR50.46 NRC approval g
II.K.3 44 Anticipated Transients with Licensee to provide results of 1/1/81 See Ites II.K.3 13.
Single Failure evaluation.
II.K.3.45 Non-ADS Depressurization Licensee to provide results of 1/1/81 See Ites II.K.3 13.
evaluation.
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Itee Tit 13 Requiresent Schedula Consitse t/Ilotes II.K.3 46 Berpons3 to ACRS Consultr.nt Lic nsa to provida results of 7/1/80 VY i W nds to comply t:ith Concerns evaluation to staff, this requirement.
II.K.3 57 Water Source Identification Licensee should verify that 10/1/80 VY intends to comply with Emergency Procedures have this requirement.
been appmpriately revised.
f III.D.3 4 Control Room Habitability Licensee should submit description 1/1/81 VY intends to comply with and schedule for completion for this requirement.
staff review.
(All modifications must be scheduled for completion by 1/1/83.)
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