ML20002D285
| ML20002D285 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 01/13/1981 |
| From: | Groce R VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| TASK-2.K.1, TASK-3.D.3.3, TASK-TM FVY-81-9, NUDOCS 8101200249 | |
| Download: ML20002D285 (4) | |
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VERMONT YAN KEE NUCLEAR POWER CORPORATION SEVENTY SEVEN GROVE STREET RUTLAND, VERMONT 05701 REPLY tot ENGINEERING OFFICE TURNPIKE RO AD B 3.2.1 wESTBORO. M ASSACHUSETTS 01581 T ELEPHON E 6 t ?-366-9019 January 13, 1981 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Office of Nuclear Reactor Regulation Darrell G. Eisenhut, Director Division of Licensing
References:
(a) License No. DPR-28 (Docket No. 50-271)
(b) USNRC Letter, D. G. Eisenhut to All Licensees of Operating Plants, dated October 31, 1980 (c) VYNPC Letter, L. H. H1ider to D. G. Eisenhut, dated December 15, 1980
Dear Sir:
Subject:
Exceptions Taken to Certain Post-TMI Requirements Reference (b) transmitted all TMI-related items approved for implementation by the Commission as of October 31, 1980. Reference (c) provided a tabulation by item of the requirements specified in Reference (b) and our specific plans addressing each one.
The attachment to this letter details the exceptions taken to certain items Reference (b).
It should be noted that although exceptions are noted, action has been taken on the item of concern.
In one case a different date for the availability of final design details is proposed.
If it becomes apparent that for any reason the date given cannot be met, the NRC will be contacted as soon
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as possible.
We trust the information cor.tained in the attachment adequately documents Vermont Yankee's reasons for taking exception to certain items given in Reference (b) and our intended actions.
If additional clarification of our l
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t U. S. Nuclear Regulatory Conunission January 13, 1981 Attention:
Mr. Darrell G. Eisenhut, Director Page 2 position is necessary, please contact us as soon as possible in order to allow a timely resolution of any difficulties.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION NY WL. H. Heider Vice President Attachment COMMONWEALTH OF MASSACHUSETTS)
)ss COUNTY OF WORCESTER
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Then personally appeared before me, L. H. Heider, who, being duly sworn, did state that he is a Vice Presdient of Vermont Yankee Nuclear Power Corporation, that he is duly authorized to execute and file the foregoing request in the name and on the behalf of Vermont Yankee Nuclear Power Corporation, and that the statements therein are true to the best of his knowledge and belief.
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wK Robhrt H. Groce' Notary Public 4
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Attachment
.e II.F.1.,, Noble Gas Effluent Monitor Table II.F.1-1 (High Range Noble Gas Effluent Monitors) states that the high range noble gas monitor should have a continuous and recording display in' equivalent Xe-133 concentration or uCi/cc of actual noble gases. However, clarification (4)(b) requires consideration of the radionuclide spectrum distribution as a function of time after shutdown.
Because of these conflicting requirements, we have chosen to have the instrument readout in dose rate (i.e., mr/hr). Conversion to equivalent Xe-133 concentration and/or actual noble gas concentration is accomplished by procedure.
NUREG 0737 requires final design details to be available for review by January 1, 1981. However, due to work still being performed by the vendor and in-house, final design details will not be available until May 1,1981.
II.F.1. Attachment 2:
Sampling and Analysis of Plant Effluents The design basis shielding envelope used for the stack sampling medium assumes the charcoal is exposed to 102 uCi/cc (I-131) for 30 minutes.
For the following reasons Vermont Yankee takes issue with the design basis shielding envelope:
Calculations based on the above assumptions and the stack sampler a.
flow rate yield 85 Ci of I-131 on the charcoal sampler. This activity only reflects the I-131 component and when other noble gases are included, the activity is significantly increased. Plant personnel would not be allowed to handle a sample of such high activity.
b.
This concentration of I-131 can only be produced at the stack by purging a containment fuel-melt LOCA source term directly to the stack at an un-filtered high flow rate. This sequence of events is
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not possible at the Vermont Yankee plant. All other sources of I-131 release to the stack would produce I-131 concentrations that are decades below 102 uCi/cc.
In the event of a high level halogen release from the plant there c.
exist more reliabic and reasonable methods for a quantitative assessment of the release. This can be accomplished through a direct measurement of the source or offsite sampling for I-131.
d.
As indicated by the Commission Meeting on Iodine Release From Accidents and Estimates of Consequences of Nuclear Accidents on Tuesday, November 18, 1980, the halogen component available for release from a LOCA is much less than that assumed for DBA's (25 percent of core inventory) due to a much higher degree of plateout and other effects. Therefore, even under the condition in which a LOCA atmosphere in containment is vented directly to the stack, the realistic halogen component would be very low.
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The plant has the capability to continuously sample plant gaseous effluents for post-accident (analysis) release of radioactive iodines and particula te s.
Onsite laboratory facilities are provided to measure and/or analyze the samples. Detailed procedures have been developed concerning the handling and analysis of these samples as well as provisions to minimize noble gas interference.
III.D.3.3., Improved Inplant Iodine Instrumentation Under Accident Conditions The clarification for this item requires the use of portable instruments using sample media that will collect iodine selectively over xenon (e.g.,
silver zeolite). The clarification goes on to state the sample should firat be purged of any entrapped noble gases using nitrogen gas or clean-air free of noble gases.
Yankee takes exception to the requirement that iodine-selective sampling media be used instead of charcoal. The clarification requires purging of the media even though it is iodine-specific. This is presumably to remove noble gases in the cartridge free air volume. Use of charcoal and
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compressed (bottled) air will accomplish the same purpose.
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