ML20023A397

States 781016 NRC Ltr Requests Rewriting of Matl Sent for Info Purposes Only.Suggests Need May Exist for Review of Staff Activities to Confirm They Are Consistent W/Priorities Established by Senior Mgt

ML20023A397
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	11/07/1978
From:	Vandenburgh D VERMONT YANKEE NUCLEAR POWER CORP.
To:	Ippolito T Office of Nuclear Reactor Regulation
References
NUDOCS 7811140224
Download: ML20023A397 (3)

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V ERMONT Y AN K EE NUCLEAR POWER COR POR ATION A(>

SEVENT Y SEVEN GROVE STREET B.l.l.3 i./ R6ri.A.sp, VEID10NT OG701 v f fj g ,,,

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WESTDO RO. M ASS ACHUSETTS 0 l S81 rELEPHONE 6 t y-ast-toi s WVY 78-94 November 7, 1978 United States Nuc1 car Regulatory Con: mission Washington, D. C.

20555 Attention: Office of Nuclear Reactor Regulation T. A. Ippolito, Chief Operating Reactors Branch 3 Division of Operating Reactors

References:

a) License No. DPR-28 (Docket No. 50-271) 1978 (FSAR b) VYNPC Letter to USNRC dated Fe uary Amendment 35) c) USNRC Letter to VYNPC dated October 16, 1978 d) YAEC Letter to Mr. Chilk dated December 16, 1976 e) USNRC Letter to MYAPC dated December 30, 1975 f) USNRC Letter to YAEC dated March 4, 1976 g) USNRC I&E Letter to VYNPC dated December 5, 1977

Subject:

FSAR Amendment Review O

The intent of our letter, Reference (b) was to update information in your copy of the Vermont Yankee FSAR. This information consisted of revised pages to FSAR Section 13.6.1, " Emergency Plan," and was for-warded primarily to enable the NRC Project Manager to keep abreast of minor administrative changes. We regret that this transmittal has caused confusion within your staff, which apparently precipitated a preliminary review by your staff. Although we would prefer to continue sending FSAR updates to our NRC Project Manager, we are prepared to terminate this service if your staff continues to use valuable time in the unnecessary review of this type of information.

Yankee has always maintained a policy of providing descriptive material in the FSAR's in an "as operated" state for the convenience of the plant and engineering staff. This philosophy is consistent with the spirit of the Proposed Rule, enumerated in Federal Register Volume 41, No. 216, dated November 8,1976, (FR Docket 76-32614), and was generally endorsed by our letter, Reference (d).

Your letter, Reference (c), requested that Vermont Yankee rewrite material which was sent to your staff for information only.. We believe your staff unilaterally initiated an unnecessary review and that their application of Regulatory Guide 1.101 was inappropriate for a licensed operating plant. Section A, " Introduction" of Regulatory Guide 1.101

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UnitedStatesNucleahRegulatory-Commission November 7, 1978 Att: #ffice of Nuclear Reactor Regulation Page 2 states that it prbvides "... gvJdance in developing the emergency plan required in the FSKI... for nuclear power plants... in the FSAR [ review]

stage." Emergency planning details for a nuclear power plant during final stages of constructioa and for an operating plant such as Vermont 7enkee, are contained within the implementing procedures of the Emergency Plan. Section C, " Regulatory Fosition" of Regulatory Guide 1.101 states that "... implementing procedures need not be incorporated into the plan and are not required to be subeitted as part of the Final Safety Analysis Report to the Commission." Yankee has and will continue to adopt the philosophy that once the emergency plan concepts and framework have been converted to detailed ~ action plans, i.e. implementing procedures, the FSAR Emergency Plan description can and should be reduced in detail by referencing the appropriate implementing procedures. This practice properly places the major review and update effort on the implementing O

procedures within the Emergency Plan.. These procedures are subject to inspection by the Office of Inspection & Enforcement, and are utilized during drills at a licensed operatingiplant or in the unlikely event of an accident.

The Vermont Yankee Emergency Plan is an adaptation of the Yankee corporate program which was found acceptable for incorporation in its entirety into the Yankee Rowe and Maine Yankee Emergency Plans, References (e and f).

In addition, the Vermont Yankee Emergency Plan has been inspected by'Rcgion I during a drill in November, 1977, and no discrepancies were detected, Reference (g).

In light of the foregoing, we see no reason or obligation to respond to your letter, Reference (c).

t We have had the privilege of reccut discussions with senior NRC management regarding the growing backlog of items requiring review by the staff and their perception that this backlog constitutes the

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primary difficulty facing them today. The institution of a program of review priorities to reduce the backlog has been a, central theme ar-ticulated by Mr. Harold Denton, Director of Nuclear Rasctor Regulation, in discussion with such groups as the Steering Group of the AIF Committee on Reactor Licensing and Safety, and the SEP Owners Group. From our perspective, the staff should complete their review of such items as those listed below, well ahead of the review of an incidental informa-tional update:

i Operation and Surviillan'ce Requirement for CAD System o

(PC.41, 7/15/76) o; Standby Gas Treatment System (PC.42, 6/8/76) o Drywell/ suppression Shamber Differential Pressure (PC.46, 2

12/10/76)

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o Single Recirculation ~ Loop Settings & Limits (PC.51, 11/10/76) o Corporate Administration Changes (PC.68,11/7/77)

o. Safety-Relief Valve-Surreillance Requirements;(PC.72, 2/2/78) s-s

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i United States Nuclear Regulatory Commission November 7, 1978 Att: Office of Nuclear Reactor Regulation Page 3 It is our view that a dichotomy exists between the senior NRC management's view of current priorities and problems, and the manner in which the staff is actually operating. Based on the fact that the staff has formally reviewed operating plant inforn;ation against the Standard Review Plan, it suggests that a need may exist for review of staff activities to confirm that they are consistent with the priorities established by senior management.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION

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cm h m A D. E. Vandenburgh Vice President ec: Victor Stello Harold Denton O

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