ML20066G415
| ML20066G415 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 01/17/1991 |
| From: | Tremblay L VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 BVY-91-09, BVY-91-9, NUDOCS 9101280041 | |
| Download: ML20066G415 (2) | |
Text
_ _ -,
VER)f0NT YANKEE NUdLEAR POWER CORPORATION
- )
M g Ferry Road, Orattieboro, VT 05301 7002
)K ENGINEERING OFFICE.
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$80 MAIN STREET.
00LTON MA Ot T40
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. (508)779 6711 January 17,1991 United States Nuclear Regulatory Commission Bvy 91 -09 :
Document Control Desk Washington, DC 20555
References:
- a. License No. DPR-28 (Docket No' 50-271) 0
- b. Letter, USNRC to VYNPC, NVY 90-215, dated December 4,1990.
Subject:
Confamiance To Regulatory Guide 1.97 For Vermont Yankee Nuclear Power Statloa d
Dear Sir:
Reference (b) transmitted the NRC Safety Evaluation Report (SER) pertainirq. VY ceniormance to Regulatory Guidt 117 along with a Technical Evald!on Report TER) p. pared by EC&G Idaho, Inc. dated, May,1990. In this letter the NRC. stated that they found the nstrumentation i
provided by Vermont Yankee Nuclear Power Corporation for meeting the recommendations of-R ' '1.97, Revision 3, acceptable, except for two variables. These two variables were foimd to i
be
' ding additional attention.- Specifically, you stated:
"We find tiiat the instrumentation provided by Vermont Yankee Nuclear Power i
Corporation for meeting the recommendations of R.G.1.97, Revision 3, acceptable, except for the following variables:. neutron flux and cooling water temperature -to ESF components. %e staff's position on neutron flux has been appealed by the BWR Owners 3
Group aad is currently under consideration."
Neutron Monitoring The necessity of Installing a R.G.1.97, Category 1, neutron flux monttoring system las-been appealed by the BWR Owners Group. The staff is-currently considering this appeal.
4 Vennont Yankee supports u e BWR Owners Group in this endeavor. The staff has concluded that,"... the existing neutron flux monitoring instrumentation is acceptable for interim operation until implementation of a sully qualified indication system is complete."
Notwithstanding the outcome of the appeal, Vermont Yankee considers its existing
~
neutron flux indication system adequate. This position is band on the determination that the
. existing LPRM system at VY is eiwironmentally qualFied. This upgrade has been accomplished thro igh the implementation of several design modiftcations. Vermont Yankee does not intend 1
to - iform ar modifications to this system at this time.
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6 United States Nuclear Regulatory Commission January 17,1991 r
Attention: Document Control Desk Page 2 i
Cooling Water Temperature to ESF Components Section 3.0 (b) of the SER states the following:
"The licensee has provided instrumentation which conforms to the Category 2 criteria of R.G.1.97 except for the range. The licensee did not provide a justification for this deviation. Therefore, the licensee should provide the range recommended by R.G.1.97."
For clarification, Vermont Yankee took exception to the range and in the Environmental Qualification (E.Q.) requirements recommended in R.G.1.97. Both exceptions were identified in our September 1,1989 submittal update. Furthermore, the Technical Evaluation Report (TER) provided to you by EG&G (Idaho), dated May 1990, noted the exception taken regarding E.Q.
for this parameter. In section 3.3.9 of that report the reviewer determined that using the instrumentation asa,ciated with this parameter, as a backup variabb, precluded the necessity of imposing 10CFR50.49 requirements on it. This issue is brought to your attention for clarification only. Vermont Yankee intends no further action regarding E.Q..
The range discrepancy can be readily justified. The temperature indication range identified in our September 1989 submittal update is 0 to 150 F. The 150 F hmit'was not based on the upper range of the temperature monit ring system. It was used as the upper limit because the design temperati.: of the piping being monitored is 150 F.
In reality, the temperature loops associated vith this parameter are calibrated to monitor a range of 0 to 600 F. The inputs are provided to an L&N multipoint recorder, TR 'A115 (previously identified as TRS10-131). This range encompasses the R.C.1.97 requirements of 0 to 200 F.
Therefore, it is Vermont Yankee's position that the existing temperature loop is acceptable as is.
Vermont Yankee intends no further action regarding the range of these variables.
We trust the information provided above adequately explains VY's position concerning the subjed R. G.1.9" variables; however,if you have any questions or desire addit!onal information, please do not hesRate to contact us.
Very truly yours, Vermont Yankee Nuclear Power Corporation h
ht4 4 h Vt&
Le nard A. Tremblay, Jr.
7 Ser8cr Licensing Engineer USNRC Regional Administrator, Region I cc:
USNRC Resident Inspector, VYNPS USNRC Project Manager, VYNPS 4
.