ML20078L779
| ML20078L779 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 02/03/1995 |
| From: | Pelletier J VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BVY-95-17, GL-89-13, NUDOCS 9502130125 | |
| Download: ML20078L779 (5) | |
Text
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VERMONT YANKEE NDCLEAR POWER CORPORATION Ferry Road, Brattleboro, VT 05301-7002
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ENGINEERING OFFICE 580 MAIN STREET BOLTON, M A 01740
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February 3,1995 BVY 95-17 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
References:
(a)
License No. DPR-28 (Docket No. 50-271)
(b)
Letter, USNRC to All Holders of Operating Licenses or Construction Permits for Nuclear Power Plants, NVY 89-156, Generic Letter 89-13, dated 7/18/89 (c)
Letter, VYNPC to USNRC, BVY 90-007, Response to Generic Letter 89-13, dated January 22,1990 (d)
NRC Information Notice 94-03, Deficiencies identified During Service Water Operational Performance inspections, dated January 11,1994 (e)
Letter, VYNPC to USNRC, BVY 94-37, Review of Generic Letter 89-13 Implementation, Vermont Yankee Service Water Self Assessment, dated March 29,1994
Subject:
Updated Status of Vermont Yankee Prograrn to Address Generic Letter 89-13 By letter dated March 29,1994 [ Reference (e)) Vermont Yankee provided a description of weaknesses identified in our program to implement actions recommended by Generic Letter 89-13 [ Reference (b)]. These weaknesses were identified during a Self Assessment of our Service Water System. To address these weaknesses, a dedicated project team was assembled to provide timely resolution of the issues identified in the Self Assessment and to ensure a robust program was developed to fully address the concerns of Generic Letter 89-13 and Information Notice 94-03. to this letter provides an updated status of our program to address the actions recommended in Generic Letter 89-13, and supersedes our original response [ Reference (c)). In addressing the issues identified in the Self Assessment, significant engineering resources were expended to reconstitute the design basis t.nd supporting design information for the Service Water and Alternate Cooling Systems.
Based on this effort, formal maintenance and testing procedures have been prepared i
to ensure these systems will continue to be operated and maintained within their i
desian bases.
95o213o125 95o2o3 I.
PDR ADOCK oS00o271
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VERMONT YANKEE NUCLEAR POWER CORPORATION United States Nuclear Regulatory Commission February 3,1995 Page 2 We trust that the information contained in this letter is satisfactory; however, should you have any questions or require additional lnformation, please do not hesitate to contact us.
Sincerely, VTYANKEE NUCLEAR POWER CORP.
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James P. Pelletier Vice President, Engineering JPP/gmv Attachment cc:
USNRC Region i Administrator USNRC Resident inspector - VYNPS j' 5h
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USNRC Project Manager - VYNPS S:'
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($8 Then personally appeared before me, James P. Pelletier, who, being duly sworn, did state that he is Vice l') resident -
Engineering, of Vermont Yankee Nuclear Power Corporation, that he is duly authorized to execute and file the foregoing document 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.
As 0.ML Sally A. S4ndstrum, Notary Public My Commission expires February 10,1995 l
ATTACHMENT 1
SUMMARY
OF NRC RECOMMENDED ACTION I:
For open cycle Service Water systems, implement and maintain an ongoing program of surveillance and control techniques to significantly reduce the incidence of flow blockage events caused by biofouling.
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Response
Vermont Yankee performe river water and substrate sampling annually to detect the presence of both Asir. tic clams and zebra mussels. If sampling detects their presence, system chlonnation or an equally effective treatment program will be instituted.
Routine testing and inspection of Service Water components are conducted to ensure the system is maintained in an acceptable condition.
Planned replacement of small diameter piping with materials not susceptible to microbiological corrosion has been completed which has reduced the incidence of flow blockage. Flushing of instrument tubing is also performed to reduce the incidence of flow blockage.
SUMMARY
OF NRC RECOMMENDED ACTION 11:
Establish an initial and periodic retest program to verify that safety-related heat exchangers will meet their design / functional requirements.
Response
While these components have been tested in the past, formal detailed acceptance criteria were not available. Vermont Yankee has developed draft testing procedures to monitor the performance of applicable safety-related heat exchangers, including appropriate acceptance criteria.
Previous heat exchanger performance data has been compared to the new acceptance criteria, and acceptable performance has been demonstrated. Based on this review, we conclude that the heat exchangers have been properly maintained.
It is expected that formal procedures to monitor the applicable heat exchangers will be issued prior to the scheduled 1995 Refueling Outage for use during and following this outage.
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SUMMARY
OF NRC RECOMMENDED ACTION lil:
Establish a routine inspection and maintenance program which will ensure that the performance of safety related systems serviced by the SW system will not degrade due to corrosion, erosion, protective coating failure, silting and biofouling in the SW system. Maintenance activities should include at least the removal of excessive accumulations of biofouling agents, corrosion products and silt and the repair of defective coatings and corroded parts which may affect safety system performance.
Response
Vermont Yankee has established preventative maintenance programs for the SW system; however, detailed acceptance criteria were not previously available.
Formal written inspection and acceptance criteria to address all critical attributes have now been developed for each component type and are expected to be incorporated into a formal procedure prior to the scheduled 1995 Refueling Outage. Although these acceptance criteria were not previously applied, overall system performance has demonstrated that components have been properly maintained.
SUMMAR'f OF NRC RECOMMENDED ACTION IV:
Confirm that the as-built SW system meets its design requirements and will perform its intended function in accordance with the applicable licensing basis of the plant; including confirmation of its ability to perform its required safety function in the event of a single active failure.
Response
Vermont Yankee has reconfirmed the ability of the Service Water and Alternate Cooling systems to meet their design requirements. Recent actions include a complete system walkdown to ensure plant drawings are accurate, and a complete single failure analysis for the SW system. An updated computerized flow model has been developed, and a design basis reconstitution effort has been completed. This information is currently being documented in a Design Basis Document which should receive final approval early in 1995.
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SUMMARY
OF NRC RECOMMENDED ACTION V:
Establish and implement maintenance practices, operating procedures and effective training programs which will ensure that safety-related equipment cooled by the SW system will perform its intended function and that plant staff responsible for this equipment will reduce the incidence of human errors that frequently occur in operation, repair, and maintenance of SW systems.
Response
4 Development of formal procedures for testing of SW system components along with formal procedures providing inspection and acceptance criteria for SW components will strengthen the Vermont Yankee programs to ensure the system i
will operate as intended. As noted above, these enhancements are expected to be in place prior to the 1995 Refueling Outage scheduled for March 1995.
Existing training programs specifically address methods to reduce human errors.
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