ML20081L156
| ML20081L156 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/21/1991 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BVY-91-60, NUDOCS 9107020414 | |
| Download: ML20081L156 (5) | |
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VERMONT YANKEE NUCLEAR POWER CORPORATION b
Ferry Road, Brattleboro, vT 05301-7002
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i' %, /9 4. !11 BVY 91-60 June 21,1991 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention:
Document Control Desk
References:
a)
License No. DPR-28 (Docket No. 50 271) b)
Letter, USNRC to VYNPC, Systematic Assessment of Licensee Performance (SALP) Report No. 50-271/89-99
Dear Sir:
Subject:
Vermont Yankes Rosponse to SALP Report 50-271/89 99 Vermont Yankee is pleased with the Nuclear Regulatory Commission's evaluation of our performance during the SALP assessment period which ended on March 16, 1991.
We are particularly pleased with your assessment of superior performance in the areas of Plant Operations, Maintenance and Surveillance, Engheering and Technical Support, Emergency Preparedness and Safety Assessment and Quality Verification.
Although we also agree with your assessment of good performance in the areas of Security and Radiological Controls, we believe we have made and will continue to make significant improvements in both areas.
The following paragraphs describe current inliiatives that are intended to address the noted weaknesses and to bring to your attention areas in which we hope to make further improvements during the subsequent SALP assessment period.
Summary of Results Section Ill.A Plant Operations o
Page 4, Paragraph 3 Subsequent to the Reactor Trip of March 21, 1990, all licensed operators have been provided additional training in the area of the Mechanical Hydraulic Control (MHC) system.
The training was completed in 1990 Cycle 4 Operator training and included both classroom and simulator instruction. This training is also scheduled to be part of the 1991 Cycle 4 Operator Requal Program.
h 9107020414 910621 PDR ADOCK 0500o271
/
VERMONT YANKEE NUCLE AR POWER CORPOR ATION U.S. Nuclear Regulatory Commission June 21,1991 Page 2 o
Page 5, Paragraph 5 With regard to the Licensed Operator Requal Program, Vermont Yankee is confident that the corrective actions implemented following the lderitification of LOR weaknesses have been effective and that ongoing corrective actions will further strongthen the program.
As requested in your Requalification Program Evaluation Report, dated April 19, 1991 this issue will be addressed in separate correspondence.
Section ill B.1 Radiological Controls Vermont Yankee has undertaken several management directed overviews of Radiological Control areas. One review was conducted by a task force which was assemb!ed and trained under Vermont Yankee's Commitment to Excellence Program (CEP).
This program utilizes proven techniques for identifying and resolving specific problem areas. A sec8nd CEP task team has completed work on Contamination Control enhancements.
/ermont Yankee also contracted the assistance of an outside consultant to review cur Radiation Protection (RP) practices and to provide management a summary of weak areas and proposed recommendations.
Based on the coqsultant's input, several improvement initiatives have been completed and others are in progress.
o Page 7, Paragraph 3 An additional CEP task which Vermont Yankee is actively pursuing is to provide adequate staffing of qualiflad RP technicians with commercial nuclear power experience during outages.
Vermont Yankee is currently working with suppliers of RP technicians to develop the appropriate work agreements to ensure a proper staffing of trained technicians is available.
Vermont Yankee intends to restructure our contract requirements for RP technicians such that additional provisions will be in place to attract a higher quality of cnntract technician and ensure technician retention through outage completion.
In addition, Vermont Yankee is developing a contract with provisions for year round badgin,g and training of up to 20 technicians with a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> res aonse time.
It is expected this will enhance RP coverage dur ng unanticipated plant shutdowns.
o Page 9, Paragraph 1 To resolve the turbine building roof vent issue, Vermont Yankee has recently submitted a commitment to the NRC to address this important issue. The submittal, dated May 15, 1991, was written in response to an outstanding item described in Inspection Report 91-09 concerning the turbine building roof vent radiation monitoring
VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Rogulatory Commission June 21,1991 Page 3 systems.
Vermont Yankee has committed to install a hardware change that will either eliminate the potential release path, reroute it via a monitored path, or provide !ocal monitoring. These changes will be completed no later than the end of the refueling outage in the fall of 1993.
o Page 9, Paragraph 2 Vermont Yankee believes that Yankee Atomic Electric Company Audit Report 90-09 titled Radwaste/ Process Control Program and dated March 30,1991 examined The Process Control Program, ALARA and i
Contamination Control Practices. Additionally, we intend to continue to audit these areas during subsequent SALP periods. We further 1
intend to substantially improve the contamination control practices associated with the loading of high integrity container with dry resin by the implementation of a
Resin De-waterinr' system.
Implementation of this system should greatly enhance the contamination control process.
Section Ill.C.
Maintenance and Surveillance o
Page 10, Paragraph 3 As a result of the identified weakness with regard to the operability of the "A" Spent Fuel Cooling Pump and its related EO impact, Varmont Yankee has established t lrectives, issued by the Senior i
Vice President, Operations, as controlled documents.
In addition, the Operations Department has clarified its interpretation of Equipment Operability when " white" tags are in use, and no longer uses such tags on equipment intended to be considered operable.
The ongoing implementation of a computer based Maintenance Planning and Control System (MPAC) is expected to continue' to assure the high quality of our maintenance activities. A computer-based surveillance schedul!ng program is already in the process of replacing our earlier manual system.
Section Ill.E.
Security o
Page 13, Paragraph 5 In the area of perimeter intrusion detection, Vermont Yankee has employed a consultant to independently assess and provide recommended improvements to our intrusion detection system.
Vermont Yankee intends to implement appropriate improvements which result from this assessment.
i VERMONT YANKEE NUCLE AR POWER CORPOR ATION U.S. Nuclear Regulatory Commission June 21,1991 Page 4 o
Page 14, Paragraph 2 Vermont Yankee is pleased wi les that are already underway with the construction of house.
The design of the new gate house was the resuu
.. view of tra proposed design by another Vermont Yankee CEP lask Force. This tat;k force provided input into design and functionality of the new gato house design.
o Page 14, Paragraph 5 Vermont Yankee has recently made some organizational changes within the security area to provide an additional full time position to assist the Security Supervisor.
In addition, we have made the Access Program Administrator a full t! e function.
We believe 7
these steps will enhance the access cont,ol area greatly and we will continue to monitor this area and make additional changes, as necessary.
Additional security system improvements worth noting have been transmitted in earlier correspondence as Safeguards information.
Section Ill.G Safety Assessment and Quality Verification o
Page 19, Paragraph 3 The Vermont Yankee Corrective Action Program continues to undergo substantial programmatic improvements.
Corrective Action training is currently being furnished to all supervisors and selected employees.
As noted earlier, the Commitment to Excellence P.ogram (CEP) has become an integral part of our problem-solving techniques.
We expect to continue this program and eventually have all employees l
trained in this CEP Process.
Vermont Yankee intends to continue to exchange technical specialists with other utilities.
o Page 20, Paragraph 5 Vermont Yankee considers employee concerns a very serious matter and provides this area with a high level of management attention.
We have taken steps to enhance our Employee improvement Suggestion Program to provide an additional vehicle by which an employee mcy identify any perceived or actual safety concern.
VERMONT YANKEE NUCLE AR POWER CORPOR ATION U.S. Nuclear Regulatory Commission June 21,1991 Page 5 We intend to evalua'e the effectiveness of our rnethods for dealing with employee concerns during the subsequent SALP period.
Vermont Yankee a apreciates the opportunity to comment on improvement initiatives which may adc ress some of the areas identified in the SALP report.
We trust that our comments will be helpful.
In the event you may have any questions or desire any additional information, please do not hesitate to contact us.
Very truly yours, Vermont Y nkoe Nuclear Power Corporation
/va-ier' l'"
Warren P. Murp 7
Senior Vice P osi ont, Op r tio.n -
cc:
USNRC Regional Administrator, Region i USNRC Resident inspector, VYNPS USNRC Project Manager, VYNPS
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