ML20112E114

Forwards LRS Consultants Rept on Team Visit 1-84 for 1984 & 840316 Transmittal Ltr to R Snelling,Governor,State of VT

ML20112E114
Person / Time
Site:	Vermont Yankee
Issue date:	03/16/1984
From:	Conway W VERMONT YANKEE NUCLEAR POWER CORP.
To:	Raymond W NRC
Shared Package
ML20112E108	List: ML20112E114 ML20112E122 ML20112E129 ML20112E140 ML20112E182
References
FOIA-84-342 NUDOCS 8501150031
Download: ML20112E114 (4)

Text

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T Ylil{MONT Y ANI;EE NUCLEAll POWElt COllPORATION

. RD 5. Box 169, Ferry Road, Bratt!choro. VT 05301 V .

March 16,1984 WwAM F. CONWAY PT.ESIDENT AND CHIEF EXECUTsvE of FACER

. (802) 257 5271 Mr. William J. Raymond Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 176 Vernon, VT 05354

Dear Mr. Raymond:

Attached is a copy of the LRS Consultants' report on Team Visit

1. 1-84 for 1984, and a copy of the transmittal letter to Governor Richard Snelling.

Please call if you have any questions concerning this report.

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Nuc1EAn POWER COIWORATION RD 5. Box 169. Ferry Road Brattleboro. VT oS301

- March 16,1984 WituAu F. CoNWAY Pet $10ENT AND CHiU ExlCutivt OffaCER (402;257 S273 .

The Honorable Richard A. Snelling Governor of Vermont  :.

Pavilion Office Building --

Montpelier, VT 05602

Dear Governor Snelling:

Enclosed is the LRS Consultants' re' port on Team Visit #1-84 which took place on February 8 through 10, 1984, at the Vernon plant site and our corporate office.

We are in agreement with the Team that activities associated with the replacement of recirculation system piping are progressing posi-tively. To date, specifications have been developed addressing ma -

terial acquisition and proposals are being sought from organizations Careful deemed qualified to perform the actual installation effort.

consideration is being given to the selection of a Project Manager who

'can efficiently and professionally interact with all entities involved in this significant project.. The prudent selection of an engineering orgar.ization is, of course, paramount and the past experience level of such an organization must clearly be considered as part of the Weevalua-are tion process necessary in attaining a final determination.

! closely following activities at those plants currently in the pipe re-j placement process and agree with the Teams' recommendation that we con- f 2

tinue to do so.

f k We are fully aware of the necessity to complete environmentalEng f qualification by the end of the 1984 outage.

ment of long-lead time equipment has been undertaken to assure this schedule .is met.

Our intention is to complete activities during the' upcomi.ng outage but should that not be possible, we do have until March 31,1985, to complete the task subject to NRC approval of sche-dular extension requests for individual components which we are pre-pared to make if need be.

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VEltMONT YANKEE NUCLEAll POWElt COltl'OltNIION The Honorable Richard A. Snelling March 16,1984 Page 2 .

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As of March 13,1984, of the'14 requi[ed design changes,'3 have been submitted, the engineering hE liEnn~complewd 65 an additional 4, the selected outside engineering contractor will submit the engineer-ing for 5 by March 16 and the remaining 2, which are relatively minor in scope, will be completed by April 1. To summarize, the necessary design changes are nearing completion and are scheduled for submittal to Vermont Yankee by April 1.

All long-lead time items have been identified and ordered with shipping dates identified as being no later than June 1.

We are presently aware of all desig'n changes, their scope and due dates. The licensing history of Vermont Yankee's environmental qualification of electrical equipment program has been documented as recommended and includes the rationale for the determination to qual-ify rather than mitigate.

The team design process recomended by LRS has, in' fact, been em-ployed to ensure that when design packages arrive at the plant they can be reviewed without impacting quality. A full time plant engi-neer was assigned to coordinate the on-site effort. In addition, we are arranging to obtain personnel to assist in developing the neces-l sary installation and test procedures associated with design change l completion.

You will recall an item in the previous report focused on Train- r I

l ing Department personnel loss. My cover letter associated with that r'eport identified our program in seeking adequate replacements. This c report notes the fact that suitable additions have been made. d

? A post-refuel ou'tage critique is conducted each year and from that session, a report is developed and issued which includes lessons-

[ learned and suggestions for future radiation exposure reductions.

4 The most recent ALARA report was published in late February.

t I I A thorough review of the February 2,1984 event is continuing.

P We are carefully considering the reduction of exit points from the ra- f l

diation control area (RCA) as a means of further centrolling the egress l of potentially contaminated material. We will apprise Commissioner i

Saudek's office on completion of our internal review and evaluation results. .

[

The Operations Department is presently struct; red in two sections under the overall direction of the Operations Supervisor. One section reports directly to the Assistant Operations Supercisor who directs '

the operations and shift activities. The remainir; section reports to e

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VERMONT YANKEE NUCI.liait PowE tt Colt PottNI son The Honorable Richard A. Snelling March 16,1984 Page 3 the Operations Engineer who handles engineering support, shift as-signed engineers, procedure development / review and assessment of in-dustry operational events. We are satisfied our current structure is most acceptable and functioning well.

We have reviewed our operational philosophy with respect to the h S(30 per'iodically manipulating controls on operating panels and are g

convinced it to be an appropriate one. The job description developed B

for this position clearly delineates responsibilities for the safe and proper operation of all plant equipment on his appointed shift. In

[ fulfilling this responsibility, .we have concluded the present method of performance to be quite acceptable. Shift _ Super. visors are clearly aware of their comnand responsibility which includes the " stand back,"

overall vie ~w of plant conditions during transient as well as normal operating conditions.

We recognize the Team recommendation relative to maintaining ACR0 proficiency and will be reviewing methods 'to fore adequately address it.

We are aware that the NRC is considering a rule requiring Shift Supervisors to have engineering degrees and although we are consid-ering methods of coping with this possibility,' we have yet to conclude

.a final disposition. We do continue.to support the contention that

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long-term, experienced, well-trained personnel can and do operate our i facility in a safe and effective manner and that the imposition of a requirement for an engineering degree is a less than adequate substi-tute with respect to the former. In reality, all operating crews are staffed with degreed personnel who are capable of providing engineer-ing advice to the shift supervisor as necessary. While these indivi-a duals are not licensed to operate the facility, they are disciplined

q. in performing the technical advisory function.

'l: i If you have further questions, concerning the report, please con-( tact me.

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4 Sincerely, L

h~ William F. Conway WFC/jh enclosure e

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