ML20128Q406
| ML20128Q406 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 05/31/1985 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| FVY-85-51, NUDOCS 8506040185 | |
| Download: ML20128Q406 (3) | |
Text
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y a.x VERMONT YANKEE NUCLEAR POWER CORPORATION
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FVY 85-51 RD 5, Box 169, Ferry Road. Brattleboro, VT 05301
,,,,,,o ENGINEERING OFFICE g
1671 WORCESTER ROAD -
FRAMINGHAM, MASSACHUSETTS 01701 T ELEPHONE 6174724100 May 31, 1985
-U.S. Nuclear Regulatory Commission Washington,' O.C. 20555 Attention:
Office of Nuclear Reactor Regulation Mr. Harold R. Denton, Director
References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, VYNPC to USNRC, FW 83-30, dated 4/19/83 c)
Letter, USNRC to VYNPC, dated 6/12/84 d)
Letter, VYNPC to USNRC, FVY.84-105, dated 8/22/84 e)
Letter, USNRC to VYNPC, dated 9/28/84 4
Dear Sir:
Subject:
NUREG 0737, Supplement I - Implementation of
- Upgraded Emergency Operating Procedures (EOP's) e By letter dated April 19,.1983 [ Reference b)], we provided you with our schedule for implementation of Upgraded Emergency Operating Procedures (EOP's).
This schedule was confirmed by order [ Reference c)]. Due to simulator unavail-ability, an extension in our implementation date for E0P's was requested until June 1, 1985 [ Reference d)], which resulted in a modification to.the original order [ Reference a)].
- In the interim, all licensed operators at Vermont Yankee. received classroom and sittulator training on the new EOP's, consistent with a June-1,1985 imple-
. mentation date._ During this period, due to concerns of operator acceptance and familiarity with these new procedures,' Vermont Yankee's licensed operators were queried as to their readiness to implement these procedures on-June 1.
The operators had expressed confidence in their ability to implement that portion of the.new E0P's which responded to design basis events addressed by our existing procedures.-'A certain uneasiness was expressed by operators regarding that por-tion lof the new EOP's which addressed postulated scenarios exceeding design basis events.for which no procedural guidance currently exists.
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VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission May 31, 1985 Page 2 n
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' Vermont Yankee's management evaluated these concerns expressed by our operators and concluded that the new E0P's should be implemented on schedule
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based upon the following:
o operators had been trained on the new EOP's; o
operator acceptance and familiarity with those portions of the new E0P's duplicating existing procedural guidance was high; o
the new E0P's guidance for scenarios in excess of design basis events enhanced the safe operation of the Vermont Yankee plant; and l
o while operator acceptance and familiarity with those portions of the new EOP's dealing with scenarios in excess of design basis events was lower than that for procedures which had been used since plani commercial operation, existing classroom and simulator training plus operator statements that they could adequately perform the procedures gave assurance that implementation would enhance the safe operation of the Vermont Yankee plant.
Within the past week, as the implementation date for the new E0P's draws closer, concerns have been expressed by licensed operators on-shift that addi-tional training (particularly simulator training) ts desired for full operator acceptance and new E0P familiarity prior to implementation.
Vermont Yankee believes these concerns should be investigated and resolved prior to implementation of the new E0P's.
Accordingly,ye request that the June 1, 1985 implementation date contained in your order of September 28, 1984-(Reference e)] be modified to permit Vermont Yankee to continue to use our
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. existing procedures for a period no later than our return to power from the' upcoming 1985-86 outage (shutdown is scheduled for September 14, 1985 and return to power is scheduled for late April 1986).
In this period, Vermont Yankee will take the following affirmative actions:
1)
Interview and query each licensed operator to determine if training provided.to date is adequate to permit that operator to undertake his licensed duties utilizing the new E0P's.
2)
'If deficiencies are identified in step 1),.above, formulate a training plan to remedy such identified deficiencies either on an individual or en mass basis. Such training may be additional classroom familiariza-tion with procedure format and/or content, additional familiarization and dry run. time at a simulator; or a combination of both.
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VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission May 31, 1985 Page 3 C
1 The requested schedule extension represents a pessimistic scenario, wherein a substantial number of licensed personnel are determined to require additional familiarization and dry runs of the new E0P's at a simulator facility, and is intended to preclude any further deferral of EOP implementation. Vermont Yankee intends to implement the new E0P's at the earliest date possible, consistent with adequate opera *.or acceptance and familiarity, to enhance safe operation of the Vermont Yankee plant.
We trust that this revised schedule is acceptable, and request your rapid review to modify the existing Confirmatory Order date.
If you should have any questions in the matter, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION Warren P. Murphy Vice President an Manager of Opera ions e.
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