ML20132F153
| ML20132F153 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/16/1985 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM NUDOCS 8507180291 | |
| Download: ML20132F153 (5) | |
See also: IR 05000271/1984011
Text
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JUL 161985
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Docket No. 50-271
s
Vermont Yankee Nuclear Power Corporation
ATTN: Mr. Warren P. Murphy
Vice President and Manager
(
of Operations
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RD 5, Box 169
Ferry Road
Brattleboro, Vermont 05301
Gentlemen:
Subject:
50-271/84-11
On August 17, 1984, you were informed of the results of a special
inspection which reviewed your post accident sampling and monitoring
capabilities relative to the specifications of NUREG-0737 (NRC In-
spection 50-271/84-11).
In response to an apparent violation identified
relative to placement of Containment High-Range Radiation Monitors (Item
II.F.13 of NUREG-0737), you took exception to the finding in letters
dated September 24, 1984 and January 9,1985, and submitted a written
justification for the installation in a letter dated January 25, 1985.
Your justification has been evaluated by the Office of Nuclear Reactor
Regulation - Radiological Assessment Branch.
Their Safety Evaluation
Report is attached.
The report concludes that the locations for the
Containment High-Range Radiation Monitors are an unacceptable alterna-
tive to the position of NUREG-0737, II.F.13.
Consequently, you are required to respond within thirty days of the date
of this letter, to the Notice of Violation relative to this matter as
originally referenced in our letter dated August 17, 1984.
It is
requested that your response be made and affirmed in accordance with the
requirements of 10 CFR 50.54(f), " Conditions of License", to enable this
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office to determine if your license should be modified relative to this
matter.
Your cooperation with us in this matter is appreciated.
Sincerely,
trigtmi 314ood By:
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Division of Radiation <fety
and Safeguards
Attachment: As Stated
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OFFICI AL RECORD COPY
05071003?1 0S0716
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ADOCK 0D000271
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Mr. R. W. Capstick, Licensing Engineer
Mr. W. F. Conway, President and Chief Executive Officer
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Mr. J. P. Pelletier, Plant Manager
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Mr. Donald Hunter, Vice President
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Mr. Cort Richardson, Vermont Public
Interest Research Group, Inc.
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ATTACHMENT 1
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RADIOLOGICAL ASSESSMENT BRANCH
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SAFETY EVALUATION REPORT
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REGARDING THE
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LOCATION OF CONTAINMENT HIGH RANGE RADIATION MONITORS
A.I
VERMONT YANKEE NUCLEAR POWER STATION
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By submittal dated January 25, 1985, the Vermont Yankee Nuclear Power
Corporation, in response to NRC Region I concerns, provided a technical
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justification for the location of the Vermont Yankee in-contaiment high-
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range radiation monitors (CHRRM) for review by the NRC.
Following dis-
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cussions with Region I personnel, the Radiological Assessment Branch has
conducted an evaluation of the licensee's rationale for the location of
the Vermont Yankee CHRRMs.
The criteria used for this review included the
guidance of Section 2.1.8.b of NUREG-0578, "TMI-2 Lessons Learned Task Force
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Status Report and Short-Term Recommendations", Item !!.F.1 of NUREG-0660,
"NRC Action Plan Developed as a Result of the TM!-2 Accident," Item !!.F.(3)
of NUREG-0737, " Clarification of TMI Action Plan Requirements," Item !!.F.1(3),
,
Regulatory Guide 1.97, " Instrumentation for Light Water Cooled Nuclear Power
Plants to Access Plant and Environs Conditions During and [ollowing an
Accident", and Chapter 12 of the Standard Review Plan.
The review also
considered information from NSAC 17 (Nuclear Safety Analysis Center), " Design
for Postaccident Radiological Conditions' (December,1980).
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Vermont Yankee's two CHRRN's hcVe the capability to measure between
IR/hr to 10 R/hr and are located at apprcximately midplane of containment
about 12 feet apart on each side of the equipment hatch.
From this
position the renitors view approximatley 25'4 of the containment volume.
The space monitored within contairrent is essentially the same for both
instrements. The monitors, as currently installed, have the range and response
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requirements of Table II.F.1-3, NUREG-0737. However, it is the staff
position that a 12 foot separation is rot sufficient to provide indeperdent
measurement, and they do not view a large fraction of the containment volume
nor do they view different spaces within the containcent.
These requirements
of flVREG-0737 were specifically highlighted as " changes to previcus requirements
and guioance" and are considered essential to the staff because they miniinize
the potential for a single event to disable both monitors and minimize the
potential for false readings due to local irregularities. The monitors do
meet the other requirements of NUREG-0737, II.F.1(3).
lle recomeno that the locations for thc CHFPM's, as described by the
licensee, be considered an uracct.ptable alternative to our positions in
liUREG-0737,II.F.1(3).
Either the high-range monitors should be moved to
widely separated locations in accordance with our position in hukE6-0737,
II.F.1(3),ortheItcenseeshculdproposeequivalent,compensatingmeasures
for our consideration.
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For the particular matter of location, the current RAB review considered
the following guidelines and recommendations:
(1)
the CHRRM's should be redundant and physically separated per
NUREG-0578, 0660, 0737, and RG 1.g7; and monitor widely separated
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spaces within containment, per NUREG 0737;
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(2)
CHRRM's should be widely separated and view a large fraction of
containment volume per NUREG-0737, and RG 1.97;
(3)
the purpose of CHRRM's is detection of significant releases,
release assessment, long-term surveillance, emergency plan
actuation per RG 1.97;
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(4)
the objectives of post-accident radiation monitoring, as outlined
in NSAC 17, which include indication of: .
(a) " fission product barrier breach.
(b)
system or area where radioactivity has been released,
(c)
release size.
(d)
trends and sudden changes in accident conditions,
(e)
effects of control measures,
(f)
potential radiological release data.
(5)
locations and functions are consistent with environmental and
radiation qualifications and conditions as indicated by NUREG-0578
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and 0737, RG 1.97, and outlined in NSAC 17..
(6)
the CHRRM's are intended to measure containment radiation levels
primarily from airborne radioactivity.
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