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Forwards SER Re Util 850125 Justification for Placement of Containment High Range Radiation Monitors (NUREG-0737,Item II.F.1),in Response to Insp Rept 50-271/84-11.Monitor Locations Unacceptable
	ML20132F153
Person / Time
Site:	Vermont Yankee
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)
	v • d • e

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JUL 161985

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Docket No. 50-271

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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

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requirements of 10 CFR 50.54(f), " Conditions of License", to enable this

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

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PDH ADOCK 0D000271

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Mr. R. W. Capstick, Licensing Engineer

Mr. W. F. Conway, President and Chief Executive Officer '

Mr. J. P. Pelletier, Plant Manager ,

Mr. Donald Hunter, Vice President t

Mr. Cort Richardson, Vermont Public ;

Interest Research Group, Inc. .

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RADIOLOGICAL ASSESSMENT BRANCH

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SAFETY EVALUATION REPORT

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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- i

range radiation monitors (CHRRM) for review by the NRC. Following dis- l

l 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

l 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),

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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

! 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;

(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; ,

(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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ML20132F153

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