ML20198S421
| ML20198S421 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/02/1986 |
| From: | Murphy W, Murrphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| FVY-86-52, GL-83-28, NUDOCS 8606100418 | |
| Download: ML20198S421 (3) | |
Text
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J VERMONT YANKEE NUCLEAR POWER CORPORATION FVY 86-52 RD 5, Box 169, Ferry Road, Brattleboro, VT 05301
,,,Lyyg ENGINEERING OFFICE 1671 WORCESTER ROAD FR AMINGHAM, MASSACHUSETTS 01701 TEL EPHONE 617472-6100 June 2, 1986 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attn:
Office of Nuclear Reactor Regulation Mr. Daniel R. Muller, Director BWR Project Directorate No. 2 Division of Licensing References a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to All Operating Reactors, Generic Letter 83-23, NVY 83-164, dated 7/8/83 c)
Letter, VYNPC to USNRC, FVY 83-117, dated 11/7/83 d)
Letter, VYNPC to USNRC, FVY 84-25, dated 3/23/84 e)
Letter, VYNPC to USNRC, FVY 84-73, dated 6/26/84 f)
Letter, VYNPC to USNRC, FVY 84-116, dated 11/25/84 g)
Letter, VYNPC to USNRC, FVY 84-120, dated 10/5/84 h)
Letter, USNRC to VYNPC, NVY 85-73, dated 4/23/85 i)
Letter, VYNPC to USNRC, FVY 85-63, dated 7/3/85 j)
Letter, USNRC to VYNPC, NVY 85-158, dated 7/26/85
Dear Sir:
Subject:
Status of Vermont Yankeee Equipment Classification Upgrade Program (Generic Letter 83-28)
The purpose of this letter is to provide an updated status of Vermont Yankee's Equipment Classification Upgrade Program, established in response to Generic Letter 83-28 [ Reference b)], specifically with regard to Items 2.1.1
" Reactor Trip System Components - Equipment Classification" and 2.2.1 " Program for Equipment Classification". Vermont Yankee has previously provided infor-mation concerning our efforts to implement certain enhancements to our Equipment Classification Program in References c) through g).
This program was also reviewed during an inspection conducted by the Region between June 3-12, 1985
[ Reference j)).
In May of 1985, our enhancement program was initiated with the establish-ment of a Project Team. Since that time, we have completed a Pilot Program in which a Project Manual and a Safety Classification Procedure were developed and utilized to determine the safety classification of all Reactor Trip Function (RTF) components. The RTF components were selected to be utilized as the trial system for the Pilot Program to conform to Reference d) commitments.
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7 VERMONT YANKEE NUCLEAft POWF.R CORPORATION ha U.S. Nuclear Regulhtory Commission
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June 2, 1986 1
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e Wd h e now completed a thorough review of our accomplishments pertinent to the Pilot Program and based upon our evaluation we are submitting this letter to revise our Project Plan from that initially stated in Reference g).
The first item in Reference g) indicated our desire to formulate a proce-dure which would provide a structured approach for making a determination of component safety classification. Such a procedure was developed for use in the Pilo' Program and is now being revised to address the findings of our evaluation of the Pilot Program. This procedure has proved to be very valuable and we y
fully' intend to insure the consistent determination of the safety classification of all plant components.
Additionally, based on our evaluation of the Pilot Frogram, we have found the implementation of items 2 and 3 of Reference g), essentially tho crestion of a pre-engineered listing to the component level of all safety related equip-
, ment, is not resource effective and is not warranted at this time. We have determined that the development of the procedure and not the creation of this single listing is the proper enhancement that should be made to our Equipment Classification Program.
It appears that the only real gain in continuing the program as stated in Reference g) would be to have a " pre-engineered" listing of the safety classification of all safety-related components. With the incor-poration of our newly developed procedure into our Equipment Classification Program, we are confident that the safety classification of all plant components can be readily and consistently determined without the need of a
" pre-engineered" Master Equipment List (MEL).
Based upon our findings from the Pilot Program, we intend to replace our
- Enhancement Program as stated in Reference g) with the following plan:
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1.
A formal Safety Classification Manual and procedure will be developed.
This manual will explain the workings of the Equipment Classification t
Program, and provide explanations of the classification of traditional 4
" grey area" components.
2.
Controls will be established such that-the new Safety Classification Manual I
i arid Procedure are utilized whenever the safety class of a component must be determined.
"k 3.
. Utilization of the Safety Classification Manual and Procedure will be
'[,
' ncorporated into the appropriate training programs.
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'4.
Appendix C*to the Yankee Operational Quality Assurance Program m "
%(YOQAP-1-A), which is one of the documents currently utilized to determine cafety classification, will be expanded to include a more explicit break-down of safety classification of plant systems, subsystems, and structures based upon safety function.
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VERMONT YANKEE NUCLEAR POwntt COIWOltATION U.S. Nuclear Regulatory Commission June 2, 1986 Page 3 5.
A review of our safety class drawings (flow diagrams and one line electri-cal drawings) will be performed to ensure that all safety class boundaries are clearly identified.
6.
The format for a Master Equipment List (MEL) will be created. Such a system will have the capability of storing pertinent data relating to plant components, including safety classifications, as such data is developed.
7.
The'results of the safety class evaluations for all RTF components which have already been prepared under the Pilot Program work, will be the first entries onto the MEL.
We intend to maintain our estimated date of December 1986 for the implemen-tation of the program outlined above. Our efforts, however, will continue past December as the MEL will be developed as an ongoing engineering activity con-current with, and integrated within, other established plant activities. As a resource effective measure, controls will be established to ensure that the results of safety class evaluations prepared under the new program are entered into the MEL to avoid repetetive evaluations.
In the interim, existing plant specific lists and controls remain in place.
We trust that this information is satisfactory; however, should you have any questions, please do not hesitate to contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION d w ---.
Warren P. Murph Vice President an Manager of Operations jdm
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