ML20207C949
| ML20207C949 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 12/19/1986 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | Muller D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 FVY-86-122, NUDOCS 8612300287 | |
| Download: ML20207C949 (5) | |
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VERMONT YANKEE NUCLEAR POWER CORPORATION FVY 86-122 RD 5 Box 169, Ferry Road, Brattleboro, VT 05301 p
ENGINEERING OFFICE 1671 WORCESTER ROAD FRAMINGHAM, MASSACHUSETTS 01701 TELEPHONE 61T-672-8100 December 19, 1986 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attn:
Office of Nuclear Reactor Regulation Daniel R. Muller, Director BWR Project Directorate #2 Division of BWR Licensing
References:
a)
License No. DFR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, NVY 85-187, dated 8/29/85 c)
Letter, VYNPC to USNRC, FVY 86-30, dated 3/31/86 d)
Letter, VYNPC to USNRC, FVY 86-81, dated 9/2/86 e)
Letter, USNRC to VYNPC, NVY 86-218, dated 10/24/86
Dear Sir:
Subject:
Request to Modify Confirmatory Order and Provide Schedular Extension for Emergency Response Capability (Supplement 1 to NUREG 0737) Requirements This purpose of this letter is to request modification of the order con-firming Vermont Yankee schedular commitments on Emergency Response Capability (Supplement I to NUREG 0737) for Safety Parameter Display System (SPDS) opera-bility and Regulatory Guide 1.97 implementation. Additionally, we are indi-cating our revised schedule for certain specific commitments associated with the Vermont Yankee Detailed Control Room Design Review (DCRDR).
Previously, Vermont Yankee established with the Nuclear Regulatory Commission (NRC) an integrated plan and schedule for addressing the issues detailed in NUREG 0737, Supplement 1, " Requirements for Emergency Response Capability".
This overall integrated approach resulted in mutually acceptable program plans for the Emergency Operating Procedures (EOPs), the DCRDR, the Regulatory Guide 1.97 assessment, a new Emergency Response Facility (ERF), and the SPDS. By letter, dated August 29, 1985 [ Reference b)], the staff transmitted its most recent license modifying order confirming Vermont Yankee NUREG 0737, Supplement 1, commitments. This order additionally stated that,
" Extension of time for completing these items may be granted by the Director, Division of Licensing, for good cause shown."
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VERMONT YANKEE NUCLEAR POWER CORPORATION 3t U.S; Nuclear Regulatory Commission December 19,~1986=
Page 2 In accordance with Vermont Yankee's integrated NUREG 0737, Supplement 1, plan and effort, commitments associated with EOPs, DCRDR, and the ERF have been completed (except that TSC data acquisition requirements will nst be fully func-tional until SPDS completion). The two remaining requirements to be completed involve SPDS operability (scheduled for completion prior to startup for Cycle 14), and Regulatory Guide 1.97 implementation (scheduled for completion prior to startup for Cycle 13). Additionally, although Vermont Yankee's confirmatory order requirements for DCRDR are completed, our letter of March 31, 1986
[ Reference c)], provided a proposed schedule for implementing all identified DCRDR Human Engineering Discrepancy (HED) modifications during the next two suc-cessive. outages (i.e., prior to Cycle 13 and 14 startup).
For the reasons and causes discussed below, Vermont Yankee requests schedular extension for commit-ments associhted with NUREG 0737, Supplement 1, pertaining to SPDS operability, and Regulatory Guide 1.97 implementation; and provides our revised schedule for DCRDR modifications.
In mid-198b, Vermont Yankee undertook an extensive effort in response to NRC initiated Mark I concerns following the Chernobyl accident regarding the capability of containments such as Vermont Yankee's to withstand severe acci-dents.
In order to properly assess the performance of Vermont Yankee's design and its ability to mitigate severe accidents, Vermont Yankee undertook a study which incorporated recent advances in analytical techniques and accounted for the significant design features specific to Vermont Yankee wnich affect the
. plant's ability to respond to a severe accident. On September 2, 1986 (Reference d)], Vermont Yankee submitted the result of this study to the NRC.
During a subsequent September 11, 1986 meeting at the NRC's headquarters in Bethesda, Maryland, it was noted that Vermont Yankee's efforts constituted a sample case for NRC's generic containment requirements activities. Consistent with that purpose, the staff stated its intention to review and comment on the Vermont Yankee study and to' provide questions in late October 1986 [ Reference e)]. While agreeing to provide timely responses to the comments and questions, Vermont Yankee stated that continuation of the level of effort associated with the containment safety initiative might conflict with certain other scheduled commitments to the NRC.
Subsequently, the staff advised Vermont Yankee to identify such cases to NRC Project Management for discussion. Accordingly, Vermont Yankee has reviewed its schedular commitments to NRC for the next several refueling outages and determined that certain commit.nents associated with NUREG 0737, Supplement 1, requirements will require schedular extension.
At the time Vermont Yankee established its commitments for NUREG 0737, Supplement 1, requirements, the extensive effort associated with the containment safety initiative was unanticipated. As a result of the resources expended by Vermont Yankee associated with this effort to date and those anticipated in the future, Vermont Yankee has concluded that the relative safety importance o# the planned containment safety efforts warrant a modification to the remaining NUREG
VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission December 19, 1986 Page 3 0737, Supplement 1, commitments involving SPDS, Regulatory Guide 1.97 and DCRDR.
Specifically, these resources included approximately 1,000 manhours in the PRA disciplines, 1,000 manhours in the System Engineering discipline, and 400 manhours each in the I&C and Electrical Engineering disciplines to perform the initial study and support the follow-up questions and meetings.
Resource estimates for the planned containment safety efforts include the following:
knengineeringscopingstudywhichexaminesthefeasibilityofimproving 1.
the reliability of the valves located in the Reactor Building associated with the alternate spray path has been estimated to require 400 manhours in the Electrical and Systems Engineering disciplines.
2.
Analysis and calculations are being performed to prove the viability of the diesel fire pump to provide water via the service water and RHR containment spray header for core cooling and drywell spray.
This analysis is esti-mated to require 600 manhours in the Systems Engineering disciplines and is scheduled for completion in mid-1987.
3.
An engineering scoping study has been initiated to evaluate the feasibility of providag a hardened, reliable vent path from the containment wetwell to the plant vent stack. Approximately 900 manhours in the Systems, Electrical, and I&C Engineering disciplines as well as 200 manhours from the Nuclear Analysis discipline will be required.
This study is scheduled for completion in the spring of 1987.
The basis for each schedular extension request is discussed below.
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' REGULATORY GUIDE 1.97 Vermont Yankee's present commitment regarding the Regulatory Guide 1.97 requirement to implement (install or upgrade) post-accident monitoring instru-mentation is prior to startup for Cycle 13 (approximately summer 1987). During the 1986 refueling outage, Vermont Yankee completed all Regulatory Guide 1.97 installation / upgrades associated with our Environmental Qualification Program.
The previously planned work scope for the 1987 refueling outage included comple-tion of all remaining Regulatory Guide 1.97 installation / upgrades.
Recently we have determined that the LPRM power supplies should have been included in the work scope for Regulatory Guide 1.97 modifications. However, due to the dif-ficulty of including this recently determined upgrade in the 1987 outage work scope in view of the containment resource commitments previously discussed and based on the fact that, with the exception of this one item, all Regulatory Guide 1.97 installation / upgrades will be completed in accordance with the
5 VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission December 19,-1986 Page 4 existing schedular commitment; we request that the subject order be modified to extend the Reguistory Guide 1.97 schedular commitment for this specific item one additional outage cycle (prior to startup for Cycle 14, approximately winter 1988/89).
DCRDR As stated in the subject confirmatory order, Vermont Yankee has completed the NUREG 0737, Supplement 1, commitment relating to DCRDR requirements. By I
letter, dated March 31, 1986 [ Reference c)], Vermont Yankee provided a proposed l
-schedule for implementing all DCRDR HED modifications, assuming no " unforeseen difficulties in the design, procurement and installation efforts associated with each of the respective modifications," during the next two successive outages (i.e., prior to Cycle 13 and 14 startup).
It is our firm belief that the HED modifications proposed from the DCRDR effort are of relatively minor operational significance and generally relate to modifications necessary to conform to specific human factors criteria.
This has been substantiated by the results of our Control Room Dynamic Evaluation per-formed in the fall of this year. Due to the higher cafety significance paced on the Containment Safety Study, a finite resource base to support Vermont Yankee's continuing Mark I Containment effort (resource commitments previously discussed], and completion of all DCRDR tasks (including Control Room Dynamic Evaluation and Expanded Task Analyses for all Vermont Yankee Specific E0P's), we have identified a one cycle schedular extension to the commitment for DCRDR HED modifications contained in Reference c).
Accordingly, our present intention is to complete these modifications during the two refueling outages prior to startup for Cycles 14 and 15, subject to no unforeseen difficulties in the design, procurement and installation efforts associated with each of the respective modifications. We will provide advanced written notification of items, if any, that are later determined to require extension.
SPDS Vermont Yankee is presently committed to having an SPDS fully operational prior to startup for Cycle 14.
As our design efforts and concurrent installa-tion scheduling activities progress, we have identified significant resource shortages in concurrently developing containment initiative tasks, and SPDS design and Installation and Test Procedure (I&T) packages.
Additionally, due to further developed design details, we can now identify significant amounts of SPDS work which can be completed during plant operation. We therefore request that the schedular commitment for SPDS be modified to state that SPDS operabi-lity and operator training will be completed prior to the end of Cycle 14.
To
r:
VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission December 19, 1986 Page 5 alleviate this resource burden and parmit more levelized resource allocation, we propose to defer commencement of SPDS installation activities until following startup for Cycle 13 (approximately Winter 1987/88) instead of our existing plan to commence with the Cycle 13 outage.
We propose a part-cycle deferral of SPDS as follows. We will proceed with SPDS development and design activities to the extent achievable with our existing resources.
Installation of non-outage driven modifiestions will com-mence and co.itinue during Cycle 13.
Outage driven modifications will be por-formed in the outage prior to Cycle 14 (approximately February-March 1989). We then anticipate having SPDS functional at startup for Cycle 14 but necessary startup testing, system verification and validation, and operator training would continue into Cycle 14 prior to the SPDS being decla' red fully operational. Full SPDS operability would be achieved prior to completion of Cycle 14.
Vermont Yankee believes that the foregoing provides good cause justifica-tion for each of the requested schedular extensions. Therefore, based on the above, we request your approval of the proposed revised schedules and modifica-tion of the order confirming Vermont Yankee schedular commitments on Emergency Response Operability (Supplement 1 to NUREG 0737) for SPDS and Regulatory Guide 1.97 and approval of schedular extension for certain commitments associated with the Vermont Yankee DCRDR.
Should you have any questions or require additional information concerning this request, please contact us.
Very truly yours, I
gg Warren P. Murphy Vice President and Manager of Operations
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