ML20209G153

Discusses Util Setpoint Control Program Implementation Schedule,As Committed to in Licensee 990514 Response to Notice of Violation,Insp Rept 50-271/97-10

ML20209G153
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	07/12/1999
From:	Leach D VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-271-97-10, BVY-99-78, NUDOCS 9907190054
Download: ML20209G153 (3)

Text

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, VERMONT YANKEE y

NUCLEAR POWER CORPORATION l

185 Old Ferry Road, Brattleboro, VT 05301-7002 (802) 257-5271 July 12,1999 BVY 99-78 United States Nuclear Regulatory Commission A'ITN: Document Control Desk Washington,DC 20555

References:

(a)

Letter, VYNPC to USNRC, " Reply to a Notice of Violation - NRC Inspection Report 50-271/97-10," BVY 98-73, dated May 14,1998

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

Vermont Yankee Setpoint Control Program Implementation Schedule In Reference (a), Vermont Yankee (VY) committed to address the issue of instrument uncertainty in an Instrument Setpoint Program. This program is a significant enhancement to our current licensing basis and has been prioritized based upon the most important instrumentation systems. The purpose of this letter is to provide updated information on the status of our Instrument Setpoint Program. The initial commitment was to complete the program by December 31,1999. We have made significant progress and will achieve completion on the following schedule. The development of the VY Setpoint Control Program is complete.

During 1997 and 1998, we completed and implemented 97 out of 226 planned calculations. The remaining calculations will be completed by August 31,2000 and fully implemented prior to startup from the 2001 refueling outage.

The Setpoint Control Program (SCP) was formulated in accordance with the NRC-approved guidance provided in Instrumentation Society Of America Standard ISA 67.04, Methodolocies for Determination of Setnoints for Nuclear Safety Related Instrumentation. The instrumentation systems selected are those used to suppoit:

' VY Environmental Qualification (EQ) Program, In-service Test Program, and Regulatory Guide e

1.97 Program.

Safety Analysis (reload, transient, safety limi Minimum Critical Power Ratio, containment).

t Technical Specifications.

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Technical Requirements Manual.

f Surveillance extensions (Allowed Outage Time / Surveillance Test Interval).

Plant operations (critical parameters, performance).

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To assist us in timely completion of this large and complex undertaking, we have engaged the sertices of indust.y experts who have significant experience in the development and implementation of similar enhancement programs.

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BVY 99-78 / Page 2 of 2 New and revised setpoint and uncertainty' analyses are being developed in accordance with the latest industry and NRC approved methods. Hese methods were not available when VY was licensed and are not

- part of the current plant design and licensing bases. Applying them is beyond the requirements of the current licensing basis. He new setpoints identified by the analyses are not intended to certify our existing licensing basis setpoints. It is expected they will be di!Terent in many cases. Hese differences do not necessarily create a conflict with the current design or licensing bases. Hey will be evaluated in the aggregate upon completion of the analyses. Herefore, the remaining analysis results, until they are implemented through changes to the affected instrumentation setpoints and procedures according to the schedule described above, do not constitute a challenge to, nor invalidate the current design and licensing bases.-

If our ongoing design basis recovery efforts, i.e. Design Basis Documents and FSAR Verification, identi'?

any additional instruments which meet the criteria for inclusion in the program, analyses for tin.m instruments will be prioritized in accordance with their significance.. Implementation of the results of any additional analyses will typically occur within six months of completion of the analyses.

i Ifyou have any questions regarding this submittal, please contact Mr. Gautam Sen at (802) 258-4111.

Sincerely, VERMONT YANKEE NUCLEAR POWER CORPORATION 1

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y-t V' e Pres" ent, Engineering j

cc:

USNRC Region 1 Administrator USNRC Resident inspector-VYNPS i

USNRC Project Manager-VYNPS i

Vermont Department of Public Service m

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SUMMARY

OF VERMONT YANKEE COMMITMENTS BVY NO.: 99-78 The following table identifies commitments made la this document by Vermont Yankee. Any other actions discussed in the submittal represent intended or planned actions by Vermont Yankee. They are described to the NRC for the NRC's information and are not regulatory commitments. Please notify the Licensing Manager of any questions regarding this document or any associated commitments.

COMMITMENT COMMITTED DATE OR " OUTAGE" Complete remaining instrument setpoint analyses August 31,2000 Implement new and revised instrument setpoint analyses by 2001 RFO end of 2001 refueling outage.

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