ML20209J022
| ML20209J022 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/24/1987 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.3, TASK-2.K.3.03, TASK-2.K.3.13, TASK-2.K.3.22, TASK-TM FVY-87-44, GL-83-02, GL-83-2, IEB-80-11, NUDOCS 8705040183 | |
| Download: ML20209J022 (6) | |
Text
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VERMONT YANKEE NUCLEAR POWER CORPORATION bYY SM RD 5, Box 169. Ferry Road, Brattleboro VT 05301
,,,LV TO N
ENGINZERING OFFICE y
l 1671 WORCESTER ROAD l
FRAMINGHAM, MASSACHUSETTS 01701 l
TELEPHONE 617-672-6100 l
April 24, 1987
{
U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 190406 Attn:
Regional Administrator
References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to VYNPC, Systematic Appraisal of Licensee Performance, dated 3/12/87
Dear Sir:
Subject:
Vermont Yankee Response to Systematic Appraisal of Licensee Performance This letter is submitted in response to the March 12, 1987 SALP Board Report of Vermont Yankee's performance during the recent assessment (Reference b)]. Although many of the comments provided within this letter were articulated at the March 27, 1987 meeting between the NRC and Vermont Yankee, we would like to take the opportunity afforded by your letter to formally document our response.
In general, we are pleased with the results of the Board's evaluation. We are particularly happy with your recognition of the major organizational and program improvements made in the area of plant security.
Not only do we view the SALP Report to be a fair and comprehensive eva-luation, but we consider it a diagnostic tool which allows Vermont Yankee mana-gement to take action on perceived weaknesses before they develop into operational deficiencies. While we agree with the majority of the conclusions, we do offer the comments identified in Appendix A.
As we stated at the Vernon SALP meeting, we continue to pursue oppor-tunities to strengthen our overall operation and therefore, strive to achieve Category 1 ratings in all functional areas.
Very truly yours, 87050 0 ff 271 W P. Hur hy DR PDR Vice President a Manager of Operat
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b
APPENDIX A IV.
PERFORMANCE ANALYSIS
REFERENCE:
A.
Plant Operation, Analysis - page 9, paragraph 1
" Completion of a Senior Operator's Certification for the incumbent Operations Supervisor remained an outstanding qualification item for this assessment period". Licensee management should assure that the present plans to obtain this certification by mid-1987 are completed."
Comments The Operations Supervisor, although not presently licensed, previously held an SRO license at the Vermont Yankee plant (1972-1974). Vermont Yankee j
Procedure AP 0720 specifies that anyone who has held an SRO license at the plant l
l is considered SRO certified regardless of license status. As such, the Operations Supervisor is considered SRO certified.
The Operations Supervisor is presently undergoing licensing training in preparation for a July license examination.
It should be noted that prior to returning to Vermont Yankee, the Operations Supervisor held a valid SRO license at a similar BWR facility.
REFERENCE:
B.
Radiological Controls, Analysis - page 12, paragraph 2 l
"The Licensee's inability to resolve the long-standing ALARA issue con-
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tinues to be an NRC concern. The item remains unresolved long after deficien-cies were brought to the Licensee's attention during previous SALPs and inspections dating back to 1983. During the current period, ALARA implementing procedures remain in draft form. The Licensee created a new "ALARA Coordinator" position, but failed to fill the position."
Comments During the 1985 recirc pipe replacement / refueling outage, a Vermont Yankee employee was temporarily assigned the responsibility of ensuring that all work expected to involve significant radiation exposure was evaluated to ensure con-sistency with ALARA principals.
During this time, the individual tasked with the ALARA program was assisted by no fewer than ten full-time contractor support personnel.
In July of 1986, as outage work diminished, ALARA staffing was decreased to a level of two (one full-time and one part-time).
We contend that we have been effective in limiting personnel radiation exposures over the years but agree that we should formalize our practices in policies and additional procedures. We filled the ALARA Coordinator position and issued a Radiation Protection Policy in December 1986, and in March 1987 issued the ALARA procedures in final approved form. We are confident that these actions and continued diligence to minimizing radiation exposures will result in a very effective ALARA program.
a
REFERENCE:
B.
Radiological Controls, Analysis, paragraphs 2 and 3 "However, the lack of active and timely plant staff review, understanding, and evaluation of the contractor's work packages and dose-saving techniques,
.also contributed to the increased expenditure."
" Contractor activities associated with the control rod drive insert /
withdrawal line hanger modifications did not benefit from historical radiation dose rate data. As a result, increasing radiation fields were experienced as 4
the plant restarted which resulted in unexpected additional exposure and which, similar to the RPRP cutage, made the original dose estimates inaccurate."
Comments We believe that your statements concerning the control rod drive modifica-tion do not accurately portray the circumstances of the work activity. Dose rate projections were in fact made based on historic information, however, an unexpected change in plant conditions resulted in'somewhat higher radiation.
levels than had been predicted. The details of this job have subsequently been discussed with the NRC inspector who originally reviewed this job and we believe has resulted in a better understanding of the events and circumstances related to these activities.
REFERENCE:
B.
Radiological Controls, Analysis - page 12, paragraph 3
" Preplanning for significant radiological work activities for the upcoming 1987 outage and for the planned spent fuel pool expansion project continues to be fragmented without clear ALARA goals, objectives and procedures."
Comments During the assessment period (October 1985 - December 1986), the scope of the 1987 outage work in general and fuel pool work specifically was not defined to the point that would allow meaningful ALARA review. Beginning in January 1987, the ALARA Coordinator began formally reviewing outage work packages.
Particular attention has been given to and will continue to be given to any work in the spent fuel pool. The ALARA Coordinator has been in close contact with all departments involved with the fuel pool rerack to ensure the work scope is
. fully understood and that the radiological dose is minimized.
REFERENCE:
C.
Maintenance and Modification, Analysis - page 16, paragraph 3 "The fact that the Licensee was unaware of these vendor suggested product change appears as examples of deficiencies in the program for the control of vendor information."
Comments Vermont Yankee and the industry as a whole has been involved in directed i
efforts to better assimilate vendor information into plant maintenance and operating practices. Consistent with this objective, Vermont Yankee implemented I
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the industry sanctioned V-TIP program. V-TIP procedurally required all incoming vendor technical information to undergo plant review. We recognize the need for additional improvement in this area and are therefore continuing to work toward meaningful program enhancement.
REFERENCE:
C.
Maintenance and Modification, Analysis, page 16, paragraph 4 "A second example concerns the failure of post-installation tests to iden-tify three failed IRM detectors and the cross connection between two IRM chan-nels following replacement of all six detectors during the outage."
Comments We remain unaware of any post maintenance test techniques that would have enabled us to identify the type of problem associated with failed IRM detectors prior to reactor criticality.
We, therefore, request that this example not be cited as indicative of inadequate post maintenance testing.
Aside from this, we agree the examples mentioned are indicative of post-maintenance shortcomings.
It should, however, be recognized that the generally smooth startup and trouble free operation following the extensive work performed during the 1985/86 outage is indicative of sound maintenance and post-maintenance test practices.
Test procedure revisions have been undertaken to better allow the iden-tification of post maintenance deficiencies in the cases cited.
REFERENCE:
C.
Maintenance and Modifications, Analysis - page 18 paragraph 1 "The resurvey validated the basic adequacy of the 1980 work, but identified j
four additional walls in the heating and ventilation corridor that had not been identified previously in the IEB 80-11 response."
Comments We believe that the walls were not identified in the 1980 Bulletin response because the turbine building which is classified "non-seismic" was not con-sidered within the scope of the original Bulletin. This was specifically stated in the Vermont Yankee letter to the NRC dated September 19, 1986. The walls were identified and are now being addressed solely as a result of the conser-vatism inherent in the re-survey initiated by Vermont Yankee.
Response to Board Recommendations Resolve the Masonry Wall and RHR Inspection issues expeditiously, o
Resolution of both issues is well under way.
RHR inspection work was started April 20th and is scheduled for completion in May 1987.
Modification relating to the Turbine Building Block Walls is expected to be completed by October 1987.
Review program for control of vendor information and change as necessary to assure that vendor information is current.
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o We will review our existing program in an effort to increase itsseffec-tiveness. We continue to participate in industry efforts for improvement in this area.
Review the status of actions taken in response to IE Bulletins and Notices to identify areas requiring additional work or attention.
o We are awaiting additional information from the Commission allowing'us to focus our review efforts. Once the scope has been more clearly defined, we will begin a timely reassessment of the identified documents.
Following completion, an audit will be performed to validate the effectiveness.
REFERENCE:
D.
Surveillance, Analysis - page 20, paragraph 2 "One procedural matter still open from the last SALP period concerns the need to add Type B and C leak rate test results in the total containment leakage determination."
Comments While total leakage is informally calculated by comparison of A test results with the sum of B and C results, we are unable to identify any specific 10CFR50 Appendix J requirements which requires adding Type B & C identified leakage to the Type A test results.
We understand that the Appendix J requirements are presently undergoing Commission review to, among other things, provide clarification of this point.
Once the revised regulation is issued, procedure modification will be made as necessary.
REFERENCE:
E.
Emergency Planning, Analysis - page 22, paragraph 4 "There were, however, recurring weaknesses noted in the operations of the Technical Support Center (TSC) including: 1) lack of coordinated actions between the Center (TSC) and TSC personnel; 2) failure of TSC personnel to aggressively follow and coordinate plant activities; and 3) excessive noise levels in the TSC."
Comments Vermont Yankee is pursuing actions to correct the causes of the noted weaknesses in TSC performance.
The facility is being enlarged, organized, and j
rearranged to improve efficiency and effectiveness. Team drills will be con-ducted, involving the TSC staff and the facilities with which the TSC inter-faces, to improve the performance of specific TSC functions as well as coordination among facilities. Applicable implementing procedures will be i
revised, if required, to provide assurance of consistently effective performance by the TSC staff.
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Additional steps taken to improve the Vermont Yankee emergency preparedness program include selection of an experienced employee with excellent qualifica-tions to serve as the full time Emergency Planning Coordinator. He will provide the point of contact for all emergency preparedness matters. This position has been upgraded and the reporting responsibility has been changed from the Plant Health Physics Supervisor to the Assistant to the President, who is highly qualified in emergency planning.
REFERENCE:
Licensing Activities, Analysis - page 41, paragraph 3
" Additional management attention is needed to assure timely closure of unre-solved items from Generic Letter 83-02 pertaining to Technical Specifications requirements for NUREG 0737 items."
Comments The Generic Letter 83-02 identified 13 items requiring Technical Specification modification. Of these, we consider 9 to be resolved. Of the items that remain unresolved (I.A.1.3; II.K.3.3; II.K.3.13; and II.K.3.22),
Vermont Yankee has submitted position statements on each.
In an effort to expe-dite resolution, we will be contacting the VY Project Manager in NRR to ensure that the necessary information has been provided to allow further evaluation of our requests.
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