ML20244E590
| ML20244E590 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/16/1989 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| BVY-89-52, NUDOCS 8906210001 | |
| Download: ML20244E590 (4) | |
Text
,
VERMONT YANKEE
- NUCLEAR POWER CORPO' RATION BVY.89-52 L.
.e Ferry Road, Brattieboro, VT 05301-7002 hl[
ENGINEERING OFFICE 580 MAIN STREET BOLTON, MA 01740 j-
<$08) 779 6711 June 16, 1989 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Document Control Desk
References:
a)
License No. DPR-28:(Docket No. 50-2.71) b)~
Letter, USNRC to VYNPC, NVY 89-108, dated 5/18/89 c)
Letter, VYNPC to USNRC, BVY 89-48, dated 6/2/89
Dear Sir:
Subject:
Response to Inspection Report'89-04, Notice of Violation During a routine safety inspection of Vermont Yankee's fire protection program conducted on March. 20-23, 1989, a violation of NRC requirements was identified. Our response to this violation is provided below.
VIOLATION Technical Specification 3.13.D requires that the carbon dioxida fire suppression.(CO ) systems located in-the cable vault end 2
diesel fire pump day tank room shall be operable whenever equip-ment in the area protected by the systems is required-to be operable. The technical specifications require a continuous fire watch if the CO2 system in the cable vault is-inoperable and an hoeris fire watch if the CO2 dystem in the fire pump day tank room is inoperable.
In a letter to the NRC dated January 31, 1977, the licensee.
stated that the carbon dioxide systems at Vermont Yankee were designed to meet the requirements of the 1977 National Fire Protection Association (NFPA) St.andard ?.2.-
NFPA~ Standard 12 Section 1-7.3 specifies that the installed carbon dioxide systems shall be tested and the tests performed shall-be adequate to determine that the system has been properly installed and will function as intended. The CO2 systems are designed to' achieve a 50 percent concentration.
In the cable vault, this concentration must be maintained for ten minutes.
Contrary'to the above, as of April 21, 1939, the CO2 systems in the cable vault and in the diesel. fire pump' day tank room had not j
been demonstrated to be operable, in that-no tests had been.per-
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formed of their capability to reach and maintain design con-
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centrations of CO, and the appropriate fire watches had not been j
2 implemented.
1 This is a Severity Level IV Violation (Supplement 1) j i
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'8906210001 890616 i
i PDR ADOCK 05000271
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VERMONT YANKEE NUCLEAR POWER CORPORATION U.S'. Nuclear Regulatory Commission June 16, 1989 Page 2 i
RESPONSE
Following a careful review of the 1977 National Fire Protection Association (NFPA) Standard 12, we have found nothing to indicate that a Full Discharge Test is required. Based on that review, we disagree with the conclusion reached in the Inspection Report and, based on the following information, respectfully l
request that this Notice of Violation be withdrawn.
The Inspection Report specifies Section 1-7.3 of (1977t NFPA Standard 12 as the applicable section.
It reads as follows:
"1-7.3 Approval of Installations. The completed system shal* be tested by qualified personnel to meet the approval of the authority having jurisdic-tion. These tests shall be adequate to determine that the system has been properly installed and will function as intended. Only listed or approved equipment and devices shall be used in the systems."
l We believe the initial testing, periodic inspection and maintenance described in Section 1-11.1 of NFPA Standard 12 is applicable since initial l
testing of the CO2 system is at issue. Section 1-11.1 reads as follows:
)
"1-11.1 A manufacturer's test and maintenance procedure shall be provided to the owner for testing and maintenance of the system.
The procedure shall provide for the initial testing of the equipment as well as for periodic inspection and maintenance."
Both of these sections are further explained in the Appendix A Explanatory.
Of particular note is Section A-1-11.1 (Testing of Systems) of the (1977) NFPA Standard 12 which does not specifically require.a full discharge test.
Item 15 reads as follows:
"15. Test A.
Puff test, minimum for acceptance.
B.
Full dis irge test as required by owner.
C.
Full dist
'ge test recommended when tardrostatic test is required.'
In recent conversations with the NRC staff, we were told that the NRC is the " authority having jurisdiction" and that the NRC requires a full discharge l
test of the CO2 systems in accordance with NFPA Standard 12, thus we are in violation of Section 1.7-3 of the Standard. We are unable ^o find a reference to support the staff position. We agree that had the NRC desired at that time of-installation to fulfill into the role of " authority having jurisdiction,"
then certainly this role would have been fulfilled by NRC.
However, at the time of acceptance testing, Vermont Yankee had no indication that the hLc intended to assume this role, thus we assumed the role of " authority having jurisdiction."
VERMONT YANKEE NUCLEAR POWER CORPORATlGN U.S*. Nuclear Regulatory Commission June 16, 1989 Page 3 Section A-1-11.1 or NFPA Standard 12 states that a puff test is the minimum for acceptance; which Vermont Yankee has performed.
Further, the Standard indi-cates that a full discharge test is at the discretion of the owner. Since Vermont Yankee is the owner and has not requirec a full discharge test, this section was clearly met.
We have also reviewed later versions of NFPA Standard 12 and agree that, if the system were installed today, a full discharge test would be required. The difference in the 1977 code versus later code revisions, however, clearly demonstrates a change in requirements which further supports our contention that a full discharge test was not required to meet the 1977 code. Vermont Yankee has not been notified by the NRC of any changes to regulatory requirements that would necessitate our compliance to any version of the NFPA standards other than the 1977 NFPA Standard.
Although Vermont Yankee disagrees with the staff position regarding the interpretation of NFPA Standard 12, we have been responsive to NRC concerns.
At significant cost to Vermont Yankee, we daclared the subject CO2 systems in-operable and established the appropriate fire watches. The Diesel Fire Pump Room CO2 system full discharge test has been satisfactorily completed and the system was declared operable. A continuous fire watch is in place in the cable vault although the system remains functional.
Complete compensatory measures were previously submitted in Vermont Yankee's Special 30-Day Report (Reference c).
The specific issue involved is whether Vermont Yankee has complied with the testing required for the applicable Fire Suppression Systems in accordance with the 1977 NFPA Standard 12.
We firmly believe that we have met this standard, and that the existing systems installed at Vermont Yankee are fully operable.
Based on the above discussion, we cannot agree with your conclusions that we are not in full compliance with the applicable requirements.
Thus, we respectfully request that the subject Notice of Violation be withdrawn. Additionally, pending NRC approval, Vermont Yankee wishes to declare the Cable Vault C02 system operable. We will, however, continue to be responsive to NRC's concerns regarding the Cable Vault CO2 system. Therefore, after dec aring the subject CO2 system operable, Vermont Yankee will establish a once per hour fire watch.
Further, Vermont Yankee will conduct a full dischar s test of the Cable Vault C02 system as soon as practicable but no later than the end or the next sche-duled outage.
i We are aware that the issue of operability of CO2 systems with respect to full discharge testing standards is a recent Region I concern with other licen-sees as well as Vermont Yankee. At your convenience, we would be willing to meet with' appropriate Region I personnel on this issue to discuss our specific situation.
VERMONT YANKEE NUCLEAR POWER CORPORATION
' U. S* Nuclear Regulatory Commission June 16, 1989 Page 4 We trust that the above information is sufficient to address the issue; however, should you have any questions or desire additional information, please feel free to contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION h
WarrenP.furphy Vice President and Manager of Operations
/dm cc:
USNRC Regional Administrator, Region I USNRC Resident Inspector, VYNPS