View source for FVY-82-108, Comments on Systematic Assessment of Licensee Performance Rept,Discussed at 820908 Meeting.Rept Fair Appraisal of Activities for Rept Period

{{Adams
| number = ML20065G339
| issue date = 09/28/1982
| title = Comments on Systematic Assessment of Licensee Performance Rept,Discussed at 820908 Meeting.Rept Fair Appraisal of Activities for Rept Period
| author name = Murphy W
| author affiliation = VERMONT YANKEE NUCLEAR POWER CORP.
| addressee name = Starostecki R
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION I)
| docket = 05000271
| license number = 
| contact person = 
| document report number = FVY-82-108, NUDOCS 8210040113
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 2
}}

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VERMONT YANKEE NUCLEAR POWER CORPORATION 2.C.2.1 FVY 82-108
      . . -                                RD 5 Box 169, Ferry Roao, Orattleboro, VT 05301               ,,pty,g y
g s-ENGINEERING OFFICE 1871 WORCESTER ROAD
* FRAMINGHAM, MASSACHUSETTS 01701
* TELEPHONE 617 472-8100 September 28, 1982 U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, PA         19406 Attention:         Richard W. Starostecki, SALP Board Chairman Director, Division of Project and Resident Programs

==References:==
(a) License No. DPR-28 (Docket No. 50-271)
(b) USNRC Letter dated August 26, 1982 (SALP Report)

==Dear Sir:==

==Subject:==
SALP Report Coments We appreciated the opportunity to meet with you on September 8,1982, to discuss the most recent SALP report on Vermont Yankee. We feel that the report is a fair appraisal of our activities for the report period, however, there are a few areas in the report that require clarification and/or correction.
Section ,I_ ; Introduction Item 1.3.1 - Licensee Activities
;                   The reference to the conditions contributing to the October 26, 1981 scram i           1s inaccurate. The scram occurred as a direct result of a specific management decision to attempt to gather dynamic data on the Mechanical Pressure Regulator just prior to a scheduled shutdown. The MPR was not being returned to service following repairs as this item indicates.
Section IV. - Performance Analysis Item 1 - Plant Operations We disagree with the statement that our interpretation of the Technical Specifications relative to the SLC boron concentration was " incorrect." Section 3.4.0 of the Technical Specifica': ions excludes the boron concentration require-l           ments as a Limiting Condition for Operation. We do believe, however, that the requirements should be a part of the specification and on July 22, 1982, we sub-mitted a proposed change to the NRC to have it included.
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l 821004o113 820928 DR ADDCK 05000273 PDR

VEHMONT YANKEE NUCLEAR POWER COHPOHATION U.S. Nuclear Regulatory Commission September 28, 1982 Page 2 We take exception to the statement that our interpretation of the Tech Specs relative to containment isolation was " incorrect and nonconservative." We believe that our action of isolating the line with a downstream manual valve was appropriate and adequate to maintain Pr9ary Containment. We will supply the NRC with a letter describing the basis for ..iis conclusion.
In reference to the statement      our " failure to resolve turbine control system problems," it should be rec gnized that we have taken extensive measures over the last several years to idertify and correct the problems in this area as they occur. In addition, we have greatly expanded the scope of preventative maintenance on these systems. Although these efforts have not completely elimi-nated the possibility of problems, we feel that we have made substantial progress in identifying and implementing the proper action to stake the system more reliable.
Based on the above comments to item 1 of Section IV, we feel that there are no adverse trends developing that may be indicative of weakness in our manage-ment controls.
Item 5 - Fire Protection / Housekeeping The manhours devoted to the functio.n of Fire Protection Coordinator have remained substantially constant over the last several years. There is no inten-l               tion to reduce the manhours or the scope of the coordination function. The internal changes that have been made or proposed relate only to a delegation of certain of the duties to other personnel under the cognizance of the Fire Protection Coordinator.
If you have any questions relative to the above coments, please do not hesitate to contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION de Warren P.
Yf urphy   V Vice President and Manager of Operations WPM /dm
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