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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217N3901999-10-25025 October 1999 Advises That Info Provided in & Affidavit Re Holtec Position Paper WS-115,rev 1,repts HI-87113, Rev 0,HI-87114,rev 0,HI-87102 Rev 0 & HI-87112,rev 0,marked Proprietary,Will Be Withheld from Public Disclosure ML20217L8591999-10-21021 October 1999 Discusses 990921 Request for Approval to Perform Alternative Testing as Part of Vermont Yankee Nuclear Power Station IST Program.Informs That Submittal Reviewed Against ASME Code Section XI Requirements & Forwards Safety Evaluation ML20217M1181999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept from Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Requal Pass Dates ML20217D9711999-10-13013 October 1999 Responds to Request That Information Titled Addl Info Re Cycle Specific SLMCPR for Vermont Yankee Cycle 21 Be Withheld from Public Disclosure.Determined Info to Be Proprietary & Will Be Withheld from Public Disclosure ML20217F1261999-10-12012 October 1999 Forwards Update to Previously Submitted RELAP5 Analytical Assumptions for App R,Re RAI of 961104 BVY-99-130, Provides Clarification of Method for Determining MSIV Maximum & Minimum Pathway at Vermont Yankee Nuclear Power Station1999-10-0808 October 1999 Provides Clarification of Method for Determining MSIV Maximum & Minimum Pathway at Vermont Yankee Nuclear Power Station ML20217C1501999-10-0707 October 1999 Forwards Insp Rept 50-271/99-11 on 990809-27.No Violations Noted.Insp Focused on Effectiveness of Engineering Functions in Providing for Safe Operation of Plant BVY-99-128, Submits Listed Addl Info in Support of 990414 Request for Clarification to SER Confirming Adequacy of Space Cooling for HPCI & RCIC Sys,Re Item II.K.3.24 of NUREG-0737.Copy of NEDE-24955,encl1999-10-0606 October 1999 Submits Listed Addl Info in Support of 990414 Request for Clarification to SER Confirming Adequacy of Space Cooling for HPCI & RCIC Sys,Re Item II.K.3.24 of NUREG-0737.Copy of NEDE-24955,encl ML20212J7891999-10-0404 October 1999 Informs That Licensee 980804,0628,29 & 990921 Responses to GL 98-01, Y2K Readiness of Computer Sys at NPPs Acceptable.Nrc Consider Subj GL to Be Closed for Plant ML20212J6501999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of VYNPS on 990913. No New Areas Identified in Which Licensee Performance Warranted Addl Insp Beyond Core Insp Program.Historical Listing of Plant Issues & Insp Plan Through Mar 2000 Encl ML20216J3531999-09-29029 September 1999 Responds to NRC Re Violations Noted in Insp Rept 50-271/99-12 on 990628-0811.Corrective Actions:Based on RFO 20 Maint Rule Outage Performance Review,Task Was Generated to Clarify & Enhance SD Monitoring Process BVY-99-122, Notifies of Intention to Reinstate Original Version of App F in FSAR & Correct Docket Re Assumption That Electrical Power Sys Are Designed IAW Requirements of GDC-171999-09-28028 September 1999 Notifies of Intention to Reinstate Original Version of App F in FSAR & Correct Docket Re Assumption That Electrical Power Sys Are Designed IAW Requirements of GDC-17 BVY-99-114, Provides Notification That Licensee Completed Y2K Remediation Efforts Described in Util 990608 Response to NRC GL 98-01,Suppl 11999-09-21021 September 1999 Provides Notification That Licensee Completed Y2K Remediation Efforts Described in Util 990608 Response to NRC GL 98-01,Suppl 1 BVY-99-113, Requests Approval to Perform Alternative Testing to That Specified by ASME Boiler & Pressure Vessel Code,Section XI & Asme/Ansi OM, Operation & Maint of Nuclear Power Plants. Attachment 1 Provides Justification for Alternative Testing1999-09-21021 September 1999 Requests Approval to Perform Alternative Testing to That Specified by ASME Boiler & Pressure Vessel Code,Section XI & Asme/Ansi OM, Operation & Maint of Nuclear Power Plants. Attachment 1 Provides Justification for Alternative Testing BVY-99-116, Informs of Determination That Wh Schulze,License SOP-10528-1,will No Longer Maintain License at Facility. Termination of License Requested1999-09-21021 September 1999 Informs of Determination That Wh Schulze,License SOP-10528-1,will No Longer Maintain License at Facility. Termination of License Requested BVY-99-121, Requests Extension Until 990929 to Respond to Violations Noted in Insp Rept 50-271/99-12,dtd 990819.Licensee Did Not Receive Rept Until 990830 & Addl Time Is Needed to Prepare & Allow for Adequate Review of Violation Response Submittal1999-09-20020 September 1999 Requests Extension Until 990929 to Respond to Violations Noted in Insp Rept 50-271/99-12,dtd 990819.Licensee Did Not Receive Rept Until 990830 & Addl Time Is Needed to Prepare & Allow for Adequate Review of Violation Response Submittal ML20212C1621999-09-17017 September 1999 Forwards Amend 175 to License DPR-28 & Safety Evaluation. Amend Revises TSs to Enhance Limiting Conditions for Operation & Surveillance Requirements Relating to Standby Liquid Control System BVY-99-118, Responds to RAI Concerning GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions1999-09-16016 September 1999 Responds to RAI Concerning GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions BVY-99-115, Forwards non-proprietary & Proprietary Responses to 990714 RAI Re Civil & Mechanical Engineering Considerations for Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355.Proprietary Encls Withheld1999-09-16016 September 1999 Forwards non-proprietary & Proprietary Responses to 990714 RAI Re Civil & Mechanical Engineering Considerations for Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355.Proprietary Encls Withheld ML20216F3171999-09-13013 September 1999 Forwards Insp Rept 50-271/99-06 on 990621-0801.One Violation Identified & Being Treated as Noncited Violation BVY-99-110, Informs of Util Intent to Replace Commitments Made in Licensee & Subsequently Ack in NRC with Containment Insp Criteria Defined in 10CFR50.55a(b)(2)(vi),per Drywell Coating Insp1999-08-31031 August 1999 Informs of Util Intent to Replace Commitments Made in Licensee & Subsequently Ack in NRC with Containment Insp Criteria Defined in 10CFR50.55a(b)(2)(vi),per Drywell Coating Insp BVY-99-111, Informs That Encl TS Bases Page 91 Has Been Revised to Allow Reactivity Anomaly BOC Steady State Core Reactivity to Be Normalized Between off-line Uncorrected Solution & on-line 3D-Monicore Exposure Corrected Solution1999-08-31031 August 1999 Informs That Encl TS Bases Page 91 Has Been Revised to Allow Reactivity Anomaly BOC Steady State Core Reactivity to Be Normalized Between off-line Uncorrected Solution & on-line 3D-Monicore Exposure Corrected Solution ML20211G4791999-08-27027 August 1999 Forwards Notice of Withdrawal of 990420 Amend Request Re TS on Reloading & Unloading Sequence of Fuel in Reactor Core When All Fuel Removed from Core BVY-99-107, Submits Response to NRC RAI Re Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355 Fuel Assemblies1999-08-26026 August 1999 Submits Response to NRC RAI Re Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355 Fuel Assemblies ML20211E8841999-08-25025 August 1999 Requests That Licensee Provide bldg-specific Justification for Use of Method A.1 at Locations Where Amplification Significantly Exceeds 1.5 Limit Above 8 Hz ML20211E1371999-08-20020 August 1999 Forwards from J Bean to H Miller & FEMA Final Exercise Rept for 990427-29 Plume Exposure & Ingestion Pathway Exercise for Vermont Yankee Nuclear Power Station.No Deficiencies Noted.Areas Requiring C/A Identified ML20211H0851999-08-19019 August 1999 Forwards Insp Rept 50-271/99-12 on 990628-0711 & Nov. Violation Re Failure to Monitor Unavailability of Specific Sys,Structures & Components During Refueling Outage Did Not Allow Adequate Assessment of Maint Effectiveness BVY-99-108, Requests That Gv Bogue,Bj Croke,Vs Ferrizzi,Me French, Bk Mcnutt,Jf Meyer & DM Navarro Take BWR Gfes of OL Exam Administered on 991006.DA Daigler & ST Brown Will Have Access to Exams Before Tests Administered1999-08-19019 August 1999 Requests That Gv Bogue,Bj Croke,Vs Ferrizzi,Me French, Bk Mcnutt,Jf Meyer & DM Navarro Take BWR Gfes of OL Exam Administered on 991006.DA Daigler & ST Brown Will Have Access to Exams Before Tests Administered BVY-99-103, Informs That Util Expects to Submit Approx Twenty Licensing Actions in FY00 & FY01,in Response to Administrative Ltr 99-021999-08-18018 August 1999 Informs That Util Expects to Submit Approx Twenty Licensing Actions in FY00 & FY01,in Response to Administrative Ltr 99-02 BVY-99-100, Forwards Revised Floor Response Spectra Diagrams,Originally Sent as Attachment 1 to Licensee to Nrc.Revised Diagrams Have More Legible Scale Markings1999-08-0202 August 1999 Forwards Revised Floor Response Spectra Diagrams,Originally Sent as Attachment 1 to Licensee to Nrc.Revised Diagrams Have More Legible Scale Markings ML20210M5791999-07-30030 July 1999 Responds to NRC 990726 Telcon Re Status of Resolution for USI A-46 Outliers.Written Summary,By Equipment Category, Listed ML20211E1701999-07-28028 July 1999 Forwards Copy of Final Exercise Rept for 990427-29,full- Participation Plume Exposure & Ingestion Pathway Exercise of Offsite Radiological Emergency Response Plans site-specific to VYNPS ML20210G5041999-07-27027 July 1999 Responds to NRC 990301 RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design- Basis Accident Conditions. Licensee Will Submit Info Re Proposed Sys Mod by 990916 ML20210J3031999-07-27027 July 1999 Submits Proposed Changes to Eals.Attachment 1 Provides Listing of Changes to EALs Along with Ref to Bases Documents Supporting Change ML20210G4271999-07-27027 July 1999 Forwards Testing Data & Associated Results for Fitness for Duty Program at Plant for 990101-0630 ML20216D7321999-07-26026 July 1999 Forwards Insp Rept 50-271/99-05 on 990510-0620.Two Viiolations Being Treated as Noncited Violations ML20209G2721999-07-14014 July 1999 Discusses Licensee Response to RAI Re GL 92-01,Rev 1,Suppl Suppl 1, Rv Structural Integrity, for Vermont Yankee Nuclear Power Station ML20209J0601999-07-14014 July 1999 Forwards Rev 11 to Vols 1-10 of State of Nh Radiological Emergency Response Plan & Vols 11-50 to Town Radiological Emergency Response Plans,In Support of Vermont Yankee & Seabrook Station.Vols 17-19 of Were Not Included ML20209G6931999-07-14014 July 1999 Forwards Request for Addl Info Re Spent Fuel Storage Capacity Expansion ML20209G1531999-07-12012 July 1999 Discusses Util Setpoint Control Program Implementation Schedule,As Committed to in Licensee 990514 Response to Notice of Violation,Insp Rept 50-271/97-10 ML20196J2321999-06-30030 June 1999 Submits Input from Util Technical Staff Re Soil Disposal on-site Under 10CFR20.2002 & Expresses Interest in Pursuing Approval to Use Same Methodology (Implemented Through Util ODCM & Reported as Noted) If Possible ML20196J7421999-06-29029 June 1999 Informs NRC That Vygs Has Implemented Severe Accident Management,As Committed to in Licensee to NRC ML20209B6111999-06-29029 June 1999 Resubmits Summary of Vynp Commitments Page to Replace Original Page Submitted with Responding to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants ML20196J2431999-06-29029 June 1999 Informs That Author Received Call from NRR on Dirt Spreading Ltr & Questions Re Cover Ltr Statement Where Util Asks to Be Allowed to Dispose of Future Soil in Same Manner Provided Same Acceptance Criteria Met ML20209C3751999-06-28028 June 1999 Forwards non-proprietary Rev 16 to EPIP OP 3524, Emergency Actions to Ensure Initial Accountability & Security Response & Proprietary Rev 12 to EPIP OP 3531, Emergency Call-In Method. Proprietary Encl Withheld ML20209B5861999-06-28028 June 1999 Provides Alternative Y2K Readiness Status Described in Supplement 1 to GL 98-01, Y2K Readiness of Computer Sys at Npps. Y2K Readiness Disclosure Rept Encl ML20196G5241999-06-22022 June 1999 Responds to Re Changes to Vermont Yankee Guard Training & Qualification Plan,Rev 8,Errata A.No NRC Approval Is Required.Encl Will Be Withheld from Public Disclosure Per 10CFR73.21 BVY-99-084, Forwards Proprietary Application & Medical Certificate for Mod of Listed SRO License,For Gj Leclair.Gj Leclair Will Be Trained & Evaluated in Accordance with Util Lsro Training Description.Proprietary Info Withheld,Per 10CFR2.7901999-06-18018 June 1999 Forwards Proprietary Application & Medical Certificate for Mod of Listed SRO License,For Gj Leclair.Gj Leclair Will Be Trained & Evaluated in Accordance with Util Lsro Training Description.Proprietary Info Withheld,Per 10CFR2.790 ML20212J0541999-06-17017 June 1999 Responds to Requesting That NRC Staff ...Allow BWR Plants Identified to Defer Weld Overlay Exams Until March 2001 or Until Completion of NRC Staff Review & Approval of Proposed Generic Rept,Whichever Comes First ML20195H1741999-06-15015 June 1999 Forwards Original & Copy of Request for Approval of Certain Indirect & Direct Transfer of License & Ownership Interests of Montaup Electric Co (Montaup) with Respect to Nuclear Facilities Described as Listed 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217F1261999-10-12012 October 1999 Forwards Update to Previously Submitted RELAP5 Analytical Assumptions for App R,Re RAI of 961104 BVY-99-130, Provides Clarification of Method for Determining MSIV Maximum & Minimum Pathway at Vermont Yankee Nuclear Power Station1999-10-0808 October 1999 Provides Clarification of Method for Determining MSIV Maximum & Minimum Pathway at Vermont Yankee Nuclear Power Station BVY-99-128, Submits Listed Addl Info in Support of 990414 Request for Clarification to SER Confirming Adequacy of Space Cooling for HPCI & RCIC Sys,Re Item II.K.3.24 of NUREG-0737.Copy of NEDE-24955,encl1999-10-0606 October 1999 Submits Listed Addl Info in Support of 990414 Request for Clarification to SER Confirming Adequacy of Space Cooling for HPCI & RCIC Sys,Re Item II.K.3.24 of NUREG-0737.Copy of NEDE-24955,encl ML20216J3531999-09-29029 September 1999 Responds to NRC Re Violations Noted in Insp Rept 50-271/99-12 on 990628-0811.Corrective Actions:Based on RFO 20 Maint Rule Outage Performance Review,Task Was Generated to Clarify & Enhance SD Monitoring Process BVY-99-122, Notifies of Intention to Reinstate Original Version of App F in FSAR & Correct Docket Re Assumption That Electrical Power Sys Are Designed IAW Requirements of GDC-171999-09-28028 September 1999 Notifies of Intention to Reinstate Original Version of App F in FSAR & Correct Docket Re Assumption That Electrical Power Sys Are Designed IAW Requirements of GDC-17 BVY-99-113, Requests Approval to Perform Alternative Testing to That Specified by ASME Boiler & Pressure Vessel Code,Section XI & Asme/Ansi OM, Operation & Maint of Nuclear Power Plants. Attachment 1 Provides Justification for Alternative Testing1999-09-21021 September 1999 Requests Approval to Perform Alternative Testing to That Specified by ASME Boiler & Pressure Vessel Code,Section XI & Asme/Ansi OM, Operation & Maint of Nuclear Power Plants. Attachment 1 Provides Justification for Alternative Testing BVY-99-114, Provides Notification That Licensee Completed Y2K Remediation Efforts Described in Util 990608 Response to NRC GL 98-01,Suppl 11999-09-21021 September 1999 Provides Notification That Licensee Completed Y2K Remediation Efforts Described in Util 990608 Response to NRC GL 98-01,Suppl 1 BVY-99-116, Informs of Determination That Wh Schulze,License SOP-10528-1,will No Longer Maintain License at Facility. Termination of License Requested1999-09-21021 September 1999 Informs of Determination That Wh Schulze,License SOP-10528-1,will No Longer Maintain License at Facility. Termination of License Requested BVY-99-121, Requests Extension Until 990929 to Respond to Violations Noted in Insp Rept 50-271/99-12,dtd 990819.Licensee Did Not Receive Rept Until 990830 & Addl Time Is Needed to Prepare & Allow for Adequate Review of Violation Response Submittal1999-09-20020 September 1999 Requests Extension Until 990929 to Respond to Violations Noted in Insp Rept 50-271/99-12,dtd 990819.Licensee Did Not Receive Rept Until 990830 & Addl Time Is Needed to Prepare & Allow for Adequate Review of Violation Response Submittal BVY-99-115, Forwards non-proprietary & Proprietary Responses to 990714 RAI Re Civil & Mechanical Engineering Considerations for Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355.Proprietary Encls Withheld1999-09-16016 September 1999 Forwards non-proprietary & Proprietary Responses to 990714 RAI Re Civil & Mechanical Engineering Considerations for Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355.Proprietary Encls Withheld BVY-99-118, Responds to RAI Concerning GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions1999-09-16016 September 1999 Responds to RAI Concerning GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions BVY-99-110, Informs of Util Intent to Replace Commitments Made in Licensee & Subsequently Ack in NRC with Containment Insp Criteria Defined in 10CFR50.55a(b)(2)(vi),per Drywell Coating Insp1999-08-31031 August 1999 Informs of Util Intent to Replace Commitments Made in Licensee & Subsequently Ack in NRC with Containment Insp Criteria Defined in 10CFR50.55a(b)(2)(vi),per Drywell Coating Insp BVY-99-111, Informs That Encl TS Bases Page 91 Has Been Revised to Allow Reactivity Anomaly BOC Steady State Core Reactivity to Be Normalized Between off-line Uncorrected Solution & on-line 3D-Monicore Exposure Corrected Solution1999-08-31031 August 1999 Informs That Encl TS Bases Page 91 Has Been Revised to Allow Reactivity Anomaly BOC Steady State Core Reactivity to Be Normalized Between off-line Uncorrected Solution & on-line 3D-Monicore Exposure Corrected Solution BVY-99-107, Submits Response to NRC RAI Re Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355 Fuel Assemblies1999-08-26026 August 1999 Submits Response to NRC RAI Re Proposed Change to TS to Increase Spent Fuel Storage Capacity from 2,870 to 3,355 Fuel Assemblies BVY-99-108, Requests That Gv Bogue,Bj Croke,Vs Ferrizzi,Me French, Bk Mcnutt,Jf Meyer & DM Navarro Take BWR Gfes of OL Exam Administered on 991006.DA Daigler & ST Brown Will Have Access to Exams Before Tests Administered1999-08-19019 August 1999 Requests That Gv Bogue,Bj Croke,Vs Ferrizzi,Me French, Bk Mcnutt,Jf Meyer & DM Navarro Take BWR Gfes of OL Exam Administered on 991006.DA Daigler & ST Brown Will Have Access to Exams Before Tests Administered BVY-99-103, Informs That Util Expects to Submit Approx Twenty Licensing Actions in FY00 & FY01,in Response to Administrative Ltr 99-021999-08-18018 August 1999 Informs That Util Expects to Submit Approx Twenty Licensing Actions in FY00 & FY01,in Response to Administrative Ltr 99-02 BVY-99-100, Forwards Revised Floor Response Spectra Diagrams,Originally Sent as Attachment 1 to Licensee to Nrc.Revised Diagrams Have More Legible Scale Markings1999-08-0202 August 1999 Forwards Revised Floor Response Spectra Diagrams,Originally Sent as Attachment 1 to Licensee to Nrc.Revised Diagrams Have More Legible Scale Markings ML20210M5791999-07-30030 July 1999 Responds to NRC 990726 Telcon Re Status of Resolution for USI A-46 Outliers.Written Summary,By Equipment Category, Listed ML20211E1701999-07-28028 July 1999 Forwards Copy of Final Exercise Rept for 990427-29,full- Participation Plume Exposure & Ingestion Pathway Exercise of Offsite Radiological Emergency Response Plans site-specific to VYNPS ML20210G5041999-07-27027 July 1999 Responds to NRC 990301 RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design- Basis Accident Conditions. Licensee Will Submit Info Re Proposed Sys Mod by 990916 ML20210G4271999-07-27027 July 1999 Forwards Testing Data & Associated Results for Fitness for Duty Program at Plant for 990101-0630 ML20210J3031999-07-27027 July 1999 Submits Proposed Changes to Eals.Attachment 1 Provides Listing of Changes to EALs Along with Ref to Bases Documents Supporting Change ML20209J0601999-07-14014 July 1999 Forwards Rev 11 to Vols 1-10 of State of Nh Radiological Emergency Response Plan & Vols 11-50 to Town Radiological Emergency Response Plans,In Support of Vermont Yankee & Seabrook Station.Vols 17-19 of Were Not Included ML20209G1531999-07-12012 July 1999 Discusses Util Setpoint Control Program Implementation Schedule,As Committed to in Licensee 990514 Response to Notice of Violation,Insp Rept 50-271/97-10 ML20196J2321999-06-30030 June 1999 Submits Input from Util Technical Staff Re Soil Disposal on-site Under 10CFR20.2002 & Expresses Interest in Pursuing Approval to Use Same Methodology (Implemented Through Util ODCM & Reported as Noted) If Possible ML20209B6111999-06-29029 June 1999 Resubmits Summary of Vynp Commitments Page to Replace Original Page Submitted with Responding to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants ML20196J7421999-06-29029 June 1999 Informs NRC That Vygs Has Implemented Severe Accident Management,As Committed to in Licensee to NRC ML20209C3751999-06-28028 June 1999 Forwards non-proprietary Rev 16 to EPIP OP 3524, Emergency Actions to Ensure Initial Accountability & Security Response & Proprietary Rev 12 to EPIP OP 3531, Emergency Call-In Method. Proprietary Encl Withheld ML20209B5861999-06-28028 June 1999 Provides Alternative Y2K Readiness Status Described in Supplement 1 to GL 98-01, Y2K Readiness of Computer Sys at Npps. Y2K Readiness Disclosure Rept Encl BVY-99-084, Forwards Proprietary Application & Medical Certificate for Mod of Listed SRO License,For Gj Leclair.Gj Leclair Will Be Trained & Evaluated in Accordance with Util Lsro Training Description.Proprietary Info Withheld,Per 10CFR2.7901999-06-18018 June 1999 Forwards Proprietary Application & Medical Certificate for Mod of Listed SRO License,For Gj Leclair.Gj Leclair Will Be Trained & Evaluated in Accordance with Util Lsro Training Description.Proprietary Info Withheld,Per 10CFR2.790 ML20195H1741999-06-15015 June 1999 Forwards Original & Copy of Request for Approval of Certain Indirect & Direct Transfer of License & Ownership Interests of Montaup Electric Co (Montaup) with Respect to Nuclear Facilities Described as Listed ML20195C5891999-05-27027 May 1999 Forwards Response to NRC 990301 RAI Re GL 96-05 Program at Vermont Yankee Nuclear Power Station ML20195D5341999-05-27027 May 1999 Forwards Description of Vermont Yankees Plans for Insp of & Mods to Certain Reactor Vessel Internals BVY-99-074, Forwards Application & Medical Certificate Required for Renewal of Jd Livingston,License OP-10049,RO License.Medical Certificate Withheld1999-05-26026 May 1999 Forwards Application & Medical Certificate Required for Renewal of Jd Livingston,License OP-10049,RO License.Medical Certificate Withheld ML20195B4081999-05-24024 May 1999 Withdraws Licensee Commitment,Contained in ,To Reinitiate ITS Project Following Completion of FSAR Accuracy Verification Project.Util Will Continue to Modify Current TS with Number of Improvements BVY-99-067, Informs That Bw Metcalf,License SOP-1761-9,has Retired from VYNPS & Will No Longer Require License.Nrc Is Requested to Terminate License1999-05-21021 May 1999 Informs That Bw Metcalf,License SOP-1761-9,has Retired from VYNPS & Will No Longer Require License.Nrc Is Requested to Terminate License ML20196L1801999-05-18018 May 1999 Withdraws Licensee & Attachment,Containing Rev 2 to Vermont Yankee Operational QA Manual, from Further Consideration by Nrc.Summary of Commitments Encl ML20206K3201999-05-0707 May 1999 Forwards Response to RAI Re Verification of Seismic Adequacy of Mechanical & Electrical Equipment ML20206J2801999-04-30030 April 1999 Forwards 1998 Annual Financial Repts for CT Light & Power Co,Western Ma Electric Co,Public Svc Co of Nh,North Atlantic Energy Corp,Northeast Nuclear Energy Co & North Atlantic Energy Svc Corp,License Holders ML20206D3731999-04-27027 April 1999 Informs NRC of Changes in Recipients of NRC Docketed Correspondence ML20206B1401999-04-23023 April 1999 Forwards Replacement of Section 3(a) of NSHC Determination Provided by Re TS Proposed Change 208,suppl Section 6 ML20205S3381999-04-16016 April 1999 Submits Revised Schedule for Response to NRC 990226 RAI Re 980630 Submittal of IPEEE Rept.Info Will Be Submitted by 991231 ML20205S3891999-04-16016 April 1999 Forwards non-proprietary & Proprietary Revised Page to Holtec Rept HI-981932,supplementing TS Proposed Changed 207 Re Spent Fuel Pool Storage Capacity Expansion ML20205S3031999-04-15015 April 1999 Forwards Revised TS Bases Pages 90,227,164 & 221a,accounting for Change in Reload Analysis from Yaec to GE Methodology, Reflecting Change in Condensation Stability Design Criteria & Accounting for More Conservative Calculation ML20205P9291999-04-14014 April 1999 Requests That Rev to NRC 821029 SER for NUREG-0737,Item II.K.3.24,be Issued to Clarify Util Installed RCIC & HPCI HVAC Configuration,As Discovered During Preparation of DBDs for Sys ML20205P8191999-04-13013 April 1999 Forwards Rev 2 to COLR for Vermont Yankee Cycle 20, Dtd Feb 1999,IAW TS Section 6.7.A.4 ML20205M3191999-04-0707 April 1999 Forwards 1998 Annual Rept of Results of Individual Monitoring, Per 10CFR20.2206(b).Licensee Is Submitting Matl to Only Addressee Specified in 10CFR20.2206(c).Without Encl ML20205K0351999-03-31031 March 1999 Informs That Certain Addl Corrections Warranted for 990121 SER for Amend 163 to License DPR-28 Re Suppression Pool Water Temp.Suggested Corrections Listed ML20205K1821999-03-31031 March 1999 Informs of Modifications That Util Made to CO(2) Fire Suppression Sys,Due to Sen 188 Which Occurred at Ineel on 980728.Compensatory Actions Will Remain in Place Until Modifications Are Complete & Systems Are Returned to Svc ML20206A6951999-03-29029 March 1999 Request Confirmation That No NRC Action or Approval,Required Relative to Proposed Change in Upstream Economic Ownership of New England Power Co,Minority Shareholder in Vermont Yankee Nuclear Power Corp,Yaec,Myap & Connecticut Yankee 1999-09-29
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059J2831990-09-10010 September 1990 Forwards Updated Operator Licensing Exam Schedule for FY91, FY92,FY93 & FY94,per Generic Ltrs 90-07 & 89-12 ML20059D9831990-08-28028 August 1990 Forwards fitness-for-duty Program Performance Data for 900103-0630,per 10CFR26.71.NRC Review of Data Will Provide Realization That Positive Testing Rate Extremely Low & Limited to pre-access Testing Population BVY-90-087, Forwards Addl Info on Use of RELAP5YA Program for LOCA Analyses.Proprietary Encl Withheld1990-08-28028 August 1990 Forwards Addl Info on Use of RELAP5YA Program for LOCA Analyses.Proprietary Encl Withheld BVY-90-086, Responds to NRC Re Violations Noted in Insp Rept 50-271/90-06.Corrective Actions:Incident Rept Initiated & All Required Locking Devices in Place by 9007061990-08-24024 August 1990 Responds to NRC Re Violations Noted in Insp Rept 50-271/90-06.Corrective Actions:Incident Rept Initiated & All Required Locking Devices in Place by 900706 ML20059F6681990-08-22022 August 1990 Comments on Review of Amend 115 to License DPR-28,including Safety Evaluation.Requests Explanation of Statement in NRC Re How NRC Considers Comments & What Resolution Could Be for Each Util Comment in BVY-90-085, Informs That Sys Testing & Operator Training Successfully Completed & SPDS Declared Operable on 900813.Util Intends to Operate SPDS in Parallel W/Original Honeywell Gepac Plant Computer Until mid-Nov 19901990-08-15015 August 1990 Informs That Sys Testing & Operator Training Successfully Completed & SPDS Declared Operable on 900813.Util Intends to Operate SPDS in Parallel W/Original Honeywell Gepac Plant Computer Until mid-Nov 1990 BVY-90-084, Notifies NRC of Intentions to Install Test Fuel Assemblies & Test Control Blades During Cycle 15 Refueling Outage in Sept 19901990-07-24024 July 1990 Notifies NRC of Intentions to Install Test Fuel Assemblies & Test Control Blades During Cycle 15 Refueling Outage in Sept 1990 BVY-90-082, Informs That Effective 900723 Facility Implemented Rev 4 of Procedure Generating Package & Corresponding Revs to Eops. Revs Developed Per Rev 4 of BWR Owners Group Emergency Procedure Guidelines1990-07-24024 July 1990 Informs That Effective 900723 Facility Implemented Rev 4 of Procedure Generating Package & Corresponding Revs to Eops. Revs Developed Per Rev 4 of BWR Owners Group Emergency Procedure Guidelines BVY-90-071, Forwards Rev 2 to Training & Qualification Plan.Rev Withheld (Ref 10CFR73.21)1990-07-20020 July 1990 Forwards Rev 2 to Training & Qualification Plan.Rev Withheld (Ref 10CFR73.21) BVY-90-078, Forwards List of Refs for Proposed Change 161 to Facility OL & Tech Specs1990-07-17017 July 1990 Forwards List of Refs for Proposed Change 161 to Facility OL & Tech Specs BVY-90-072, Forwards Supplemental Effluent & Waste Disposal Semiannual Rept for Third & Fourth Quarters 1989,Including Annual Radiological Impact on Man for 19891990-06-27027 June 1990 Forwards Supplemental Effluent & Waste Disposal Semiannual Rept for Third & Fourth Quarters 1989,Including Annual Radiological Impact on Man for 1989 ML20043G4351990-06-15015 June 1990 Requests Temporary Waiver of Compliance from Tech Spec Requirements for Limiting Conditions for Operation for Certain post-accident Monitoring Instrumentation Listed in Tech Spec Table 3.2.6.Parameters Listed ML20043E4011990-06-0808 June 1990 Responds to Second Request for Addl Info on Use of RELAP5YA. Explanation Re Why More Accurate View Factor Calculation Not Included in Huxy Code Addressed ML20043C6131990-06-0101 June 1990 Forwards YAEC-1659-A, Simulate-3 Validation & Verification. ML20043C5991990-06-0101 June 1990 Forwards Accepted Version of YAEC-1683-A, MICBURN-3/ CASMO-3/TABLES-3/SIMULATE-3 Benchmarking of Vermont Yankee Cycles 9 Through 13. ML20043C4821990-05-30030 May 1990 Informs of Three Organizational Changes That Will Become Effective on 900601.WP Murphy,Jp Pelletier & DA Reid Will Be Senior Vice President of Operations,Newly Created Vice President of Engineering & Plant Manager,Respectively ML20043B7561990-05-23023 May 1990 Informs That Util Intends to Utilize Relationship Between Frosstey & FROSSTEY-2 to Support Cycle 15 Calculations.Nrc Approval of FROSSTEY-2 Needed by Aug 1990 for LOCA Analysis Program ML20043B6481990-05-17017 May 1990 Forwards Rev 19 to Physical Security Plan.Rev Withheld (Ref 10CFR73.21) BVY-90-058, Forwards Public Version of Vermont Yankee Nuclear Power Station Emergency Response Preparedness Exercise 1990. Exercise Scenario Package Includes All Info Pertinent to Performance of Exercise Scheduled for 9007181990-05-17017 May 1990 Forwards Public Version of Vermont Yankee Nuclear Power Station Emergency Response Preparedness Exercise 1990. Exercise Scenario Package Includes All Info Pertinent to Performance of Exercise Scheduled for 900718 ML20042G9061990-05-10010 May 1990 Forwards Proprietary Supplemental Info to 900419 Response to NRC 900309 Ltr Re FROSSTEY-2 Fuel Performance Code.Info Withheld ML20042F6471990-05-0404 May 1990 Ack That NRC Will Issue Supplementary Info to NRC 900307 Request for Installation of Neutron Flux Monitoring Instrumentation That Conforms to Requirements of Reg Guide 1.97 & 10CFR50.49 at Plant ML20042E7291990-04-23023 April 1990 Forwards Pages Omitted from 900314 Revs 16-18 to Physical Security Plan.Revs Withheld ML20012F3511990-03-30030 March 1990 Provides Supplemental Response to Station Blackout Rule (10CFR50.63).Util Will Use Alternate Ac Power Source Available within 10 Minutes of Onset of Station Blackout to Meet Requirements of Station Blackout Rule ML20012D0301990-03-19019 March 1990 Forwards Response to Generic Ltr 89-19 Re Resolution of USI A-47.Feedwater Sys Trip Relays,Interfacing W/Feedwater Pump Control Circuitry,Powered from Supplies Originating from safety-related Dc Sources ML20012D0241990-03-16016 March 1990 Forwards Supplemental Info Re Feedwater Check Valve V28B Flaws Evaluation,Per NRC Request.Util Remains Committed to Replacement of Subj Valve During Upcoming 1990 Refueling Outage ML20012C6381990-03-15015 March 1990 Forwards Vermont Yankee Nuclear Power Corp Financial Statements 891231,1988 & 1987. ML20012C6071990-03-15015 March 1990 Forwards Method for Generation of One-Dimensional Kinetics Data for RETRAN-02, Per NUREG-0393 & 891211 Request ML20012B8311990-03-0909 March 1990 Forwards Proprietary Vermont Yankee Evaluation Model Sample Problem 0.7 Ft(2) Break in Recirculation Discharge Loop, in Response to 900208 Telcon.Rept Withheld (Ref 10CFR2.790) ML20012B6131990-03-0909 March 1990 Informs of Schedular Changes Made W/Regard to Plant Licensed Operator Requalification Training Program ML20006E8871990-02-15015 February 1990 Provides NRC W/Results of Licensee Review of Design Bases & Operability Status of torus-to-reactor Bldg Vacuum Breakers ML20011E6791990-02-0505 February 1990 Responds to Weaknesses Noted in SALP Rept 50-271/88-99 for Jul 1988 to Sept 1989.Implementation of Emergency Response Facility Info Sys Nearing Completion & Remaining Safety Class Vendor Manuals Will Be Completed During 1990 ML20006D1571990-02-0202 February 1990 Responds to 891226 Request for Addl Info Re YAEC-1683 on MICBURN-3/CASMO-3/TABLES-3/SIMULATE-3 Benchmarking.Hot Eigenvalue Std Deviation on Table 5.7 of YAEC-1683 Reduced to 0.00098 w/SIMULATE-3 ML20006B1351990-01-22022 January 1990 Forwards Responses to Generic Ltr 89-13 Re Svc Water Sys Problems Affecting safety-related Equipment.Establishment of Program Revs Prior to Startup from Next Refueling Outage, Scheduled for Fall 1990,planned ML20006A4441990-01-16016 January 1990 Forwards Revised Page 127 of Tech Specs to Clarify Proposed Change 134, Rev of Pressure Suppression - Reactor Bldg Vacuum Breaker Sys Operability Requirements. Change Involves Adoption of Language Consistent W/Bwr STS ML19354E8001990-01-16016 January 1990 Forwards Addl Info Re Testing of Cable Vault C02 Suppression Sys During 891031-1102,per NRC 890518 & 0821 Requests.Encl Final Test Rept Demonstrates That Carbon Dioxide Sys Will Satisfy Design Bases for Greater than 10 Minutes in Room ML20005G0841990-01-10010 January 1990 Responds to NRC Bulletin 89-002 Re Stress Corrosion Cracking of high-hardness Type 410 Stainless Steel Internal Preloaded Bolting in Anchor Darling Model S350W Swing Check Valves or Valves of Similar Design ML20005E8201990-01-0202 January 1990 Forwards Minutes of NRC 890907 Meeting W/Util in Rockville,Md Re Util LOCA Analysis Program.List of Attendees Also Encl ML20005F0551990-01-0202 January 1990 Informs That Util Has Implemented Fitness for Duty Program, in Compliance w/10CFR26 ML20005E3531989-12-28028 December 1989 Forwards Response to Generic Ltr 89-10 Re safety-related motor-operated Valve Testing & Surveillance.Util Intends to Extend Existing IE Bulletin 85-003 Program to Cover motor- Operated Valves within Scope of Ltr ML20005E3191989-12-28028 December 1989 Responds to Violations Noted in Insp Rept 50-271/89-17 on 890906-1016.Corrective Actions:Plant Procedures Revised & Addl Meetings Between Plant Manager,Dept Supervisors & Personnel to Take Place ML19332G1791989-12-12012 December 1989 Forwards Rev 0 to Vermont Yankee Nuclear Power Station Cycle 14 Core Operating Limits Rept. ML19332F2781989-11-30030 November 1989 Forwards Rev 1 to YAEC-1693, Application of One-Dimensional Kenetics to BWR Transient Analysis Methods, Per 891106 Ltr.Rept Presents Methodology,Verification & Justification for Application of RETRAN-02 One Dimensional Option ML19332E3511989-11-29029 November 1989 Forwards Annual Cashflow Statements for 1989 as Evidence of Util Maint of Approved Guarantee,Per Requirements of 10CFR140.21 Re Licensee Guarantees of Payment of Deferred Premiums ML19332E5281989-11-28028 November 1989 Requests Removal of Change B to Proposed Change 148 Re Rev to Pages 5b & 6a Correcting Administrative Error in Tech Spec 2.1 ML19332D3801989-11-22022 November 1989 Responds to NRC Generic Ltr 89-21 Re Request for Info Re Status of Implementation of USI Requirements.Encl Table Details Implementation Status for USIs for Which Final Technical Resolution Achieved ML19324C1501989-11-10010 November 1989 Responds to NRC Bulletin 88-010,Suppl 1 Re Molded Case Circuit Breakers.Program Initiated to Ensure That Breakers Can Perform Safety Functions ML19324C2201989-11-0606 November 1989 Requests Change in Review & Approval Basis from Facility Specific to Generic Because Methods Described in YAEC-1693 & YAEC-1694 Applicable to All BWRs ML19325F0261989-11-0606 November 1989 Responds to Generic Ltr 89-07, Power Reactor Safeguards Contingency Planning for Surface Vehicle Bombs. Util Has Evaluated Listed Considerations,Including Safe Standoff Distances for Vital Equipment ML19324B7431989-10-30030 October 1989 Responds to Generic Ltr 89-16 Re Installation of Hardened Wetwell Vent.Util Expects to Establish Specific Design Criteria to Install Enhanced Containment Overpressure Protection Capability by End of 1992 Refueling Outage ML19324B8481989-10-30030 October 1989 Provides NRC W/Test Acceptance Criteria for Alternate Test of CO2 Suppression Sys,Per 891025 Meeting.Ability to Contain CO2 at Appropriate Concentration for Required Duration,As Well as Ability to Withstand Dynamics of Discharge,Verified 1990-09-10
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VERMONT YANKEE NUCLEAR POWER CORPORATION
. RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 ,,,,y 7, p ENGINEERING OFFICE 1671 WORCESTER ROAD
- TELEPHONE 617-872-4100 March 1, 1985 U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, PA 19406 Attention: Mr. Richard W. Starostecki SALP Board Chairman Division of Project and Resident Programs
References:
a) License No. OPR-28 (Docket No. 50-271) b) Letter, USNRC to VYNPC, SALP Report No. 50-271/84-25, dated 12/21/84 c) letter, USNRC to VYNPC, I&E Inspection Report No. 50-271/84-21, dated 12/6/84 d) Letter, VVNPC to USNRC, FVY 85-02, dated 1/14/85 e) Letter, USNRC to VYNPC, I&E Inspection Report No. 50-271/83-26, Enforcement Conference Findings, dated 3/13/84 f) Letter, USNRC to VYNPC, I&E Inspection Report No. 50-271/83-26, dated 11/2/83 .
g) Letter, VYNPC to USNRC, FVY 84-24, dated 3/14/84 h) Letter, VYNPC to USNRC, FVY 84-53, dated 5/21/84
Dear Sir:
Subject:
Systematic Assessment of Licensee Performance (SALP) Report Comments The purpose of this letter is to provide you with comments regarding the most recent Systematic Assessment of Licensee Performance (SALP) Report which was issued by letter dated December 24, 1984 [ Reference b)]. We appreciated the opportunity to discuss the findings of the report at the January 24, 1985 meeting in King of Prussia. In general, we believe that the report is a fair appraisal of our activities during the May 1983 through October 1984 reporting period; however, as discussed at our meeting, there are certain areas within the report that warrant clarification and/or correction.
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U.S.LNuclear Regulatory Commission
-March 1,.1985
'Paga 2
. VEHMONT YANKEE NUCLEAR POWER CORPORATION
, PI' ease note that your' December 24. 1984 letter requested that any comments on the: report be formally submitted within twenty (20) days of the January 24, 1985 meeting. However, due to the complex nature of some of the areas discussed
- in the report,'we required an additional _ two (2) weeks to prepare our comments.
The need for additional time was ' discussed with and agreed to by Mr. William
.Raymond of your staff.
We. respectfully submit the following comments for your consideration:
-(1).SectionIV.A.1, Operations (Page9_)_
aThe SALP Report-states that "the management decisions and actions to con-
'tinue plant operation from. September 16-18, 1984 with an anomalous core power-to-flow relationship and .in spite of; clear _ indications that -the plant was operating Lin an unanalyzed condition, appeared as a significant deviation from the normally conservative approach taken' to assure safe plant operations.' NRC . considered that the licensee. had an insufficient. :
basis to continue operatic' with the anomaly,-and the_ licensee's decision was_neither prudent nor conservative."
1We strongly disagree .with the NRC's' assertion that our decision to continue operation was neither' prudent nor conservative. As discussed in our January 14, 1985 [ Reference c)] response to I&E Inspection Report 84-21
-[ Reference d)], we believe that we effectively and prudently._ analyzed the '
- situation during the entire course of this occurrence (from indication that an anomaly existed-through rejection of hypothetical =causes to iden-tification of a tentatively identified cause). While we evaluated possible-causes of the anomaly,_we simultaneously assured to our satisfaction that Lcontinued operation was prudent and posed no' safety concern.
The details of our engineering assessment of the anomaly is discussed in detail in our January 14, 1985 submittal. We believe the actions taken
- were consistent with our conservative _ philosophy of assuring safe plant operations. Thus, we believe' that your stated conclusion that Operations declined over the Report period due to a "non-conservative operational
- philosophy" is unfounded.
(2)Section IV.E.1, Fire Protection and Housekeeping (Pages 2_5_ and 26) o The SALP_ Report states that-as a result of the August / September 1983
. inspection of Vermont Yankee's compliance to Section III,of Appendix R to 10CFR50, Fire Protection Requirements, "one violation is being con-sidered for escalated enforcement action."
a.
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U.S. Nuclear R:gulatory Commission March 1, 1985 Page'3 VERMONT YANKEE NUCLEAR POWER CORPORATION As described in various submittals made to the NRC subsequent to the 1983 Appendix R inspection, Vermont Yankee has performed extensive engineering analyses to demonstrate the adequacy of our fire protec-tion capabilities and is continuing with the installation of addi-tional modifications to enhance our overall fire protection design. .
We believe our response to the findings of the 1983 inspection have been timely, responsive to the NRC's concerns, and reflect a strong commitment on the part of Vermont Yankee and its management to achieve compliance with the provisions of Appendix R. We recognize the time it- has taken to address all of the NRC's concerns; however, the con-tinual issuance of guidance criteria by NRR regarding Appendix R compliance (i.e., Generic Letter 83-33, Generic Letter 85-01, various Information Notices, and information resulting from Regional Workshops) has made the task of achieving literal compliance that much more difficult. Enclosure 1 provides a chronol,ogical history of events associated with the Appendix R issue at Vermont Yankee. These events include formal submittals made by us as well as numerous meetings held with various NRC Staff members to resolve this issue.
Based on these efforts, we believe that the pending enforcement action should be formally dispositioned with a finding that escalated enfor-cement action is not warranted.
-o The SALP Report also states that, "the licensee did not take the ini-tiative to assure that his assumptions for the Reactor Building were consistent with the NRC staff's positions. Licensee exceptions to the requirements were 'not properly identified to the NRC staff."
This statement reflects the basic misunderstanding between the NRC and Vermont Yankee with respect to compliance with Section III.G to
~ Appendix R. As discussed at the January 10, 1984 Enforcement Conference held in King of Prussia, we had received various correspon-dence from the NRC which indicated to us that to comply with Section III.G, we need only provide alternate safe shutdown capability for the Control Room, Cable Vault and Switchgear Room. This correspondence, discussed in detail in the March 13, 1984 Enforcement Conference Meeting Minutes [see Reference e)], was- the basis for our conclusion that our'overall Fire Protection Program satisfied the intent of Section III.G with respect to our Reactor Building and that the NRC was cognizant of our assumptions and positions which were documented in our 1978 Fire Hazards Analysis Report, o The SALP Report states that "The licensee took considerable time to respond to the issues identified by the inspection team. The NRC positions regarding the Appendix R requirements were clearly presented m
U.S. Nuclear Regulatory Commission March 1, 1985 Page 4 VEltMONT YANKEE NUCLEAll POWElt COllPOlt ATION
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to the licensee by the NRC review team in August 1983, but the licen-see did not become fully committed to address the identified deficien-t cies and differences between his and the NRC staff's position until March 1984. Considerable NRC effort was required to get the licensee ;
to perform the reanalysis and implement the actions necessary to q correct the violation."
In addition, the Report states that "the lower rating this assessment period is due to the licensee's incorrect implementation of the _
Appendix R rule and the licensee's slowness in responding to the NRC initiatives once deficient areas were identified."
As discussed above, we believe our response to the findings were timely and appropriate. Immediately following the 1983 inspection, we initiated a re-review of the requirements of Appendix R to 10CFR Part 3
50 and initiated a re-survey of our Reactor Building to ensure we met the separation criteria of Section III.G.2. It should be noted that our re-survey was performed assuming a fire induced loss of off-site -
power which was consistent with our original interpretation of the loss of off-site power provisions of Appendix R. We also initiated a breaker coordination study and an engineering analysis of plant safe shutdown systems against the separation and fire protection criteria of Section III.G.2 of Appendix R. _
Once the formal findings of the inspection were issued in the November 2, 1983 Inspection Report [see Reference f)], we performed an a analysis of the safety significance of the inspection's findings. The results of our analysis were presented to the NRC at a November 22, 1983 meeting at King of Prussia where it was concluded that there were no findings that would preclude our ability to safely shut down the plant in the event of a fire. At that meeting, we also presented a draft report entitled " Analysis to Demonstrate Safe Shutdown Capability During and After Fires," which documented our analysis.
Following the November 22, 1983 meeting, we continued with our engi-neering efforts to address the deficiencies cited in the November 2, 1983 Inspection Report. We reported the scope and status of our efforts to the NRC at an Enforcement Conference held in King of Prussia on January 10, 1984. We also discussed differences between Vermont Yankee and the NRC in interpreting certain provisions of Appendix R. Specifically, the NRC stated that Appendix R implies the need for safe shutdown capability for the plant, assuming a loss of off-site pouer for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> concurrent with a fire in any area of the
U.S. Nuclear Regulatory Commission March 1, 1985 Page 5 VERMONT YANKEE NUCLEAlt POWEll Colli'C ION plant. Vermont Yankee's assumption, both in the pre-Appendix R Fire
' Hazards Survey and the post-inspection re-survey was that a non-mechanistic loss of off-site power need not be considered. The NRC also stated that Vermont Yankee's use of " fire zone boundaries" in the Reactor Building did not meet Appendix R requirements for physical
" fire area boundaries." Vermont Yankee's position was that the inherent spatial separation between areas of the Reactor Building, .
coupled with physical barriers and extensive fire protection features installed in the Reactor Building met the intent of the " fire area boundaries."
At the January 10 Conference, Vermont Yankee committed to submit the results of the Section III.G.2 re-survey (including an associated cir-cuits study), docket formal requests for exemption from the specific separation criteria of Section III.G.2, and submit the details of fire protection system enhancements and/or corrective actions deemed necessary as a result of the re-survey. At the time, we still believed our loss of off-site power and fire area boundary positions were justifiable.
On March 14, 1984 [see Reference g)], we submitted requests for exemp-tion for certain areas of the Reactor Building that did not meet the specific separation criteria of Section III.G.2. The exemption requests included the technical basis for justification as well as descriptions of specific fire protection system enhancements /modifi-cations which we deemed were necessary as a result of our III.G.2 re-survey.
In April 1984, our design engineers attended an NRC sponsored Regional Workshop held to discuss and clarify NRC positions regarding compliance with the provisions of Appendix R. Following the Regional Workshop, a meeting was held hetween Vermont Yankee and Yankee Atomic Electric Company engineers and management to discuss the results of the workshop and the status of our Appendix R compliance efforts.
Based on an assessment from engineers who attended the Regional Workshop that the NRC was adament on the need to assume a random loss of off-site power coincident with a fire, Vermont Yankee management directed the engineering staff to expand the scope of the III.G.2 re-survey (including the associated circuits study) to include a random loss of off-site power. In addition, based on the results of the workshop and discussions with NRR fire protection engineers, it was recognized that additional detailed engineering would be necessary to support Vermont Yankee's position that " fire zone boundaries" in the Reactor Building were an acceptable alternative to the NRC's " fire area boundaries." It was agreed that the report documenting the ex-panded III.G.2 re-survey would include detailed justification of the acceptability of " fire zone boundaries."
7 U.S.! Nuclear Rzgulatcry Commission March 1, 1985
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Paga16
. VERMONT YANKEE NUCLEAR POWER CORPORATION 4
Vermont Yankee then requested that a meeting be held with the NRC (NRR and.I&E) to; discuss the status of our engineering efforts and establish:a means to close out Appendix R for Vermont Yankee. On
.May 21, 1984 [see Reference h)], we. issued a comprehensive. response to the findings detailed in the November 2,1983 Inspection Report. This letter also -included a proposed schedule for the completion of the expanded III.G.2.re-survey.(including the associated circuits study),
.provided . schedules for completing enhancements /modificiations known to be necessary as a result of our . initial re-survey, and committed to certain interim compensatory measures until the enhancements /
modifications wer'e completed.
~ ~
LWe met .with the.NRC in King of Prussia on May 24, 1984 to discuss and clarify the . contents of our May -21,1984 Inspection Report response, as well as other correspondence recently submitted by Vermont ~ Yankee
.(i.e., a request for exemption from the 72-hour cold shutdown Lrequi rement) . At that time, we restated our intention to conduct a.
- complete III._G.2 re-survey of the plant including a circuits separation and associated circuits study. t At the meeting we also . stated our intention to keep the NRC-informed as to our progress and findings.as
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the' study progressed, focusing on any-additional compensatory measures
'which may be deered necessary. Finally, at the request of the staff, we agreed to consider additional compensatory measures beyond those committed to in our May 21, 1984 Inspection Report response.
-/ ..
The'expan'ed d III.G.2.re-survey and associated circuits study.was.per-formed during June and Julyc1984 culminating-in a draft report which
. detailed the findings. During. August 1984, we performed an engi-Y : neering evaluation of_.the findings to scope the necessary modifica-
. tions and corrective measures to address additional areas that did not meet the specific separation criteria of Section.III.G.2 of Appendix R. .We also began drafting a comprehensive report which would be sub-
-mitted to the NRC. In early September we informed the NRC of the status'of our efforts and committed to .mplement additional interim
- compensatory ' measures based on the findings of the expanded re-survey.
On November'26',11984, we submitted the results of the expanded re-surveysin a report entitled " Safe Shutdown Capability Analysis". This report was submitted in draft 1 form at the request of the NRC so as to ensure that.the format and technical content were sufficient for NRC review purposes. . This report contains .the re-survey results, asso-ciateo circuits analysis, basis for accep6 ability of " fire zone bounardies," and identifies all corrective actions. required for ulti-mate compliance with' Appendix R.
E /
U.S. Nuclear Regulatory Commission March 1, 1985 Pagi 7 VERMONT YANKEE NUCLEAR POWER CORPORATION We had scheduled a meeting with the NRC for December 21, 1984 to discuss their comments on the report, but the NRC was unable to sup-port the meeting. Because of the subsequent difficulty in trying to reschedule the meeting, it is our intent to finalize and formally docket the report in the near future. We will also be submitting additional requests for exemption from the provisions of Section III.G
.of Appendix R (as described in Appendix A of the " Safe Shutdown Capability Analysis Report"), and will continue with the completion of necessary fire protection enhancements / modifications and other correc-tive actions (i.e., procedural revisions).
. As discussed above, we believe Vermont Yankee has been responsive to the concerns identified by the NRC and is committed to closing out the Appendix R issue at the earliest possible time. Although we had phi-losophical differences with the staff with respect to the need to assume a random loss of off-site power coincident with a fire as part of our_ reanalysig and the acceptability of fire zones in lieu of fire areas,.we believe these differences in interpreting the requirements of Appendix R should not be characterized as failure to respond to the NRC's concerns in a timely manner. We also believe that based on the extensive efforts we have made to achieve full compliance with Appendix R, a strong case can be made for a better performance rating
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than the one received for the Fire Protection and Housekeeping func-tional area. At a minimum, we expect the text of the final SALP Report to more acc'urately reflect the high degree of management atten-tion and true level of responsiveness to this issue that Vermont Yankee has displayed.
Vermont Yankee took and continues to take an aggressive leadership position in completing compliance with Appendix R and looks forward to a prompt review by NRC of the " Safe Shutdown Capability Analysis Report" such that the steps we are now taking based on that report can be concluded as acceptable in meeting the provisions of Section III.G of Appendix R.
-(3) SectionIII.A,OverallFacilityEvaluatien(Page6_)_
The' SALP Report states that, "tnis assessment noted numerous personnel errors during the performance of routine duties in the surveillance radiological controls, operating and refueling functional areas. The errors resulted-from either a lack of attention to details during perfor-mance of routine duties or an over-reliance on experience as a substitute for strict adherence to established procedures."
m- _
IV.S. Nuclcar R;gulatory Comissicn
. March 1, 1985 Pag] 8 We clearly recognize the need for continued management attention and involvement to minimize the instances of human error. Events resulting from human error are and will continue to be evaluated to determine if pro-cedural, policy, programmatic, or design changes are warranted. We will' continue to focus our attention at minimizing the instances and consequen-ces of human error.
Again, we appreciate meeting with you and the Board to discuss the subject report and to reaffirm Vermont Yankee management's continued commitment to the safe and efficient ' operation of the Vermont Yankee Nuclear Power Station. Be assured _that although we do not always agree with your assessment findings, we will always be responsive to your concerns of safety and/or compliance. We view your assessment of our-performance as positive input to enable us to carry out our commitments and responsibilities. We hope'you consider our feedback as positive input into your evaluation / assessment process.
Very. truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION W wy Warren P Murphy V Vice President and Manager.of_ Operations WPM /dm O
ENCLOSURE 1 VERMONT YANKEE /NRC CHRON0 LOGY OF EVENTS REGARDING APPENDIX R TO 10CFR50 Since the inspection of August 29/ September 2, 1983, Vermont Yankee has taken many steps in its attempt to comply with NRC requirements. These steps include:
- 1. September 1983 - Began a review of Appendix R and the licensing correspon-dence in order to understand why part III.G had not been applied to the Reactor Building.
- 2. October 1983 - Concluded that, per Appendix R, the entire plant should have been re-examined for compliance with III.G. Began re-survey. Generic letter 83-33 issued.
- 3. November 1983 - Received written results of inspection. Studies and
. reviewed inspection results in detail with management.
Completed first draft of " Analysis to Demonstrate Safe-Shutdown Capability During and After Fires".
Held internal meetings to consider safety implications of the inspection findings.
Attended meeting with Region I staff to demonstrate that continued safe operation of the plant was possible and justified, based on the low proba-bility of the adverse safety effects from the non-conforming areas and the redundant safe shutdown capabilities of the plant. The plant was allowed to continue operating. The NRC Region I Report confirming continued safe operation was received in January 1984.
4 December 1983 - Continued to exanine re-survey. Scoped design changes and exemptions to correct inspection deficiencies. Held internal management
-and engineering meeting to discuss status of Appendix R.
- 5. January 1984 - Attended Enforcement Conference at Region I. Committed to completing design changes to correct inspection deficiencies by Dece:aber 1984
- 6. February 1984'- Plant and NSD engineers attended the Fire Protection Seminar in Washington, D.C. These engineers met informally with NRC staff
--the~ day before the seminar to review draft exemption requests relative to inspection items.
- 7. March 1984 - Formally submitted exemption requests relative to Inspection Report 83-26 commitments.
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ENCLOSURE-1 v.
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- 8. April 1984 - Engineers attended Region I Regional Workshop and also met
' informally with NRR staff for scoping comments, as the workshop indicated that drafts of studies on III.G compliance were to be informally submitted to the staff and discussed before formal submittal.
9.. April 1984 - Meeting on Appendix R was held during which management directed the engineering staff to expand the scope of the III.G.2 re-survey to include random loss of off-site power.
- 10. May-1984 - Held scheduled and follow-up conference with Region I staff.
The NRC minutes of this meeting note that the meeting was at Vermont Yankee's request. Vermont Yankee was only required to commit to a schedule within thirty days of the meeting with NRR staff to review the draft work on III.G. The NRR meeting has not yet taken place.
Vermont Yankee committed to Interim Compensatory Measures at this time.
The need for these measures had only been clarified at the Regional Workshop.
'11. Mid-July 1984 - Conducted formal re-survey, circuit separation, and asso-ciated circuit analyses.
12.- July 1984 - Completed minor changes to Alternate Shutdown System and declared it operational per required schedule.
Made changes to two plant. circuits so that plant would conform to the inspection and. associated circuits study. One change addressed an inspec-tion firding. One change resulted from the associated circuits study.
- 13. August 1984 - Completed design scoping of corrective measures based on re-survey and associated circuits study. Began drafting report and optimizing-solutions.
14 September 1984 - Informed NRC Region I of progress. Implemented additional Interim Compensatory. Measures.
'15. November 1984 - Submitted draft " Safe Shutdown Capability Analysis" to NRR and Region I staffs, per process indicated at regional workshops.
Extensive color photographs included.
- 16. . January 1985 - Completing installation of design changes to address Inspection Report commitments. Began design change on additional emergency lighting, made necessary by findings of draft " Safe Shutdown Capability Anaysis Report".
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" ' ' ' - ENCLOSURE 1
- 17. February 1985. - Completed installation of all modifications detailed in March.14 1984 Inspection Report response letter.
- 18. .In Progress - Completing installation of additional modifications detailed in the " Safe Shutdown Capability Analysis Report". Preparing formal exemp-tion requests- for submittal to NRR. Completing necessary procedural
, changes as detailed in the Analysis Report. Continuing with interim com-
~ pensatory measures until all actions complete.
- 19. - September 1983'through Present - Scope and status of engineering efforts to address Appendix R inspection findings were discussed at routine monthly meetings held between L Vermont Yankee and Yankee Atomic Electric Company engineers _ and management.- These monthly neetings are held to discuss the scope and status of ongoing engineering activities.
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