BVY-96-121, Responds to Concerns Expressed Re Util EOP Program as Identified in Insp Rept 50-271/96-05

Responds to Concerns Expressed Re Util EOP Program as Identified in Insp Rept 50-271/96-05

ML20129C428
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	10/16/1996
From:	Wanczyk R VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BVY-96-121, NUDOCS 9610240024
Download: ML20129C428 (2)

Text

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o V8RMONT YANKEE NUCLEAR POWER CORPORATION P.O. Box 157, Governor Hunt Road

,(q q\\,,f Vernon, Vermont 05354-0157 (802) 257-7711 October 16, 1996 j

BVY %-121 United States Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Referencer (a)

License No. DPR-28 (Docket No. 50-271)

(b) letter, USNRC to VYNPC, Inspection Report No. 50-271/ % -05, NVY %-108, dated 6/19/96 (c)

Ixtter, VYNPC to USNRC, BVY 95-137, dated 12/20/95 (d)

Letter, USNRC to VYNPC, NVY %-139, dated 8/16/%

SUBJECT:

Emergency Operating Procedure Issues J

The purpose of this letter is to respond to your concerns expressed in Reference (b), regarding the Vermont Yankee Emergency Operating Procedure (EOP) Program. As was discussed during our meeting at King of Prussia on September 16, 1996, we share similar concerns and have taken steps to address them.

We believe the cause for the continuation of problem identification 2nd timeliness of their resolution is attributed to unnecessarily complex and cumbersome administrative controls, and insufficient management oversight of our EOP maintenance and revisio 1 process.

Nevertheless, based on verification and validation of our EOPs and their use in our licensed-operator simulator training programs, we remain confident that our EOPs adequately control and mitigate the entire spectrum of postulated events.

To address the shortcomings and upgrade our EOP program to be consistent with the highest industry standards, we have implemented the following action plan:

(1)

The technical justifications for the deviations discussed in section 5.12 of Reference (b), have been developed and incorporated into the Procedure-Generation Package (PGP).

(2)

An independent review of EOP support calculations has been performed and all program or procedural changes identified as a result of this effort have been implemented.

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ACD% O 9610240024 961016 PDR ADOCK 05000271 F

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e VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission October 16,1996 Page 2 (3)

A comprehensive assessment of our entire EOP program to identify additional improvement opportunities has been initiated. This assessment will include:

Comparison of BWR Owncrs Group Emergency Procedure Guidelines a.

(EPG) Rev.4 with the Plant Specific Technical Guidelines (PSTG) to ensure all differences are properly identified and justified in the PGP, b.

Review of the EPG to PSTG, and PSTG to OE differences appendices, The Verification and Validation (V&V) program, including more specific c.

qualifications and experience criteria for those individuals that provide oversight of V&V implementation, d.

Review of the EOP Program administrative controls, including an assessment of the maintenance and revision process.

(4)

An individual, who is knowledgeable in this subject area has been assigned full i

time responsibility for the completion of this action plan. This individual reports directly to the Operations Manager, the line manager responsible for the EOP functional area.

Our objective is to complete this action plan and have our program ready for followup inspection in April 1997.

We trust that the information provided is responsive to your concerns; however, should you require any additional information, please contact this office.

Sincerely, NT YANKEE NUCLEAR POWER CORPORATION Ae to Robert J. Wanczyk Plant Manager CC:

USNRC Region 1 Administrator USNRC Resident Inspector - VYNPS USNRC Project Manager - VYNPS