ML20057A698

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Forwards SE of IST Program for Pumps & Valves at Plant for Third 10-yr Insp Interval
ML20057A698
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 09/03/1993
From: Dan Dorman
Office of Nuclear Reactor Regulation
To: Reod D
VERMONT YANKEE NUCLEAR POWER CORP.
Shared Package
ML20056D272 List:
References
TAC-M85067, NUDOCS 9309150169
Download: ML20057A698 (5)


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L UNITED STATES (gg/

NUCLEAR REGULATORY COMMISSION W A S H IN G T O N. D. C 205S5-0001 Septenber 3, 1C93 Docket No. 50-271 Mr. Donald A. Reid, Vice President Operations Vermont Yankee Nuclear Power Corporation Ferry Road Brattleboro, Vermont 05301

SUBJECT:

SAFETY EVALUATION OF THE INSERVICE TESTING PROGRAM RELIEF REQUESTS FOR PUMPS AND VALVE:

VERMONT YANKEE NUCLEAR POWER STATION (TAC N0. M85067)

By letter dated November 30, 1992, Vermont Yankee Nuclear Power Corporation submitted the inservice testing (IST) program for pumps and valves at Vermont Yankee (VY) for the third ten-year inspection interval.

This submittal also contained a relief request (RR-01) that would extend the end of the second ten-year inservice inspection (ISI) and IST intervals from November 30, 1992, to August 31, 1993 (i.e., 9 months). The NRC responded to RR-01 by letter dated April 6,1993, indicating the acceptability of the interval extension.

The updated program for the licensee's third ten-year interval contained 20 requests for relief from specific testing requirements of the Code.

The Code of Federal Regulations,10 CFR 50.55a, requires that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where alternatives are authorized or relief is granted by the Commission pursuant to 10 CFR 50.55a(a)(3)(i), 10 CFR 50.55a(a)(3)(ii), or (f)(6)(i).

In order to obtain authorization or relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety, (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, or (3) conformance is impractical for its facility.

Guidance on acceptable alternatives to Section XI requirements was provided in Generic Letter (GL) 89-04, " Guidance on Developing Acceptable Inservice Testing Programs," for certain aspects of IST.

Furthermore, in rulemaking to 10 CFR 50.55a effective September 8, 1992, (See 57 Federal Reaister 34666), the 1989 Edition of ASME Section XI was incorporated in paragraph (b) of 50.55a. The 1989 Edition provides that the rules for IST of pumps and valves shall meet the requirements set forth in ASME Operations and Maintenance Standards Part 6 (OM-6), " Inservice Testing of Pumps in Light-Water Reactor Power Plants," and Part 10 (OM-10), " Inservice Testing of Valves in Light-Water Reactor Power Plants." Pursuant to 50.55a(f)(4)(iv), portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met, and therefore, relief is not required for those IST that are conducted in accordance with OH-6 and OH-10, or portions thereof. Whether all related

%g'y 8 requirements are met is subject to NRC inspection.

In response to a request 7por i

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, Donald A. Reid september 3, 1993 by the licensee dated August 13, 1992, the staff approved the use of OM-6 and OM-10 for the Vermont Yankee Nuclear Power Station third ten-year interval IST program pursuant to 10 CFR 50.55a(f)(4)(iv) (reference NRC letter dated September 2, 1992). is the staff's safety evaluation (SE) and Enclosure 2 to the SE is the technical evaluation report (TER) prepared by EG&G Idaho, Inc.

The staff is granting relief from certain testing requirements that are impractical to perform and authorizing proposed alternatives where compliance r

would result in a hardship without a compensating increase in safety or where l

the alternative testing provides an acceptable level of quality and safety.

The second ten-year interval for VY ended on August 31, 1993. Therefore, the licensee should have its revised program implemented. The IST program RR for VY in the referenced submittal are acceptable for implementation provided:

(1) the anomalies identified in Appendix A of the TER are addressed in the revised ten-year interval updated program, as applicable, and (2) the procedural or program changes covered in the anomalies are completed in j

accordance with the revised interval program. The licensee is expected to i

take action on (as appropriate) and respond to these seven anomalies within 1 year or by the end of the next refueling outage, whichever is later. The l

granting of relief or authorization of alternatives is based upon the fulfillment of any commitments made by the licensee in the basis for each RR and the alternatives proposed.

Program changes involving new or revised requests for relief or authorization of alternatives should not be implemented prior to approval by the NRC. New l

or revised requests that meet the positions in GL 89-04, Attachment 1, should be submitted to the NRC but can be implemented provided the guidance in l

GL 89-04, Section D is followed.

Program changes that add or delete i

components from the IST program should also be provided to the NRC.

Sincerely, i

Original signed by:

l Daniel H. Dorman, Project Manager Project Directorate I-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation i

Enclosure-l Safety Evaluation, w/ attachment cc w/ enclosure:

i See next page

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Donald A. Reid September 3, 1993 r

by the licensee dated August 13, 1992, the staff approved the use of OM-6 and OM-10 for the Vermont Yankee Nuclear Power Station third ten-year interval IST program pursuant to 10 CFR 50.55a(f)(4)(iv) (reference NRC letter dated September 2, 1992).

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I is the staff's safety evaluation (SE) and Enclosure 2 to the SE is the technical evaluation report (TER) prepared by EG&G Idaho, Inc.

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The staff is granting relief from certain testing requirements that are impractical to perform and authorizing proposed alternatives where compliance would result in a hard; hip without a compensating increase in safety or where the alternative testing provides an acceptable level of quality and safety.

The second ten-year interval for VY ended on August 31, 1993. Therefore, the licensee should have its revised program implemented. The IST program RR for 2

VY in the referenced submittal are acceptable for implementation provided:

1 (1) the anomalies identified in Appendix A of the TER are addressed in the revised ten-year interval updated program, as applicable, and (2) the procedural or program changes covered in the anomalies are completed in accordance with the revised interval program.

The licensee is expected to take action on (as appropriate) and respond to these seven anomalies within 1 year or by the end of the next refueling outage, whichever is later.

The granting of relief or authorization of alternatives is based upon the

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fulfillment of any commitments made by the licensee in the basis for each RR 2

and the alternatives proposed.

't Program changes involving new or revised requests for relief or authorization of alternatives should not be implemented prior to approval by the NRC. New or revised requests that meet the positions in GL 89-04, Attachment 1, should be submitted to the NRC but can be implemented provided the guidance in GL 89-04, Section D is followed.

Program changes that add or delete components from the IST program should also be provided to the NRC.

R Sincerely, b

LW Daniel H. Dorman, Project Manager Project Directorate I-3 l

Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

Enclosure:

Safety Evaluation, w/ attachment 1

cc w/ enclosure:

See next page 1

J

l Mr. Donald A. Reid, Vice President Vermont Yankee Nuclear Power Station Operations l

CC:

Mr. Jay Thayer, Vice President G. Dana Bisbee, Esq.

Yankee Atomic Electric Company Office of the Attorney General 580 Main Street Environmental Protection Bureau Bolton, Massachusetts 01740-1398 State House Annex 25 Capitol Street Regional Administrator, Region I Concord, New Hampshire 03301-6937 l

U. S. Nuclear Regulatory Commission 1

475 Allendale Road Resident Inspector King of Prussia, Pennsylvania 19406 Vermont Yankee Nuclear Power Station i

3 U.S. Nuclear Regulatory Commission R. K. Gad, III P. O. Box 176 Ropes & Gray Vernon, Vermont 05354 One International Place Boston, Massachusetts 02110-2624 Chief, Safety Unit Office of the Attorney General i

Mr. Richard P. Sedano, Commissioner One Ashburton Place,19th Floor j

Vermont Department of Public Service Boston, Massachusetts 02108 120 State Street, 3rd Floor j

Montpelier, Vermont 05602 Mr. David Rodham, Director i

Massachusetts Civil Defense Agency Public Service Board 400 Worcester Rd.

j State of Vermont P.O. Box 1496 120 State Street Framingham, Massachusetts 01701-0317 Montpelier, Vermont 05602 ATTN: James Muckerheide i

Chairman, Board of Selectmen Mr. Raymond N. McCandless 4

Town of Vernon Vermont Division of Occupational l

Post Office Box 116 and Radiological Health l

Vernon, Vermont 05354-0116 Administration Building l

Montpelier, Vermont 05602 Mr. J. P. Pelletier, Vice President Vermont Yankee Nuclear Power Mr L. A. Tremblay l

i Corporation Senior Licensing Engineer a

Ferry Road Vermont Yankee Nuclear Power l

Brattleboro, Vermont 05301 Corporation 580 Main Street i

3;.

Bolton, Massachusetts 01740-1398 i

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F DISTRIBUTION:

Docket File NRC & Local PDRs PDI-3 Reading T. Murley/F. Miraglia J. Partlow E. Rossi J. Lieberman S. Varga J. Calvo W. Butler S. Little D. Dorman OGC E. Jordan G. Hill (2 copies)

ACRS (10)

OPA OC/LFDCB V. McCree, EDO J. Linville. RI D. Fischer f

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