ML20065K651
| ML20065K651 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 08/22/1990 |
| From: | Sterzinger G VERMONT, STATE OF |
| To: | Fairtile M NRC |
| Shared Package | |
| ML20065K639 | List: |
| References | |
| NUDOCS 9012040035 | |
| Download: ML20065K651 (2) | |
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STATE OF VERMONT
. DEPARTMEST OF PUBUC 3ERVICE 120 STATE STPIET MONTPEUER ST 05602 TEL 802 828 2811 FAX: 802-828 2M2 i
August 22, 1990 License DPR-28 (Dicket No. 50-271)
Morton Fairtile, Project Manager U.S. Nuclear' Regulatory Commission Washington, D.C.
20555
Subject:
State Comments in Accordance with 10 C.F.R. S 50.91
Reference:
. (1) NRC Letter dated September 7, - 1989 ~, " Issuance of' Amendment' 115 to Facility Operating License No.
DPR-28 Vermont Yankee Nuclear Power Station (2)~ Vermont Letter dated February 9,
- 1989, j
" Comments on Proposed Modification to Appendix A of;the Operating License -- Valve Testing
Dear Mort:
~
We have ~ completed. our review of Amendment.115 as described in 1 Reference. (1). '
We.are concerned.that our-comments, provided'in-Reference (2) appear not to have been addressed.
The cover letter of Reference.(1) includes the following statement:-
"By letter dated February.9, 1989, the State of Vermont-made: comments on the proposed license amendment. The NRC
. staff considered,these comments in their review..
Our j.
enclosed.'. Safety Evaluation reflects this consideration r-of'the State's comments."
L However, a review of the " enclosed Safety Evaluation" does not
--yield,,even by.the most generous interpretation, any inkling that.
the-State's. comments have~been addressed.
9012040035 901128 I
PDR ADOCE 0500027l 1
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As you know, the State Consultation provisions of 10 C.F.R. S 50.91 are an important component of the State / Federal interface in the area of radiological health and safety.
We are keenly aware that the State consultation procedures do not give the State the right to veto the Commission's proposed or final determination (10 C.F.R.
S 50.91(c)).
Yet without thoroughly and clearly resolving comments when provided, a State is left with litigation as the only alternative for resolution of its concerns.
We feel our comments in Reference (2) are well-founded, serious concerns regerding the proposed amendment and the NRC staff's control of primary containment isolation valve testing on the subject pages of the amendment, and we have yet to be informed regarding the resolution of these comments.
Consequently, we request an explanation of the statement from Reference (1):
How '
did "[t]he NRC staff consider () these comments in their review"?-
Further, what is the resolution of each of Vermont's comments in Reference (2)?
We appreciate your attention regarding this important matter.
Should you have questions please call Mr. William Sherman of our staff.
Sinc /l
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DEP ARTMENT OF PUBLIC SERVICE 120 ST ATE STREET 4
ST ATE OFFICE SUILDING MONTPELIER 01402 m.eenoneesii f
February 9, 1989
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License DPR-28 (Docket No. 50-271)
Morton Fairtile, Project Manager U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Subject:
Comments on Proposed Modification to Appendix A of the Operating License -- Valve Testing l
Dear Mr. Fairtiles We have reviewed the licensee request for modification of Appendix A to the Operating License (Vermont Yankee l-letter--BVY 89-14, dated February 2, 1989), and make the following comments pursuant to-Section 50.91 of the Commission's Rules and Regulations.
The proposed modification is a request to delete three l
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l RHR systems valves from Technical Specification Table 4.7.2.b
-pertaining to primary containment isolation valves not subject to' Type C leakage tests.
The proposed modification is characterized as an administrative follow-up to previously ll approved physical modifications.
Our review of this proposed ir.odification encompassed Technical Specification Tables'4.1.2.a and 4.7.2.b which define Type C testing applicabiliny, and the appropriate portions of Technical Specificaticr. 3.7/4.7 which refer to l,
the above mentioned Tables.
Our comments'are'as follows:
I 1.
If approval is granted to remove valves RHR-32, RHR-33 and Valve 10-29 from. Table 4.7.2.b, the penetration should be listed on Table <4.7.1 and made. subject to Type B-testing.
2.
The relationship between Tables 4.7.2.a and 4.7.2.b, and their consistency.with FSAR Table 5.2.2 is. unclear.
No Bases is provided to-explain why any of the valves listed'in Table 4.7.2.b:are excluded from Type C tests.
A number of valves are identified in FSAR Table h$
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M 5.2.2 as containment isolation valves which do not appear on either Tables 4.7.2.a or 4.7.2.b.
i Our review concentrated specifically on core m
spray' inlet valves.to the reactor (CS-13A, B;
- CS-12A, B),;which appear in FSAR Table 5.2.2,
' but not in Technical Specification Tables 4.7.2.a and 4.7.2.b.-
A canvas.of other Mark I l
BWR's (Pilgrim, Duane Arnold) indicated that core spray valves are included in their Type C programs.
Further review indicated an unresolved regulatory history (Vermont Yankee Proposed License Change 121, 2/26/84; NRC Request for Additional Information, 2/14/86; Vermont Yankee Response, 10/10/86).
We believe that, coincident with this proposed modification, NRC should require the licensee to:
- 1) establish consistency between Technical Specifications and FSAR, 2) assure that all appropriate valves are included within the Type C program, and 3,'
require that exceptions to
.the Type C prograx (Table 4.7.2.b) are docu-mented in the Bases section.
3.
Technical Specifications 3.7.D.1, 4.7.D.1.a
. (1), 3.7.D.2, and 4.7.D.2 refer to Table 4.7.2, which does not exist.
This should be corrected L
with the proposed modification.
L We ut ge your consideration of these comments, and L
specifically Comment No. 2.-
We are. concerned that certain b
valves which should be included within the-Type C program may not be included,-leading to greater than measured leakage.
- We are further concerned about the application of_ Technical.
~ Specification 3.7.4,.regarding acceptable leakage during.
cm operation, and'that operation may continue if valves not G
' included on' Tables 4.7.2.a or 4.7.2.b are leaking at. levels
- greater than this LCO.
We appreciate.the opportunity to provide comments.
If-you.have questions, please call Mr. William Sherman of our
.c.
staff at-(802) 828-2811.
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eor e er-Commis e
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.Mrs. M. Miller, NRC Region I lur. G. Grant, NRC Resident, VY l
Mr. W. Murphy, VY I
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