ML20140G255

Forwards Rev 1 to VRR-1 for Third Insp Interval IST Relief Request.Withdrawal of Relief Request VRR-7,requested

ML20140G255
Person / Time
Site:	Maine Yankee
Issue date:	06/09/1997
From:	Hebert J Maine Yankee
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
JRH-97-156, MN-97-75, NUDOCS 9706160086
Download: ML20140G255 (4)

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MaineYankee l REll ABLE ELECT AICITY SINCE 197_2

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329 BATH ROAD + BRUNSWICK, MAINE 04011 + (207) 798-4100 June 9,1997 i

MN-97-75 JRH-97-156 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, D.C. 20555  !

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References:

(a) License No. DPR-36 (Docket No. 50-309)

(b) Letter, Maine Yankee to USNRC, " Maine Yankee Inservice inspection and Inservice Testing Programs for the Third Inspection Interval,"

dated February 2,1993 (MN-93-13) l (c) Letter, USNRC to Maine Yankee, " Maine Yankee Inservice Test Program for the Third Inspection Interval Relief Requests," dated June 1 17,1994 l (d) Letter, Maine Yankee to USNRC," Third Inspection Interval IST Relief i Requests and IST Program Anomalies," dated February 23,1996 (MN- l 96-22) i

Subject:

Third Inspection Interval IST Relief Requests (VRR-1 & VRR-7) l Gentlemen:  !

L l Reference (c) conditionally granted or authorized as acceptable for implementation the IST i program relief requests submitted, in part, by Refersnce (b). This a? proval and

! authorization was conditioned upon the resolution of the action items identifiec in Appendix A (IST Program Anomalies) of the TER within one year of the date of the SER, or by the end of the next refueling outage, whichever is later. Reference (d) responded to the i anomalies and provided a revision of the complete Maine Yankee IST Program including i outstanding program changes and completion schedules.

! In addition, Reference (d) requested reconsideration of Relief Request VRR-1. Reference i (c) had approved this Relief Request pursuant to 10CFR50.55a(f)(4)(iv), which allows the use of later approved editions of the code. This approval was conditioned upon the i implementation of all related requirements of OM-10. In Reference (d), Maine Yankee l provided additional justification for approval of VRR-1. Upon further consideration, Maine i Yankee has decided to commit to the full implementation of OM-10; specifically paragraphs

! 1.3, 3.1 through 3.6 and 4.2.1.3 through 4.2.1.9 in reference to VRR-1. The full I l implementation of OM-10 will require a complete revision of the ap?ticable test procedures '

l' and program documentation. Maine Yankee proposes a scheduleciimplementation of OM-10 during Cycle 16 with a scheduled completion by the end of the next refueling outage.

It is believed that a scheduled implementation during the next cycle will increase our margin of safety by allowing proper planning and execution of OM-10 requirements. In the intenm, Maine Yankee proposes the use of IWV-3417 acceptance criteria in conjunction i

with the related corrective actions of OM-10. Attached is a revision to VRR-1 which reflects this proposed relief and commitment. Maine Yankee believes the proposed alternative to be an increased benefit to safety over the required corrective actions of IWV, in the interim

time period prior to full implementation of OM-10, 1 i 9706160086 970609

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MaineYankee

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l UNITED STATES NUCLEAR REGULATORY COMMISSION MN-97-75  !

l Attention: Document Control Desk Page Two i i

l Reference'(d) also requested Relief Request VRR-7 to obtain-relief from the tyalcal  ;

. suggested methods of observing the obturator movement / position for three check va ves.  :

Upon further consideration, Maine Yankee has decided to withdraw Relief Request VRR-7 l

1 based.upon the availability of non-intrusive testing techniques for performing these observations.

l Please contact us should you have any questions regarding this matter. l I

Very truly yours, m Q<

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I dames R. Hebert, Manager L Licensing and Engineering Support

!. Attachments l c: Mr. Hubert Miller Mr. Jimi T. Yerokun Mr. Daniel H. Dorman Mr. Patrick J. Dostie Mr. Uldis Vanags l

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i ATTACHMENT b

1 VALVE RELIEF REQUEST VRR-1 .

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REVISION 1 I

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l MAINE YANKEE ATOMIC POWER COMPANY DOCKET NO. 50-309 l JUNE 1997 f

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.s MYAPCo IST PROGRAM VALVE RELIEF REQUEST VRR-1, Revision 1 l NUMBER:

i GENERIC RELIEF REQUEST:

in accordance with 10CFR50.55a (a)(3)(i), Maine Yankee requests relief for valves l requiring stroke timing from the use of previous test values to the use of a fixed reference value for the basis of determining increased test frequencies.

CODE REQUIREMENT: .

lWV-3417 "For power operated valves, an increase in stroke time of 25% or more from the previous test for valves with full-stroke times greater than 10 seconds or 50% or more for valves with full-stroke times less than or equal to 10 seconds is observed, test frequency shall be increased to once each month until corrective action is taken, at which time the original test frequency shall be resumed."

RELIEF REQUEST Relief is requested from the requirement to use the previous test results for the basis of increased test frequency. The use of a fixed reference value determined from the results from several previous tests would be used instead.

BASIS FOR RELIEF:

Using a fixed reference value provides a more logical and stringent basis for determining corrective action. This value is determined from the results of previous l '

tests established when the valve was known to be operating acceptably and represents a proper perspective of the valves' normal actuation time.

ALTERNATE TEST:

A fixed reference value based on the results of the previous tests when the valve was known to be operating properly, will be assigned to the valve. These values will be based on historical valve stroke trends during the Second Interval IST Program.

Until the next refueling outage, if a fixed reference value is exceeded by either: l

a. 25% or more for those reference values greater than 10 seconds, or

b. 50% or more for those reference values less than or equal to 10 seconds, the corrective actions of OM-10 for valve stroke timing will be applied, namely paragraph 4.2.1.9.

During the next refueling outage, the related requirements of OM-10, namely Paragraphs 1.3,3.1 through 3.6 and 4.2.1.3 through 4.2.1.9 will be implemented.

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