ML20195F946

Supplement to 990416 Proposed Change 213 for License DPR-28, Allowing Use of Amse Code Case N-560,in Lieu of Certain Provisions of GL 88-01

ML20195F946
Person / Time
Site:	Vermont Yankee
Issue date:	06/09/1999
From:	Wanczyk R VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20195F951	List: ML20195F946 ML20195F953
References
BVY-99-62, GL-88-01, GL-88-1, NUDOCS 9906150144
Download: ML20195F946 (8)

Text

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VERMONT YANKEE r y7 NUCLEAR POWER CORPORATION

' 185 Old Ferry Road, Erottleboro, VT 05301-7002 I (802) 257-5271 i

June 9,1999 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 j l

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References:

(a) Letter, VYNPC to USNRC, " Proposed Change No. 213 - Generic Letter 88-01 and Use of Code Case N-560," BVY 99-13, dated April 16,1999. j (b) NRC Generic Letter 88-01, "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping," NVY 88-09, dated January 25,1988.

(c) American Society of Mechanical Engineers (ASME) Boiler and Pressure ,

Vessel Code Section XI,1986 Edition, " Rules for Inservice Inspection of j Nuclear Power Plant Components" (d) ASME Code Case N-560, "Altemative Examination Requirements for  ;

Class I, Category B-J Piping Welds," approved August 9,1996. 1 (c) Letter USNRC to VYNPC, " Request to Use Code Case N-560 as an Alternative to the Requirements of ASME Code,Section XI, Table IWB-2500-1 At VYNPC (TAC No. M99389)," NVY 98-155, dated November 9, 1998.

Subject:

Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271) l Supplement to Submittal of Proposed Change No. 213  ;

Generic Letter 88-01 and Use of Code Case N-560

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l Pursuant to 10CFR50.90, Vermont Yankee (VY) submitted Reference (a) proposing changes to

! the VY Technical Specifications (TS) to allow use of ASME Code Case N-560, which was approved by the NRC via Reference (c), in lieu of certain provisions of Generic Letter (GL) 88- l l

01. In a telephone conversation with VY's NRC Project Manager on April 23,1999, VY was )

advised that the Staff would prefer wording in the TS that is more representative of the specific circumstances of the required change. VY had proposed more general wording that was intended to facilitate adoption of future NRC-approved alternatives to our GL 88-01 commitment.

' Accordingly, VY has revised the afTected TS pages and the Description of Changes to address the Staffs request. In addition, the Determination of No Significant Hazards Consideration has been clarified to confirm that the proposed language is administrative in nature because it simply conforms the TS to agree with the previous Staff approcal for use of Code Case N-560 at VY, as documented in Reference (e). VY has reviewed the modifications to the Reference (a) submittal l in accordance with 10CFR50.92 and concludes that these updates do not adversely affect the {3 l

previous conclusion that no significant hazards considerations exist, f['

VY has also reviewed the modifications to Proposed Change No. 213 against the criteria of l 10CFR51.22 for environmental considerations and concludes that the modifications do not g adversely affect the previous belief that the proposed change is eligible for categorical exclusion from the requirements for an environmental impact statement in accordance with -[

10CFR51.22(c)(9).

9906150144 990609 f^ -,,

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• VI'.HMoNT YANhi',l'. Nt'ca. :.Au l'ows.n CouronriloN BVY 99-62 / Page 2 of 2 The cttached pages completely replace and supersede the original Attachment 1, " Supporting Information and Safety Assessment for Proposed Change," Attachment 2, " Determination of No Significant Hazards Consideration," Attachment 3, " Marked-up Version of the Current Technical Specification Pages," and Attachment 4, " Retyped Tecimical Specification Pages," that were submitted with Reference (a). Please discard the original pages and replace them with the revised pages included with this submittal.

if you have any questions regarding this submittal, please contact Mr. Wayne M. Limberger at (802) 258-4237.

Sincerely, VLRMONT YANKEE NUCLEAR POWER CORPORATION r( . A+M RobertJ.han zyk Director ot'Mfety and Regulatory Affairs Attaciunents cc: USNRC Region 1 Administrator .

USNRC Resident Inspector-VYNPS p 34 l USNRC Project Manager- VYNPS Vermont Department of Public Service V NOTAm  ;

STATE OF VERMONT - ) g pgggg WINDHAM COUNTY o Then personally appeared before me, Robert J. Wanczyk, who being du cig g he is Director of Safety and Regulatory Affairs of Vermont Yankee Nuclear Power le is duly authorized to execute and file the foregoing document in the name and on the behalf of Vermont Yankee Nuclear Power Corporation, and that the statements therein are true to the best of his knowledge and belief.

Y h.b!W Sally A. Sadistrum Notary Public

Docket No. 50-271 BVY 99-62*

s Attachment 1 Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 213 Generic Letter 88-01 and Use of Code Case N-560 Supporting Information and Safety Assessment for Proposed Change _

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• Replaces BVY 99-13. Attachment 1 j

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4 BVY 99-62 / Attachment I /Page 1 DESCRIPTION OF CHANGE

' VY proposes to change the subject Technical Specifications (TS) to be less prescriptive in the manner in which the NRC may grant relief from Section XI requirements, and to conform the TS language regarding GL 88-01 to agree with the NRC's previous approval to use ASME Code Case N-560 at VY.

The proposed change is as follows:

-3 Technical Specification 4.6.E.1 states, " Inservice inspection of piping, identified in GL 88-01, shall be performed in accordance with the staff positions on schedule, methods, and personnel and sample expansion included in the Generic Letter." VY proposes to add a caveat to the end of that sentence, stating, "except that sample selection for the scope of Category A welds may be in accordance with ASME Code Case N-560."

In Technical Specification 4.6.E.l' the words, " pursuant to 10CFR50, Section 50.55a(gX6Xi)" will be stricken following "except where specific written relief has been granted by the NRC."

Because the NRC has provided an acceptable alternative to criteria inherent in both ASME Section XI and GL 88-01 by approving AFME Code Case N-560 for use at VY, it is necessary to

- clarify the applicability of Code Case N-560 to GL 88-01 in the VY Technical Specifications.

Furthermore, Technical Specification 4.6.E.1 allows relief from ASME Section XI requirements to be granted by the NRC only under 50.55a(gX6Xi). It is inappropriate to reference only one paragraph from 10CFR50.55a when other paragraphs may be applicable to the granting of relief.

This proposed change will serve to clarify this stipulation as well.

REASON FOR CHANGE VY has received NRC approval to use ASME Code Case N-560 in association with inservice inspection of Class 1, Category B-J, piping welds [see Reference (d)) under ASME Section XI.

All of VY's ASME Category B-J piping welds are also Category A piping welds as defined in GL88-01. This Case reduces the 25% inspection sample required by both ASME Section XI and GL 88-01 to 10%, while stipulating selection of that sample in accordance with a risk-informed analytical methodology. The Technical Specifications specifically reference the staff positions on schedule, methods, personnel and sample expansion in GL 88-01. Approval of Code Case N-560 affects the sampling requirements of GL 88-01 by allowing altenative sample selection criteria for Class 1 Category B-J (GL 88-01 Category A) piping welds.

BASIS FOR CHANGE The NRC has approved the use of Code Case N-560 for VY in a Safety Evaluation Report (SER) provided in Reference (d).' The basis for the change from the ASME Section XI and GL 88-01 criteria are found in that SER.

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BVY 99-62 / Attachment I / Page 2 Draft Guide 1061, as well as DraA SRP Chapter 3.9.8 (Standard Review Plan For The Review Of Risk-Informed In-service Inspection of Piping) and Draft Regulatory Guide DG-1063 (An Approach For Plant-Specific, Risk-Informed Decision Making: Inspection of Piping), identified five principles ofrisk informed regulation. They are:

1. Meet current regulations,

2. Maintain defense in depth, j

- 3. Maintain sufficient safety margins, i

4. Proposed increase in risk (including cumulative effects) is small, NRC goals are not exceeded,and

5. Performance-based implementation and monitoring strategies.

The basis for meeting each of the above five principles is detailed in the referenced SER.

Because an NRC-approved alternative approach may be applied to the 25% sample inspection criterion of ASME Section XI, Table IWB-2500-1 for Class 1, Category B.J welds, this approval is also considered to be applicable to the identical criterion in GL 88-01 for Category A welds. l The NRC has approved the Vermont Yankee weld selection process itself and, in addition, the actual sample of welds that have been selected. Note also that, in Section 3.1 of Reference (d),

the NRC concluded that: "In addition to the other Section XI activities not affected by the implementation of N-560 are the augmented inspection programs, such as those made in response to Generic Letter 88-01 (NRC Position on IGSCC in BWR Austenitic SS Piping) and Generic j

' Letter 89-08 (Erosion / Corrosion Induced Wall Thinning)."

SAFETY ASSESSMENT VY has shown that implementation of the Code Case N-560 program would result in an '

l insignificant change in risk even with fewer inspections, since the inspections will take place where degradation mechanisms are more likely to occur, and procedures and personnel will target these specific locations using improved techniques and expanded volumes. These compensatory measures will mitigate and balance the latent risk involved in reducing the number of welds

. subjected to inspection. The NRC staff determined that the alternative method described in VY's submittal (ASME Code Case N-560 as augmented by EPRI TR-106706) provides equivalent or better examination criteria for Class 1 Category B-J welds than that provided by the current Section XI requirements (and by extension, GL 88-01).

Therefore, NRC staff concluded that approval.of VY's proposed alternative would provide an acceptable level of quality and safety, in that the alternative provides reasonable assurance of the structural integrity of the affected components. [ Relief was granted pursuant to 10 CFR 50.55a(a)(3)(i)].

The purpose of this proposed change is to refine the existing Technical Specification wording to be less prescriptive in the manner in which the NRC may grant relief from ASME Section XI requirements and, as it relates to GL 88-01, to eliminate conflict with implementation of the approved Code Case N-560 attemative methodology.

Docket No. 50-271

. . BVY 99-62*

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l Attachment 2 ,

1 Vermont Yankee Nuclear Power Station l

Proposed Technical Specification Change No. 213 Generic Letter 88-01 and Use of Code Case N-560 i

Determination of No Significant Hazards Consideration

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• Replaces BVY 99-13, Attachment 2

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BVY 99-62 / Attachment 2/ Page 1 1

Pursuant to 10CFR50.92, VY has reviewed the proposed change and concludes that the change does not' involve a significant hazards consideration since it satisfies the criteria in 10CFR50.92(c).

't. The ooeration of Vermont Yankee Nuclear Power Station in accordance with the orooosed -

amendment will not involve a sinnificant increase in the probability or consecuences of an accident previousiv evaluated?

His change is only an administrative change that: 1) clarifies the NRC's authority to grant i relief to a specific requirement, and 2) conforms the TS language regarding GL 88-01 to agree with the NRC's acceptance of ASME Code Case N-560 for use at VY. This conclusion isjustified in that:

a) - The pursuit of relief from the ASME code and the imposition of alternative requirements are governed by 10CFR50.55a and require NRC approval. There are several sections in the regulations under which such relief can be granted. The removal of reference to a

. specific section of CFR that may be used to grant relief has no effect on plant equipment or its operation.

b) Adding words to clarify the relationship between GL 88-01 and Code Case N-560 eliminates a contradiction in sample selection criteria and does not affect any equipment or its operation.

These changes can be considered administrative in nature and do not change any of the accident analyses for the facility. Thus, there are no changes to the probability or consequences of accidents previously evaluated.

2. The operation of Vermont Yankee Nuclear Power Station in accordance with the proposed amendment will not create the nossibility of a new or different kind of accident from any accident oreviously evaluated.

The revision of the wording in the TS to generalize the granting of relief to the ASME code does not result in any changes to the plant equipment or its operation. Similarly, adding words to allow use of the NRC approved alternative to the sample selection guidance provided in GL 88-01 does not impact plant equipment or its operation. These changes are administrative in nature and do not result in the creation of any new or different kinds of accidents.

3. The operation of Vermont Yankee Nuclear Power Station in accordance with the orqp_ogd amendment will not involve a significant reduction in a margin of safety.

This change primarily revises the wording in the TS to clarify the NRC's authority to grant

. relief to ASME Section XI requirements. The change maintains the requirement for NRC approval to be obtained for such relief. Secondly, this change conforms the TS language 1 regarding GL 98-01 to agree with a previous relevant NRC disposition [ Reference (e)]. )

These administrative changes do not result in a reduction in any margin of safety. l l

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BVY 99-62 / Attachment 2 / Page 2 l

Vermont Yankee has also reviewed the NRC examples oflicense amendments considered not likely to involve significant hazards considerations as provided in the final adoption of 10CFR50.92 published in the Federd Renister (FR), Volume 51, No. 44, dated March 6,1986.

Example (i) on FR page 7751 provides a dit,cussion of" purely administrative changes", including those proposed to achieve consistency as in the present case, which indicates that it is likely no significant hazards considerations are involved.

On the basis of the above, VY has determined that operation of the facility in accordance with the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92(c), in that it:

1) does not involve a significant increase in the probability or consequences of an accident previously evaluated;

2) does not create the possibility of a new or different kind of accident from any previously analyzed accident; and

3) does not involve a significant reduction in a margin of safety.

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