ML20203A688
| ML20203A688 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 02/04/1999 |
| From: | Maret G VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20203A692 | List: |
| References | |
| BVY-99-10, NUDOCS 9902100068 | |
| Download: ML20203A688 (4) | |
Text
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VERMONT YANKEE r
i NUCLEAR POWER CORPORATION 185 Old Ferry Rood, Brattleboro, VT 05301 7002 (802) 257-5271 February 4,1999 BVY 99-10 United States Nuclear Regulatory Commission NITN: Document Control Desk
)
Washington,DC 20555
References:
(a) letter, VYNPC to USNRC, "Vennont Yankee Operational Quality Assurance Manual (VOQAM) Revision 2," BVY 98-161, dated December 23,1998 (b) letter, VYNPC to USNRC, " Response to Request for Information Regarding Adherence to Quality Assurance Program Provisions," BVY 98-55, dated April 10, 1998.
(c)
NRC Special Inspection Report 50-271/98-80," Notice of Violation and Exercise of Enforcement Discretion, EA 98-333/EA 98-372," dated July 16,1998, as amended July 24,1998.
Subject:
Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Supplement to Submittal of Vermont Yankee Operational Ouality Assurance Manual (VOOAM) Revision 2 in response to NRC questions regarding Reference (a) pasented during a telephone conversation on January 11, 1999, Vermont Yankee (VY) has revised page 17 of 26 (now pages 17 and 18 of 27) of Appendix B to VOQAM Revision 2. The changed pages am enclosed as part of a revised Appendix B, which should be substituted for the version submitted with Reference (a). The Table of Contents and Amendment pages affected by the increase in Appendix B page count am also being resubmitted.
Specifically, VY has addressed NRC QA questions in the following areas:
Ouestion #1:
Does Vermont Yankee intend to apply Section 4.13.1 of ANSS2.1-1983 in its entirety, or only subsection (4)?
Resoonse:
After further consideration, VY has clarified the applicability of Section 4.13.1 of ANS52.1-1983 to specify only subsections (1), (3) and (4), which directly address the Non-Nuclear Safety (NNS) functional obligations of the fuel handling equipment, including correct positioning of fuel bundles, prevention of mechanical damage to the fuel and safehandling of the fuel itself.
Ouestion #2:
. Section 4.13.4 of ANSS2.1-1983 identifies both Safety Class 3 and NNS classifications for the Fuel Handling and Storage system. Is it Vermont Yankee's intent to apply the safety-related provisions to certain of the fuel handling equipment functions and the NNS criteria to the remaining functions, or will the entire subsystem be NNS? 090066
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Response
i The safety-related classification attributed to the Fuel Storage and Handling Equipment in Section 4.13.4 is related to the functions identified in Section 4.13.1 that ensure adequate cooling of the spent fuel. The fuel handling portion of the system does not perform any cooling function, and therefore must meet only the NNS provisions of 4.13.4 and 4.13.1. VY has clarified the applicability of Section 4.13.4 of ANS52.1-1983 4
by stating in general that the NNS criteria and the additional " selected requirements" of the ANS standard l
will be imposed on this equipment, as stipulated in the referenced sections.
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Ouestion #3:
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There is an apparent typographical ermr on page 17 of 26 of Appendix B to VOQAM Revision 2. Should the reference to "3.4.5.2j" read "3.4.5.2" and should the reference to "33.1.4" red "33.1.4.j"?
Response
i VY has changed "3.4.5.2.j" to "3.4.5.2", and has modified the "33.1.4" reference to state "33.1.4, including subsections (h) and (j)". We have exp=A~l the applicability of Section 33.1.4 to include
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subsection (h) henam fuel handling equipment provides an operational function (fuel movement) that involves radioactive material (spent fuel) and is regulated by 10CFR100. (Also see ANS52.1-1983, Appendix A, Table A-1, Section 4.13.c.)
Ouestion #4:
Section 33.1.4 of ANSS2.1-1983 includes Footnote 17 that imposes the criteria contained in Table 3.5 and Section 4, and mentions use of Appendix A for additional guidance. Has Vermont Yankee confirmed that the selected requirements applied under this section satisfy the expectations of the footnote?
Response
VY has clarified the applicability of Section 33.1.4 of ANSS2.1-1983 to include Table 3.5 as required by Footnote 17 [Section 4 of the standard was already addressed in Reference (a) and in the response to Questions #1 and #2; use of the guidance in Appendix A, which is provided for information and is not part i
of the standard, was not necessary for this determination except as noted in the response to Question #3]. A review of Table 3.5 has confirmed that:
- 1) The probability of failure of the fuel handling equipment is acceptably low in that it was
_ specified to be single-failure-proof regarding control of loads; all parts of the crane system were specified to have a design minimum factor of safety of 5 with a capacity hoist load of 1700 lb. with the bridge at rest, moving or stopping; is of all-welded construction insofar as possible; and, where bolts were used, was designed to prevent bolting fmm dropping into the water. (Vendor calculations supporting the design considerations of the purchase specification are on file at VY.) Critical load-bearing and drive-train components (bridge structural members, trolley wheels, drive shafts, gears, sheaves, bolting, etc.) were specified to be manufactured from ASTM materials. Post-installation hardware modifications (anti-turnover brackets and control system components) have further enhanced its reliability (NOTE 4 of Table 3.5).
aVY 9910fage 3 ef 3 VERMONT Y ANKEIC NUCLICAR l'OWF.R CORl*OR ATION
- 2) Table 3.5 Note 5 does'not apply to Sections 3.3.1.4.h or 3.3.1.4.j.
- 3) Original design and fabrication wem performed in accuit r.ce with the AISC Steel i
Construction Manual,7th Edition,1970; each post-installation modification specified AISC requirements commensurate with the edition existing at that time (NOTE 7 of Table 3.5).
l Ouestion #5:
i Vermont Yankee proposes to apply selected QA requirements of ANSI NIS.7-1976 in lieu of selected requirements of NQA-1-1979 as stipulated in section 3.4.5.2 of ANS52.1-1983. Which requirements of ANSI N18.7-1976 will be applied, or, ifit is simpler to describe, which requirements will not apply?
Remonse:
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VY has clarified the reference to ANSI N18.7-1976 by identifying the sections of the standard that would not be applicable under Section 3.4.5.2 of ANS52.1-1983, and the alternate controls that would be imposed.
'Ihe non-applicable sections are 5.2.13.1 and 5.2.13.2.
VY has determined that these clarifications and corrections have no adverse impact on the
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10CFR50.54(a)(3) evaluation performed for submittal of Reference (a).
If you have any questions regarding this submittal, please contact Mr. Wayne M. Limberger at 1
(802) 258-4237.
Sincerely, VERM NUCLEAR POWERCORPORADON h,
ib go Director rations Attachment cc:
USNRC Region 1 Administrator USNRC Resident Inspector-VYNPS USNRC Project M.anager-VYNPS Vennont Department of Public Service M,'-
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VOQAM AMENDMENT / REVISION SHEET Revision N22 Data Reason 0
5/1/98 To adopt Rev. 27 of the YOQAP as Rev. O for the VOQAM. (Reference VY letter to NRC, dated j
4/12/98.)
1 10/16/98 To update organizational changes, removed all references to YAEC and YNSD. VY assumed all YNSD responsibilities. Changed Sr. Vice President, Operations, to Director of Operations.
l 2 12/23/98 Revised Table of Contents /Index to identify l
l number of effective pages in-each VOQAM i
l section. Adopted ANSI N101.4-1972/ Reg. Guide j
1.54 in Section II, page 4 of 7.
Revised l
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l Appendix B, pages 17 and 18 of 27, to address a l
specific application of ANS-52.1-1983.
Revised l
l Appendix B, page 24 of 27, to clarify l
l provisions for initiating procedure changes in l
response to plant events, violations and l
l nonconformances.
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Title:
~ Amendment / Revision Sheet Page:
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l Rev.:
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