ML20204H990

Comment on Proposed Rule 10CFR50.54(a)(3) Re Changes to Quality Assurance Programs

ML20204H990
Person / Time
Site:	Vermont Yankee
Issue date:	03/24/1999
From:	Sen G VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-64FR9035, RULE-PR-50 64FR9035-00004, 64FR9035-4, BVY99-41, NUDOCS 9903290231
Download: ML20204H990 (2)

Text

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m DOCKET NUMBER V PROPOSED RULE N 50 t/

5 VERMONT YANKEE (Wgg,og) y NUCLEAR POWER CORS'URXTION 185 Old Ferry Road, Brattleboro, VT 05301-7002 -

(802) 257 5271 .g g 3 g)) $4 March 24,1999 BVY 99-41 Secretary, U.S. Nuclear Regulatory Commission g Washington,DC 20555 Air

• Attention: Rulemaking and Adjudications Staff  ;

References:

(a) Federal Register, Vol. 64, No. 35, pages 9030 through 9037,10CFR Part 50, RIN ,

3150 AG-20," Changes to Quality Assurance Programs," dated February 23,1999. l

Subject:

Vermoet Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)

Comments Regarding Proposed Amendmeets to 10CFR50.54(a)(3)

Pursuant to instructions in Reference (a), Vermont Yankee (VY) is submitting the following comments and questions regarding the subject rulemaking, which is scheduled to become effective on April 26,1999.

1. It is clear from the Section-by-Section Analysis on page 9032 of Reference (a) that section 10CFR50.54(aX3Xi) of the proposed rule is intended to apply to programmatic quality assurance standards, such as ANSI N45.2 and its daughter standards, endorsed by NRC Regulatory Guides.

However, a licensee may have referred to other national codes or standards in its Quality Assurance (QA) program, either as primary references or approved alternatives, that contain specific QA guidance although they are not endorsed by Regulatory Guides. An example in VY's case would j be ANS-22," Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants,"  !

which includes criteria for safety classification of plant systems and which has been superseded by j ANS-52.1, a later standard with the same title. ANS-22 was approved for this purpose by the NRC for use at VY as an acceptable alternative to adherence to Regulatory Guide 1.26.

Are such non-programmatic QA standards intended to come under the purview of section 10CFR50.54(aX3Xi) of the proposed rule if earlier editions are presently included by reference in a licensee's approved QA program? .

1 2.- Section 10CFR50.54(aX3(i) of the preposed rule allows later editions of QA standards currently referenced in a licensee's QA program to be adopted by that licensee if they have been found I

acceptable by the NRC with respect to the requirements of 10CFR50 Appendix B.

Does inclusion of a later edition by reference in a licensee's approved licensing bases constitute erspuis by the NRC for adoption by other licensees under 10CFR50.54(aX3Xi)? [ Note that O 10CFR50.54(aX3Xii) allows use of a QA alternative or exception approved by the NRC in a Safety Evaluation Report for another facility as long as applicability to the adopting licensee's facility is demonstrated; however, this is not addressed in 10CFR50.54(aX3Xi)]

9903290231 990324 PDR PR 50 64FR9035 PDR hI

VERMONT YANKEE NUCLEAR POWER CORPORATION 4]

8 BVY 99-41\ Page 2 of 2 Please direct any questions regarding this correspondence to Mr. Wayne M. Limberger at (802) 258-4237.

Sincerely, VERM YANKEE NUCLE POWER CORPORATION

)ML L

/Gauhn Sen /

Licensing Manager cc: USNRC Region 1 Administrator USNRC Resident Inspector- VYNPS USNRC Project Manager-VYNPS Vermont Department of Public Service