ML20205E953

Forwards Request for Addl Info Re Inservice Insp Program. Info Re Interval Dates & Code Applicability for Piping Exams Needed within 60 Days

ML20205E953
Person / Time
Site:	Vermont Yankee
Issue date:	10/25/1985
From:	Vassallo D Office of Nuclear Reactor Regulation
To:	Capstick R VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 8511040048
Download: ML20205E953 (5)

Text

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4 October 25, 1985 Docket No. 50-271 Mr. R. W. Capstick Licensing Engineer Vermont Yankee Nuclear Power Corporation 1671 Worcester Road Framingham, Massachusetts 01701

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION -

INSERVICE INSPECTION PROGRAM Re: Vermont Yankee Nuclear Power Station We are reviewing your submittal on the Inservice Inspection Program (ISI) dated November 27, 1984, and find that we neet additional information to complete our review. We request that you provide responses to the enclosed request within 60 days of receipt of teis letter.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents, therefore, OMB clearance is not required under P.L.96-511.

Sincerely, Original signed by RAHermann for/

Domenic.B. Vassallo, Chief Operating Reactors Branch #2 Division of Licensing

Enclosure:

As stated cc w/ enclosure:

See next page

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Mr. R. W. Capstick Vermont Yankee Nuclear Power Corporation Vermont Yankee Nuclear Power Station cc:

Pr. W. F. Conway W. P. Murphy, Vice President &

President & Chief Executive Officer Manager of Operations Vermont Yankee Nuclear Power Corp. Vermont Yankee Nuclear Power Corp.

R. D. 5, Box 169 R. D. 5, Box 169 Ferry Road Ferry Road Brattleboro, Vermont 05301 Brattleboro, Vemont 05301 Mr. Donald Hunter, Vice President Mr. Gerald Tarrant Commissioner

. Vermont Yankee Nuclear Power Corp. Vermont Department of Public Service 1671 Worcester Road 120 State Street Framingham, Massachusetts 01701 Montpelier, Vemont 05602 New England Coalition en /

Nuclear Pollution Hill and Dale Fam Public Service Board R. D. 2, Box 223 State of Vermont -

Putney, Vermont 05346 120 State Street '.

Montpelier, Vermont 05602

- Mr. Walter Zaluzny Chairman, Board of Selectman Vermont Yankee Decommissioning Post Office Box 116 Alliance Vernon, Vermont 05345 Box 53 Montpelier, Vermont 05602-0053 J. P. Pelletier, Plant Manager Vermont Yankee Nuclear Power Corp.

Post Office Box 157 Resident Inspector

. Vernon, Vemont 05354 U. S. Nuclear Regulatory Commission Post Office Box 176 Raymond N. McCandless Vernon, Vemont 05354 Vermont Division of Occupational

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& Radiological Health Yemont Public Interest Administration Building Research Group, Inc.

10 Baldwin Street 43 State Street Montpelier, Vemor.t 05602 Montpelier, Vermont 05602 Honorable John J. Easton Thomas A. Murley Attorney General Regional Administrator State of Vcrmont Region I Office 109 State Street U. S. Nuclear Regulatory Comission Montpelier, Vermont 05602 631 Park Avenue King of Prussia, Pennsylvania 19406 John A. P.itscher, Esquire Ropes & Gray 225 Franklin Street .

Boston, Massachusetts 02110

REQUEST FOR ADDITIONAL INFORMATION INSERVICE INSPECTION (ISI) PROGRAM VERMONT YANKEE NUCLEAR POWER CORPORATION VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271 Preliminary review of the second interval ISI Program submitted November 27,1984,(I) has raised two general issues:

(1) Interval Dates (2) Code Applicability for Piping Examinations.

In this review we have also examined (a) the EC's letter of May 19, 1983,(2) transmitting an SER on the first interval ISI program; (b) Ver-mont Yankee's letter of April 19, 1984,(3) about the planned 1984 ISI, Inspection; and (c) the report (4) of that inspection.

Interval Dates 6

In Reference 3, the licensee states that the first inspection interval was extended from Decenber of 1982 as " permitted by NA-2400(a)" of Section XI "to allow the final inspection to be concurrent with the plant outage which ended on June 16, 1983." In Reference 1 (p.11), the licen-see then revised Interval 2 so that it extends from June 16, 1983, to June 16, 1993. This practice is clearly contradictory to NA-2400(c) which staths: ~

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"Each inspection interval may be decreased or extended (but not cumulatively) by as much as 1 year. For power units that are out of service continuously for 6 months or more, the inspection interval during which the outage occurred say be extended for a period equivalent to the outage." '

Since the Code does not allow cumulative extensions, the second interval should be scheduled to end by byember 30,1992, the 20th Anni-versary of the commercial operating date. ~

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In a similar situation with another licensee, the staff has determined that:

"The extension of an interval, i.e., a change of the ten-year interval date, which is calculated from the start of plant commercial operation, is different from the extension of the time interval allowed by Section XI of the ASME Code to accommodate the occurrences of plant outages and inservice insper,';ns. The extension of the interval date can occur only if the plant is out of service continuously for six months or more during that interval. The amount of time to which the interval date may be extended is equivalent to the plant's out-of-service time. .

The interval date signifies the beginning of a new inspection interval and serves as the date for determining Code editions and addenda' to be used for the new ten-year inservice inspection program plan."

,. Unless Vermont Yankee can claim extended outages, the date for determining Code Editions and addenda is November 30, 1982, which would make the 1977 Edition (with addenda to Summer 1979) the code of record for the second interval. The licensee should propose a schedule for completing all second interval inspections by November 30, 1992, including the extent to which he will meet the intermediate percentage requirements of Inspection Program B (Tables IWB-2412-1 and IWC-2412-1). If the licensee

still wishes to use the 1980 Edition with Winter 1980 addenda, he should

, request Commission approval in accordance with 10 CFR 50.55a(g)(4)(iv).

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! Code Applicability for Piping Examinations The licensee has selected the 1974 Edition of the code with Summer 1975 Addenda as the basis for his piping examinations (Item A, p. i of Reference 1). In item B, the licenree proposed to use the acceptance 4

criteria from the same code. This use is counter to 10 CFR 50.55a(b)

(2)(11)-which the staff interprets to mean that 74S75 applies only to the extent and frequency column of Tables IWB-2500 and IWC-2520. All.other requirements are to be to the later code specified in 50.55a(b).*

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i The licensee's other documentation adds to the confusion. The plan (pp I-46 to I-74 of Ref.1) specifies volumetric examination only for all B-J Code Item 4.5 piping welds, which is the outdated requirement in 74575.

However, the report of the 1984 inspection (p. 6 of Ref. 4) shows that both volumetric and surface examinations were done for most B-J weld nihich would meet the later codes. (Some 10 and 20 in. D. welds were surface examined which meets neither code.) Also, most of the B-J welds inspected during the 1984 outage of the first 40-month period of the second interval were not scheduled to be inspected at any time during that period by the second-interval program. '

Please clarify these discrepancies.

• The intent of the second paragraph in the cover letter to the second-interval programII) is not clear, but to the extent it counters the staff interpretation, it needs to be revised.

References '

1! FW 84-139, hvember 27, 1984.

2.

D. B. Vassallo (RC) to J. B. Sinclair ( W NPC), May 19, 1983.

3. FW 84-37, April 19,1984.

4.

W NPC 1984 Inservice Inspection Sumary Report (received 10/29/84 by RC). N I

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