ML20205L659
| ML20205L659 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/12/1999 |
| From: | Croteau R NRC |
| To: | |
| References | |
| TAC-MA4446, NUDOCS 9904140235 | |
| Download: ML20205L659 (3) | |
Text
If%sk Crotapu - Vyrai3.wpd Pcge 1j FOR. DM(055ior4 of. r2/23N& L9TTG,. (TM M 4Mh N
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,4/12/99 Request for Additionalinformation (Revised)
Vermont Yankee Operational Quality Assurance Manual, Revision 2.
References:
(1) Letter, VYNPC to USNRC, " Vermont Yankee Operational Quality Assurance Manual (VOQAM), Revision 2," BW 98-161, dated December 23,1998.
(2) Letter. WNPC to USNRC, " Supplement to Submittal of Vermont Yankee, Operational Quality Assurance Manual (VOQAM), Revision 2," BW 99-10, dated February 4,1999.-
(3) Letter, VYNPC to USNRC, " Operational Quality Assurance Program, Revision 28," BW 98-22, dated February 25,1998.
In the
- Background" section (page 1) and
- Reasons for the Change" section (page 2) of Reference (1), the licensee stated respectively:
"However, W is presently reviewing the requirements of ANS-52.1-1983 for suitability and expecu.o make a future submittal to adopt the safety classification methodology of this later standard, in whole or in part, since it provides a more comprehensive classification basis than is available in ANS-22."
" Guidance is available in ANS-52.1 that will allow W to assure the original design-basis safety function capability of the fuel handling equipment, and thereby maintain projected off-site radiation exposure resulting from a postulated refueling accident within 10CFR100 limits as described in the W Final Safety Analysis Report."
Briefly expand upon the rationale for determining the suitability of ANS-52.1 -1983 as relates to the reclassification of Vermont Yankee (VY) fuel handling system equipment (i.e., equipment reclastdfication from safety-related to non-safety-related), versus the suitability of ANS-22, Draft 4, Rev.1,1973 and Regulatory Guide (RG) 1.26, " Quality Group Classification and Standards for Water, Steam, and Radioactive
-Waste-Containing Components of Nuclear Power Plants," Revision 3, February 1976.
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In particular, point out ANS-52.1 guidance that "will allow W to assure the original O j design-basis safety function capability of the fuel handling equipment,...etc." is there a more recent version of ANS-52.1 that may be applicable (o the reclassification of fuel handling system equipment?
hO 2.
In the " Basis for Acceptability of the Change" section (page 2) of Reference (1), the -
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licensee stated:
"At a later date the equipment classification was changed to declare the load-bee;ing Safety Class 3, leaving all other subcomponents as NNS, and a seismic a@ sis of i40ON
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, major load-bearing components was completed. In 1993, the entire system was reclassified as " Augmented Quality" (VY's "OOA" classification), using the methodology in ANS-52.1-1983 as then allowed by the VY Safety Classification Manual."
"VY has performed an evaluation that supports reclassification of this equipment as NNS, but with selected, limited functional obligations (specifically, prevention of damage to irradiated fuel) that warrant application of supplemental quality assurance measures in keeping with the provisions of ANS-52.1-1983, Sections 4.13.1,4.13.4,3.3.1.4 and 3.4.5.2."
"VY believes that an " Augmented Quality" reclassification for this equipment provides a level of operational-phase quality assurance (e.g., design control, procurement, installation and testing) commensurate with the importance of the safety function performed. These activities are conducted under procedures that impose the applicable elements of ANSI N18.7. Ample justification for this classification is provided in the referenced portions of ANS-52.1."
Define VY's " Augmented Quality" (OOA) classification. Explain how the entire fuel handling system was reclassified as " Augmented Quality" using the methodology in ANS-52.1-1983 (as allowed by the VY Safety Classification Manual in 1993).
Provide a copy of VY's evaluation that supports the reclassfication of fuel handling system equipment as non-nuclear-safety (NNS) (i.e., non-safety-related). What are the supplemental quality assurance measures in keeping with the provisions of ANS-52.1-1983 (Sections 4.13.1,4.1.3.4,3.3.1.4 and 3.5.2) that can be applied to fuel handling system equipment, which has been reclassified as NNS with selected functional obligations?
Clarify how VY's " Augmented Quality" reclassification of fuel handling system equipment relates to procedures that impose applicable elements of ANSI N18.7. What is the ample justification for this reclassification provided in the referred portions of ANS-52.17 Point out the referenced portions of ANS-52.1.
3.
In the " Fuel Handling Equipment" section (page 17) of the proposed Appendix B submitted with Reference (2), the licensee stated:
" Vermont Yankee will apply the Non-Nuclear-Safety criteria and additional " selected requirements" of ANS-52.1-1983, as delineated in paragraphs 4.13.1(1),4.13.1(3),
4.13.1(4),4.13.4,3.3.1.4 including subsections (h) and (J),3.4.5.2, and Table 3.5, except in lieu of NOA-1-1979, quality assurance measures shall be applied using the requirements of ANSI 18.7-1976, excluding the provisions of 5.2.13.1 and 5.2.13.2."
Explain (from a safety perspective) why the functions, as delineated in paragraphs
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. 4.13.1(1),4.13.1(3),4.13.1(4) and 3.3.1.4 of ANS-52.1-1983, should have the classification of NNS (or non-safety-related) versus a safety classification (or safety-related), and therefore be applicable to the reclassiiication of VY fuel handling system equipment? Should the above wording related to paragraph 3.3.1.4 read instead, "....... 3.3.1.4 including on!v subsections (h) and (j)?"
l 4.
In an apnt,priate format (e.g., table), provide a break down, identifying both fuel handling system equipment that has been reclassified as NNS (or non-safety-related) and fuel handling equipment that remains classified as safety-related, using ANS-52.1-1983 as compared to ANS-22, Draft 4, Rev.1,1973.
5.
In VY's response to the staff's Question #2 in Reference (2), the licensee stated:
"VY has clarified the applicability of Section 4.13.4 of ANS-5.2-1983 by stating in general that the NNS criteria and the additional" selected requirements" of the ANS standard will be imposed on this equipment, as stipulated in the referenced actions."
What are the specific NNS criteria and additional " selected requirements" of the ANS-5.2-1983 standard that will be imposed on the fuel handling system equipment?
- 6. for Reference (3) provides a comparison of ANS-22, Draft 4, Rev.1, May 1973 and those portions of ANS-52.1,1983 that have been used as a substitute for the information provided by ANS-22. Provide a similar comparison for the fuel handling system, which adds a column for RG 1.26 and includes system safety-related and non-safety-related functions. Attachment A provides 1 page of the Attachment 2 in Reference (3), as an example.
7.
92 the 1^Fn50.50 piecess beca cons ldered fe.,ecl&ee:fying fuc' hand;;ng cy;tc;r, c';dp "c? " ^^t, "ty not-?
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