ML20205S403

Application for Amend to License DPR-28,modifying Inservice Insp Requirements of Section 4.6.E to Allow NRC-approved Alternatives to GL 88-01

ML20205S403
Person / Time
Site:	Vermont Yankee
Issue date:	04/16/1999
From:	Wanczyk R VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20205S406	List: ML20205S403 ML20205S408
References
BVY-99-13, GL-88-01, GL-88-1, TAC-M99389, NUDOCS 9904260208
Download: ML20205S403 (8)

Text

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' l VERMONT YANKEE y NUCLEAR POWER CORPORATION I

• 185 Old Ferry Road, Brattleboro, VT 05301 7002 l (802) 257-5271  ;

April 16,1999 BVY 99-13 U.S. Nuclear Regulatory Commission ATFN: Document Control Desk Washington, D.C. 20555

References:

(a) NRC Generic Letter 88-01,"NRC Position on IGSCC in BWR Austenitic ,

Stainless Steel Piping," NVY 88-09, dated January 25,1988.

(b) American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI,1986 Edition, " Rules for Inservice Inspection of Nuclear Power Plant Components".

(c) ASME Code Case N-560, " Alternative Examination Requirements for Class 1, Category B-J Piping Welds," approved August 9,1996.

(d) Letter USNRC to VYNPC, " Request to Use Code Case N-560 as an Alternative to the Requirements of ASME Code,Section XI, Table IWB- i l 2500-1 At VYNPC (TAC No. M99389)," NVY 98-155, dated November 9, l 1998.

Subject:

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

ProDosed Channe No. 213 - Generie Letter 88-01 and Use of Code Case N-560 Pursuant to 10CFR50.90, Vermont Yankee (VY) hereby proposes to amend its Facility Operating /

License, DPR-28, by incorporating the attached proposed change into the VY Technical I j

Specifications. This proposed change will modify the inservice inspection requirements of Section 4.6.E to allow NRC-approved alternatives to Generic Letter (GL) 88-01. The NRC in reference (d) has recently approved use of ASME Code Case N-560 for inservice inspetion of j Class 1 piping welds at VYe This initiative affects the sample selection and inspection schedule )l$

criteria given in GL 88-01. Specifically, the Code Case permits selection of 10% of Category B-J welds for inspection (versus the 25% we committed to under OL 88-01 and ASME Section XI),

provided the welds selected have been determined, using risk-informed analytical methods, to be those most susceptible to the applicable failure mechanisms (Intergranular Stress Corrosion Cracking, Flow-Accelerated Corrosion, etc). Thus, Code Case N-560 provides an NRC-approved

! alternative to certain of the criteria specified in GL 88-01. The basis for this request is the same as the basis for approval to use ASME Code Case N-560.

Attachment I to this letter contains supporting information and the safety assessment for the proposed change. Attachment 2 contains the determination of no significant hazards consideration. Attachment 3 provides a mark-up of the carrent Technical Specification pages.

Attachment 4 provides the retyped Technical Specification pages.

I VY has reviewed the proposed Technical Specification change in accordance with 10CFR50.92 and concludes that the proposed change does not involve a significant hazards consideration.

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9904260208 990416 PDR ADOCK 05000271 i P PDR _

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VEnMoN r YANME Nrcu;An PowLn ConconmoN BVY 99-13 \ Page 2 of2 9 a VY has also reviewed the proposed change against the criteria of 10CFR51.22 for environmental considerations and concludes that the proposed change will not increase the types and amounts of effluents that may be released offsite. Thus, VY believes that the proposed change is eligible for categorical exclusion from the requirements for an environmental impact statement in accordance with 10CFRSI.22(c)(9).

VY will be completing examinations for the second period of the third inspection interval during our Fall 1999 refueling outage and therefore requests review and approval of this amendment by September 1999.

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

Sincerely, VERMONT YANKEE NUCLEAR POWER CORPORATION Robert J. Wahk Director of Safety and Regulatory Affairs Attachments p $f cc: USNRC Region 1 Administrator USNRC Resident inspector-VYNPS

' pf#%[k USNRC Project Manager-VYNPS ,

NOUM b$ " hB Vermont Department of Public Service g, t _ pg31 J CI t. f d '/,

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STATE OF VERMONT )

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Then personally appeared 1 efore me, Robert L Wanczyk, who being duly swom, did state that he is Director of Safety and Regulatory Affairs of Vermont Yankee Nuclear Power Corporation, that he 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 tme to the best of his knowledge and belief.

Eintly A. Sa6dstrum; Notary Public My Commission Expires February 2,2003

1 Docket No. 50-271 BVY 99-13 I

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Attachment i Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 213 Generic Letter 88-01 and Use of Code Case N-560 l

Supporting Information and Safety Assessment for Proposed Change 4

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BVY 99-13 / Attachent I /l' age 1  !

l DESCRIPTION OF CHANGE VY proposes to change the subject Technical Specifications to clarify that the NRC may grant relief from GL 88-01 requirements, and to also be less prescriptive in the manner in which the NRC may grant relief from Section XI requirements.

The proposed change is as follows:

Technical Specification 4.6.E.1 states, " Inservice inspection of piping, identified in GL 88-01, shall be performed in acemdance 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 where specific written relief has been granted by the NRC."

1 In Technical Specification 4.6.E.1 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 granted relief fro:n criteria inherent in both ASME Section XI and GL 88-01 by approving ASME Code Case N-560 for use at VY, it is necessary to clarify the applicability of GL 88-01 in our 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 l 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 be.th 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 j schedule, methods, personnel and sample expansion in GL 88-01. Approval of Code Case N-560 j affects the sampling requirements of GL 88-01 by allowing alternative sample selection criteria i for Class 1 Category B-J (GL 88-01 Category A) piping welds.

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BASIS FOR CHANGE l

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The NRC has approved the use of Code Case N-560 for VY in a S=fety Evaluation Report (SER) provided in Reference (d). The basis for the change from the .. .ME Section XI and GL 88-01 requirements are found in that SER.

BVY 9913 / Attachment I / Page 2 Draft Guide 1061, as well as Draft 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:

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1. Meet current regulations,

2. Maintain defense in depth,

3. Maintain sufficient safety margins,

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 relief has been granted from the 25% sample inspection required by ASME Section XI, Table IWB-2500-1 for Class 1, Category B-J welds, relief has, in effect, also been granted from the identical requirement in GL 88-01 for Category A welds. The NRC has approved the  !

Vermont Yankee weld selection process itself and, in addition, the actue.1 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 N560 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 Letter 89-08 (Erosion / Corrosion  !

Induced Wall Thinning)."

SAFETY ASSESSMENT 2

VY has shown that implementation of the Code Case N-560 program would result m an insignificant change in risk even wid 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 r*ructural 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.

p Docket No. 50-271 BVY 99-13 Attachment 2 Vermont Yankee Nuclear Power Station Proposed Technical Specification Change No. 213 Generic Letter 88-01 and Use of Code Case N-560 Determination of No Significant Hazards Consideration

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BVY 99-13 / Attachment 2/ Page 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).

1. The operation of Vermont Y,ankee Nuclear Power Station in accordance with the oronosed -

amendment will not involve a sienificant increase in the probabilfty or conscauences of an accident oreviously evaluated?

This change is only an administrative change that recognizes the NRC's authority to grant 4 relief to a specific requirement. 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 I granted. 'Ihe 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. Adding words to allow the granting of alternatives to the GL 88-01 guidance in the TS also does not affect any equipment or its i operation. These changes can be constered administrative in nature and do not change any I of the accident ana!yses 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 orooosed 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 NRC approved alternate positions with regard to the 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 orooosed amendment will not involve a sinnificant reduction in a marnin of safety.

This change is only an administrative change that revises the wording in the TS to recognize the NRC's authority to grant relief to specific requirements. The changes maintain the

. requirement for NRC approval to be obtained. These administrative changes do not result in a reduction in any margin of safety.

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 Federal Renister (FR), Volume 51, No. 44, dated March 6,1986.

Example (i) on FR page 7751 provides a discussion 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.

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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:

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

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

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

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