ML20236N455

Submits Revised Response to Work Request Requesting Review of Region I Task Interface Agreement Re Interpretation of TSs at Vermont Yankee

ML20236N455
Person / Time
Site:	Vermont Yankee
Issue date:	10/06/1997
From:	Eaton R NRC (Affiliation Not Assigned)
To:	Hehl C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20236J990	List: IA-98-155, Responds to 980513 Request from Duquesne Light Co to Provide Written Interpretation of Beaver Valley Power Station,Unit 1 & 2 TSs Requirements for Channel Calibration of Rtds & Thermocouples IR 05000482/1991021 ML20236J987 ML20236K746 ML20236K751 ML20236K780 ML20236K784 ML20236K803 ML20236K816 ML20236K840 ML20236K853 ML20236K883 ML20236K902 ML20236K916 ML20236K936 ML20236K963 ML20236L549 ML20236L558 ML20236L563 ML20236L580 ML20236L584 ML20236L590 ML20236L597 ML20236L653 ML20236L921 ML20236L955 ML20236L971 ML20236M014 ML20236M020 ML20236M034 ML20236M057 ML20236M117 ML20236M138 ML20236M148 ML20236M911 ML20236M924 ML20236M966 ML20236M983 ML20236M996 ML20236N007 ML20236N047 ML20236N052 ML20236N066 ML20236N221 ML20236N240 ML20236N257 ML20236N271 ML20236N288 ML20236N323 ML20236N333 ... further results
References
FOIA-98-155 NUDOCS 9807150133
Download: ML20236N455 (2)

Text

...

h ,, .p f- g%

UNITED STATES

-,, y j NUCLEAR REGULATORY COMMISSION WASHINGTON D.C. SDeeHOM r.,e..,*j October 6, 1997 MEMORANDUM T0: Charles W. Hehl, Director Division of Reactor Projects Region I FROM: Ronald B. Eaton, Acting Director Project Directorate I-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation

SUBJECT:

WORK REQUEST DATED AUGUST 4, 1997, REQUESTING REVIEW OF A REGION I TASK INTERFACE AGREEMENT (TIA) REGARDING INTERPRETATION OF TECHNICAL SPECIFICATIONS (TS) AT VERMONT YANKEE - REVISED RESPONSE By memorandum dated August 14, 1977, (Eaton to Hehl), PDI-3 provided the August II,1997, review performed by the Technical Specifications Branch (TSB) of the subject TIA. The TSB response was based on a 30-day frequency for the Vermont Yankee (YY) surveillance requirement (SR) at issue as discussed in the TIA. Subsequently, it has been noted that the SR in question has a stated

" frequency of "once a month," and that frequency has been interpreted by OE (Attachment) as meaning once per calendar month. In light of this, the TSB revisited the TIA and provided the results of its rereview based on the once per calendar month interpretation. The TSB rereview is provided below.

The TSB does not believe that the term "once a month" should be interpreted to mean "once per calendar month." The basis for this interpretation is as follows. First, a literal interpretation of the latter would mean that a surveillance could be conducted on the first of the month and the next surveillance conducted on the last day of the following month. This would result in nearly 2 months between surveillance, which is clearly not the intent. Second, surveillance requirements normally deal in intervals or frequencies. Thus, we interpret the term "once a month" to require a surveillance interval of 1 month, which could be as long as 31 days or as short as 28 days. Said another way, if a surveillance is conducted on the 15th of the month, the next surveillance would be due on the 15th of the next month. Based on this interpretation of the term "once a month," the TSB position is essentially unc1anged from our August 11, 1997, memorandum, but is restated below using a monthly interval rather than a 30-day interval.

The VY TS (4.10.C.2) requires that a sample of stored diesel fuel be obtained "once a month" and checked for quality. While it is implied that the results of the diesel fuel analysis must be provided in the same 1 month interval in which the sample was taken (i.e., prior to taking the next sample), the YY TSs do not explicitly state this. But in any event, the TS would clearly be violated if the sample was not checked for quality prior to the next surveillance interval.

71 3 980624 UNNERST98-155 PDR

,' 2 With respect to LER 96-029, we believe that the licensee may have violated their procedure, which requires the analysis results to be obtained within a month interval. This should be reviewd by the Region and processed for normal enforcement action.

If you have any questions regarding this matter, please contact Kahtan N. Jabbour at (301) 415-1496.

Attachment:

As stated cc w/att: J. Johnson RII G. Grant. RII T. Gwynn RIV K. Perkins RIV

)ISTRIBUT"0N:

)ocket F1'e PDI-3 Rdg.

J. Lieberman Acting PECB Branch Chief B. Boger .

E. Adensam J. Zwolinski R. Eaton S. Little M. Boyle (MLB4)

H. Oprendek. RI T. Liu N/B W. Cook. RI /

5C ranch Chief M y.c /+<t R f DOCUMENT NAME: G:\JABBOUR\TIA0908.97 sEE mvous coweuwuCE r//h 7 1

v. e . m. d ni. m e k..: e . con .=m.n.nv.ne E con -m . men,n.nv.new,. n . o 0FFICE PDI 3/PM //A l PDI 1/LA n), l (A)D:PDI 3 gM l OGC* h ( ' ) ['

NAME KJ.thour ff /O(4- Stittl. V RE. ton / 8P " AModedon l /ilW// l DATE 1D/ I /97 1D/ l /97 1D/ M97 09/29/97 V "

OFFICE DD:DRPE g '

WAME JZwotinski N '

Wseekner / 0// /f 7 JLie Ml L. _

DATE %f/$ /97 ema - 09/1D/97/ /U /)

OfFACIAL ALCORD CQPT #

l l

4 y C//) O/j L