View source for BVY-99-113, Requests Approval to Perform Alternative Testing to That Specified by ASME Boiler & Pressure Vessel Code,Section XI & Asme/Ansi OM, Operation & Maint of Nuclear Power Plants. Attachment 1 Provides Justification for Alternative Testing

{{Adams
| number = ML20212F627
| issue date = 09/21/1999
| title = Requests Approval to Perform Alternative Testing to That Specified by ASME Boiler & Pressure Vessel Code,Section XI & Asme/Ansi OM, Operation & Maint of Nuclear Power Plants. Attachment 1 Provides Justification for Alternative Testing
| author name = Wanczyk R
| author affiliation = VERMONT YANKEE NUCLEAR POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000271
| license number = 
| contact person = 
| case reference number = RTR-NUREG-1482
| document report number = BVY-99-113, GL-89-04, NUDOCS 9909280297
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 8
}}

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VERMONT ' YANKEE                                                                              l p               NUCLEAR POWER CORPORATION N               ' 185 Old Ferry Road, Brattleboro, VT 05301-7002 (802) 257-5271 September 21,1999 BVY 99-113 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555

==Reference:==
(a)    Letter, USNRC to VYNPC," Safety Evaluation of the Inservice Testing Program for Pumps and Va!ves, nird Interval Plan, Revision 19, Vermont Yankee Nuclear            I Power Station (TAC NO. MA4503)," NVY 99-29, dated March 12,1999.

==Subject:==
Vermont Yankee Nuclear Power Station License No. DPR-28 (Docket No. 50-271)
Request For Alternative Testing Per 10CFR50.55a(s)(3)(ii) Inservice Testine (IST) Proeram Pursuant to 10CFR50.55a(aX3Xii), Vermont Yankee Nuclear Power Corporatiori (VY) hereby requests approval to perform alternative testing to that specified by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section XI, and ASME/ ANSI OM, " Operation and                        )
Maintenance of Nuclear Power Plants." Attachment 1 provides thejustification for the alternative testing.
The proposed alternatives were previously implemented under Refueling Outage Justifications prepared in accordance with NUREG 1482. This practice is no longer acceptable to the NRC as stated in Reference (a) and now requires submittal of formal relief requests pursuant to 10CFR50.55a(aX3Xii).
Approval for the use of the alternative testing is requested by October 29, 1999 in order to sepport scheduled testing during the 1999 Refueling Outage. Upon approval, these alternative methods will be incorporated into our IST Program Plan.
1 If you have any questions regarding this transmittal, ptease contact Mr. Wayne M. Limberger at (802) 258-4237.
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Sincerely,                                                        '
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VERMONT YANKEE NUCLEAR POWER CORPORATION
                                                            </LP         ,     Antt Robert J. Wanczy -                     /(/                      ,
Director of Safet      d Regulatory Affairs
                                                                                                            /
Attachment cc:       USNRC Region 1 Administrator USNRC Resident Inspector- VYNPS USNRC Project Manager- VYNPS Vermont Department of Public Service 9909290297 990921 PDR      ACOCK 05000271 p                        PDR

Docket No. 50-271 BVY 99-113 ATTACHMENT 1 Vennont Yankee Nuclear Power Station Request For Alternative Testing Per 10CFR50.55a(a)(3)(ii)
Inservice Testing (IST) Program PROPOSED ALTERNATE TEST METHODS RR-V17, Rev. O Service Water Loop Header Discharge Check Valves RR-V18, Rev. O Service Water Vacuum Breaker Check Valves

y Vcrm:2t Ycakee Nucl: r Pcwsr St::ti:n                                 l Ins:rvice Testing Program RELIEF REOUEST l
Number: RR-V17, Revision 0 (Sheet 1 of 2) i SYSTEM:'          Service Water COMPONENTS:
          , Valve Number           OM Cat. Safety Class           Drawing Number         Dwg. Coord.
V70-43A                 C           3                      G-191168               F-06 V70-43B                -C           3                      0-191168               D-06 These 8" swing check valves are the Service Water System loop header discharge check valves.
These check valves have a safety function in the open direction to provide cooling water to various ECCS room' area coolers during normal plant operation and to the standby emergency diesel generator
         ~ jacket water, lube oil and after coolers when the diesel generator is in service.
These valves have a safety function in the closed direction to prevent reverse flow during the service -
water attemate cooling mode of operation. . When the service water system is operating in the altemate cooling mode, these check.vnives close to ensure Residual Heat Removal Service Water (RHRSW)             l pump flow is directed to the RHR heat exchangers, ECCS area coolers and the standby emergency diesel generatorjacket water, lube oil and after coolers.
EXAM OR TEST CATEGORY:
Category C-(Alternative to Full Flow Testing of Check Valves)
CODE REOUIREMENT: Part 10 Para. 4.3.2.1 " Exercising Test Frequency"
           " Check valves shall be exercised nominally every 3 months, except as provided by paras. 4.3.2.2, 4.3.2.3,4.3.2.4 and 4.3.2.5."
REDUESTIOR RFlJEEt
         ~ Reliefis requested on the basis that OMa 1988, Part 10, Paragraph 4.3.2.4(c) permits disassembly every refueling outage to verify operability of check valves. NUREG 1482 and Generic Letter 89-l          04, Positiore 2 permit' the use of a sample disassembly and inspection plan when the licensee             !
j        . determines it is burdensome to disassemble and inspect all applicable valws each refueling outage.       l L          Additionally, NUREG- 1482, 4.1.2 permits the use of non-intrusive techniques using a sample
                           .                                                                                        i L          program. However, since the issuance of the NUREG recommendation, the NRC staff determined                ;
that the legal basis for approving the deviation from Code requirements may not be accomplished by        l referencing the NUREG. The deviation may only be authorized as an alternative to the regulations pursuant to 10 CFR 50.55(a)(3)(ii) or as a specific exemption to 10 CFR 50.12.
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Verm:nt Ycckee Ntcle:r Pcwer St:tirn                                  Ins:rvice Tcsting Program RELIEF REOUEST Number: RR-V17, Revision 0 (Sheet 2 of 2)
BEDUEST FOR RELIEF (CON'T):
During refueling outages extensive maintenance is perfonned on all Service Water components in the Imp scheduled to be out of service while relying on the operable loop to supply needed loads. It is burdensome to drain portions of both Service Water Loops during each refueling outage to affect component disassembly ofonly one valve.
ALTERNATE TEST METHOD:
OMa-1988, Part 10, Paragraph 4.3.2.4(c) perrnits disassembly every refueling outage to verify operability of check valves. NUREG 1482 and Generic Letter 89-04, Position 2 permit the use of a sample disassembly and inspection plan when the licensee determines it is burdensome to disassemble and inspect all applicable valves each refueling outage. Additionally, NUREG 1482, 4.1.2 permits the use of non-intrusive techniques using a sample program.
Partial flow testing of these valves is satisfied quarterly. Disassembly and inspection or use of non-intrusive techniques will be used to satisfy forward and reverse flow testing. Use of either method will be performed using a sampling program during refueling outages. A sampling program is justified due to the extent of system isolation and drain-dovm required to perform check valve disassembly combined with the need to keep certain ECCS systems and the diesel generators available during refueling outages. Regarding non-intrusive testing, NUREG 1482 specifies that the extensive effort to set up test equipment and the adverse impact on system operation provide sufficientjustification to defer the test to a refueling outage.
Specifically, one check valve will be disassembled and inspected or non-intrusively tested every refueling outage with the other check valve being disassembled and inspected or non-intrusively tested the following outage. During the disassembly, the intemals of the valve will be verified to be structurally sound (no loose or corroded parts.) If the disassembled valve is not capable of achieving full stroke when exercised or there is binding or failure of the valve intemals, the other valve will also be disassembled, inspected and manuaUy exercised during the same refuel outage. Regarding non-intrusive testing, if problems are found with the sample valve that are determined to affect the operational readiness oNe valve, the other valve must be tested using non-intrusive techniques during the same outage.
USNRC EVALUATION STATUS:
Reliefis pending approval for Relief Request RR-V17, Revision 0, submitted September 1999.
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Vcrm:nt Yc kee Ncclear Pcwer Statia                                  Ir.servico Testing Przgrcm RELIEF REOUEST                                                 '
Number: RR-V18, Revision 0 (Sheet 1 of 2)
SYSTEM:          Fuel Pool Cooling & Cleanup Service Water 1
COMPONENTS:                                                                                            '
Valve Number           OM Cat.      Safety Class          Drawing Number         Dwg. Coord.
V70-244A               C            3                    G-191173 Sh 2           B-10 V70-244B               C            3                    0-191173 Sh 2           B-10 V70-281 A              C            3                    G-191159 Sh 1           J-09 V70-281B               C            3                    G-191159 Sh 1           B-09 V70-281C               C            3                    G-191159 Sh 1           J-09                  j V70-281D               C           3                     G-191159 Sh 1           C-09 V70-511B               C            3                    G-191159 Sh 1           H-12 V70-511C               C            3                    G-191159 Sh 1           H-12 V70-252B               C            3                    G-191159 Sh 2           G-05                   '
V70-252C               C            3                    G-191159 Sh 2           G-05 1
These 2" swing check valves are the Service Water System vacuum breaker check valves.                   l These valves have a safety function in the open direction to eliminate vacuum in the service water system that is postulated to occur following a station electrical blackout or an Appendix R postulated '
fire. Eliminating the vacuum minimizes the potential for system water hammer upon service water pump restart.
These vacuum breaker check valves have a safety function in the closed direction to maintain the service water system pressure boundary.
EXAM OR TEST CATEGORY:
Category C -(Alternative to Full Flow Testing of Check Valves) l CODE REOUIREMENT: Part 10 Para. 4.3.2.1 " Exercising Test Frequency"
  " Check valves shall be exercised nominally every 3 months, except as provided by paras, 4.3.2.2, 4.3.2.3,4.3.2.4 and 4.3.2.5."
L

l Verm:nt Ycnkea Nucl=r Pcwer St:ti:n                                 Inservics Testing Program RELIEF REOUEST Number: RR-V18, Revision 0 (Sheet 2 of 2)
REOUEST FOR RELIEF:
Reliefis requested on the basis that OMa-1988, Part 10, Paragraph 4.3.2.4(c) permits disassembly every refueling outage to verify operability of check valves. NUREG 1482 and Generic Letter 89-04, Position 2 permit the use of a sample disassembly and inspection plan when the licensee determines it is burdensome to disassemble and inspect all applicable valves each refueling outage.
Additionally, NUREG 1482, 4.1.2 permits the use of non-intrusive techniques using a sample                 i program. However, since the issuance of the NUREG recommendation, the NRC staff determined that the legal basis for approving the deviation from Code requirements may not be accomplished by         ,
referencing the NUREG. The deviation may only be authorized as an alternative to the regulations           j pursuant to 10 CFR 50.55(a)(3)(ii) or as a specific exemption to 10 CFR 50.12.
During refueling outages extensive maintenance is performed on all Service Water components in the         l loop scheduled to be out of service while relying on the operable loop to supply needed loads. It is       I burdensome to drain portions of both Service Water Loops during each refueling outage to affect a limited amount of component disassemblies.
ALTERNATE TEST METHOD:
OMa-1988, Part 10, Paragraph 4.3.2.4(c) permits disassembly every refueling outage to verify operability of check valves. NUREG 1482 and Generic Letter 89-04, Position 2 permit the use of a sample disassembly and inspection plan when the licensee determines it is burdensome to disassemble and inspect all applicable valves each refueling outage.
Disassembly and inspection will be used to satisfy forward and reverse iflow testing. Based on the large grouping of valve pairs and the altemating refueling outage basis for scheduling individual service water subsystem maintenance actions, disassemblies will be perfomaed using a sampling program during refueling outages. Specifically, three pairs of valves (6 valves total) will be disassembled, inspected, and full stroke exercised during one refueling outage with the other two pairs (4 valves total) being disassembled, inspected, and full stroke exercised the following refueling outage. During the disassembly, the disk will be manually exercised and the internals of the valve will be verified to be structurally sound (no loose or corroded parts). If a disassembled valve is not capable of achieving full stroke when exercised or there is binding or failure of a valve's internals, all other vacuu n breaker check valves in both groups will be disassembled, inspected, and manually full stroke exercised during the same refueling outage. Use of non-intrusive techniques was consi:lered for this application and determined to be impractical given the valve design and system application. Partial valve stroking with flow is not practical following reassembly. Quality disassembly, reassembly and inspection techniques provide sufficient confidence that the valves will perform their intended function when challenged.
USNRC EVALUATION STATUS _;.
Reliefis pending approval for Relief Request RR-V18, Revision 0, submitted September 1999.

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             .                                                                          l Docket No. 50-271 BVY 99-113 1
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Attachment 2 Vermont Yankee Nuclear Power Station Request for Alternative Testing Per 10CFR50.55a(a)(3)(ii)
Inservice Testing (IST) Program Summary of Vermont Yankee Commitments
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==SUMMARY==
OF VERMONT YANKEE COMMITMENTS BVV NO.: 9'9-113 The following table identifies commitments made in this document by Vermont Yankee. Any other actions discussed in the submittal represent intended or planned actions by Vermont Yankee. They are described to the NRC for the NRC's ir. formation and are not regulatory commitments. Please notify the Licensing
      . Manager of any questions regarding this document or any associated commitments.
COMMITMENT                                              COMMITTED DATE OR " OUTAGE" Alternative testing methods will be incorporated into our IST                  1999 Refueling Outage Program Plan upon NRC approval.
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VYAPF 0058.04                   ;
AP 0058 Original Page1of1
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