IR 05000271/1998014

Forwards Request for Addl Info Based on Review of Util 961115 & 970313 Responses to GL 96-05 & Insp Rept 50-271/98-14 of GL 96-05 Program at Vermont Yankee Nuclear Power Station

ML20207K318
Person / Time
Site:	Vermont Yankee
Issue date:	03/01/1999
From:	Croteau R NRC (Affiliation Not Assigned)
To:	Maret G VERMONT YANKEE NUCLEAR POWER CORP.
References
50-271-98-14, GL-96-05, GL-96-5, TAC-M97114, NUDOCS 9903170131
Download: ML20207K318 (5)

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March 1, 1999 i

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Mr. Gregory A. Maret'

Director of Operations ~ .

Vermont Yankee Nuclear Power Corporation 185 Old Ferry Road Brattleboro, VT 05301-

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SUBJECT: REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER I 96-05 PROGRAM AT VERMONT YANKEE NUCLEAR POWER STATION (TAC NO. M97114)

Dear Mr. Maret:

On September 18,1996, the NRC issued Generic Letter (GL) 96-05, " Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves," to request that nuclear '

power plant licensees establish a program, or ensure the effectiveness of the current program, to verify.on a periodic basis that safety-related motor-operated valves (MOVs) continue to be capable of performing their safety functions within the current licensing basis of the facility.

On November 15,1996, and March 13,1997, you submitted a description of your planned response to GL 96-0E. On November 16-18,1998, the NRC staff conducted an inspection of i the GL 96-05 program at Vermont Yankee Nuclear Power Station (Vermont Yankee). The staff i documented Me results of that inspection in NRC inspection Report (IR) 50-271/98-14, dated )

January 28,17 9.

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Based on a review of your submittals and IR 98-14, enclosed is a request for additional  !

information regarding the GL 96-05 program at Vermont Yankee. We request that your response be provided within 90 days of this letter as agreed to by Mr. Jeff Meyer of your staff j on February 25,1999.

Sincerely, original signed by:

Richard P. Croteau, Project Manager Project Directorate 1-2 '

Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-271 \ i Enclosure: Request For AddnionalInformation i j

cc w/ encl: See next page plSTRIBUTION i Docket File PUBLIC E. Adensam PDI-2 Rdg. J. Zwo:inski D. Terao R. Croteau OGC ACRS C. Anderson, RI gog .

DOCUMENT NAME: G:\CROTEAU\RAl97114.WPD To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy *

with Ittachment/ enclosure "M" = No copy OFFICE PM:PDI-2 l . LA:PDI-2 lN D:Pyl-Py l l_ l NAME RCroteatf8 TClarkW EA887 sam

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DATE 02/ 9 99 02/2f/99 3 / / /99

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l Mr. Gregory Director of Operations Vermont Yankee Nuclear Power Corporation 185 Old Feny Road

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Brattleboro, VT 05301 '

SUBJECT: REQUEST FOR ADDITIONAL INFORMATION REGARDING GENERIC LETTER 96-05 PROGRAM AT VERMONT YANKEE NUCLEAR POWER STATION l

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(TAC NO. MS7114)

Dear Mr. Maret:

On Septe,mber 18,1996, the NRC issued Generic Letter (GL) 96-05, " Periodic Verification of i

Design Basis Capability of Safety-Relatud Motor-Operated Valves," to request that nuclear power plant licensees establish a program, or ensure the effectiveness of the current program, to verify on a periodic basis that safety related motor-operated valves (MOVs) continue to be capable of performing their safety functions within the current licensing basis of the facility.

On November 15,1996, and March 13,1997, you submitted a description of your planned response to GL 96-05. On November 1618,1998, the NRC staff conducted an inspection of the GL 96-05 program at Vermont Yankee Nuclear Power Station (Vermont Yankee). The staff documented the results of '. hat inspection in NRC Inspection Report (IR) 50-271/98-14, dated January 28,1999.

Based on a review of your submittals and IR 98-14, enclosed is a request for additional information regarding the GL 96-05 program at Vermont Yankee, We request that your response be provided within 90 days of this letter as agreed to by Mr. Jeff Meyer of your staff l on February 25,1999.

Sincerely, f n

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Richard P. Croteau, Project Manager Project Directorate 1-2 Division of Licensing Project Management l

Office of Nuclear Reactor Regulation Docket No. 50-271

' Encic /re: Request For AdditionalInformation cc w/ encl: Sea next page

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. Vermont Yankee Nuclear Power Station ec:

Regional Administrator, Region i U. S. Nuclear Regulatory Commission Mr. Raymond N. McCandless 475 Allendale Road Vermont Division of Occupational King of Prussia, PA 19406 and Radiological Health Administration Building i Mr. David R. Lewis Montpelier,VT 05602 Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W. Mr. Gautarn Sen Washington, DC 20037-1128 Licensing Manager Vermont Yankee Nuclear Power Mr. Richard P. Sedano, Commissioner Corporation Vermont Departrnent of Public Sorvice 185 Old Ferry Road 120 State Street,3rd Floor Brattleboro,VT 05301 Montpelier, VT 05602 Rosident inspector Public Service Borad Vermont Yankee Nuclear Power Station State of Vermont U. S. Nuclear Regulatory Commission 120 State Street P.O. Box 176 '

Montpelier, VT 05602 Vernon, VT 05354 Chairman, Bor2rd of Selectmen Mr. Peter LaPorte, Director Town of Vernon ATTN: James Muckerheide P.O. Box 116 Massachusetts Emergency Management Vernon, VT 05354-0116 Agency 400 Worcester Rd.

Mr. Richard E. McCullough P.O. Box 1496 Operating Experience Coordinator Framingham, MA 01701-0317 Vermont Yankee Nuclear Power Station P.O. Box 157 Jonathan M. Block, Esq.

Governor Hunt Road Main Street Vernon, VT 05354 P. O. Box 566 ,

Putney, VT 05346-0566 l G. Dana Bisbee, Esq.

Deputy Attorney General Mr. Michael J. Daley 33 Capitol Street Trustee and Legislative Representative !

Concord, NH 03301-6937 New England Coalition on Nuclear Pollution. Inc.

Chlof, Safety Unit Box 545 Office of the Attorney General Brattleboro,VT 05301 One Ashbudon Place,19th Floor l Boston, MA P.108 Ma. Deborah B. Katz Box 83

.Shelburne Falls, MA 01370 I

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REQUEST FOR ADDITIONAL INFORMATION REGARDING l

GENERIC LETTER 96-05 RESPONSE FOR 1 VERMONT YANKEE NUCLEAR POWER STATION 1. In NRO Inspection Report (IR) 50-271/98-14, the NRC staff discussed the results of an inspection to evaluate the implementation of the motor-operated wve (MOV) program at the Vermont Yankee Nuclear Power Station (Vermont Yankee) in response to Generic Letter (GL) 96-05," Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves." In IR 98-14, the NRC staff noted that the licensee was supporting the Joint Owners Group (JOG) Program on MOV Periodic Verification developed in response to GL 96-05. The JOG program consists of three phases: (1) an " interim" MOV static ,

diagnostic testing program with a frequency based on margin and safety significance of j each GL 96-05 MOV, (2) a dynamic testing progrE.m over the next 5 years to identify ;

potential age-related increases in thrust or torque required to operate gate, globe, and j butterfly valves, and (3) an evaluation of the information from the dynamic testing program to confirm or modify the interim program assumptions. The NRC staff reviewed and accepted the JOG program with certain conditions and limitations in an NRC safety i

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evaluation dated October 30,1997. In IR 98-14, the NRC staff reported that the licensee

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had not committed to implement the JOG program primarily because of differences in the interim MOV diagnostic testing programs at Vermont Yankee and those recommended by the JOG. At Vermont Yankee, the licensee intends to rely to a large extent on test data obtained from the Motor Control Center (MCC) in its interim MOV static diagnostic testing program. The licensee did not indicate any significant objections to the other two phases of the JOG program. The NRC staff recognizes that licensees may wish to implement interim MOV static diagnostic testing programs that differ from the JOG program. The licensee should discuss whether its participation in the JOG constitutes a commitment to implement the second and third phases of the JOG program, or to notify the NRC and Justify any significant deviations from the long-term JOG program.

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2. In IR 9814, the NRC staff noted that the licensee intends to implement its GL 96-05  !

program at Vermont Yankee using the methodology described in American Society of )

Mechanical Engineers (ASME) Code Case OMN-1, "Altemate Rules for Preservice and '

Inservice Testing of Certain Electric Motor Operated Valve Assemblies in LWR Power l Plants," OM-Code-1995 Edition; Subsection ISTC. In GL 96-05, the NRC staff indicated '

that the method in OMN-1 meets the intent of the generic letter with certain limitations. The licensee should discuss its consideration of those limitations in its use of OMN-1 in implementing the recommendations of GL 96-05. Also, if the licensee intends to apply OMN-1 as an alternative to the quarterly MOV stroke-time tests r' quired by the ASME

' Boiler and Pressure Vessel Code as incorporated by reference i le NRC regulations, the ,

licensee must submit a request for relief from its Code of recc or NRC review and

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approval before implementing OMN-1.

Enclosure ,

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3. In IR 98-14, the NRC staff noted that, with one exception, the licensee had implemented the

. long-term items discussed in IR 50-271/97-08 during the completion of the NRC review of GL 89-10. " Safety-Related Motor-Operated Valve Testing and Surveillance," at Vermont Yankee. The exception involved the lack of formal evaluation by the licensee of the dynamic test results of certain MOVs with respect to their design calculations. The NRC staff considered the licensee's informal approach to revising the valve design calculations to i be a weakness in design control and configuration management. The licensee should {

discuss the actions taken at Vermont Yankee ". snsure that its GL 96-05 program will 1 provide appropriate and timely documented esuation of MOV test results to maintain the MOV design basis up to date.

4.' in IR 98-14, the NRC staff noted that the licensee had r'ot fully developed the l

documentation for its GL 96-05 program at Vermont Yankee. The licensee should discuss 1 the status of its actions to develop the GL 96-05 program documentation.

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5. In IR 98-14, the NRC staff found that the licensee was conducting dynamic tests of specific MOVs at Vermont Yankee as part of its participation in the JOG dynamic testing program to identify age-ralated degradation. However, the licensee had not committed to implement at .

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least the long-term JOG program and, therefore, could not rely on the JOG testing program  !

as the process for obtaining information regarding the degradation of valve operating

- requirements for all_GL 96-05 MOVs at Vermont Yankee. The licenses thould discuss its j olans to establish degradation rates for MOV operating requirements fo. its GL 96-05 i MOVs. l

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6. The JOG program focuses on the potential age-related increase in the thrust or torque required to operate valves under their design-basis conditions. In the NRC safety ,

evaluation dated October 30,1997, on the JOG program, the NRC staff specified that l licensees are responsible for addressing the thrust or torque delivered by the MOV motor actuator and its potential degradation. In IR 98-14, the NRC staff found that the licensee was developing a means to monitor MOV motor actuator output degradation at Vermont Yankt.e but that the orecise process for determining motor-actuator output and rates of degradation in static and dynamic performance was not fully developed. The licensee should describe the plan at Verr'ont Yankee for ensuring adequate ac and de MOV motor-actuator output capability, including consideration of recent guidance in Limitorque Technical Update 98-01 and its Supplement 1.

7. In IR 98-14, the NRC staff noted that several aspects of the licensee's GL 96-05 program with respect to its periodic testing method were not fully developed at Vermont Yankee.

- These aspects included (1) validation of MCC-based diagnostic equipment, (2) validation that the proposed long-term test method will detect MOV degradation under dynamic conditions, (3) justification of MOV test intervals that exceed 10 years, and (4) finalization of MOV test schedules. The NRC staff also notes that the licensee's documentation of MOV '

performance trends appeared to focus on diagnostic test data without similar attention to

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qualitative trends of MOV performance problems and repetitive maintenance. The licensee

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should describe the development of its plans for periodic testing and trending of GL 96-05 MOVs at Vermont Yankee.

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