ML20236N357

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Responds to Work Request Dtd 970804,requesting Review of Region I Task Interface Agreement Re Interpretation of TSs at Vermont Yankee,Revised Response
ML20236N357
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 09/08/1997
From: Beckner W
NRC (Affiliation Not Assigned)
To: Berkow H
NRC (Affiliation Not Assigned)
Shared Package
ML20236J990 List: ... further results
References
FOIA-98-155 50-271-96-11, NUDOCS 9807150100
Download: ML20236N357 (3)


Text

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,,,,,* Septempter 8, 1997 MEMORANDUM TO: Herbert N. Berkow, Director Project Directorate, II-2 Division of Reactor Projects, NRij , p, //y FROM: William D. Beckner, Chief M Technical Specifications Branch Associate Director for Projects, NRR

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 memo dated August 11, 1977, (W. D. Beckne'r to H. N. Berkow), the Technical specifications Branch (TSB) provided the results of our review of the subject TIA. The TSB response was based on a 30 day frequency for the Vermont Yankee (VY) Surveillance Requires.ent (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 ,as meaning once per calendar month. In light of this, we were requested to revisit the ,

TIA and provide results of our rereview based on the once per calendar month '

interpretation. We have completed that review and provide the following conclusions. '

The TSB does not believe that the ters 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 two months between surveillance which is clearly not the intent. Second, surveillance requirements nomally deal in intervals or frequencies. Thus, we interpret the tem 'once a month" to require a surveillance interval of one 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 unchanged from that in our August 11, 1997, memo, 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 fuel be obtained "once a month" and checked for quality. While it is implied that the results of the l fuel oli analysis be provided in the same one month interval in which the sample was taken, the VY TS do not explicitly require this. Therefore, failure to obtain analysis results in the sample interval does not constitute i a TS violation. In this regard, we agree in principle with the conclusions  ?

stated in Attachment I to the TIA (excerpt from inspection report 50-271/96- h b) 0

11) except for the reference a 30 day SR interval as opposed to a month interval.

A(.b .<.#3 Ni?C FRE SENTEP c0PY 1.11H. H.1.11.11 E.lli.ll 9807150100 980624 -

NER -155 PDR

.. H. N. Berkow September 8, 1997 With respect to LER 96-029, the licensee is incorrect since the TS do not explicitly state when the fuel oli analysis results must be obtained.

If you have any questions regarding this matter, please contact Mr. E.

Tomlinson of my staff, on 415-3137.

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H. N. Berkow September 8, 1997 With respect to LER 96-029, the licensee is incorrect since the TS do not explicitly state when the fuel oil analysis results must be obtained.

If you have any questions regarding this matter, please contact Mr. E.

Tomlinson of my staff, on 415-3137.

\ DISTRIBUTION:

File Center TSB R/F RPZimmerman BBoger KJabbour ETomlinson DOCUMENT NAME: G:\EBT\TIA8-28 0FFICE TSB:ADPR:NRR / // # C:TSB:ADPR:NRR NAME EBTomlinson WDBeckner Cu D6 l 08/ /97 08/29/97 $/g/97 4 ' I N I