IR 05000271/1987019

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-271/87-19.Agrees Certificate of Compliance Acceptable Basis for Demonstrating Qualifications Provided Under Listed Conditions

ML20151Z982
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	08/18/1988
From:	Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 8808300350
Download: ML20151Z982 (3)

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v 18 AUG 198a Docket No. 50-271 License No. OPR-28 Vermont Yankee Nuclear Power Corporation ATTN: Mr. Warren P. Murphy Vice President and Manager of Operations RO 5, Box 169 Ferry Road Brattleboro, Vermont 05301 Gentlemen:

Subject: Inspection No. 50-271/87-19 This refers to your letter dated March 28, 1988, in response to our letter dated February 22, 1988.

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We have revfewed your response to the Notice of Violation and observe that your position re Operators) is garding that theItem No. 3 (Qualification Certificate of Dinks of Compliance Brakes presented at in thelimitorque Valve inspection was sufficient to establish qualification. We agree that a Certiffcate of Compliance is an acceptable basis for demonstrating qualifications if it is providtd under the following conditions:

1. The licensee must have required the vendor to have a quality assurance program that complies with 10 CFR 50, Appandix B and verified its implementation.

2. The licensee must have transmitted the plant specific environmental requirements, the performance specifications and the electrical characteristics to the vendor through the procurement specification or other suitably controlled documents.

3. Tha vendor or other egent must have performed the appropriate testing or analyses to establish qualification of the component in accordance with the regulatory requirements.

4. The supplier of the C of Q must maintain the equipment environmental qualification file that complies with 10 CFR 50.49, ensure the file

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is available for the life of the component and provide accessibility for NRC audit if requested. The C of C must contain information that directly relates the component to the EQ file.

OFFICIAL RECORD COPY RL VY 87-19 8808300350oogM1 PDR ADOCK O

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Vermont Yankee Nuclear Power 2

Corporation

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The inspectors, in this instance, asked that documentation be provided in accordance with conditions 3 and 4 above to support the radiation qualification of the Dings brakes. At the time of the inspection, neither you nor the vendor e provided the necessary documentation. It is our understanding that the infor- 7 mation provided was newly assembled subsequent to the inspection. In this case, t a violation of 10 CFR 50.49 is sustained. *

t Per telephone conversation between P. R. Johnson of Yankee Atomic, T. P. White l of Vermont Yankee and L. Cheung of NRC on June 9, 1988, we understand that the i completion date for the resolution of the Rome Cabic deficiency (Item #5) will .

l be revised from "prior to start-up from the next refueling outage" to '

September 15, 1988 (reference: Yankee atomic memorandum W.O. #4440 dated June 9, 1988). Your corrective actions will be examined during a future ,

EQ inspection, t

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Your cooperation with us is appreciated, i

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Sincerely,

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William V. Johnston, Acting Director !

, Olvision of Reactor Safety cc:  !

J. Weigand, President and Chief Executive Officer  !

J. Pelletier, Plant Manager J. DeVincentis, Vice President, Yankee Atomic Electric Company  !

R. Capstick, Licensing Engineer, Yankee Atomic Electric Company C. Richardson, Vermont Public Interest Research Group, Inc.

William Steinhurst, Acting Commissioner, Vermont Department of Public Service P. Agne: Assistant Secretary of Public Safety, Commonwealth of Massachusetts Public Document Room (POR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Hampshire State of Vermont Commonwealth of Massachusetts

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APA'A9,, APAAMM MAMni Aq ent Ag ga name e a

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YermontYankeeNuclearPower 3 ov Corporation bec:-

Region I Docket Room (with concurrences)

M. Perkins, Management Assistant, DRMA (w/o encl)

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D. Haverkamp, Section Chief, ORP G. Grant, SRI - Vermont Yankee (w/ concurrences)

H. Eichenholz, SRI - Yankee V. Rooney, PM, NRR R. Bores,. Technical Assistant, DRSS K. Abraham, PA0 (12) (SALP Reports.Only)

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RI:0RS RI:0RS Cheung/ tim /rw Anders[onRI:0R$ Ourr n-/

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OFFICIAL RECORD COPY RL VY 87-19 - 0001.2.0 08/03/88

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VERh10NT YANKEE NUCLEAR POWER CORPORATION

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FVY 88-21

. RD 5. Box 169. Ferry Road Brattieboro. VT 05301 ,, ,,

y ENGINEERING OFFICE 1671 WoACESTER AOAo

, F R AMINGH A M, MA$$ACHUSETTS 01701

ttLINoNe tir 472 tico March 28, 1988 U.S. Nuclear Regulatoty Commission Washington, D.C. 20555 Attn Document Control Desk

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References: a) License No. OPR-28 (Docket No. 50-271)

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b) Letter, USNRC to VYNPC, NVY 88-019, "January 26, 1988 Meeting with the VYNPC, Re: Environmental Qualification Issues", dated 2/9/88

.c ) Letter, USNRC to VYNPC, NVY 88-025, "Inspection Report

, , No. 50-271/87-19 and Notice of Violation", dated 2/22/88

Dear Sir:

Subjects' Response to Inspection Reoort 87-19, Notice of Violation -

This letter is written in response to your Notice of Violation, dated February 22, 1988 (Reference c)).

VIOLATION -

As a resuit of the environmental qualification (EQ) inspection conducted on October 19-23, 1987 and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement i Policy 1987), the following violation was identified:  !

10 CFR 50. A9 paragraphs (f) and (g), and paragraph (k) (for 00R Guidelins provision) require that each item of electrical equipment important to safety be qualified and that qualification must be completed no later than Novetter 30, 1985. Contrary to the above on October 23, 1987:

1. Qualification of the EP/Hypalon cables was not established at the time

of the inspection in that the qualification test report was invalid because of problems identified in ','nformation Notice 84-44 (inadequate QA program, test equipment not properly calibrated, test deficiencies and test anomalies improperly documented, and test documents impro-perly controlled).

t 2. The qualification of 3M ta r.r splices was not established at the time of the inspection in that N type test report nor adequate similarity analysis was available in the EQ file to support the tape splices'

qualification.

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VERMONT YANKEE NUCLEAR POWER CORPORATION

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U.S. Nuclear Regulatory Commission March 28, 1988 Page 2 .

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3. The qualification of Dings brakes in the Limitorque valve operator was !

not established at the time of the inspection in that the EQ file did not contain evidence to demonstrate the radiation qualification of the Dings brakes for application inside the drywell.

4. The qualification of GE EB 5 terminal block was not established at the time of the inspection in that 1) the type test report did not demonstrate that this terminal block can perform its safety functions because low insulation resistance values were observed during the test and 2) no similarity analysis was available in the EQ file for GE EB-5 and GE CR 1518 terminal blocks.

5. The qualification of Rome XLPE/PVC cables was not established at the time'of. the inspection in that the test conditions did not envelope

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the required service conditions (303*F for four hours vs 325'F for three hours).

6. - The qualification of Lewis PE/PVC instrumentation cables was not established at the time of the inspection in that no valid test report

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was available in the EQ file to support the qualification of this type of cables.

This is a Severity Level IV violation (Supplement I).

RESPONSE The Vermont Yankee Nuclear Power Corporation response to the violation will address each of the six items described above separately as follows:

1. This ites deals with Cerro cable. During the inspection, Vermont Yankee was able to obtain a Franklin ReseaEc6~ Center test repor't which verified

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the qualification of the cables. A qualification documentation review (QOR) package revision is in progress to include this report and to upgrade the file as required. When the additional information is incorporated, this QOR will document, in accordance with the Division of Operating Reactor (DOR) Quidelines, that equipment subjected to harsh environmental

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conditions will perform its intended safoty function. This action will bring Vermont Yankee into full compliance with 10 CFR 50.49. This will be completed by May 1, 1988.

2. Item 2 involved 3M tape splices. During the inspection, Vermont Yankee was able to obtain a letter from Wyle Laboratories, dated October 21. 1987, summarizing testing that Wyle had performed on 3M tape splices. Vermont Yankee has since obtained a copy of the Wyle Test Repor?. No. 58316 docu-menting the qualification of the 3M tape splices. In addition to the above mentioned test report, Vermont Yankee has obtained a second Wyle Te?t a

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VERMONT YANKEE NUCLEAR POWER CORPORATION

U.S. Nuclear Regulatory Commission March 28, 1984 Page 3 ,

l Report #17947-01, which further tested 3M splices in various con- l figurations. This test, which satisfies the intent of IEEE 323 1983,  !

included LOCA and main stese line break testing which envelopes the Vermont Yankee application with margin. A QOR revision is in progress to upgrade l the file as required. When the additional information is incorporated, l this QOR will document, in accordance with Division of Operating Reactor j (DOR) guidelines, that equipment subjected to harsh environmental con-ditions will perform its intended safety function. This action will bring l Vermont Yankee into full compliance with to CFR 50.49. This action will be

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completed by July 1, 1988.  !

3. Itee 3 involved the qualification of Dings brakes in Limitorque valve {

It continues to be Vermont Yankee's position that the qualifi-

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operators.

cation of Limitorque valve actuators equipped with Dings brakes is ade- {

quately addressed in Vermont Yankee's existing EQ file. The Certificate of Compliance contained in our file states: "The brake motor supplied with i r

special endiation resistant brake coils with materials equivalent to K8110  !

wou.1d be equivalent to, or superior to, the brake motor included in Limitorque Qualification Report 600194. The capability of the motor and I brake coil to withstand radiation only can be supported by Qualification Report 600376A."

Qualification for radiation is clearly. established by the Certificate of Coispliance. Qualification Report 600376A tested an actuator with motor i which was irradiated to a radiation-dose of 2 x 10 R, 8 which exceeds our i

requirements with s,ignificant margin. During the meeting between NRC and l Vermont Yankee on January 26, 1988, the acceptability of vendor documen- l tation to demonstrate qualification was discussed in detail. At that ,

meeting, NRC management concurred that Certificates of Compliance to a test report from a QA-approved vendor are acceptable to link qualification to the certified test report. In that Certificates of Compliance are the basis of nearly all nucleae documentation, a certificate of Compliance in this instance is as acceptable, if not more so than a letter from a vendor.

Accordingly, it is Vermont Yankee's position that at the time of the inspection, the qualification file clearly established qualification and this ites was in costiliance. However, in order to fully address Inspection Item 50-271/87-19-06. we will upgrade our file to incorporate the addi-tional informattor,obtained on the material composition of the Vermont

• Yankee Dings brake and the radiation threshold doses. A QOR revision is in progress. This will be completed by May 1, 1944.

4. This iten involved the qualification of the GE ES-5 terminal blocks.

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As stated in the inspection report, Vermont Yankee obtained a memorandue from OE _durjng the audit documenting the similarity of the ES-5 block and the CM-1518 block. In addition, the EQ file had an overly conservative operating time leading to the auditor's conclusion that the 50119 Limitorque test report did not demonstrate the qualification of the ES-5 block for required insulation resistance. A QOR revision is in progress to document the required operating time of the blocks and to include the sini-larity documentation obtained from GE. When the additional information is

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VERMONT YANKEE NUCLEAR POWER CORPORATION e

U.S. Nuclear Regulatory Commission March 28, 1988 Page 4 *

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l incorporated, this QOR will document, in accordance with the Livision of Operating Reactor (00R) Ouidelines, that equipment subjected,to harsh environmental conditions will perform its intended safety function. This l action will bring Vermont Yankee into full compliance wi,th 10 CFR 50.49.  ;

This will be completed by June 1,1988.

5. This item involved the qualification of Rome XLPE/PVC cable. The inspec-tion report states that the peak temperature is not enveloped by actual Rome cable testing and that the file did not contain sufficient information to show similarity to the tests of other manufacturer's cable used by Vermont Yankee to qualify the peak temperature. Vermont Yankee provided additional operability time information during the inspection. The inspec-tion repor,t concludes that based on the data furnished by Vermont Yankee

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during-end after the inspection, the licensee would be able to establish  ;

qualificaitbn. A QOR revision is in progress to incorporate the infor-nation provided to the NRC. In addition, Vermont Yankee will perform ,

material and chemical composition testing on selected samples of cables to '

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further establish and document the' similarity of the Rome cable to the cables tested by other manufacturers. When the additional information is  !

incorporated, this QOR will document, in accordance with the Division of  !

Operating Reactor (00R) Guidelines, that equipment subjected to harsh

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' environmental conditions will perform its intended safety function. This action will bring Vermont Yankee into full compliance with 10 CFR 50.49.

This will be completed prior to startup from the next refueling outage.

6. This item involved the qualification of Lewis PE/PVC cables. The inspec-tion report states that at the time of the inspection, no valid test report was available in the EQ file to support qualification. During and following the inspection, Vermont Yankee submitted additional information

to the NRC to support the qualification of the Lewis cables. The inspec-i tion report concludes that based on the additional information provided, the licensee would be able to estabitsh qualification. A QOR revision is in progress to incorporate the information provided to the NRC. When the i

additional information is incorporated, this QOR will document, in accor-

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dance with the Division of Operating Reactor (DOR) Ouidelines, that

! equipment subjected tu harsh enviromental conditions will perform its 1'

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intended safety function. This action will bring Vermont Yankee into full compliance with 10 CFR 50.49. This will be completed by July 1, 1988.

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The Vermont Yankee EQ Program is a dynamic, ongoing program supported by 67 i volumes of documentation. The documentation supporting this program undergoes a

revision based on new information obtained from a variety of sources including j the NRC, utility groups, and lessons learned from other utilities and inspec-tions. This ongoing process will ensure future compliance with NRC rules and regulations precluding future violations.

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VERMONT YANKEE NUCLEAR POWER CORPORATION

U.S. Nuclear Regulatory Commission March 28, 1988

Page 5 We trust that this information is satisfactory and fully responsive to your request. However, should you have any questions or require additional infor-mation concerning this matter, please contact us.

Very truly yours,

VERMONT YANKEE NUCLEAR POWER CORPORATION

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Warren P. Murphy

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Vice President and

, , Manager of Operations

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cci W,V. Johnston, NRR USNRC Region I, Regional Administrator USNRC Resident Inspector, VYNPS

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