ML20034C264
| ML20034C264 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 04/24/1990 |
| From: | Sherman W VERMONT, STATE OF |
| To: | VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| CON-#290-10298 OLA-4, NUDOCS 9005020240 | |
| Download: ML20034C264 (84) | |
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UNITED STATES OF AMERICA-USNRC NUCLEAR REGULATORY COMMISSION before the 5
ATOMIC SAFETY AND LICENSING BOARD:
'90 APR 27 A11 :39-1 OfTICE OF SECRETARY.
1 00CK(11NG A SLUVICL BRANCfi In the Matte,r of-
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)
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VERMONT YANKEE NUCLEAR
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Docket No. 8 0-2 71-OLA-4. -
b
' POWER CORPORATION
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(Operating License
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Extension) i (Vermont Yankee Nuclear
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Power Station)
)
l ll RESPONSES-TO INTERROGATORIES BY' STATE?OF VERMONT TO THE VERMONT YANKEE NUCLEAR POWER CORPORATION s
(Set No.: 2):
To the extent that a given interrogatory appears to. seek a legal conclusion, it iscobjected'to, and to the extent that' i
such interrogatories are answered, itis.not to be' considered a legal. answer.
Q.1 Pleasa define what SOV contends isLincluded within the' scope of the term " maintenance program" asLused by..it'in i
its Contention 7.
A.1 Vermont uses the term " maintenance program" to include any policy, procedure, guideline', method,.
i practice or standard which accomplishes, controls,-or relates to " maintenance" as.it-is defined in NRC' Policy; i
Statement on Maintenance of Nuclear Power. Plants (53 FR 9430)'.
The definition in the Policy Statement'is consistent' with the definition in NUREG-1212, Volume-1,." Status of 1
1 9005020240 900424 PDR ADOCK 05000271 t
G PDR N
Maintenance in the U.S. Nuclear Power Industry, 1985,"
Section 1.1.
Q.2 Does SOV contend that NRC imposes any requirements upon the content, substance or form of the VYNPS " maintenance program" as that term is used by SOV in its Contention 7?
If so, please identify, by citation to or identification of a document, each and every such requirement.
A.2 Because of the reliance in the application on the maintenance program for protection of public health and safety in the extended period, the basic requirement is the reasonable assurance requirement of 10 CFR 50.57 1
(a) (3).
In addition the following contain NRC requirements for maintenance:
a.
10 CFR 50. 55 (a) (g) b.
10 CFR 50.49 c.
10 CFR 50.59 d.
Regulatory Guide 1.33 (QA Program Operations) e.
Regulatory Guide 1.58 (ANSI 45.2.6) f.
Regulatory Guide 1.88 (ANSI 45.2.9) g.
Regulatory Guide 1.129 (IEEE STD 450) h.
10 CFR 50.34 (Paragraphs 5 and 6)
Also, because of the NRC's concern regarding nuclear plant maintenance, and its policy, "In view of the progress made to date, as well as the industry's express commitment to improve maintenance, the Commission has decided to hold 1
rulemaking in abeyance for an 18 month period to I
monitor industry initiatives and progress (54 FR 50611),"
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P and because of the timing and' content of this proceedinge the " industry initiatives" become NRC' requirements'for:
the licensee's-maintenance-program..
In addition, we recognize the process'of'makingL voluntary commitments as?a source of;NRC maintenance requirements'for the licensee's program..-Through pressurefromhheNRC, licensees often voluntarily commit--
tc= changes rather than incur regulatory forced' shutdowns.
or forced backfits.' Such an example is the Uninterruptible Power Supply system ab Vermont Yankee.
The licensee has committed tofreplace.this system in the q
1990 refuelling. outage-because of poor reliability of the present system.
This is' an example of aul NRC maintenance 4
program requirement, j
Q.3 Please define what SOV-contends ils included.within the:
scope of the term " surveillance program" as used.by'it:in its Contention 7.
A.3 Tne term " surveillance" is used in the broadest sense as expressed in applicableLNRC and industry' i
sources, including the application.
We note that 10 CFR 50.36-(c)(3) defines " surveillance requirements" as requirements relating to test, calibration, or inspection i
to assure that'the necessary quality of-systems and components is maintained, that-facilitycoperation will be I
within the safety limits, and the limiting conditions of-operation will be met.
Draft Regulatory-Guide DG-1001 i
3
b wc defines " maintenance surveillance" as; consisting ~of-collecting data at--specific frequency that supports the.
predictive and; corrective maintenance programs..
A " surveillance program" includes any policy, procedure, guideline, method, practice or; standard which-accomplishes,: controls,-or relates'to surveillance.
The surveillance program is one-aspect-of the, maintenance' program (refer to the response =to-question 1).
Q.4 Does SOV-contend that NRC imposes any. requirements upon the content, substance or from of the VYNPS " surveillance.
program"-as-that term is used by:SOVrin its' Contention 7?:
If'so,'please identify,:by citation to or identification of a document, each andlevery such requirement.'
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1 A.4 The following are surveillance program. requirements.
j established by NRC:
l a.
NRC requires surveillance as-indicated in the
'I technical specifications.
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b.
NRC requires surveillance as provided,in the a
inservice testing and inservice inspection program.
c.
NRC requires special surveillance when circumstances dictate.
For example, NRC intends'to require i
special surveillance requirements on flawed feedwater check valves if. licensee does not replace them during the next refueling outage.
i Q.5 Does SOV contend that NRC imposes any requirements =upon
.j the content, substance or form of the VYNPS " program to.
j maintain and/or determine and replace all components-found to have aged to a point where they no longer meet 4
k y<
the safety standards applicable to this~ plant" as that term is-used by SOV in its Contention 77-If so, please identify, by citation to or' identification of a document, each and every such-requirement.
A.5 Vermont contends.that the VYNPS maintenance program does not meet the NRC, requirement of =10 - CFR 50.57 (a) (3), ~
that reasonable assurance hasinot.been demonstrated that 1
the maintenance. program will function:to the' degree
~
relied upon iri the application, to maintain the plant' within its current licensing basis in the extended-
{
period.
To the extent that this. question requests N legal opinion of what this reasonable: assurance'is, or should be, Vermont objects, since this will.be determined by the Board at the end of the hearing.
Notwithstanding and'without waiving'our objection, f
Vermont states that we are not' aware of each and every?
requested requirement.- However, Vermont is aware-that-NRC, as its policy, expects-industry; initiatives to improve maintenance (54.FR 50611),.and as stated in response to question 2, these initiatives become i
.1 l
requirements in this proceeding.
Some of'these industry initiatives are described in an NRC Memorandum of-
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December 28, 1989 (Roe to Murley), " Meeting with'NUMARC j
on Maintenance."
Also, Draft Regulatory Guide DG-1001:
sets requirements applicable to the licensee's program.
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Q.6 Please list and describe in as much detail as is j
available to SOV each of the changes to the VYNPC maintenance program, surveillance program, or other i
5
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- program that, if made'to;the programs, would render 1Sov's Contention 7 satisfied..
A.6 Vermont objects to this question to'the extent that it requests a legal opinion?of reasonable assurance-that the maintenance and surveillance _ programs willl provide adequate protection.
This matter will be-determined at the end of the hearing,by-the Board.' Notwithstanding and a
without waiving-the objection,~ Vermont states thattit would not be responsible at this stage _toLidentify all changes which would render contention VII satisficd:('if this were possible) without fully-reviewing with our
-technical consultant'allithelinformation we seek'in:
discovery.
Nevertheless, programLinadequacies are identified in response:to question 44.
Program modifications to correct these inadequacies are q-necessary.
For example,Lthe' program needs to be' proceduralized rather than relying on individual worker l
skills.
Vendor manual updates'need to be controlled and i
used.
Post maintenance-test requirements need-to be
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included in procedures.
Adequate staffing resources need to be provided to accomplish review of-completed maintenance requests.
The program needs-to be I
computerized to track and account for each component in the plant and to track surveillance activities so that 4
surveillance and maintenance activities are nos missed.
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-Management needs to take an. active role in trend evaluation.
The trend evaluation process needs to be j:
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-formalized to1 establish criteria for action with degrading trends.
Industry initiatives, such as reliability-centered maintenance) which shift the" emphasis from corrective to preventive maintenance, need' to be considered.
Performance monitors for maintenance-1 need to be established,;along with' criteria-for actions based on'such monitors.
Finally, once these,landiother; changes identified as:
-a result of our discovery, are made,-they must be monitored, as-stated in response to question 100.s Q.7 Please define the failure mechanisms that SOV contends are within the: scope,of;the phrases"found to have-aged to' a point where they no longer meet the safety standards-applicable to this plant" as this: phrase-is used byLit-in its Contention 7.
A.7 Refer to the response to-licenseei s set no.
1, question 1.
Vermont, and'probably the industry, is"
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unaware of all the applicable;and operable failure mechanisms which affect the structures, systems and-a components, and which will cause-degradation.'and: failures i
in the extended period.
However, we have provided:as complete a list as possible at'this time in the sub--
j parts to contention VI.
1 1
Q.8 Please identify the components or~ classes of components that SOV contends are potentially subject'to each of the 4
failure mechanisms that SOV contends is within the scope of the phrase "found to have aged to a point where they; no longer meet the safety standards applicable to'this plant" as phrase is used by:it in its contention 7.-
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A.8 Again, with the_ qualification noted-in the. priori s
1 response that many' age failure mechanisms are.not understood,:we state that:the'sub-parts of' contention VI'
' identify classes of components that are subject to.the-various failure mechanisms.-
t Q.9 PleaseJdefine'the measureof "sufficiently affective"Las-the term is'used by/SOV in its contention 7.
A.9
-To the' extent that this-question' requests.a legal _
definition = for "sufficiently effective'!, Vermont objectse 4
This is a matter which willLbe datermined by the1 Board at the end of the hearing.
Notwithstanding and'without waiving the objection, we state that " effective" refers j
to the implementation of'the maintenance-program. -Facts d
3, 6,
7, 8,
9, 11 and 12, identified in: response to question-44, relate to aspects of the maintenance program
)I i
which are not "sufficiently effective."
i Q.10 Please identify or describe all of the-bases for-the-definition supplied in response to the-foregoing interrogatory.
A.10 The ultimate basis for the measure of-"sufficiently_
effective" is the decision of the Board.'
1 i
Q.11 Pleasecdefine the measure of "sufficiently...
- k comprehensive"-as the term is used by SOV in its i
Contention 7.
A.11 To the extent that this question requests a legal j
definition for "sufficiently... comprehensive", Vermont 8
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. objects.. This.is a matter,which will:be determined by l
i the Board at the end of'the' hearing.
Notwithstanding and without waiving ~the objection, we offer that
" comprehensive" refers to the completeness of the!
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program.
Facts'1, 2,,3,(4, 5, 10,tand 1311dentified'in-response'44. relate to aspects of the' program which are not sufficiently comprehensive.-
Q.12 Please : identify or describe all' of. the bases' for the:
definition supplied in~ response to the. foregoing interrogatory.
A.12 The ultimate basis for the measure'of "sufficiently comprehensive"'is the decision of the Board.
Q.13 Does SOV contend that the~VYNPS maintenance program.is not in compliance'with.all~ applicable NRC requirement?-
l A.13 Yes.
Q.14 If your response to the'_ foregoing interrogatory is-anything otherithan an unqualified-negative,;please:
identify, by citation to or: identification of'a document, each and every such. requirement withlwhich SOV contends' the VYNPS maintenance. program is notlin. compliance, and, i
for eachisuch requirement, each and every reasonzwhy.SOV?
contends that the VYNPS maintenance program'is_not in-compliance with it.-
A.14 Vermont contends that the VYNPS maintenance program'
.does not meet the NRC requirement of 101CFR ' 50. 57 (a)[(3 ),
f 11 that reasonable assurance has not been demon'stratedithat 4
the maintenance program will function to-the degree and I
i in the manner relied'upon in the application to. maintain L
the plant within its current licensing basis in the l
extended period.
To the extent that this question 9
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t requests a legal opinion of what constitutes this reasonable assurance, Vermont objects,'since-this will'be~
determined by the Board at the end of the hearing.
Notwithstanding: and without-waiving: the objection, Vermont states that facts indicating; maintenance. program aspects which'do'not demonstrate reasonable assurance, are provided'in response to question 44'.-
Q.15 Does.Sov contend-that'the VYNPS surveillance. program is-not in compliance with any applicable NRC: requirement?;
A.15 To the extent that the surveillance ~ program ~is one aspect of the maintenance' program which. we ' contend 'does not meet'NRC requirement (s)- (refer to-the responses to j
questions 13 and 14), we respondfyes.
Q.16 If your response to the foregoing interrogatory is-anything other than an unqualified-negative,.please identify, by citation to or identification of a document,.
each and every such requirement.withLwhich SOV1 contends the VYNPS surveillance program is-not~in compliance, _ and, -
for each such requirement, each and every reason why SOV-contends that the VYNPS surveillance; program. is ~ not irr compliance with it.
A.16 Refer to the response to question 14. : Fact 7, in response to question 44, specifically relates to surveillance.
t Q.17 Please describe what SOV means by the phrase "no closure' showing improvement" as used by it in sub-paragraph "b."
of its Contention 7.
A.17 By "no closure showing improvement", we, meant that at the time of the filing'of the contention, the'NRC l
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i Maintenance Team had notireinspc *.ed and' issued a-followup inspection report indicatingLthat corrective action had been.taken forLall of the listed weakness.
In addition, as noted in response 18, once weaknesses:are identified, two distinct meanings of " closure" come'into being:
closure by thelNRC-Maintenance Team,fand closure; by Vermont.
Q.18 Please describe the set of items, events or circumstances-that would constitute'" closure showing improvement">
within-the meaning of sub-paragraph "b." of. Contention 7 such that, were any'such-item,-event or circumstance to:
occur or, exist, sub-paragraph "b." would no longer be.
true.-
A.18 To the extent this question calls for-a legal opinion of what would' constitute 1 reasonable-assurance' that the listed weaknesses were1 corrected,.it'is objected to,.and is a matter which.willlbe decided by the Boardfat the end of the hearing.
Notwithstanding'and:without
.i waiving the objection, Vermont. states,;that once weaknesses are identified, two distinct' meanings of
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" closure" come into being.
In the one sense, closure will occur when the NRC Maintenance Team:reinspects, and issues an inspection report indicating the weaknesses;
~
have been corrected.
However,'once the weakness-is=
identified, attention is focused.on'it. -Vermont reviews 1
the circumstances surrounding the weakness-and independently determines the extent and nature of the i
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-c 6L weakness and its-solution.
Closure ~ay Vermont'is, therefore, independently-evaluated-and determined..
Q.19 If the-NRC Staff-were to publisN aLdocument or'make.a finding to the effect that any item' described by it'in;an Inspection Report _("IR") is now closed,;would.SOV acknowledge:that-such-publication or. finding constitutes'
" closure" asithat term is used by SOV'in;sub-paragraph:
"b." of its' Contention 7 of the_ item in~ respect of which' the publication or finding _ were made?:
i A.19 ReferLto the previous response.
Q.20 If your response to the-foregoing interrogatory is anything other than an unqualified affirmative, please>
describe all of the reasons why such a1 publication'or finding would not constitute " closure."-
A.20 Refer to the response to question 118.
1 Q.21 Please identify each-of the-issues _ adverted 1tolin Contention 7, including sub-paragraphs "b.",
"c.",~"d.",1 "e.", "g.",
"h. (1) ",
"h. (2) ", "j.",
"k.";
"m.",.and "n."
thereof and sub-paragraphs "1.", "n." and-"o." of-Contention 8, that Sov acknowledges have'been_" closed" as of the date on which your answers:toithese interrogatories are filed.
A.21 Vermont is not aware, and does not consider,'that any of the items have been " closed" as of=the:date of these answers.
Q.22 Does SOV contend that all vendor-recommended preventative maintenance must be performed in order for.the VYNPS'-
l maintenance program:to be adequate to prevent aging failures?
Please give all the reasons for your answer and, if your answer is qualified, all of the qualifications applicable to VYNPS and the reasons for l
them.
A.22 No.
It is possible to adjust a vendor a
recommendation through technical analysjs, testing, 4
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and/or' concurrence by the vendor.J 'The types of-analyses and testing required-vary according to the type of component, the' environment,-the operating mode, the current licensing basis, and the specificLvendor-recommended' preventive maintenance item.
Q.23 Please-describe exactly how'SOV contends that post' maintenance testing must be' incorporated?into'the.
maintenance procedures in order;for the procedures-to be) i adequate..
A.23 To the extent.thatsthis question callscfor a legal' definition of what'would constitute reasonable' assurance 3-that the lack of post maintenance testing 1 requirements 11n?
maintenance procedures was' corrected, itcis objected to, and is a matter which will'be decided by,the Board at the
.end of the hearing.
Notwithstanding;and.without: waiving-this objection, Vermont statesLthat proceduralizationD of?
these requirements-is necessary to assure consistent application of post maintenance' testing, rather than depending of the random skills of,the individual preparer or reviewer in the maintenance or operations department.
Vermont notes, from section 4'.7 of Draft. Regulatory" Guide) l DG-1001, that:
1
'"The work control process'should be based on j
procedures that provide for... post maintenance-
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testing, return-to-service procedures..."
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1 Such procedures'should provide systematic guidance to:the-craftsman, should-be technically correct,' complete and' up-to-date; and should be. presented using sound human.
factors principles.
Q.24 If SOV rentends that post maintenance testing;mus: oc.
procedural 1L?dnin order for the maintenance prog;am-to-be, adequate, plu3nc describe the steps that SOV= contends must be included in ths procedures for insuring that-post maintenance testing is_comprahensive-enough for a givenL
. maintenance task.
A.24 To the extent that "ccaprehensive enough" in this:
question calls for a legal defin',. tion of: what would' constitute reasonable assurance that theLlack'of post
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maintenance testing requirements'in maintenance procedures was corrected,.it is objectedito, and isfa-
- 1 matter which_will be decided by the board atithe end'of.
i the hearing.
Notwithstanding andjwithout' waiving this objection, Vermont states that we are unable to) identify 4
specific procedural stepsLwithout a'cesstto'the c
maintenance procedures, which.we have not beenigranted.
Q.25 Please describe what SOV means by its assertion that-"PRAL concept not incorporated into Vermont Yankee maintenance-program" at page 43 of its contentions.
1 A.25 By the use of this statement, "PRA concept not i
incorporated into Vermont Yankee maintenance program >a l
which is quoted from IR 89-80, Vermont means that thn PRA concepts of reliability-centered-maintenance, along.with 1l other industry initiatives, should be employed to provide 14 1
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assurance in the' areas' identified-by; Facts-2 andi 13:in response to question 44.
c Q.26 Please. describe in detail' exactly how SOV' contends that "PRA concept" should be " incorporated" into-the VYNPS:
maintenance program.
A.26~
To'the. extent that this question calls for aJlegal defin(tion of what would constitute reasonable assurance--
that the lack of. incorporation of PRA: concepts-into the-t maintenance program was corrected, it is objected-to, and is a matter which.will be decided by the Board at.the'end-of the hearing.,.Notwithstanding.and without waivingithis objection, Vermont states that~ practices"which contribute to an effective maintenance program are.proactive'as opposed to reactive, that' preventive maintenance is emphasized over corrective maintenance. JVermont. Yankee's' maintenance program has been characterized as a program!
j with weak preventive maintenance, needingLa more l
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proactive posture, and with naintenance. activities heavily oriented to corrective maintenance.
In a proactive program, PRA concepts are usedito provide a systematic consideration of~ system' functions.and the ways in which functions can fail, leading'to the-
.1 identification of applicable and effective preventive maintenance tasks with consideration of safety and economics.
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Q.27 Please state,your basis <for,'and each authority on which' you rely.in' support of,.-your response'to the foregoing i
interrogatory.
j.
A.27 Characterization of Vermont Yankee's maintenance f
program'is drawn from-the: safety system functional inspection (SSFI): conclusions! Presented at the NRC Regioni I meeting of January 26, 1989.
PRA concepts are employed ~
by reliability-centered maintenance. techniques,: which are discussed in EPRI NP-6152, Volume 1, January 11989,
" Demonstration of'Reliabilityacentered Maintenance,-
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Volume 1: Project Description."
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Q.28 Please identify-each and every benefit thatLSOV contends A
~
would result from the." incorporation" of "PRA concepto:
4 into the VYNPS maintenance program,~ and please state each~
and every reason'whycSOV contends that such benefit would.
1 result.
A.28 EPRI NP-6152 identifies " realignment'of maintenance-
-i resources to improve.overall plant availability;and i
safety," and " producing a more favorable preventive' maintenance to corrective: maintenance ratio," as objectives of reliability-centered maintenance.
l f,
Q.29 Does SOV contend-that its asserted non-incorporation'of "PRA concept" renders the VYNPS maintenance program,,or.
-the operation of VYNPS, in any respect:not in compliance with any regulatory requirement of the Commission?
A.29 Vermont objects to this question 1to theuextentothat' it asks for a legal. opinion of whether non-incorporation of "PRA concept" defeats a demonstration of reasonable 1 a
assurance.
This will be decided by the. Board as a result of the hearing.
Notwithstanding and without waiving this 16 l
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objection, Vermont states'that in response to question 44.
we have identified _ facts-relatingLto a failure'to-demonstrate reasonable assurance.-- Facts 2 and 13Lrelate to non-incorporation of "PRA concepts." ! Incorporation'of "PRA concepts" would assist toward demonstrating reasonable assurance that the maintenance program would' function as claimed in the application.
Q 30
'If your answer to Interrogatory No. 29 is anything other than an' unqualified negative, please state'each and:every-regulatory requirement of the commission with which SOV contends VYNPS is not-in' compliance on account of!the non-incorporation lof "PRALeoncept"'into the VYNPS maintenance program.
A.30 Refer to the previous response.
Q.31 What significance,cif_any, to the; question of whetherithe
" incorporation" of "PRA concept"-into a maintenance program is necessary to the permissibility of plant-3 operation does SOV. attribute to the fact that the commission has-declined.to impose 1such-a requirement through the promulgation ofca regulation? :Please state in detail the bases for your-response.
A.31 Vermont objects to this questionson the basis that it asks for a legal opinion, and'that the Commission's 1
1 decision not to the promulgate a regulation, assuming the activity is not prohibited, is not a matter of substance in this proceeding.
Q.32 How, if at all,,does SOV contend that the " incorporation" of "PRA concept" into the VYNPS maintenance program-would modify the safety margins established by the existing!
. j VYNPS Technical Specifications?
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A.32 Refer to the response to'questihn 28.-
" Improving overall plant availability" means: decreasing theLamount
.of time the' plant will be in a " limiting 1 condition for operation."
This improves the safety of the plant and is consistent with the-concern of Three Mile.Isl'and' item-II.K.3.171(NUREG-0737) regarding cumulative outage time requirements:in the technical specifications.
uQ.33 Please define what is meant by SOV by the: term " qualified replacement personnel" as?it is used.by-SOVLin sub-paragraph "c" of.its contention 7.
A.33 By " qualified replacement personnel," we mean.
maintenance personnel with a level of skill, stability,.
knowledge of,the plant,.long-term experience,Eandt i
expertise, necessary to perform maintenance,fas defined.
j
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in response to question'1'.
'I Q.34 Please define what'is'meantIby Sov by the. term " clearly' established management" control" as-it/is used by SOV in sub-paragraph "c" of its: Contention 7.
A.34 The quoting the statement, " clearly established' management control," we mean policies and procedures' controlling maintenance, which are-approved by 1
management, and which-provide clear and detailed--
information so that the' individual worker skills are not I
relied upon so heavily.
Refer to the response to Set'No.
i 1,
question 8, for further. elaboration of-Vermont's meaning for the phrase.
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Q.35.
Please identify.the author (or authors):of_the work datod October 9, 1989, to which SOV refers in sub-paragraph "c."
of its Contention'7.
t A.35' Margaret L. Ryan, Chief Editor, Nucleonica Week,
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Suite 1200, 1120 Verment Ave.
N.W., Washington, D.C,'202-463-1651.
s a;
'l Q.36-Please describe the qualifications ofEthe author (or' authors).of the work, dated. October 9, 1989, to which SOV.
refers.in sub-paragraph "c."
of its~ Contention'7.
A.36 Ms. Ryan is a. journalist.
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8 Q.37 Please describe-the data, investigations'and analytical or investigative processes upon which the conclusionsLof the author (or authors) of the work dated October 9, 1989, to which SOV refers ~in sub-paragraph "c.".of its Contention 7'were based.
A.37
' Vermont objects to this. question as requesting information which is outside the scope-of what car. by or s
s should be known to Vermont.- Notwithstanding andlwithout' t
l waiving this> objection, Vermont states that the' work'was partially based on the references identified-in' response:
to Set No.
1, question 8.
Q.38 Has SOV taken any step to verify independently any of-the opinions or conclusions of the author (or authors)1of.the work dated October 9, 1989, to which SOV' refers in sub-paragraph "c." of.its contention 77 A.38 Yes.
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Q.39 Does SOV contend'that a maintenance program " based on the stability of maintenance staff, their skill in their.
professions, and their knowledgetofLplant-system
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characteristics that-come with long-term. experience"-will R
always be incapable of achieving.the purposes of a q
maintenance program?
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e A.39~
No.
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-Q.40 If your answer to the foregoing' interrogatory;is anything'
)
I other than.an unqualified = affirmative, please-state-the conditions under which SOVtacknowledges that a-maintenance program " based on the stability of i
maintenance staff,-their skill-in:their professions, and'
-their knowledge of. plant system' characteristics that:come-with-long-term experience" can be. capable of achieving i
the purposes of a maintenance-program?
D A.40 The'above question is similar toLSet;No.
1, question
.9, and we respond on a similar. basis. 'We-.respondi no, based on the word "always"Lin'the questione ;Within the-time continuum, a.maintenancejprogram " based-onithe stability of maintenance-staff, their skill.in their-professions,.and;their: knowledge of; plant system characteristics that come withT1ong-term ~ experience" will; at some time be capable of achieving the purposes of a.
maintenance program'.
For example,-the NRC Maintenance Team believes these attributes of the present. maintenance' 1
program compensate'for many weaknesses.
However, refer to our response to Set No.
1, question 4, for our l
position regarding the NRC Maintenance Team. conclusions.
Q.41 Does SOV agree without qualification with'the:following statement:
"The standard for the quality of.
maintenance work at VYNPC is high and this standard is reflected-in a relatively low rework rate for j
maintenance and repairs on plant
-a systems."
l If your answer is anything other than an unqualified affirmative, then please:
20
1: -g 4
r State each;and every qualification you have a.
with respect to the quoted-assertion.-
4 b.
State each and every fact ~on which_your qualification-is based.-
c.
Describe all of the evidencelin'SOV's possession or of which SOV has knowledge that SOV contends establishes-each suchLfact.-
d.
For'each qualification / either provide the technical qualifications-(education, employment history, licenses and certificates, experience, or other information which-'SOV' contends establishos the qualifications.of the person), or any person on whoseD expertise SOV relies for the-qualification or state that SOV'does not rely upon the expertise oftany person for the qualification.
If SOV agrees with the substance of the1 foregoing
_ 1 assessment, then please:
e.
State each and every= reason why SOV-believes that the situation described-therein has come to exist.1 f.
State each and every reason why, assuming the rejection.of this 3
contention. the SOV contends (if'it' j
i does) that the same condition.might'not be expected to continue through.the balance of the existing VYNPS license-O term.
~
g.
State each and.every reason-why, assuming the rejection.of this-contention, the SOV' contends (if'it does) that the same condition mightinot-ba expected to continue;through the l
4 balance of the extended VYNPS license term.
. j A.41 Vermont recognizes this statement as.a finding of the,NRC Maintenance Team, from page 8 of IR 89-80.
We state facts and evidence in response to question 44 which i
21
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p E
i showLthatvendormanual'shavenotbeen= controlled, surveillances and maintenance'_ activities'have'been-
~
missed, trend data showing degrading trends have not1had; i-managementjinvolvement'and action, and maintenance 1 errors; have caused failures and safetyLsystem challenges. 'These-facts do not lead Vermont to1the conclusion thatJthe.
standard-for quality of maintenance work is-high. -Refer s to the response to question 44'for facts,Levidence and expertise relied!upon.
Q.42 Does SOV agree without qualification with the following-statement:=
"The-overall Vermont-Yankee management support at-the corporate:
and plant levels for maintenance is strong and' effective."-
- 1
- c If your answer is anything other than.an unqualified j
affirmative, then please:-
1
[
State-each and every qualification you.
a.
have with respect to the quoted-1 assertion.
b.
State each and every fact.on which your.
E qualification is' based.
1 c.
Describe all of the evidence in SOV's-1 possession or of which SOV has q
knowledge that SOV contends establishes-each such fact.
I d.
For each1 qualification; either provide the technical qualifications (education, employment history, licenses and certificates, experience, or other information which SOV contends establishes the i
qualifications of the person), of_any person on whose expertise SOV relies.for the qualification or.
state that SOV does,not rely upon the expertise of any person for the qualification.
22 1
N
?
~
~
~
v
.C r
i If SOV agrees with the substance'of thefforegoing
[
assessment,fthen please:
4 e.
State each-and everyfreason why_Sov-believes that the situationidescribed therein'has'come to exist.
,d 1
f.
State'each and every reason why,.
assuming the-rejection of this-contention,.the SOV contends ~(if it'
' does)b that the same condition might not' be expected to. continue throughsthe-l' balance' of the existing: VYNPS license i
term.s
-f g.
State each and,every reason why, assuming the rejection of this-..
l contention,1the Sovfcontends1(if it.
i does) that the same-condition might not be expected to continue through,thes balance of the extended VYNPS: license-term.
t A.42 Vermont recognizes this-statement as a.findingfofs the NRC Maintenance Team,7from page~10Lof IR 89-80.
'We.
I state facts and evidence in response to question,44_whichi 7
show that management hac not established clear policies and procedures but rather-relies on individual; worker skills, management has'not periodically reviewed overall.
j program requirements, management is.reluctantito-incorporate industry changes, management has not established effective. policy to control-vendor manuals,.
management has allowed surveillances and maintenance' activities to be skipped, management has not:been actively involved in managing. trend data, management has-not allocated sufficient. resources to allow completed L
maintenance request reviews, and management has 23 O
o
1 e
- s.
k establishedLa program which has relied-more:upon corrective maintenance'rather.than preventive:
maintenance.
These facts do-not lead' Vermont to the conclusion that management support is. strong and effective.
Refer to'the response to question 44'for-facts, evidenceJand' expertise relied upon".
{-
Q.43 Does!SOV agree without qualification with'the following:
statement" i
'"VYNPS's. informal management oversight and' feedback system works well to assure safe'and reliable-plant operations."'
If your answer is.anything-other than an unqualified affirmative, then please:
State each and every qualification you, a.
have with respect to the quoted assertion.
b.
State each'and every; fact on-which your.
qualification-is based.
c.
Describe all of the evidence'in SOV's possession or of which.SOV-has knowledge that SOV contends' establishes each such fact.
d.
For each qualification, eitherLprovide the technical.
[
qualif.ications (education, employment' history, licenses and certificates, experience,.or other information which SOV; contends establishes-the qualifications of the person), of.any; person (nr l
whose expertise SOV relies for the qualification or.
- l state that SOV does not rely upon the expertise of 1
any person for the qualification.
)
O r
1, If SOV agrees with the substance of the-foregoing assessment, then please:
hl 24 y
i
~...
I
[
a i
e.
State each and every reason why SOV believes that the situation described therein has come to exist.
f.
State each and every reason why,-
assuming the rejection of this content;on, the soV contends (if it does) that the same condition might not i
be expected to continue through the l
balance of the existing VYNPS license term.
I g.
State each and every reason why, assuming the' rejection of this contention,-the SOV contends (if it f
does) that the same condition might not be expected to continue through the balance of the extended VYNPS license term.
l A.43 Vermont recognizes this statement.as a finding of i
the NRC Maintenance Team, from page 10 of IR 89-80.
We r
state facts and evidence in response to question 44'which show that equipment information showing degrading trends has not had management involvement and the. equipment has been allowed to continue to degrade, degraded components have not been detected for long periods of time, 1
l maintenance errors have caused equipment failures and i
safety system challenges, equipment with reliability problems has not been promptly replaced, and aging l
equipment has failed prematurely before' detection and
?
replacement by the maintenance program.
These facts do not lead Vermont to the conclusion that informal management oversight and feedback work well to assure safe and reliable plant operation.
Refer to the response
)
25
(
to question 44 for facts, evidence and expertise relied upon.
Q.44 Does SOV agree without qualification with the following statement" "VYNPC has implemented a maintenance program adequate to provide reasonable assurance that VYNPC can and will be operated without endangering the health and
[
safety of the public."
If your answer is anything-other than an unqualified affirmative,-then pleases a.
State each and every qualification you have with respect to the quoted assertion.
b.
State each and every fact on which your qualification is based.
c.
aescribe all of the evidence in SOV*s possession or of which E0V has knowledge that SOV contends establishes each such fact.
d.
For each qualification, either provide the technical qualifications (education, employment history, licenses and certificates, experience, or other information which SOV contends establishes the qualifications of the person), of any person on whose expertise SOV relies for the qualification or state that SOV does not rely upon the expertise of any person for the qualification.
If SOV agrees with the substance of the foregoing assessment, then please:
e.
State each and every reason why SOV believes that the aituation described therein has come to exist.
f.
State each and every reason why, assuming the rejection of this contention, the SOV contends (if it does) that the same condition-might not 26 wm
1 be expected to continue through the balance of the existing VYNPS license-term.
l g.
State each and every reason why, assuming the rejection of this contention, the SOV contends (if it
~
does) that the same condition might not be expected to continue through the
~i balance of the extended VYNPS license i
term.
A.44 No.
Rather than agree with this statement, Vermont l
asserts Contention VII.
Vermont has not been granted' access to much of licensee's maintenance internation, and, therefore, feels it is not able to. identify each and every fact in disagreement with this statement until it fully reviews with its technical consultant material
)
which is sought from discovery.
Nevertheless, at this point we have determined the following facts, with their H
stated bases:
-t 1.
Implementation of the maintenance program has relied too much on worker skills rather than on consistent, well developed procedures.
This is based'on
^
evidence from the report of the NRC Maintenance Team t
review (IR 89-80), "NRC Maintenance Team Report," and the summary of Westec Incorporated safety system functional inspection (SSFI) provided at the NRC Eegion I meeting of.
January 26, 1989, "Westec SSFI Summary."
\\
t 2.
The program has relied on program elements which were established at startup rather than-on i
27 l
a
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requirements'which have been comprehensively reviewed and i
updated to latest methods.
There has been a reluctance j
to modify the maintenance program to' meet industry l
t standards.
This is based on evidence from the NRC
'?
Maintenance Team' Report, the Westec SSFI' Summary, and LRS-F Incorporated, Reports #3-88'and #2-89.
[
3.
. Updated recommendations from vendors have not'
~
been controlled.
This is based on evidence from the NRC r
Maintenance Team Report, the Westec SSFI Summary, and'LRS I
Incorporated, Report #2-89.
4.
The program has not included a requirement for management review and evaluation of trends.
This is f
based on evidence from-the NRC Maintenance Team Report.
5.
The program has not included a long term plan to reverse degrading trends.
This is based on evidence from the NRC Maintenance Team Report.
6.
Sufficient engineering resources'have not-been allocated to complete the review of maintenance l
l requests promptly.
This is based on evidence from the n
NRC Maintenance Team Report, the Westec SSFI Summary, and 3
LRS Report #3-88.
7.
The maintenance program has not provided the control to avoid missed surveillances and preventive maintenance.
This is based on evidence from the Westec SSFI Summary and LERs 88-03, 88-13, 88-14, 89-10, 89-23, and 89-24.
r 28 ii
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8.
The maintenance program has not detected, or has left undetected for long periods, degraded components.
This is based on evidence related to flaws in the feedwater check valves, incorrect wiring and post modification testing of the " squib" valves, and inoperability of service water check valves (LER 89-17).
9.
The maintenance program has had maintenance errors or omissions which have caused failures, or has allowed actions which could have led to failures or the inability of components to perform ~their safety function.
This is based on evidence from LER 89-14, LER 88-09,-and the Westec SSFI Summary.
10.
Control and evaluation of equipment has relied on worker skills rather than on a comprehensive and all-inclusive master equipment list.
This is based on evidence from the NRC Maintenance Team Report and LRS Report #2-89.
11.
The maintenance program'has failed to I
identify reliability problems and/or obsolete equipment and take prompt action.
This is based on evidence from the NRC Maintenance Team Report, LRS Report #3-88.
12.
Instances have occurred in which the maintenance program has been unable to determine and replace aging components.
This is based on evidence from the NRC Maintenance Team Report and LERs 89-07, 87-07, k
85-07, 84-11, 89-03, 89-04, 89-19,,and 89-21.
29
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t 13.
The maintenance program has'been characterized by weak preventive maintenance, with activities heavily oriented to corrective maintenance.
This is based on evidence from the Westec SSFI Summary.
The evidence described above is supplemented by the expertise of Mr. H. Shannon Phillips, whose I
qualifications have been provided in-response _to licensee's interrogatories, Set No. 1.
Q.45 Please define the term " age-related problem" as it_is used by SOV in sub-paragraph "d." of Contention 7.
A.45 By " age-related problem," we mean any action or lack-of action which causes or allows structures, systems and components to age to a point where they no longer meet the safety standards applicable to the plant.
Q.46 Please define the term " timely fashion" as it is used by SOV in sub-paragraph "d." of contention 7.
A.46 The term, " timely fashion," is quoted from IR 89-80.
To the extent this question asks what the author i
meant by this statement, it is unanswerable, since-the author's meaning is unknown to Vermont.- Vermont's meaning in quoting the term is that it is an aspect of a weakness in the Vermont Yankee program identified by a respectable author.
Q.47 Does SOV contend that there is an applicable NRC requirement specifying the maximum amount of time within which VYNPC must perform a " review (of) the 30 l
q 1
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. __ __u
I k
appropriateness and technical adequacy of completed-l maintenance activities?"
If so, please identify, by citation to or identification of a document, each and j
every such requirement.
A.47 Vermont is unaware of'each and every NRC requirement t
~
for maintenance programs.
However, licensee claims, as a f
basis for-the proposed life extension, that mechanical components are periodically inspected and maintained, and t
that age-related degradation will be identified and corrected, and component functional capability maintained.
Yet, IR 89-80 reports weakness with regard I
i to the review of maintenance activities for i
appropriateness and technical adequacy.
Thus, the applicable requirement is the. reasonable assurance 9
requirement of 10 CFR 50.57(a) (3), which Vermont contends y
has not been demonstrated.
t b
Q.48 Does SOV contend that, without regard to any applicable NRC requirement, there is a maximum amount of time within which VYNPC must perform a " review (of) the appropriateness and technical adequacy of completed maintenance activities?"
l A.48 Yes.
Q.49 Unless your answer to the foregoing interrogatory'is an unqualified negative, please identify what SOV contends is such a maximum amount of time and provide each and every reason why SOV contends that its time is the j
maximum allowable.
A.49 To the extent that this question requests the maximum time which would provide reasonable assurance that the procedural step was effective, it calls for a 31 o
I
legal conclusion and is objected to,'and is a
'j i
determination.which will be made by the' Board at the end 1
of the' hearing.
Notwithstanding and without waiving this 1
objection, we offer that we are not able, at this time, i
l to supply quantitative values for these attributes which i
demonstrate any. effective program.
Measurable attributes upon which to judge the effectiveness of the procedural' l
j step, " review (of) the appropriateness and technical j
i adequacy of completed _ maintenance-activities," are l
backlog and maximum amount of time elapsed since j
completion of the activities; Additionally, an effective 1
program will set priorities in the review of the 1
appropriateness and technical adequacy of completed l
maintenance activities, such that activities involving critical structures, systems, and components will be given a higher priority for review than will non-critical structures, systems, and components. -Vermont Yankee has not demonstrated that it has set such priorities for its t
process of reviewing completed' maintenance activities.
Q.50 Please identify each and every instance'of which SOV is aware in which, after the maintenance or repair of-a I
component, the lack or untimeliness of a " review (of) the j
l appropriateness and technical adequacy of completed r
maintenance activities" subsequently led to "a failure before correction."
A.50 Vermont is aware of the failure of the RCIC-21 valve as a result of maintenance activities (LER 89-14), and j
the maintenance related failure in the turbine pressure i
32
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l l
I control system (for example, LER 88-09).
While it is i
(
possible that untimeliness of the " review (of) the l
l appropriateness and technical adequacy of completed l
maintenance activities" played a part in'these failures, i
Vermont has not been granted access to the review records-of maintenance activities for these, or any other events,
(
upon which to base a response to this question.
Q.51 For each instance identified in response to the foregoing j
interrogatory, please provide each and-every reason why SOV believes (if it does) that the event in question was related to aging.
A.51 LER 89-14 states, "the root cause of this event is I
~
believed to be premature end of life [ sic) failure."
LER 88-09 states, "the suspected root cause of this event is the malfunction of the MHC control oil system...it is.
[
suspected that the MHC control oil system may have operated improperly due to dirt / grit lodging in the oil pressure control valves."
The~ buildup of dirt and grit;
{
is an aging phenomenon.
Q.52 Please define the term " timely updating" as-it is used by SOV in sub-paragraph "e." of contention 7.-
A.52
" Lack of timely updating" refers to,-and is considered equivalent to, the NRC Maintenance-Team statement of program weakness in that same sub-part e.
{
l Q.53 Please describe the types of circumstances under which SOV understand VYNPC vendor-manuals to be updated.
For each such type of circumstance, please explain the mechanisms by which, as SOV contends is the case, t
33 i
a i
s.
a
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"information on aging equipment from the vendors will be-critical to prevent failure of safety equipment."
i A.53
. Vermont has not been granted access to. vendor manuals er vendor manual updates, nor has it reviewed this material.
It is conceivable that a vendor manual update could incorporate safety-significant changes to i
recommendations as a result of operating experience, which, if not incorporated into the vendor manual, would l
l be ignored by the maintenance program, and-thus result.in' i
1 failure of the equipment.
[
Q.54 Please identify each and every. instance of which SOV is l
aware in which an " update" of a vendor manual contained
(
information not previously available that was " critical l
to prevent failure of. safety equipment"-in which the l
criticality was directly related to aging.
l A.54 Vermont has not been granted access to vendor manuals and vendor manual updates, and has not completed
.i its evaluations in this area.
However,-Vermont offers,:
for example, that 1) vendor or EPRI/NMAC information may have been available to prevent the burn out of the RCIC-21 motor (LER 89-14), and 2) that the safety evaluation.
may be incomplete in that it neither proved nor considered whether the valve would have prerformed its function in the accident environment, nov did'it evaluate the consequences of being unable to close the RCIC-21 valve once it was opened.
The RCIC-21 valve is safety equipment, and LER 89-14 identifies the root cause as j
premature end of life failure.
34 l
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Q.55 Does SOV contend that there is an applicable NRC requirement specifying the nature and content of trend analysis programs applicable to the VYNPS maintenance program?
If so, please identify, by_ citation to or.
identification of a document, each and every such requirement.
A.55 Vermont is unaware of each and every NRC requirement for' maintenance programs.
However, as stated in sub-part g. to Contention VII, licensee-relies on trend analysis to indicate decreased equipment reliability and expected life in the extended period.
Yet, IR 89-80 reports weakness in the evaluation of adverse trends.
Thus, the applicable requirement is the reasonable assurance requirement of 10- CFR 50.57(a) (3), which Vermont contends has not been demonstrated.
Q.56 Please define the term " Reliability-Centered Maintenance-(RCM) program" as used by SOV' in sub-paragraph "h. (1)"
(hereinafter used to refer to the'first of the two sub-paragraphs labelled by SOV "h ") of'its contention 7.
A.56 A reliability-centered maintenance program is a systematic consideration of system functions and the ways in which functions can fail, leading to the identification of applicable and effective preventive maintenance tasks with consideration of; safety'and-economics.
Q.57 Please define the term " life-extension" as used by SOV in.
sub-paragraphs "h. (1)" of its Contention 7.
A.57 Vermont uses the word, extension, as used on page 1 of Attachment 1 to the application:
35
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I L
l 1
l "This extension is within the range permissible...."
In the context above, " extension," refers.to "a change to
>j the expiration date of the current license."1 Vermont equates "a change to the expiration date of the current license" to " plant life," or simply to " life."
Therefore, the proposed amendment constitutes " life X
p extension."
Vermont further uses the term " life L
extension" to refer to the extended service lives of the l
l I
structures, systems and components of the plant which result from " plant life extension."
\\
Q.58 Would SOV acknowledge that, if what the authors of.EPRI NP-6152, (January, 1989) meant by the term " life.
extension" does not include the authorization sought by this operating license amendment, then sub-paragraph I
"h. (1)" of Contention 7 is without basis?
A.58 Vermont objects on the basis that this question is a i
hypothetical question with no foundation in facts which are of record.
Q.59 If your response to the foregoing. interrogatory is other-l than an unqualified affirmative, please state each and every fact or circumstance that SOV contends provides a basis for sub-paragraph "h. (1)" of contention 7.
t A.59 The concepts of reliability-centered maintenance apply to the life extension proposed by this amendment, whether or not the authors of EPRI NP-6152 had the life extension of this proposed amendment in mind.
36 y
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i Q.60 Please describe what SOV understands to be the special effectiveness of RCM for " life-extension."
J A.60 Reliability-centered maintenance can result in realignment of maintenance resources-to improve overall plant availability.and safety, and a more favorable preventive maintenance to corrective maintenance ratio.
As part of the reliability-centered maintenance program,.
controlling degradation mechanisms can be identified, important predictive and preventive maintenance program 3
features can be determined, and plant data and record-
-i keeping requirements to minimize-the potential for 3
unanticipated failures can be established.
Data can be collected and evaluated to determine specific evaluation documentation requirements for aging mechanisms that have been identified as potentially limiting to.the life-of i
critical components.
Recommendations can be developed to modify data and records requirements to support component reliability assessments.
One task of: the reliability--
3 centered maintenance program can be to reduce the rate of life-limiting degradation mechanisms and to monitor the L
4 rate of degradation in order to avoid failure or I
I expiration of qualified design life.
Vermont notes that all of the above-is essentially l
l the expectation that the licensee places on the maintenance program in its application for the operating 4
l license extension.
+
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l l
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Q.61 Does SOV contend that there is an applicable NRC requirement VYNPS have in place, or have made a i
commitment to, an RCM maintenance program?
If so, please identify, by citation to or identification of a document, each and every such requirement.
g A.61 Vermont is unaware of each and every NRC requirement for maintenance programs.
However, as stated in
.i responses to the previous question, the licensee relies l
)
t on its maintenance program to serve the functions, in the
[
extended period, which could be provided by a reliability-centered' maintenance program.
Yet licensee has not described the use of reliability-centered maintenance techniques and the NRC Maintenance Team has l
identified the lack lof the use of PRA concepts as a weakness.
Thus, the applicable requirement is the reasonable assurance requiremont of 10 CFR 50.57(a) (3),
which Vermont contends has not been demonstrated.
[
Q.62 Does SOV contend that, without regard to any NRC l
requirement, RCM is the only way that a maintenance program can be effective to combat the effects of aging?
l A.62 Vermont objects to this question to the extent that i
l it requests a legal opinion of whether a reliability-l l
centered maintenance program is'the only way to provide reasonable assurance in the context of 10 CFR 50.57 (a) (3).
This is a matter which will be decided by the Board at the end of the hearing.
Notwithstanding and without waiving our objection, we respond, no.
38 l
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i Q.63 If your response to the foregoing interrogatory is anything other than an unqualified negative, please-state each and every reason.why SOV contends that RCN is the only way that a maintenance program can be effective to r
ccabat the effects of aging.
A.63 Refer to the previous response.
j Q.64 Please state each and every alternative method to RCM that SOV is aware of and, for each such alternative, state whether SOV contends that the alternative is superior to, equal to, or substantially inferior to RCM for correcting the deficiencies alleged by SOV in its contention-7, and state each and overy reason why SOV so r
contends.
A.64 Vermont objects to this question to the extent that
(
it requests a legal opinion concerning reasonable
[
assurance.
This is a matter which will be determined by the board at the end of the hearing.
Notwithstanding and without waiving this objection, we offer'that we have not performed any evaluation to determine, and therefore are unaware of, alternate methods to reliability-centered 1
maintenance which would accomplish the same function.
l Q.65 Does SOV agree without qualification with the'following statement" "RCM is primarily a means of decreasing maintenance costs and increasing plant' economics, accomplished.by eliminating
-i unnecessary preventative-maintenance and prioritizing the rest toward those systems and components with.the greatest-impact on megawatt-hours produced?"
t If your answer is anything other than an unqualified affirmative, then please:
r 39 9
.. _ ~
-~
l l
s i
l a.
State each and every qualification you l
have with respect to the quoted assertion.
j b.
state each and every fact on which your j
qualification is based.
c.
Describe all of the evidence in 80V's I
possession or of which sov has I
knowledge that sov contends establishes i
each such fact.
l d.
For each qualification, either provide'the. technical'
. qualifications (education, employment history, i
licenses and certificates, experience,_or other
(
information which SOV contends establishes the E
qualifications-of the person), of any person on I
whose expertise SOV relies for the qualification or t.
state'that Sov does not rely upon the expertise of l
any person for the qualification.
i A.65 No.
The definition of reliability-centered maintenance is provided in response to question 56.
The
't aspect missing from the statement in this question'is the.
identification, by reliability-center maintenance methods, of additional and different preventive and predictive maintenance techniques which improve. plant availability and safety.
Vermont bases this upon the facts regarding reliability-centered maintenance presented in EPRI NP-6152, which constitutes all the' evidence we have knowledge of at the present time.
Vermont relies on the expertise of Mr. H. Shannon Phillips, whose qualifications were provided'with the f
response to licensee's Set No. 1.
Q.66 Please explain in detail what connection (if any) SOV l
contends exists between IR 89-80 and the NRC Draft 40 3
l-F i
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U i
s L
Analysis for Proposed Rule-making on Maintenance of Nuclear Power Plants, November 1988.
i A.66 Both documents are NRC documents related to maintenance.
Both relate to NRC's concern regarding-maintenance at nuclear plants.
The " Draft Analysis" states, "NRC has identified a number of maintenance-related safety concerns that form the basis for its view 1
that improvements in maintenance are necessary."
IR 89-j 80 states, "This inspection was performed as part of'
'i NRC's industry wide effort to evaluate the effectiveness i
of maintenance activities at licensed power reactors."
l Q.67 Please define what is meant by SOV by the term " weakness-in the maintenance programs"-as it is used by SOV in sub-paragraph "h. (2)" (hereaf ter used to refer to the second i
of the two sub-paragraphs labelled by SOV "h") of its contention 7.
A.67 Refer to the response to set No.
1, question 6.
j l
Q.68 Please state each and every reason SOV contends that I
" weakness in the maintenance programs" is "of' specific risk," and, for each reason, pleases-a.
State each and every fact on which your reason is based.
i r.
b.
Describe all the evidence in SOV's possession or of which SOV has knowledge that SOV-contends I
establishes each such fact.
I c.
For each reason, either provide the technical
~
qualification (education, employment history, licenses and certificates, experience, or other 1
information which SOV contends establishes the J
qualifications of the person), of any person on whose expertise SOV relies for the reason or state that SOV does not rely upon the expertise of any-1 person for the reason, j
i 41 I
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L
i 1
3 A.68
. Vermont objects to this question to the extent that l
l.
i a legal definition of reasonable assurance is-requested, since this will be determined at the end of the hearing-by the Board. - Notwithstanding and without waiving this.
objection, Vermont' states that " Weakness in the I
maintenance programs" is "of specific risk" when it i
i p
negates the. demonstration _ of reasonab'to assurance that
]
i b
p stection of public health and safety is or will be-provided.
Facts, along with evidence and expertise relied upon, have been provided in response.to question l
44 which illustrate aspects of the maintenance program-l
\\
.i which do not provide this assurance.
i Q.69 Please identify, including but not limited to a specific l
citation, all " aspects of maintenance problems relevant to the proposed action" for.which Sov contends the " Draft Regulatory Analysis" "provides a summary and identification."
A.69 Vermont identifies items 1 through 4 listed in j
i Section 1.1.1 of the " Draft Regulatory Analysis," which t
are listed in response to the following. question.
j Q.70 For each and every " aspect [] of maintenance. problems" identified in response to the foregoing interrogatory, please state each and every reason why SOV contends.it is
" relevant to the proposed action."
A.70 Vermont has not completed a review-to determine each t
and every reason why these aspects are relevant to the
-3 proposed action.
However, we are aware of the following:-
t 42 I
t c
r
I i
W j
N "1.
There is' indication that needed maintenance is not being accomplished or is not performed effectively."
t p
The NRC Maintenance Team identified a large backlog of i
completed Maintenance Requests awaiting review for
[
l appropriateness and technical adequacy. lGRS Incorporated identified that the backlog of maintenance requests is large and there is no visible push to rectify the' i
J situation.
SSFI Observation VY-WCS-7 recorded that more than half the environmentally qualified limitorque motor l
l operator valves have not had grease changeout or spring L
l pack inspection since the original installation.
SSFI j
Observation VY-WCS-3 records non-performance of vendor i
recommended preventive maintenance.
SSFI' Observation VY-WRB-4 records lack of testing of check valves in the diesel generator air start system.
SSFI Observa' tion VY-WRB-5 records lack of adequate logic testing of the HPCI j
i I
system.
LERs 88-03, 88-13, 88-14, 89-10, 89-23, and 89-i 24 identify missed surveillances.
'4 "2.
Many failures result from improper performance of maintenance."
t LER 89-14 identifies an instance ef. improper maintenance.
LER 88-09 identifies a suspected case of inproper maintenance.
SSFI Observation VY-SMK-6 records that-t 43 1
4.
4 heating' lamps installed by maintenance request to keep HPCI turbine bearing housing warm may not be seismically anchored or qualified to withstand a seismic. disturbance.
SSFI Observation VY-WCS-5 records that diesel generator minimum lube oil pressure requirement.of 20 psig is set below manufacturer's' recommended-minimum' pressure of 26 psig.
SSFI Observation VY-WCS-4 records the current HPCI-lube oil filter high dp setpoint is set above the filter internal bypass fully open position.
SSFI Observation VY-WRB-6 records that motor operated valve RHR-V10-65A and 65B valve actuation time (and surveillance' test I
acceptance criteria) may not be adequate to assure its full stroke open por.ition can be reached.
SSFI Observation VY-WRB-7 records that acceptance criteria for the stroke time of safety related valves exceeds times specified in the FSAR and exceeds the time required for the system to perform its function.
SSFI Observation VY-WGD-3 records that circuit breaker and relay setpoint selection and control has not been established-i l
"3.
The interface between maintenance and operations is presently inadequate."
LRS Incorporated identifies that better utilization of the Assistant to the Operations Supervisor in handling corrective MR's... could significantly reduce the administrative burden.
LRS Incorporated 44
l 1
identifies that operators do not feel Vermont Yankee pays sufficient heed to their desires for hardware repair and replacement.
"4.
The number of maintenance-related challenges to j
safety systems is excessive."
l l
LER 89-14 and LER 88-09 identify maintenance-related f
challenges to safety systems.
l Q.71 Does SOV contend that VYNPS " plant management" has not adequately " review (ed) the industry practice in maintenance planning to determine.if the industry trend in establishing formal maintenance planning groups would aid in increasing productivity ~in the maintenance area."'
c If your answer is anything other than an unqualified negative, then please:.
a.
State cach and every qualification you have with respect to the quoted assertion.
b.
State each and every fact on which your
(
qualification is based.
l l
c.
Describe all of the evidence in SOV's
(
possession or of which SOV has 1
knowledge that SOV contends establishes each such fact.
l.
d.
For each qualification, either provide the-technical qualifications (education, employment. history, i
licenses and certificates, experience,-or other i
information which SOV contends establishes the qualifications of the person), of any person on whose expertise Sov relies for the qualification or state that SOV does not rely upon'the expertise-of any person for the qualification.
A.71 Vermont contends that was true in October 1988, at-the time of the LRS Incorporated Report.
Vermont is not 45
?
s
i o
o aware of the extent to which the licensee has acted on this LRS recommendation.
But Vermont further contends that management has been reluctant to meet new industry l
standards and had not established a policy for reviewing the maintenance policy and program for current trends.
These are shown by facts, along with evidence and j
i expertise relied upon, provided in response to question 44.
Q.72 Please state each and every' reason Soy contends (if it does) that'a " review (of) the industry practice in maintenance planning to determine if the industry trend in establishing formal maintenance planning groups would aid in increasing productivity in the maintenance area"-
would materially impact safety through the balance of the extended VYNPS license term, j
A.72 Formal maintenance-planning groups can take the form of planning groups for such areas as maintenance policy, i
program specifics, professionalism, outage management
'i assistance, and human performance evaluation.
While we are aware that licensee-has taken some initiatives in the area of maintenance planning, we are similarly aware of.
the Westec Incorporated SSFI general conclusion that licensee is reluctant to modify maintenance programs to j
meet industry standards.
We are also awsre of the NRC-Maintenance Team identified weakness of the lack of q
comprehensive and structured review for adequacy and' applicability of the plant's maintenance requirements.
In sum, we believe the lack of " review,(of) the industry 46 a
+
t
+
4 4
practice in maintenance planning (which) would aid in increasing productivity in the maintenance area" can i
contribute to the lack of demonstration of reasonable j
assurance that the proposed action will protect the 1
public health and safety.
j Q.73 Please define what is meant by SOV by the term "better
]
L computerization of the MR system" as it is used by SOV in l
k sub-paragraph "j" of its Contention 7.
i 1
t i
A.73 Vermont quotes the phrase, "better computerization of the MR system" from LRS Report, #3-88,'because-we I
agree that.better computerization is needed.
The Vermont Yankee "Visicard" system is a manual system which was established before the development of personal computer technology, and is outdated. -Computerization would allow
{
the creation and use of a master equipment list, and will allow tracking of maintenance activities.
Q.74 Please state each and every reason SOV contends (if it does) that "better computerization of the MR system" d
would materially impact safety through the balance of the extended VYNPS license term.
A.74 Better computerization of the MR system would allow f
better tracking of maintenance activities.- This could lead to reducing the number of missed surveillance and maintenance activities which could have safety significance.
Better computerization would also provide a master equipment list which would assist in tracking i
[
47
~
9 9
safety requirements and classifications for each 1
i component.
j 5
i s
Q.75 Please define what is meant by SOV by tr.e term "better
{
utilization of the Assistant to the operations Supervisor" as it is used by SOV in sub-paragraph "j" of i
its Contention 7.
A.75 Vermont quotes the phrase, "bester utilization of l
the Assistant to the operations Supervisor" from LRS i
l Report, #3-88, because we agree that it would be desirable to reduce or eliminate shift supervisor review time.
Q.76 Please st. ate each and every reason SOV contends-(if it i
does) that "better utilization of the Assistant to the operations Supervisor" would materially impact safety through the balance of the extended VYNPS license tera..
A.76 The LRS Report gives the impression that review of I
i maintenance requests place a significant burden on the shift supervisor.
Safety is impacted by either 1) diverting shift supervisor from other shift monitoring I
duties, or 2) delaying completion of maintenance requests.
(
Q.77 Please define what is meant by SOV by the term
['
l
" sufficient heed to their desires" as it is used by Sov in sub-paragraph "j" of its contention 7.
A.77 The phrase " sufficient heed to their desires" is
'f quoted from LRS Report, #3-88.
To the extent this question asks what the author meant by this phrase, it is unanswerable, since the author's meaning is unknown to i:
48 h
i Vermont.
Vermont's meaning in quoting the phrase is that it is an apparent weakness in the Vermont Yankee maintenance program, identified by LRS Incorporated, on its face a credible and respected expert opinion.
Q.78 With respect to the matter referred to on page 47 of its
" Supplement to Petition to Intervene" as the second excerpt from "LRS Report, #3-88, p.7," does SoV possess any information regarding the matter beyond'that contained in the LRS Report?
If so, please set forth all the information known or believed by Sov to be known by it relating to that matter.-
A.78 No.
Q.79 please state each and every reason why SOV contendsL(if it does) that. " pay ing) sufficient heed to- [the operators) desires [for hardware repair and replacement" would materially impact safety through the balance of the extended VYNPS license term.
A.79 The policy, practice or occurrence of-not " pay (ing) sufficient heed to (the operators) desires for hardware repair and replacement" is an apparent weakness in the maintenance program.
The maintenance program is offered as a basis for the assurance that the proposed amendment-will protect public health and safety.
This identified weakness contributes to the lack of assurance that the-maintenance program will perform as claimed'in the application.
To the extent that this question requests a legal opinion of this assurance, Vermont objects since.
this will be determined by the-board at the and of the hearing.
-49
o a
i Q.80 Please describe in detail exactly what "more work" SOV contends (if it does) needs to be done in the
" certification area,"'as these terms are used'in sub-paragraph "j" of its contention 7, and: state each and every reason SOV contends (if it.does) that.such work would materially impact safety for the balance.of the extended VYHPS license term.
A.80 Vermont has not made a determination of exactly what "more work" needs to be-done in the " certification area'."
f The area of certification of training skills isLan
!q identified weakness in the maintenance. program.
The maintenance program is offered as.a basis for the
~
assurance that the proposed amendment will protect public health and safety.
This identified weakness contributes l
t l
to the lack of assurance that the maintenance program-l will perform as claimed in the application.
To the
'[
extent that this question requests a legal opinion of I
this assurance, Vermont objects since this will be
'I determined by the board at the end of the hearing.
1 Q.81 Please define the term " formality" as it is used by SOV in sub-paragraph "j" of its Contention 7'.
l A.81 The term "formL11ty" is quoted from LRS Report, fi--
f 89.
To the extent this question asks what the author i
meant by this term, it is unanswerable, since the
[
t author's meaning is unknewn to Vermont.
Vermont's meaning in quoting the term is that it is an apparent i
weakness in the Vermont Yankee ~ maintenance program, 50
l 4
1 identified by LRS Incorporated, on its face a credible and respected expert opinion.
Q.82 Please state each and every reason SOV contends (if.it
)
does) that " formality" would materially impact safety for the balance of the extended VYNPS license term.
j A.82 The lack of maintenance program formality is an l
i identified weakness in the maintenance program.
The maintenance program is offered as a basis for the assurance that the proposed amendment-will protect public health and safety.
This identified weakness contributes-to the lack of assurance that the maintenance program t
will perform as claimed in the application.
To the extent that this question requests a legal opinion of i
this assurance, Vermont objects since this will be l
determined by the board at the end of the hearing.
l Q.83 Please define what is meant by SOV by the term " program
.i informality" as it is used by SoV in sub-paragraph "k."
of its Contention 7.
.i A 83 The phrase " program informality" is quoted'from LRS Report, #2-89.
To the extent this question asks what the author meant by this phrase, it is unanswerable, since the author's meaning is unknown to Vermont.
Vermon6's meaning in quoting the phrase is that it is part of a statement of an identified weakness in the Vermont Yankee l
l maintenance program, identified by'LRS Incorporated, on its face a credible and respected expert opinion.
i i
51 t
l n
o t
Q.84 Please define what is meant by SOV by the term
" vulnerable" as it is used by Sov in sub-paragraph "k."
of its Contention 7.
i A.84 The term " vulnerable" is quoted from LRS Report, #2-
.89.
To the extent this question asks what the author
.j meant by this term, it is unanswerable, since the l
author's meaning is unknown to Vermont.
Vermont's-l meaning in quoting the term is that it is part of a l
statement of an identified weakness in the Vermont Yankee maintenance program, identified by LRS Incorporated, on
]
its face a credible and respected expert opinion.
Q.85 Please define what is meant by Sov by the~ term " attrition in the experienced maintenance organization" as it is used by SOV in sub-paragraph "k." of its contention 7.
1 l
A.85 The phrase " attrition in the experienced maintenance l
organization" is quoted from LRS Report, #2-89.
To the extent this question asks what the author meant by-this-i phrase, it is unanswerable, since the author's meaning is
?
unknown to Vermont.
Vermont's meaning in quoting the phrace is that it is part of a statement of an identified I
weakness in the Vermont Yankee maintenance program,
[
identified by LRS Incorporated, on its face a credible f
\\
l and respected expert opinion.
{
i Q.86 Please describe how SOV contends that " program informality" (as SOV uses the term) leaves VYNPS
" vulnerable" (as SOV defines the term) to-" attrition in the experienced maintenance organization" (as SOV uses the term).
52 I
a 4
e s
A.86 As. stated above,. Vermont's use.of the-LRS. quotation is to document the identification'of a weakness in the' vermont Yankee maintenance program, identified by LRS Incorporated, on its faceLa credible and respected expert opinion.
Vermont has not specifically: evaluated the meaning of-thisLquotation'further.- To the extent this question asks _what the author meant'by this_ phrase,'it' is.
unanswerable,-since the author's meaning-is unknown;to Vermont.
Notwithstanding the above, Vermont offers that this question is answered'by the responses to Set No.
1, questions 8, 9 and 10.
Q.87 Please describe each and every' enhancement.to " program o
formality" that-SOV contends is. required to obviate VYNPS's " vulnerability" to " attrition in the experienced maintenance organization," and, for each'suchl enhancement, set forth all of.the reasons why SOV contends that, if implemented,1the enhancement would l
obviate the vulnerability.
.{
l i
A.87 To the extent the request to identify " enhancement (s-l
\\
which) would obviate the vulnerability" represents a request for Vermont to demonstrate reasonable assurance that the maintenance program would protect public health ~
i and safety in the extended period, Vermont objects, since this demonstration must be made by licensee.
- Further,
-i i
Vermont objects to the extent that this requests a legal opinion of what would constitute reasonable assurance,
{
which will be determined by the board at the'end of the i
1 hearing.
Notwithstanding and without waiving these 53 i
m v --,,
"\\
C in
- objections,; Vermont offers that we.are unable to answer.
~
this question without access to and review of licensee's:
~
maintenance documents.
Q.8J Please define what-is meant by SOV byLthe term
" communications problems"=as-it is used by SOV 1n sub-7 paragraph "k." of its contention 7..
A.88 The term-" communications problems" is' quoted from LRS Report, #2-89.
To the extent:thisEquestionfasks;what q,
the author:meantiby this term; it is unanswerable, since the author's1meaningfis unknownito Vermont.
Vermont's meaning in quoting the term is that it is partiof a1 statement of an identified weakness.in the Vermont Yank'ee-
~.
i maintenance program, identified by LRS-Incorporate'
,4 d
onL its face a credible and respected expert ~ opinion.
Q.89 Please describe how.SOV contends that " program.
informality" (as SO(V uses.the term)= leaves VYNPS
" vulnerable" (as SOV defines /the term) to"" communications-
,j problems" (as SOV uses the term).
I I
A.89 As stated above, Vermont's use of the LRS quotation ~
l is to document the identification'of a weakness;in'the Vermont Yankee maintenance program, identified by LRS-Incorporated, on its face a credible.and respected expert f
opinion.
Vermont has not specifically evaluated-the meaning of this quotation further.
To the extent this
~
question asks what the author meant by this phrase, it is unanswerable, since the author's meaning is unknown to I,
1 Vermont.
4 54 j.
1
1 h
]
r F
Q.90 Please1 describe eachiand every enhancement to " program
}
1 L
formality" that-Sov' contends is required to obviate ~
l VYNPS's " vulnerability",to " communications problems" and,
~
h for each such enhancement,-: set forth-all'of the reasons l
why SOV contends that, if implemented, the enhancement
-l L
would obviate'the. vulnerability.
~
1.;
A.90 To the extent the request to identifyf" enhancement [s which) would obviate the' vulnerability" represents a request for Vermont to demonstrate' reasonable assurance
.that the maintenance program;would protect'public health'
'i and-safetyLin the extended period,-Vermont' objects,.since f
1 this demonstration must be made by licensee.
- Further, j
i Vermont objects to the extent that this. requests'aT1egal j
opinion of what.would constitute reasonable' assurance, L
l
'which will be determined by the board at;the-end of the t
hearing.
Notwithstanding and without waiving these j
objections, Vermont offers that-we are unable to answer this question without access'to'and. review'of licensee's'-
.?
maintenance documents.
i 1
Q.91 Please define what is meant by SOV by the term." incidents:
involving vendor data shortcomings" as it is.used by.SOV in sub-paragraph "k." of its' Contention 7.
l A.91 The phrase " incidents involving vendor. data r
-i shortcomings" is quoted from.IJtS Report, ~ #2-89.
To the extent this question asks what the author meant byIthis phrase, it is unanswerable, since the author's meaning is unknown to Vermont.
Vermont's meaning in quoting:the-phrase is that it is part of a statement of an identified b
55 v
- l n
-,.n,
w 1
g
.l' i
weakness in the. Vermont Yankee maintenance 1 program,-
~
identified-by LRS Incorporated,:on11tstface a~ credible and respected' expert opinion.
Notwithstanding'the above, n
Vermont believes this' phrase refers to the~1ack-of=
effective policy =and procedures for controlling and:
updating' manufacturer technical manuals,r identiEled as a'
. weakness-in IR-89-80..
Q.92
- Please-describe how'SOV contends-that'" program informality" ' (as ' SOV. uses ; the term) leaves VYNFS
" vulnerable".L(as Sov defines'the term):to'"incidentsc involving vendor' data shortcomings" (as SOV:uses the term).
A.92 As stated abovel Vermont's use of the LRS quotation; is to document the identification of.a weakness 1in the.
Vermont Yankee maintenance program,-identified by LRS Incorporated, on its face a credible;and respected expert i
opinion.
Vermont has not specifically evaluated the meaning of this quotation further.
To'the extent this question asks what-the author meant by this phrase, it is unanswerable, since.the author's meaning is unknown-to Vermont.
Notwithstanding the above, Vermont' offers that further response to this question is provided in response to questions 53 and 54.
Q.93 Please describe each and every enhancement. tot" program j
formality" that SOV contends is required'to obviate-VYNPS's " vulnerability" to " incidents involving: vendor 4
data shortcomings"'and,-for each such enhancement,' set' forth all of the reasons why Sov contends that,~if 1
implemented,' the enhancement would obviate the-j vulnerability.
q 56 j
d 1
a 1
l
lg -
A.93 To the extent the request'to identify " enhancement (s which) would obviate the vulnerability"1representsia
-l l
f request for Vermont-to demonstrate reasonable assurance:
that the maintenance program would protect public health:
and safety in-the extended' period',JVermont_ objects, since this demonstration must-be made by licensee.
- Further, b
Vermont objects to the extent that this requests:a legal opinion of what-would constitute reasonable assurance, 3
j which will-be determined by_the board at theiend ofcthe-hearing.
Notwithstanding-and without waiving,these j
objections, Vermont-offers that we are unable to' answer l
this question without access toLand review of licensee's maintenance documents.
,i Q.94 Please define what_is meant by SOV by the term
" procedural inadequacies" as it is used by-SOV in sub--
j paragraph "k." of its contention 7.
A.94 The term " procedural inadequacies"'is quoted from 1:
LRS Report, #2-89.
To the extent this question asks what the author meant by this term, it is unanswerable, since
{j the author's meaning is unknown to Vermont.
Vermont's-meaning in quoting the term'is that it is part'of a t
statement of an identified' weakness in the Vermont Yankee-i maintenance program, identified by LRS Incorporated, on
.i its face a credible and respected expert opinion.
5 57 1
.c
-c.
DQ.95~
Please1 describe how SOV; contends that " program informality" (as SOVL uses/ the Jterm)? leaves VYNPS
" vulnerable" _ (as SoV defines the term) toi" procedural inadequacies" (as SOV:uses the, term)..
A.95 As stated above,, Vermont's use of the LRS quotation-is to document the identification of'a weakness in the Vermont Yankee maintenance program, identified by LRS'
. Incorporated, on its face a' credible and-respected expert opinion; Vermont has:not specifically evaluated the meaning of this quotation further.- To_the extent this.
question-asks'what the author meant by-this phrase,Eit is unanswerable, since the. author's meaning is unknown to
,y Vermont.
Q.96 Please describe each and every enhancement to!" program q
formality" that-SOV contends is requiredJto obviate.
4 VYNPS's " vulnerability" to " procedural = inadequacies" and, j
for each such enhancement, set.forth all of the reasons why SOV contends that, if implemented,Dthe-enhancement would obviate the vulnerability..
i A.96 To the extent the request to identifyf" enhancement (s which) would obviate the vulnerability" represents a l
request for Vermont to demonstrate reasonable assurance-that the maintenance program would protect:public health, and safety in the extended period, Vermont objects, since this demonstration must be made by licensee.
- Further, j
Vermont objects to the extent that this requests a legal
~
opinion of what would constitute reasonable assurance,-
which will be determined by the board at the end of the-58
k
i c-
.s e
hearing.
Notwithstandingland without daiving these
~
objections,cVermont' offers.that we are unable to answerr this question without accessito-and revice of-licensee's L
maintenance documents.-
l-
-l Q.97
-Please define what is meant by SOV by.the term "humani error" as it is used by SOV in sub-paragraph "k." of its.
Contention 7.
A.97-The term " human error" is quoted from.LRS Report,
- 2-89.-
To the-extent this question asks-what theLauthor; i
t meant by'this term, it is unanswerable,;since the' author's meaning is unknown to. Vermont. = Vermont's.
1
- meaning in quoting thel term is'thatlitiis part of a statement of an. identified weakness.in the Vermont Yankee n
maintenance programi identified.by-LRS. Incorporated, on 1
t-its face a credible and respected expert: opinion..
Q.98 Please describe how SOV contends that " program informality" (as SOV uses:the: term)l leaves:VYNPS E
" vulnerable" (as SOV defines-the term) to " human error" (as SOV uses the term).
I
+
A.98 As stated above, Vermont's use of the LRS, quotation is to document the identification of a weakness in the Vermont Yankee maintenance program, identified.by LRS Incorporated, on its face.a credible and-respected expert 7
opinion.
Vermont has not specifically evaluated-the l
meaning of this quotation further.
To the extent this question asks what the author meant by this phrase, it is-unanswerable, since the author's meaning is unknown-to j
59 w
4 e
.,..n.-~
,m y
1 a
i Vermont.
NotwithstandingLthe above', Vera'ont offers that.
1 this refers >to the weakness identified byLIR 89-80:1 1
"The licensee's failure-.to develop;a. comprehensive
-j set of. documents'to~ formalize and upgrade existing' practices; thereby, providingian.' infrastructure.
-capable of sustaining future good performance'ini light of the certainty;of, staff turnoveriiis y
h considered the licensee'sigreatest' weakness;"'
3q i
Q.99-
~ Please describe each and every enhancement to "programl Q
formality" that SOV conten'ds is required.to obviate j
- VYNPS's " vulnerability";to " human error"'and, for eachi l
such enhancement, set'forth all"ofLthe raasonsiwhy.SOV contends that,~if implemented, theJenhancement'would obviate the. vulnerability, l
\\
A.99 To the extent the request to identifyf" enhancement (s-
'?
which)1would obviate-the vulnerability" represents a:
request for Vermont to demonstrate' reasonable assurance =
P l
that the maintenance' program'.would protect publicLhealth E
l and safety in the extended period, Vermont objects,1since-L l
this demonstration must be made byllicensee..Further,-
4 o
I Vermont objects to the extent-that this requests ~a;1egal; opinion of what would constitute reasonable assurance,
?(
l which will be determined by the-board at_the'end of the hearing.
Notwithstanding and without waiving these a
L i
objections, Vermont offers that we~are unable to answer l
g a
this question without access to and review of licensee's-L maintenance documents.
i j
60 4
l l-l 4
s i,w w
e
~
e
J j
c 4-it l
l
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l Q.100-Please define what is meant by SOV-by the term " tested-l with satisfactory-performance"=as it.is'used by sov in f
l sub-paragraph "k." of its contention 7, including the testing-interval requirement and the acceptance-~ criteria.
implied ~thereby.-
5 1
A.100 The phrase, " tested with-satisfactory; performance,"-
means that simply altering procedures:and-implementing enhancements can not be: considered remedy to-demonstrate:
O reasonable assurance that the proposed 1 amendment will:
l
].
protect: health and-safety until"these-procedural changes.
1 3"
and enhancements are proven effective over a period cdC j
i
. time.
Should-th"e board decide that a. set'ofEprocedural?
I t
changesLand enhancements would provide reasonable assurance if-demonstrated effective,: Vermont 1
provisionally believes.a monitoring period =of;five years would represent a reasonable' testing intervalSLwith-agreed upon acceptance criteria and1 access to monitor.-
5 L
Q.101 Please state each and every reason why SOV contends that "the proposed action cannot be considered" until."such E
maintenance improvements-are made and1 tested with<
satisfactory performance," and, for eachtsuch reason, please:
[
a.
State each and every fact on which your reason:is j
F based.
I b.
Describe all the evidence in SOV's possession ornof I
which SOV has knowledge that SOV contends' establishes each such fact ~.
c.
For each reason, either provide the technical qualification-(education,-employment history, licenses and certificates, experience, or other information which.SOV contends establishes the qualifications of the person), of'any person on.
whose expertise SOV relies for the reason or state 61 i
d
f a
P' G; '
i
'that SOV does not rely.upon the expertise of any4 person for the reason.
?
A.101 The reason "the proposedEaction cannot be i
considered" until "such maintenance-improvements lare-made l;
'and tested with satisfactory performance,"71s that 1
l reasonable' assurance'can'not be. demonstrated until 1
L procedural. changes and program. enhancements which: purport l
~
to make such a demonstration are proven effective.-
j r
1 L
Vermont relies on the' expertise'of Mr. H. Shannon.
h
[
Phillips to establish this reason.and-fact.
s Q.102 Please describe in'as muchLdetail as is available-to'SOV what is referred to by SOV in'sub-paragraph "m."
of'its-1 Contention 7 as "the failuresto maintain the Uninterruptible Power Supply."
A.102
" Failure to maintain:the:Uninterruptible Power Supply (UPS)... to' meet reliability standards" refers to
^
the fact that the existing UPS is a reliability outlier,,
which licensee has committed to replace during the next' refueling outage.1 Q.103 Please set forth'each and every~ reason.why SOV contends that what is referred to by Sov in sub-paragraph 1"m." of its Contention 7 as "the failure to maintain the a
Uninterruptible' Power Supply" demonstrates "a history'of:
4 maintenance induced problems-and incorrectly executed maintenance and surveillance programs."
While recognizing that UPS design and the A.103 i
environmental conditions of its location contribute to its unreliability, Vermont nevertheless contends thati numerous corrective maintenance. efforts-have.been unable T
62 J
?
1
'f
(-
q
[i q
h..
to. prevent recurrence:of reliability problems, and-predictive and preventive maintenance.have not stopped, j
unavailabilities from occurring.
Q.104 Please set forth each-'and every reason.why SOV contends the.t.what is referred.to by SOV in.sub-paragraph "m." of l
its Contention 7 as "the failure to maintain...the toxic L
gas monitors". demonstrates "a history of maintenance' induced problems and incorrectly executed maintenance'and' surveillance programs."
N A.104 While recognizing that the toxic gas monitor design contributes to its unreliability, Vermont nevertheless m:
contends that numerous corrective maintenance efforts:
have been unable to prevent recurrence-of reliability-problems, and predictive and preventive maintenance have not stopped unavailabilities from occurring.
I Q.105 Please define what~is. meant'by SOV by the term ~
" reliability standards" as it is used by.SOV in sub-paragraph "m" of'its contention 7.
A.105 Vermont is aware that INPO-uses the' Nuclear Plant.
Reliability Data System (NPRDS) and the Component Failure Analysis Report (CFAR) to identify and report significant component failure rate problems.
This reporting, system amounts to and results in a " reliability standard" for'
-a components,. and it is in this context that the term is.
used.1 t
Q.106 Does SOV contend that NRC imposes any requirements.as to
" reliability standards" as that term is used by SOV in.
't sub-paragraph "m" of its. Contention 7.
If so, please identify, by citation to'or identification of a specific provision of a document, each and every~such requirement.
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-A.106 NRC! imposed requirements'on. reliability havel worked-to-elicit a commitment from1the licensee to replace the.
UPS.
In addition' Draft )HU: Regulatory. Guide DG-10011 states:
"Maintenanceeffectiveness'indicakorsbasedon
~
component failure data 1should be monit'ored to-provide indication:ofethe. effectiveness ofsthe I
3 overall-maintenance' program.-Lone < acceptable. method i
is to establish indicators based on-the? number of:
failures experienced or discovere'd peraunitLtime."=
t
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!i Vermont. contends-that this is~an appropriateLrequiremehth j
for the' licensee's proposed life' extension.-
n i
Q.107 With respect to the matter' referred:to on page 49 of:.its~
" Supplement to Petition to-Intervene".asx"LER-89-24,"
does SOV passess any information regarding'the matter beyond:that contained-inithe Licensee. Event Report?: If l
so, please set forth all of the information known or.
1 believed by SOV to be known by it relatingoto that matter.
A.107 At this time we have no information beyond'that in-the LER.
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Q.108 Please describe each and every change to the,VYNPS'.
maintenance program or surveillance program-that:~SOV-contends, had such chango been implemented earlier, would-have precluded the occurrence:of the' matters. described in the Licensee Event Report described in the foregoing interrogatory.
A.108 This LER has yet not been evaluated by. Vermont with-regard to the requested information.1 64 I
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.c Q.109 With respect to the matter referred to on page 49 of'its-i
" Supplement toLPetition'to. Intervene"-as "LER-89-23,"
does SOV posssss any informacion regarding'the matter beyond that contained'in:the-Licensee Event; Report?: If so, please set forth all of~the information,known or-believed by Sov.to be-known byLit relatingLto'that matter.
A.109 At this time we have no information beyond that in the LER.
4 Q.110 Please describe-mach and every change to the VYNPS maintenance program or surveillance program'that Sov j
contends, had such change (been-implemented earlier,'would1 have precluded the occurrence of the matters; described in-q" the Licensee Event Report described in the^ foregoing interrogatory.
A.110 This LER has not been evaluated by. Vermont withi i
regard to the requested-information.
y Q.111 With respect to the matter referred to on page.49 of its?
f
" Supplement to Petition to Intervene" as "LER-89-17,"
does SOV possess any information regarding.the matter beyond that contained in;the Licensee Event-Report?
If so, please. set forth all of.the information known^or.
believed by SOV to be known by=it relating.to that matter.
\\
A.111 At this time we.have no information beyond that in
. i the LER.
q t
Q.112 Please describe each and every change to:the VYNPS' i
maintenance program or surveillance program that'S0V contends, had such change been implemented earlier,owould have precluded the occurrence of the' matters described in the Licensee Event Report described.in the foregoing i
interrogatory.
A.112 This LER has not been evaluated by Vermont with regard to the requested information.
i 65
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.c LQ.113-With respect to the matter referred to onJpage 49.of its:
4
" Supplement to-Petition to Intervene" as "LER-89-14,"-
does Sov possess.any information-regarding the: matter-beyond that contained in the LicenseeLEvent Report?
If; 1so, please set-forth all=of the information known or
-believed lby'SOV to be known by it relating-to.that-matter.
g i
-A.113 Atthis time we have no information'beyond that=in
[
g the LER.
l-Q.114
-Please describe'each and_every change to the VYNPS' maintenance program or surveillance program that SOV contends,~had-such change been= implemented earlier, would',
have precluded the occurrence of the matters described in ithe Licensee Event Report described inithe-foregoing interroge. tory..
A.114 This - LER has not been: completely: evaluated _ by' N
. Vermont with regard to the requested:information..
However,. refer to the responseTto question 54.
Q.115 With respect to the matter referred to'on page;49'ofLits
" Supplement to Petition to. Intervene" as="LER-89-10,"
does Sov possess.any information regarding the matter beyond that contained in the Licensee Event-Report?- If so, please set forth all'of the information-known or' believed by SOV to be known by it relating-to that-matter.
A.115 At this time we have no information beyonds that in i
the LER.
2 Q.116 Please describe each and every change-to'the VYNPS maintenance-program or surveillance _ program.that Sov contends, had such change been implemented earlier,'would
[
i have precluded the occurrence of the matters-described'in.
the Licensee Event Report described in the foregoing interrogatory.
A.116 This LER has not been' evaluated by Vermont with
.l regard to the requested information.
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i Q.117
. With respect to the matter: referred to on'page'49 of its:
" Supplement to Petition to Intervene" as:"LER-88-14,"'
does-SOV. possess any information regarding the matter beyond.that contained in the Licensee Event Report?
If so, please; set forth~alliof theLinformation known or believed by SOVLto be known by itirelating to that; matter.-
A.117
~ At this. time we have no'information beyondithat in the LER..
.Q.118 Please describe each and every change to the'VYNPS maintenance program or' surveillance program that SOV contends,=had such change been-implemented earlier, would have-precluded the occurrence of the: matters ~ described-in:
the Licensee Event Report described in the-foregoing.
interrogatory.
A.118 This LER has not been eval'uated.by Vermont.with?
regard to the requested-information.
l Q.119 With respect to the matter referred to'on page 491of'its j
" Supplement to Petition to Intervene"LasT"LER-88-13,"
l does SOV possess any information regarding~the~ matter ll beyond that contained in the' Licensee Event Report?
If so, please set forth all of-the'information1known or believed by SOV to be known by it relating torthat matter.
y' l
A.119 At this time we have no'information.beyond that in the LER.
Q.120 Please describe each.and every change to theVYNPS'
~
maintenance program or surveillance program that SOV contends, had such. change been implemented' earlier, would 4
have precluded the occurrence of the matters described-in the Licensee. Event Report described.in the foregoing.
i interrogatory.
1 i
A.120 This LER has not been evaluated by Vermont with i
i regard to the requested information.
Q.121 With respect to the matter referred to on page 49 of its
" Supplement to Petition to Intervene" as "LER-88-09,"
I 67 a
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3 1
does Sov possess any information-regarding the matter beyond that contained in the Licensee Event Report?
If so, please' set'forth all;of the information known or--
believed by SOVito-be known by_it relating to that.
matter.
= A.121 We-believe the reactor trip on March -21,:1990,~is.
an event related to the event of LER 88-09.
Vermont was provided with verbal: explanations _and descriptions of the-March 21, 1990 trip from the licensee.
This'information-consisted of a description of the-reactor trip and an explanation of the function of the turbine pressure:
control system.
Q.122 Please describe each and every change to the VYNPS 1
maintenance program or surveillance program that Sov contends, had such change _been implemented earlier, would have precluded-the occurrence of the' matters describedLin-a the Licensee Event' Report described in the foregoing j
interrogatory.
-l A.122 This LER has not been completely evaluated by I
Vermont with regard to the requested information.
_j Provisionally, we believe the maintenance procedure for l
i the turbine pressure. control system.(if one exists).did not provide for proper cleaning and-setpoint determination of the oil system pressure control valves.
l Additionally, relevant vendor manual updates may-not have been incorporated which would have prevented the reactor trips.
Finally, the turbine pressure control system may be approaching obsolescence. Such changes cannot be confirmed-or dismissed until access is gained to licensee's maintenance program documentation, j
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Q.123 With respect to the matter: referred to on-page 49 of its s
" Supplement to~ Petition to: Intervene" as "LER-88-09,"
please::
Explain what is, meant:by the term,"(inadequate'non-a.
safety related maintenance-cuased(sic),reactorf Ltrip)";
b.
Identify the author of the_ phrase _quotedfinJsub-part a of this interrogatory..
c.
Explain all of the reasons why SOVfso classifies the-p
. event in_ question.
A.123 The phase was-authored =by Mr. William Sherman,cbased p
on the suspected root causeffrom the.LER, ".it isL suspected that the MHC: control oil system may have-operated improperly due to' dirt / grit. lodging in'the1 oil-system pressure control valves.". The presence'of-
~9 l
dirt / grit lodging in the oil' system pressure controly 1
?
valves is'an age-related occurrence of thet type'which j!
licensee purports the: maintenance programswill detect-andL l
correct before failure in.the extended period.
Q.124 With respect to the. matter referred;to;on page'49 of its-1
" Supplement to Petition to Intervene".as?"LER-88-05,"~
doas SOV_ possess any information regarding;the matter-l beyond that contained in the Licensee Event Report?,
If I
so, please set forth all of the information known or-believed by SOV to be:known by it'relatingsto that-matter.
a 1
A.124 At this time we have no'information'beyond'that.in-1 the LER.
q Q.125 Please describe each and every change to the:VYNPS.
' i maintenance program or surveillance program that SOV contends, had such change been implemented earlier, would have precluded the occurrence of the matters described'in 1
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the. Licensee Event Report' described inctherforegoing a
interrogatory.
r A.125.
This LER-has not been evaluated by' Vermont 1withi
]
- i regard'to the requested information, q
t Q.126' With respect to the matter referred to on page 50 of its;
~
" Supplement to. Petition to Intervene" as "LER-88-04,"
does SOV possess any information.regarding the.matterL_
beyond that' contained in the Licensee Event-Report?: 'If.
i so,-please set forth all of the'information known or-i-
believed.by SOV to be known by it-relating toLthat C
' matter.
A.126 At this1 time we have no information beyond thatLin the LER.
Q.127 Please describe each and every change to the VYNPS' maintenance program or~ surveillance. program that:SOV J
contends, had such-change been-implemented earlier,Lwould:
have precluded the. occurrence ofsthe matters described in.
the Licensee Event Report described in-the foregoing interrogatory.-
A.127 This LER has not been evaluated:by!VermontLwith regard to the requested information.
Q.128 With respect to the matter referred.to:on page 50 of its
" Supplement to Petition to Intervene" as "LER-88-03,"
does SOV possess any information regarding>the matter beyond that contained in the Licensee-Event Report?
If so, please set forth all of'the information known or believed by SOV to be known by it relating to that matter.
A.128 At this time we have no information'beyond that in the LER.
Q.129 Please describe each and every' change to the VYNPS maintenance program or surveillance program that SOV-contends, had such change-been implemented earlier, would-have precluded the occurrence of the matters described in-the Licensee Event Report described in the foregoing interrogatory.
4 70
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A.129 Thi,s LER has not' been-evalua' ed; by-Vermont with.
t A
regard to the requested ~information.
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Q.130
-With respect to the matter referred to on page 50 ofJitst
?f i
" Supplement to Petition to Intervene" as "LER-89-07,":
does SOV possess any information regarding thelmatter beyond that contained.in the' Licensee. Event Report?c If-so, please set forth all of the information-known or-R believed-by SOV to be known by'it relating to that
-matter..
A.130 Vermont'has in.its-possession'BVY 89-64, " Primary Containment Leak-Rate. Test Report," July 7,'1989.- With the exception of~the quoted, related'.LERs,Jand~NRC
{
requirements, such as 10 CFR'50, AppendixiJ,-we areinot; aware that we possess' additional related information.
Q.131 Please describe each and-'every change-to the VYNPS-maintenance program or surveillance program that-SOV contends, had such change'been-implemented earlier, would-have precluded the occurrence ofLthe matters described in'
)
the Licensee Event Report described in the' foregoing interrogatory.,
4 F
A.131 This LER has not been~evaluatedLby! Vermont with?
regard to the requested.information.
Q.132 With respect to the. matter referredLto on page 50 of-its l
Y
" Supplement to Petition to' Intervene" as "LER-87-07,"-
^
does SOV possess any information:regarding the-matter-beyond that contained in the Licensee Event-Report?. If j
so, please set forth all of the information known or 1
believed by SOV to be~known by it relating to that matter.
a A.132 With the exception of the quoted,-related LERs, wef i
are not aware that we possess additional related 3
information.
i 71
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"i Q.133-Please_ describe each and every change tolthe VYNPS<
)
maintenance program or.' surveillance program that'SOV
~
i contends, had,such change'been implemented earlier, would j
have precluded the-occurrence of the matters l described;in:
i the Licensee Event' Report described in the. foregoing-j interrogatory..
'A.133
'This'LER has not been evaluated'byLVermont with regard to the' request'ed'information.:
-1 l
l
- Q.13 4' With respect;to the matter ~ referred to ont page 50 of-its
'i
~
L
" Supplement to Petition to Intervene" as;"LER-85-07,"
1 does SOV possess any information regarding the matter beyond that contained in the Licensee = Event, Report? lIf -
i so,'please set.forth all of the information known-or "r
believed by SOV to be known by it. relating to that:
l matter.
s A.134-With the exception of the-quoted,;related LERs,.we:
I are not aware that we possess additional related information.
Q.135 Please describe each and every~ change to'the VYNPS.
I maintenance program or surveillance program-that SOV.
contends, had such change been: implemented earlier, would l.-
have precluded the occurrence-of the matters described'in.
the Licensee Event report described in the foregoing interrogatory.
A.135 This LER has not been evaluated by Vermont with-regard to the requested information.
e-Q.136 With respect to the matter referred to-on page 501of its 6
" Supplement to Petition to Intervene"as'"LER-84-11~," does Sov possess any information regarding the' matter beyond=
that contained in the Licensee Event Report?
If so,-
please set forth all of the information known.or believed by SOV to be known by it relating to that matter.
A.136 With the exception of the quoted, related~LERs, we1 are not aware that we-possess additional related l
information.
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i Q.137
'Please describe each andl.every' change'to.the1VYNPS maintenance-program orLaurveillance program that:SOV J
contends, had such-change: been Limplemented earlier, wouldt
-have precluded!the. occurrence of the. matters described'in the Licensee Event Report described in the foregoing interrogatory.-
A.137
.This LER has-not been' evaluated by Vermont with regard to the requested information.
l
^
3 Q.138 Please define " weakness" as-~that" term is:used by Sov:in sub-paragraph'"1" of-its contention 8.
-l A.138 Refer to the response"to Set'No.-1, J
_ question'6.~
E Q.139 Please define " future. inadequacies'in-the maintenancei program" as that term is used by SOVLin:sub-paragraph "1" of its Contention 8.
a
~
A.139
" Future inadequacies in the' maintenance program" 1.
refers'to the fact that. reasonable assurance has-not been l
l demonstrated that the maintenance program 1will. perform as
[.
j-claimed-in the extended periodito protect publici health j
and safety.
Q.140 Please state each and every reason SOV; contends,that VYNPS will have " future. inadequacies in~[its). maintenance-program", and, for each such reason,-please:
a.
State each and every fact on which'your' reason is-based.
b.
Describe'all of the-evidence in'SOV's possession or-of which SOV has knowledge that Sov contends L
l' establishes each such fact.
c.
For.each reason, either; provide the technical qualification (education-employment. history,-
licenses and certificates, experience,'orJother information which Sov contends establishes the qualifications of the person), of' any person on p
whose expertise SOV' relies for the reason or state i
73 1
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?
that_SOV does not rely upon the expertise of any
)
person;for:the reason..
}
A.140 Refer.to response to question 14.
Q.141 Please define " adequacy of tho containment"'as-that term is used by SOV in sub-paragraph "1" of its? Contention:8.
A.141
" Adequacy of containment" refers to the ability of.
the containment to neet all.of its current-licensing.
bases.
4 s
Q.142
-Please state each and'every-reason SOV contends that-
~
"past and future inadequacies of the maintenance program" "put in doubt" the " adequacy of'the containment for the extended period," and, for-each reason,:please:
a.
Please list each of the'" inadequacies" that SOV i
contends put the matter in' doubt.
b.
State _each and every fact on which your reason-.is 4
based..
c.
Describe all of the evidence in SOV's possession or of which SOV has knowledge that Sov contends establishes each such fact.
d.
For each reason, either provide the technical qualification (education, employment history, licenses'and certificates, experience, or.other information which SOV' contends establishes the qualifications of the person), ofLany person on whose expertise SOV relies for the: reason:or state that SOV does not rely upon the expertise;of any.
person for the reason.
V m
t A.142 See sub-part m. of Contention-VIII., Vermont contents that "past and future inadequacies of the-maintenance program "put in doubt" the " adequacy of the a
containment for the extended period," because.four.
successive past failed containment leakage tests.show.
74 i
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-that-licensee has not demonstrated reasonable assurance that an effective and comprehensive program will maintain and/or determine:and replace-aging containment' components;
-to meet its current. licensing basis for the extended' period.
1.
It'is a fact that-the; containment has_ fail'ed four successive tests.
It is~a fact thatithe ability to meet _the 2.
requirements of 10~CFR'50'fAppendix J,:is part of l
the current licensing basis-for the containment.
3.
It is a fact that age-related mechanisms were Partially responsible for the-previous ~ failures'.'.
4.
It is a fact that' licensee's programmatic efforts have not been successful to allow the containment to meet its current licensing l basis-in.
the as-found condition.
5.
It is a fact that, if licensee was unable to a
demonstrate that maintenance functioned as1 claimed
+
in the past, it has not so-demonstrated'for the future.
l Refer to the-responses to questions 130, 132, 134 and4 136-
't for evidence in our possession.
The expertise of Mr. H.
i Shannon Phillips is relied.upon.
1
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Q.143-Please-define whattis meant by'SOV.by.the term "the_
reliance claimed" as it is used by SOV in sub-paragraph "n" of:its Contention 7.
A.143
" Reliance claimed" refers to'cach and'avery-claim b'y the. licensee -that it has' a program 1to maintain and/or y
' determine and replace all components found1to have aged' to.a point'where they~no-longer meet the safety st'andards_
i 1
-applicable to this plant.
l Q.144
.Please define the term " gross age failure of1the drywell-paint system" as it is used by SOV in sub-paragraph "n" of its Contention 8.
A.144
" Gross age failure of-the drywell-paint' system"'
refers-to the drywell paint failure discovered by the:NRC'
~
Maintenance-Team, and described in' letter, BVY 89-69.;
'l 1
Q.145 With respect t'o the-matter-of " gross age failure of.Lthe l
drywell paint system" referred;to by SOV in sub-paragraph "n" of its Contention 8,-does,Sov possess any=
information regarding the matter beyond.that. contained in
" letter, BVY 89-69, Pelletier to NRC"?
If so,Jplease set-3 forth all of the-information known or' believed by SOV to 1
be known by it relating to that matter.
1 A.145 At this time, we have no additional documents I
regarding the containment paint failure.
We are aware ojh a
information related to paint failures in NRC Information.
Notice 85-24 and INPO SER 68-83.
In addition we possess Regulatory Guide'1.54, Quality Assurance Requirements for-Protective Coatings Applied to Water-Cooled Nuclear-Power l
Plants, June 1973, and the document, " Analytical' Evaluation of Station Service Water; System," Comanche' Peak Nuclear Power Station, Case Consultant Jack Dole, 76
o-
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December:31, 1989.
This document evaluates painting-failure; modes.
Q.146 Please define the term " adequacy'of the: coating system in d
the extended period"~as it is used by SoV-in-sub-paragraph "n" of:its' contention 8.
A.146
" Adequacy of the coating system in the extended-
-period" means.the ability of:the coating / system =to meet its current licensing basis in the extended period.
Q.147 Please state'each and every reason.SOV contends,(if.it.
~ t does) that the " adequacy of the coating system" would j
differ for the extended period.from its " adequacy";for 1
the balance of.the present VYNPS license term, zand, for; each reason, please:
State each and_every fact'on which your reason;is a.
- based, b
Describe all of the evidence in SoV's possession or of which SOV has knowledge'that SoV; contends establishes each such-fact.
For each' reason, either provide the technical; c.
j qualification--'(education, employment history,-
i licenses and certificates, experience, or;other i
information which SOV contends' establishes the qualifications of the person), of any; person on whose expertise SOV-relies forithe: reason ~or state that Sov does not rely upon the expertise'of any person for the reason.
A.147 Vermont objects to such a comparison with " adequacy" in the present licensing-term, since this is-not'at issue in the present proceeding.
Notwithstanding'and without l
~
' waiving this objection, Vermont states that we contend
.i simply that reasonable assurance has not been i
demonstrated that the containment coating system will' meet its current licensing basis in the extended period.
77
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Q.148' Please set forth.all of the information known or believed by SOV to-be known bylitirelatingsto " torus wall' thinning experienced =at Nine Mile ~ Point."
A.148 We are aware, through following:industryfactivities, that a torus wall thinning problem exists at'Nine Mile' -
LPoint.. Jul investigation provided verbal information.that.
the'Nine Mile Point torus is uncoated,1while the Vermont.
Yankee: torus is coated.
At1this time, we have no:
additional information.1 Q.149 Please set-forth each and every respect,'and' reason therefor,-why'Sov contends that the " torus wall-thinning experienced at Nine Mile Point" applies to VYNPS.
A.149 BVY 89-69 identifies degradation of the coating j
system in.the: Vermont-Yankee torus.- We1 contend-that; "i
once the coating system degrades, the corrosion mechanism j
active at Nine Mile-Point may become activeEat Vermont q
Yankee.
Q.150 Please define what is meant by SOV1by the term "ECCS criteria is not met" as it is'used-by SOV.in sub-i paragraph "o" of its contention 8.
A.150 "ECCS criteria" refers to the. requirements of_10 CFR 50.46; 10 CFR 50, Appendix K; 10 CFR'50, Appendix A, Criteria 35; NRC Regulatory Guide 1.1 (Safety Guide 1),
..3
" Net Positive Suction Head for Emergency Core Cooling and' Containment Heat Removal System Pumps," and all aspects j
of the Vermont Yankee ECCS current licensing basis.
4
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Q.151 Please define what is meant;by Sov byithe term-t "misoperation of a proposed hardened _ containment vent"Las it is used by SOV in sub-paragraph "o".of'its contention 1 8,
including for each mode,of "misoperation":that'30V.
contends might occur, the resulting plant condition and.
safety. impact'
]
A.151 Were venting to occur in accident ~ sequences with g
l t
L high' core power and high steaming rates, flashing in the suppression pool'could cause ECCS pumps-to fail on-loss v
of suction.
Misoperation refers to any venting scenario
~
L which would allow this to occur. ;An example;isJa' passive venting system which would;not allow sufficient time.for j
manual operator action to terminateLventing.'
i Q.152 Please state each and every reason SOV. contends that-
"ECCS pump suction must.
. - be evaluated with: regardito; the effects of operation and misoperation of a-proposed.
hardened containment vent," and,'for each reason,--please:
l 1
L a.
State each and every fact _on which-your reason is
.i based.
a b.
Describe all of the evidence.in.SoV's. possession.or-of which SOV has knowledge that-Sov contends establishes each such fact.
t c.
For each reason, either provide theftechnical qualification (education,' employment history, licenses and certificates, experience, or.other information which SOV contends = establishes the qualifications of the-person), of.any. person on whose expertise Sov relies for the reason ~or state 1
that SoV does not rely upon the expertise of any; person for the reason.
A.152 Refer to the previous response. 'TheLquestion cannot-be' answered until the final design for the containmentE vent is submitted by Vermont Yankee, t
Q.153 Please identify each person assisting:SOV in the t
preparation of its answers to these interrogatories.
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A.153 Mr'. William,Sherman and Mr.:H.JShannon;Phillipsfassisted' l
'in the preparation of the answers to these interrogatories.. Counsel assisted in the preparation 1of objections.-
i Q.154 For each person requ' ired to be identified in response to?
-the foregoing interrogatory,^please:
j lf 1
a.
Identify the interrogatory: answers prepared by thatL -
person or, if such person prepared only a portion: of j
t an answer, the portions of.the; answer provided by
-r such person.
s b.'
Provide the1 technical qualifications?(education,-
f employment history, licenses 1and certificates, experience, or.other-information which SOV contends establishes-the qualifications of:the: person)', if
~
any, of-such person in each area in which SOV.
L contends such person-to.be; technically qualified.
4 c.
Identify each and everyfreport,-paper or;other document prepared by such person-(whether<or not1in i
conjunction with other persons)$ and made available-
- j to SOV.
l l
A.154 Mr. William Sherman assisted in.the answers to all t,
questions.
Mr. Sherman's qualifications have been provided in response to question 17'of the first set of 4
interrogatories.
i Mr. H. Shannon Phillips-assisted in the answers to an questions 41, 42,-43, 44,~65, 68, 71,f l00,,101, 140, i
i 142, 145, 147 and 152.
Mr.:Phillips' qualifications?
p q
L have been provided in response to question 117 of the first set of interrogatories.
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i A.154.c Vermont objects to the request to identify each and every report, paper or other document as overbroad and burdensome.
- Further, Vermont objects to the production of such reports unless and until such person is identified as an expert witness in this case.
Notwithstanding.and-without waiving these objections, Vermont answers, none.
Q.155 If, in response to any of the foregoing interrogatories, SOV has responded that it cannot answer or that it cannot answer completely without-the acquisition by it of additional information, for each such response:-
a.
Describe the additional information that SOV contends is required in order for it to answer or to answer completely the interrogatory, b.
State'each and every reason why Sov contends ~that the acquisition of.such information is necessary in order for it to ar,swer or to answer. completely the interrogatory.-
State the steps that SOV is taking to acquire the c.
information, and, for each step, the anticipated date on which it will be completed.
d.
State the intent.lons, if any, of SOV concerning supplementation of its answer to the-interrogatory, including (if supplementation is intended), the date on which it in anticipated that SOV will serve its supplemental response.
A.155 Vermont objects to this question on the grounds that.it is burdensome, that it seeks disclosure of.the thought processes of counsel, and that it seeks disclosure of j
case strategy.
1 81 1
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Q.156 Does SOV intend to offer into evidence the. testimony of l
any expert witness or witnesses?
If so, then for each such witness, provide f
a.
An. identification of the witness, b.
The technical qualifications (education, employment history, licenses-and certificates, experience, or other information which 80V contends establishes the qualifications of the witness), if any, of the i
witness in each area in which SOV contends the J
witness to.be. technically qualified.
I a
l c.
A summary of the facts and opinions to whichtSOV expects the witness to testify.
l d.
For each such opinion, a summary of the basis therefor.
A.156 Vermont has not yet made any final determination on this matter.
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82
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AFFIDAVIT STATE OF VERMONT COUNTY OF WASHINGTON, SS.
WILLIAM K. SHERMAN,-being duly sworn, states.that the foregoing answers are true and correct to the best of my knowledge.
Dated at Montpelier, Vermont, this 24th day of April, 1990.
W_ _
WILLIAM K. SHERMAN Subscribed and sworn to before me this 24th day'of April, 1990.
h een b d lfotary Public My Commission Expives:
2/10/91 i
As to Objections:
Wm_
James Volz '
j Dir i or for Public A$vocacy l
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'e UNITED STATES OF AMERICA
$[hc NUCLEAR REGULATORY COMMISSION
{
before the ATOMIC SAFETY AND LICENSING BOARD'90 APR 27 All :39
)
In the Matter of
.- )
FnCE N SECRMAM VERMONT YANKEE NUCLEAR
.)
Docket Mo F[b h [b b k POWER CORPORATION
)
(Operating License
)
Extension)
(Vermont Yankee Nuclear
)
Power Station)
)
)
CERTIFICATE OF SERVICR
.I hereby certify.that on April 24, 1990, I made' service of the within document in accordance with rules of the Commission by mailing a copy thereof postage prepaid to the followingt-Administrative Judge Administrative Judge Robert M. Lazo, Chairman Jerry Harbour Atomic Safety and Licensing Board Atomic safety and Licensing U.S.. Nuclear Regulatory Commission Board Washington, DC 20555 U.S.. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Ann P. Hodgdon, Esq.
Frederick J. Shon Patricia A. Jehle, Esq.
Atomic Safety and Licensing Board office of the General Counsel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC_20555 R. K. Gad, III, Esq.
Anthony Z. Roisman, Esq.
Ropes & Gray Cohen, Milstein, Hausfeld &
One International Place Toll
{
Boston, MA 02110 Suite 600 l
1401 New York Avenue, N.W.
i
- l Adjudicatory File Washington, D.C.
20005 Atomic Safety and Licensing Board Panel U.S.N.R.C.
Washington, DC 20555 W
. b ames Volt"
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Dated:
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