ML20056B214

Supplemental Responses to Applicant Interrogatories by State of VT (Set 2).* Clarification Re Scope of Term Surveillance Program as Used in Contention 7 Provided.W/Certificate of Svc.Related Correspondence

ML20056B214
Person / Time
Site:	Vermont Yankee
Issue date:	08/06/1990
From:	Sherman W VERMONT, STATE OF
To:	VERMONT YANKEE NUCLEAR POWER CORP.
References
CON-#390-10712 OLA-4, NUDOCS 9008150211
Download: ML20056B214 (14)

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UNITED STATES OF AMERICA 4 NUCLEAR REGULATORY COMMISSION '90 AUG -9 A10:56 before the ATOMIC SAFETY AND LICENSING : BOARD Of flCr DF SECdt.l ARV ,

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!!HANCH i In the Matter of ) >

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VERMONT YANKEE NUCLEAR ) Docket No. 50-271-OLA-4 POWER CORPORATION ) (Operating License

) Extension)

(Vermont Yankee Nuclear )

Power Station) )

SUPPLEMENTAL RESPONSES TO l APPLICANT'S' INTERROGATORIES BY STATE OF VERMONT +

(Set No. 2) pursuant to 10 C.F.R. 5 2.740(e), and the Board's1 Memorandum and order in this proceeding dated July 20, 1990, the State of Vermont supplements its-" Responses to Interrogatories-by State of' Vermont'to the Vermont Yankee f

Nuclear Power Corporation (Set No. 2)" dated April 124, 1990.

This supplementation consists of supplemental responses to Vermont Yankee Interrogatories (Set No. 2)'Nos. 1, 3, 9, 10, l i, 11, 12, 37, 80, 147 and 152. In addition, Vermont herewith

!' voluntarily supplements responses to Vermont Yankee L -Interrogatories (Set No. 2) Nos. 44 and 142.

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H, SUPPLEMENTAL RESPONSES Q.1 Please define what SOV. contends.is included within the scope of the term " maintenance program" as used.

by'it in its, Contention 7. A Supplemental Response A.1 Vermont clarifies that.the definition provided in response to Vermont Yankee Interrogatory (Set No. 2) No. 1-f is a completely inclusive definition with the addition of

.the category-" document":

The term " maintenance program" (as used in contention VII is defined as].any policy, procedure, guideline,. method, practice, standard or document which accomplishes,  ;

controls, or relates to " maintenance" as it- '

is defined in NRC Policy Statement on Maintenance of Nuclear Power Plants (53 FR ,

9430).

~Q.3 Please. define what SOV contends is included within the scope of the term " surveillance program" as used by it in its contention 7.

Supplemental Response A.3 l Vermont clarifies that the definition provided in response to Vermont Yankee Interrogatory (Set No. 2) No. 3 is a. completely inclusive definition with the addition of the category " document":

A " surveillance program" (as used in

. Contention VII is defined as) any policy, procedure, guideline, method,' practice, standard or document which accomplishes, controls, or relates to surveillance.

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, l Q.9: Please define'the measure of'"sufficiently

' effective" as the term is used by-SOV in'its Contention'7.

Supplemental Response A.9 Vermont supplements this response to state that a

additional. facts are provided in supplemental responses- to Vermont Yankee Interrogatories (Set No. 2)'Nos. 142 and 147.

Vermont clarifies this response to state that, at this time,.  ;

the facts identified in the original and supplemental

• response to this interrogatory are the only bases for  !

believing that.the maintenance program will not be sufficiently effective.

Q.10 Please identify or describe all of the bases for the definition supplied in response to the foregoing interrogatory.

Supplemental Response A.10 Vermont clarifies-its response to state that the bases are provided in the foregoing supplemental response, j

-t Q.11 Please define the measure of "sufficiently...

comprehensive" as the term is used-by SOV in its Contention 7.

Supplemental Response A.11.

i Vermont supplements this response to state that additional facts are provided in supplemental responses to Vermont Yankee Interrogatories (Set No. 2) Nos. 142 and 147.

Vermont clarifies this response to state that, at this time, the facts identified in the original and supplemental 3

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l response to this interrogatory are the only bases for g believing that the maintenance program will not be sufficiently comprehensive.

Q.12 Please identify or describe all of the bases for the definition supplied in response to the foregoing interrogatory. '

O Supplemental Response A.12 Vermont' clarifies its response to state that the bases are provided in the foregoing supplemental response. ,

Q.37 Please describe the data, investigations and analytical or investigative processes upon which the conclusions of the author (or authors) of the work u" dated October 9, 1989, to which SOV refers in sub-paragraph "c." of its contention 7 were based.  !

Supplemental Response A.37 Vermont clarifies that the references identified in response to Vermont Yankee Interrogatory:(Set No. 3) No. 12- ,

are the only ones'that Vermont knows to exist related to the work dated October 9, 1989.

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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 L without endangering the health and safety of the public."

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If=your answer-is'anything other than'an' unqualified affirmative, then please:

L r a. State each and every qualification ; iou 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 l possession or of which SOV has knowledge that SOV contends establishes each such fact.  ;

s N d. For each qualification, either provide the technical qualifications (education, employment history,. l licenses and certificates, experience,:or other =i information which SOV contends establishes the l qualifications of the person), of any. person on whosa expertise SOV relics 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 t assessment, then please:  !

e. State each and every reason.why SOV believes that the situation described therein has come a to exist.

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f. State'each and'every reason why, assuming the I rejection of this contention,.the SOV contends (if it does) that the same condition i might not be expected to continue through the -

balance of the existing VYNPS. license term.

g. State each and every reason why, assuming the rejection of this contention, the SOV '

contends (if it does) that the same' condition '

P' might not be expected to continue through the 1 balance of the extended VYNPS, license term. '

- Supplemental Response A.44 -

Vermont supplements its response as follows:

Additional facts and evidence are provided in 1 i

response to Vermont Yankee Interrogatories (Set No. 2) I Nos. 142 and 147. ,

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". , 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 VYNPS license term.

Supplemental Responsu A.80 LVermont clarifies that it has not completed case development to'a point where it can identify any required certification work.

Q.142 Please state each and every reason SOV' contends that -f "past and future inadequacies of the maintenance program a "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 contends put the matter in doubt.

b. State each and every fact on which your reason is based, r

c. Describe all of the evidence in SOV's possession or of which SOV has knowledge that SOV contends  !

establishes each such fact. F

d. For-each reason, either provide the technical i qualification (education, employment history, licenses and' certificates, experience, or other a information which Sov contends establishes the 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 person for the reason.

Supplemental Response A.142 6

L Vermont-supplements this response with additional facts and related evidence as follows:

6. Feedwater Check Valve FDW-96A could not be pressurized in the 1989 containment leakage rate test. (BVY 89-64, LER 89-07) l l 7. Maintenance requirements for FDW-96A include l

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replacement of valve seals at the end of every cycle.

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8. Valve seals were not replaced in the 1987 refueling

. outage as required, which illustrates an ineffective maintenance program. (Maintenance History. Card for Valve FDW-96A)

9. LER 89-07 claims'that inboard isolation valve FDW-2BB would have prevented' leakage, despite the fact that FDW-28B~is not tested in the containment leakage program. Yet, excess FDW-28B seat leakage was identified in April 1987,-as document on Maintenance Request (MR) 87-0787. Further, the maintenance was not performed on FDW-28B until March 1989, allowing excess-leakage of a containment isolation valve to exist for two years without correction. Again this I illustrates an ineffective maintenance program. (LER 89-07, MR 87-0787) i

10. When MR 87-0787 was finally acted upon in March

• E 1989, valve' cracks were discovered which resulted in a l

L decision to replace the valve in the 1990 outage. The lack l.

of proper maintenance action in 1987 allowed this l

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. 1 potentially serious problem to exist for two extra years.

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11. The licensee's analysis of the safety effects of Valve'FDW-96A in LER.89-07 are not convincing. Had a design basis accident. occurred, and using design-basis assumptions, containment' leakage greater than the plant design basis t

would occur, resulting-in doses greater that the plant design basis. This is a result of .nadequate maintenance on Valves FDW-96A and 28B. (LER 89-07, MR 87-0787, Maintenance

, History Records for'FDW-96A and 28B)

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Refer to the responses to questions 130, 132, 134 and 136' for evidence in our possession. The expertise of Mr. H.-

Shannon Phillips is relied upon.

Q.147 Please state each and every reason.SOV contends (if-it'does) that the " adequacy of the coating system" -

would differ for the extended period from its >

" adequacy" for the balance of the present VYNPS license term, and, for each 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 establishes each such fact.

I: c. For each reason, either provide the technical qualification (education, employment history, licenses and certificates, experience, or other l information which SOV contends establishes the l 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 person for the reason.

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Supplemental Response A.147 Vermont supplements its response to state that licensee's maintenance program in the present term has not maintained the containment coating such that the safety standards applicable to the plant have been met. Based on this i

.present performance, there is no assurance.that future

-maintenance activities will prevent similar occurrences in the extended. period. Facts and related-evidence are presented below:

1. The poor adherence of paint to the drywell and torus was identified in the 1970's and has remained uncorrected ever since. (BVY 89-69) ,

2. Loose paint was noted in a drywell inspection of September 22, 1987 in accordance with Procedure OP 4115, Primary Containment Surveillance. This loose paint was not removed but left in place throughout the operating period from October 1987 to March 1989,1 indicative of an ineffective maintenance-program. (Form 4115.04 dated l

September 22, 1987; Stone & Webster letter of April 4, 1989 (R. Martin to D. Yasi))-

l 3. The acceptance criteria for peeling paint is not adequate to assure corrective action when loose paint is ,

discovered.. (Form 4115.04 dated September 22, 1987, Form  !

l 4115.04 attached to OP 4115, Rev. 23) l l 9 L

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I f 4. Procedure OP 41*.5,_Section D requires that 4 .

corrective action be indicated for items, discovered in the visual inspection of containment. Yet no corrective action i-

.s indicated regarding the peeling paint observed in-1987.

h There is no indication that the safety constriences of this-peeling paint were evaluated, a violation of procedure AP 0010, Occurrence Reports / Notifications and Report's Due. ,

(Form 4115.04 dr,ted September 22, 1987; OP 4115, Rev.-23; AP 0010 Rev. 21)

5. As a result of not correcting the imme'diate drywell peeling paint in 1987 (and the overall paint problem since 1972), a more severe peeling problem was allowed to exist, ,

1 which was discovered by the NRC maintenance team in 1989. [

(IR 89-80) ,

6.- In the 1989 outage, approximately 30% of the topcoat 3 e

in the upper section of the drywell was removed by scraping.

(Response to Vermont Interrogatory (Set No. 1) No. 78) 7.- The licensee was informed by its painting consultant

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"(T]he topcoat materials failed by delamination and produced chips as large as one square foot.

Transport of these chips to-the safety system suction strainers could potentially result in

partial blockage of the. strainers."

L Despite this notification, there is no indication that the-safety consequences of this peeling paint as it existed

.before scraping in March 1989 were evaluated, a violation of p procedure AP 0010, Occurrence Reports / Notifications and l'

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1 Reports Due. (Stone & Webster letter of April 4, 1989 (R.

Martin to D. Yasi)! PRO log for 1989) 8.- Licensee's evaluation of the peeling paint' (BVY 89-

69) does-not make it clear that its evaluation is only

- applicable to the "as-scraped" condition. The "as-found" )

delamination and future'd91 amination are not evaluated. I (Stone & Webster letter of April 4, 1989 (R. Martin to D. .(

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. Yasi) ; BVY 89-69)

9. Licensee's calculation for minimum net positive l l

' suction head of the ECCS pumps does not include any ,

assumption for the combination of fouling by a mixture of insulation fibers and paint chips. Licensee instead makes a non-conservative assumption, improper for ECCS safety j analysis, that paint chips will not foul suction strainers.

A proper conservative assumption would result in fouled suction strainers, inadequate NPSH, and a defeated safety function. (BVY 89-69; Calculation.VYC-808)

Vermont relies on the expertise of Mr. H. Shannon Phillips for this response. Mr. Phillips' qualifications were provided with Set No. 1 Interrogatory responses.

'Q.152 Please state each and every reason SOV contends that "ECCS pump suction must. . . be evaluated with regard to the effects of operation and misoperation of a proposed hardened containment vent," and, for each reason, please:

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'* Stat'e each and every fact on which your reason is

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b. Describe all of the evidence in Sov's possession or of which SOV has knowledge that.SOV-contends establishes each such fact. I

c. For each reason, either. provide the technical qualification (education, employment history, licensesLand 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

-T that SOV does not rely upon the expertise of any, person for the reason.

Supplemental Response A.152 Vermont clarifies ~that it has not yet made a decision regarding an expert or experts for the area of misoperation- l of.a proposed hardened containment vent.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

VERMONT YANKEE NUCLEAR ) Docket No. 50-271-OLA-4 POWER CORPORATION ) (Operating License

) Extension)

(Vermont Yankee Nuclear )

Power Station) ) ,

AFFIDAVIT OF WILLIAM K. SHERMAN  !

I, '.iILLIAM K. SHERMAN, being duly sworn, state that the answers provided on August 6, 1990,

" Supplemental Responses to Applicant's Interrogatories by the State of Vermont (Set No. 2)", are true and correct to the best of my knowledge.

Dated at Montpelier, Vermont, this 6th day of August, 1990. b

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' WILLIAM K. SHERMAN r

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b Subscribed and sworn to before mo this 6th day of August, 1990. '!

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' W otary Public My Commission Expires: 2/10/91 i

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e i MiilD UNITED STATES OF AMERICA UwhC NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD '90 E -9 M;56

)

In the Matter of Ori n f of SECadt."Y

) nacg im3 3. 'ilitVICI VERMONT YANKEE NUCLEAR ) Docket No. 50-271-OLAF4ANC" POWER CORPORATION ) (Operating License

) Extension)

(Vermont Yankee Nuclear )

Power Station) )

)

CERTIFICATE OF SERVICE I hereby certify that on August 6, 1990, I made service of a

" Supplemental Responses to Applicant's 7nterrogatories by State of Vermont (Set No. 2)." in accordance W.ith rules of the Commission by mailing a copy thereof postsge prepaid to the ,

following:

Administrative Judge Administrative Judge Robert M. Lazo, Chairman Jerry R. Kline 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 i

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. houlear Regulatory Washington, DC 20555 Commission Washington, DC 20555 R. K. Gad, III, Esq. Anthony Z. Roieman, Esq.

Ropes & Gray Cohen, Milstein, Hausfeld &

One International Place Toll Boston, MA 02110 Suite 600 1401 New York Avenue, N.W.

Adjudicatory File Washington, D.C. 20005 Atomic Safety and Licensing Board Panel U.S.N.R.C. A Washington, DC 20555 /

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Kurt Jansopf Special AsM stant Attorney General Dated: August 6, 1990 i l

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