ML20059L824
| ML20059L824 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/14/1990 |
| From: | Pelletier J VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | VERMONT, STATE OF |
| References | |
| CON-#490-10844 OLA-4, NUDOCS 9010010316 | |
| Download: ML20059L824 (171) | |
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6EATED CORRESPONDENCE totatue UbNkC UNITED STATES OF AMERICA 3 20 P2 Z2 NUCLEAR REGULATORY COMMISSION (Fi Tf (J St.C.R! W '
!"WI before the.
00Chil Igl ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of
)
) Docket No. 50-27l-OLA-4 YERMONT YANKEE NUCLEAR ) (Construction Period POWER CORPORATION
) Recapture)
)
(Vermont Yankee Nuclear
)
Power Station)
)
)
ANSWERS OF YERMONT YANKEE NUCLEAR POWER CORPORATION TO INTERROGATORIES PROPOUNDED BY THE STATE OF YERMONT (Set No. 3)
Pursuant to 10 C.F.R. i 2.740b, Vermont Yankee Nuclear Power Corpora-tion hereby responds to the interrogatories propounded to it by the State of Vermont. (By stipulation, the time within which these responses were due was enlarged to September 14, 1990.)
General Response Regardlag Doenments: In each case in which a document is identified hereinafter to be available, the documents will be produced for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation, in Brattleboro, on a date and at a time to be agreed upon by counsel.
laterrogatory No.1, Please identify all persons who participated in the preparation of answers to Vermont Interrogatories (Set No. 2);
- a. Describe in detail the specific portions of each response to which each person contributed,
- b. Provide the most current resume available for each identified individual.
- c. Describe the qualifications of each identified individual, including training and papers published.
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Response
James P. Pelletier All Francis J. Helin All William J. Daley 1, 2 Robert J. Waneryk 3,7,55,61,63,67,69,70,78 H. Michael Metell 8,46 Richard P. Lopriore 9,10,i1,15,16,17,27,28,29,36,37,38,39, 40, 41, 42, 43, 44, 81, 82, 95, 97 Terril A. Watson 66,87,93,95,100 Patrick J. Done!!ey 77,85 Lonnie Cantrell 21,22,23 Richard W. De Vercelly 30,31,320 The qualifications of the above-listed individuals are described in their resumes and trainint records, which have previously been offered for inspection, laterrogatory No. 2.
Please identify all persons who participated in the preparation of answers to these interrogatories:
- a. Describe in detall the specific portions of each response to which each person contributed.
- b. Provide the most current resume available for each identified individual.
- c. Describe the qualifications of each identified individual, including training and papers published.
Response
James P. Pelletier All Francis J. Helin All Robert J. Wancryk 143 Richard P. Lopriore 52, 26, 32, 33, 34, 36, 37, 68, 73 135, 137, 156, 157, 158, 159, 160, 163, 164, 165, 166, 167, 168, 169, 170, 171, 172, 173, 174, 175 176, 177, 178, 179, 180, 181, 182, 183, 184, 185, 188, 191, 192, 193, 194, 195 James C. Kinsey 6,7,8,9,10,11,12,13,17,20,28,29,141 H. Michael Metell 46,133 Kathleen M. Casey 65 Sandra M. Ward 38,39,40 2-
i i
William M. Pittman 78,98,122,149 James M. Devincentis 19 Richard E. McCullough 56, 57 3
Richard G. Mossey 80,81,82,83,84
)
William J. Daley 124,125 j
Peter S. Littlefield 3,4,5,14,21, Jeffery S. Chisever 13, l
Kathy M. Hotelik 23 Richard E. $wensen 44,121 Paul R. Johnson 74, Walter K. Peterson 60,61,62,63, William D. Fields 138 Leonard A.Tremblay 45, 51, 52, 53, 54, 79, 85, 86, 87, 88, 89, 90, 91, 92, 93, 94, 95, 96, 97, 99, 100, 101, 102, 103, 104, 105, 106, 107, 108, 109, 110, Ill, 112,113, lid,115,116,117, lit,119,120, 121,122,123,150,151,152 Richard Martin 102, 104, 105, 106, 107, 108, 109, 110 The qualifications of the above-listed individuals are described in their rest mes. The resumes and training records already have been (or, for any that have not been will be) produced for inspection by SOY vpon request.
laterrogatory No. 3.
The following containment leakage rates are stated in licensing basis sources as follows:
(1) 0.5%/ day @ 43.5 psis, FSAR at page 14.6-26 (Rev. 2);
(2) 0.9%/ day @ 44 psig. SER (6/1/71) et page 64;
()) 0.8%/ day @ 44 psis, Tech. Spec. 3.7.A.3; (4) 1.5%/ day @ (4 psis, Tech. Spec. Bases 4.7.A at page 142,
- s. Please state the current licensing basis for allowable containment leakage rate,
- b. Please explain why the value chosen is the current licensing basis,
- c. Please explain the reasons why the other values in (!),(2),(3) or (4) above are not the current licensing basis for allowable containment leakage rate.
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Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not
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relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather espressly relying upon the same, and without accepting SOV's premise that each of the values in question has its basis 'in (a) licensing basis source [],' Vermont Yankee supplies the following information:
- a. The current licensing basis containment leakage is 0.3%/ day.
)
- b. This value is the Tech. Spec, limit as presented in Tech. Spec. 3.7.A.3.
This value would limit the calculated site boundary doses following a i
design basis LOCA to approalmately 1/2 of the 10 C.F.R., Part 100 criteria. The calculational methodology is conservative in that it does not take account of real world phenomena that would further reduce actual site boundary doses.
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- c. The 0.5%/ day value is the mechanical design basis for the primary containment structure.
l The specific basis for the 0.9%/ day in the SER is not known. 1t is, however, most likely the Staff's calculation of a leak rate that'would maintain the DBA LOCA dose to 1/2 of the part 100 limit.
As discussed in Tech. Spec. bases 4.7.A, the 1.5%/ day is a value for leakage rate that was determined to not eaceed the 10 C.F.R., Part 100 criteria.
laterrogatory No. 4.
Does Vermont Yankee agree that, if the containment integrity has not been maintained such that the containment leakage rate less [ sic) than or equal to the allowable containment leakage rate in the current 4
licensing basis, then containment integrity no longer meets the safety standards applicable to the Vermont Yankee plant.
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for such reason:
- a. State each and every fact on which your reason is based.
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- b. Dascribe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Yermont Yankee i
contends establishes each such fact.
Objection:
Vermont Yankee objects to this laterrogatory on tne ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather espressly relying upon the same, Vermont Yankee supplies the following leformation:
j No. As stated above, the Vermont Yankee Tech. Spec. limit is designed to surpass the 10 C.F.R., Part 100 requirements, and exceedence of the limit would not result in a failure to meet that requirement.
l Interrogatory No. 5.
Does Vermont Yankee agree that,if the containment integrity has not been maintained such that had a design basis loss-of-ooolant accident i
occurred with the single worst effect active failure and with radio-logical consequence (calculated in accordance with Standard Review Plan l$.6.$ with Appendices and Regulatory Guide 1.2) for such event calculated to be greater than the esposure limits of 10 CFR i
Part 100, then the containment integrity no longer meets the safety standards applicable to the Vermont Yankee plant?
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
{
- a. State each and every fact on whleh your reason is based,
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
l Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
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As we read this interrogatory, it is in the form of a hypothetical question that supplies its own mandatory answer. It is in the form: do you agree that if X, then X (where X is that the Part 100 timits are enceeded). Such a question is meaningless, and we therefore suspect some inadequacy in its j
presentation, j
if the question was intended to ask whether etceedence of the 0.8%
licensing basis limit would result in etceedence of the Part 100 limits, then the answer b, as set forth above, no. We add only that the design basis accident calculations for Vermont Yankee are not based on SRP 15.6.5 but on l
FSAR Chapter 14. Finally, we point out that the calculational methodology of Chapter 14 takes so credit for such real world phenomena as containment j
pressure decrease, condensation, suspended matter deposition, and the like, and thus necessarily overstates the resulting site boundary implications.
laterrogatory No. 6.
Does Vermont Yankee agree that, based on the results of LERs 89-1 07,87-07,85-07 and 84-11, the Vermont Yankee plant was operated i
while technical specifications 3.7.A.3,3.7.A.4, and 3.7.A 8 were not
]
met?
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
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- a. State each and every fact on which your reason is based.
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- b. Describe all of the evidence in Vermont Yankee's possession or of i
l which Vermont Yankee has knowledge that Vermont Yankee I
contends establishes each such fact.
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Objection:
Vermont Yankee objects to the interrogatory on the grounds that it (i)is not a proper interrogatory, (ii) aseks a bare legal opinion, and (111) is not l-relevant to the admitted contention.
Response
Without walving the foregoing objections, but rather expressly relying upon the same, Vermont Yankee states that the referenced documents speak for themselves. However Vermont Yankee further provides the following 1
information:
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l' No. The terms of Technical Specifications wetions 3.7.A.3, 3.7.A 4, 3.7.A.8 and 4.7.A are not such that operation of the plant was a violation l
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whenever it might be inferred from subsequently observed tests that the leak rates were higher than the Tech. Spec. dictated 'as left' limits.
To the contrary, the fact that the leak tight lategrity of primary oostain-ment isolation valves may degrade between tests is anticipated by both the YYNPS Tech. Specs and 10 C.F.R., Part 50, Appendix J. Note la particular the following two excerpts from the ' Bases'section of Tech. Spec. spetion 4.7.A:
'The maximum allowable test leak rate at the peak accident pressure of 44 psis (La) is 0.30 weight % per day. The maximum allowable test leak rate at the retest pressure of 24 psig (Lt) has been conserva-tively determined to be 0.59 weight % per day'
'To allow a margin for possible leakage deterioration between test intervals, the maximum allowable operationalleak rate (Ltm), which will be met to remain on the normal test schedule, is 0.75 Lt.'
Similarly, Appendix 3 recognises that failures of leak rate tests will from time to time occur, as demonstrated by the statement in the ' introduction' that one of the purposes of the tests is to assure that ' periodic surveillmce of reactor containment penetrations and isolation valves is performe, so that proper maintenance and repairs are made during the service 11 of the containment and systems and components penetrating primary con' 41 ament.'
in addition, the acceptance criteria of sections 3.7.A.3 and 3.7.A.4 must be read in conjunction with the other provisions, including 4.7.A.2. Finally, it must be reentled that many of the valves to which these sections are applicable are not capable of being tested during plant operations. Therefore, it is not an acceptable interpretation of the Technical Specifications as an integrated document that a violation of the compensatory action statement occurs whenever subsequently determined conditions might imply that a test, could it have been performed at an earlier non required time, would have resulted in values above the 'as left' limits, a & b. See above, laterrogatory No. 7.
How long does Vermont Yankee believe the Vermont Yankee plant was operated while technical specifications 3.7.A.3, 3.7.A 4, and 3.7.A.3 were not met? Please state every reason for your answer, and for each reason:
a.-
State each and every fact on which your reason is based. -
- b. Describe all of the evidence in Vermont Yankee's poseension or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to the interrogatory on the grounds that it (i) is
' not a proper interrogatory, (ii) seeks a bare legal opinion, and (iii) is not relevant to the admitted contention.
Response
Without waiving the foregoing objections, but rather espressly relying upon the same, Vermont Yankee provides the following information:
Zero time. Please see the response to inserrogatory No. 6.
laterrogatory No. 8.
If it cannot be determined how long the Vermont Yankee plant was operated while technical specifications 3.7.A.3,3.7.A.4, and 3.7.A.
were not met, does Vermont Yankee agree with the conservative assumption (for the purpose of consequence evaluation) that the plant operated the entire operating cycle in such condition?
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based.
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
- c. State the conservative assumption (for consequence evaluation) and its basis with which Vermont Yankee does agree.
Response
No response required by the terms of the laterrogatory, laterrogatory No. 9.
LER 89-07 at page 3 of 5 states,
'Even though valve FDW.96 A could not be pressurised, minimum pathway leakage would probably not be affected for the following reasons....* (emphasis added)
.g.
- a. Please emplain what is meant by *probably not.'
- b. What is the probability that" minimum pathway leakage would...
not be affected?'
c, Please describe in detail each and every effort to determine the probability that ' minimum pathway leakage would... not be affected?"
- d. Please identify each and every individual who participated in the determination that
- minimum pathway leakage would proba6?y not be affected.'-
- e. Please identify each and every document which roo'ords the deter.
i mination that ' minimum pathway leakage would probably not be affected.'
Response
- a. The term "probably not* as used in the subject reference was based on an engineering judgment concerning a series of low probability events that would be required to occur before minimum pathway leakage would be effected. Since the simultaneous occurrence of these events is unlikely, the term 'probably not* reflects this low probability,
- b. Although it was determined that no rigorous failure probability analysis was required to be performed, the following simultaneous events must occur to effect minimum pathway leakage:
Both the inboard (FDW.2sB) and outboard (FDW.96A) check valves must fail. This is unlikely since check valve closure is very reliable.
These valves would fall to close only if they were physically blocked by some foreign material or as a result of serious mechanical binding.
A third check valve (FDW-27A), for which no credit is taken in the subject LER, exists in this feedwater line. Therefore, an additional valve would have to fall in the manner specified above to allow this inventory to leak through.
If all three check valves failed to seal, the line will remain water covered until the entire feedwater inventory has leaked through. Thus, a period of time is available to allow closure of the upstream motor-operated valves. These motor operated valves are remotely operated from the control room.
Even if the check valves and the motor-operated valves failed simul-taneously, system operating pressure can be maintained higher than the 9
i
primary containment accident pressure, thereby preventing leakage from the penetration.
The conclusion of very low event probability was reached on the basis of the foregoing considerations.
- c. See sub-part b,
- d. J. DeVincentis, G. Cappuccio H. Metell. LER: also receive PORC review and Plant Manager approval (J. Pelletier),
laterrogatory No.10.
Is it Vermont Yankee's current licensing basis to assume valve V2-2sB will provide isolation *even though not tested (LER 89-07 at page 3 of 5)7' If your answer is affirmative, please provide a specific reference to the ' facility operating licene (including Technical Specifications, Applicable Commission Regulations, Certain NRC orders (those amounting to license amendments)[or] Certain licensee commitments *
(quote from Vermont Yankee response to laterrogatory (Set No.1)
No. 6) within your current licensing basis which allows this assump-tion.
Objection:
Vermont Yankee objects to this inter:ogs:ory on the ground that it 5 nc t 3
relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, VY points out that the interrogatory misreads the LER. The LER says that
- valve V2 28B, even though not tested, will provide an isolation function in tambination with P2-964.' (Emphasis added.) This is, in fact, the current licensing basis for these valves. See Letter USNRC to VYNPC,NVY 83-192, 8/19/83.,
l Interrogatory No. II.-
LER 89 07 at page 4 of 5 states,
'There is reasonable assuranet that, with the exception of a i
feedwater line break (in the same line as FDW-96 A), there would how been enough time for the motor operated valves at the discharge of the high pressure feedwater heaters to be closed before there was any escape of containment atmosphere.'
(emphasis added) f Please state each and every reason why Vermont Yankee be'lieves there is
- reasonable assurance
- that.'there would have been enough time for the motor operated valves at the discharge of the high pressure feedwater heaters to be closed before there was any escape of containment atmosphere,' and for each reason:
j
- a. State each and every fact on which your reasor, is based, t
- b. Describe n!! of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
]
- c. For each reason, either provide the technical qualifications (education, employment history, licenses and certificates, experience, or other information that Yermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee telles for the reason or state that Vermont Yankee does not rely upon the expertise of any person g
for the reason.
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i Objection.
Vermont Yankee objecu to this interrogatory on the ground that it is not relevant to the admitted contention,
Response
Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee offers the following information-
- n. The facts relied upon for this conclusion are:(1) the high reliability of check valves;(2) the large inventory of feedwater available within the system (approximately 130 feet of 10-inch pipe and 41 feet of 16-inch pipe between the vessel and the outboard check valve;(3) the readily accessible remote operating switches for the motor-operated valves in the control room; and (4) the anticipated operator action. See the response to Interrogatory No. 9, i
I above, for additional information.
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- b. In addition to the above discussion, Vermont Yankee relies on conclusions reached in a USNRC Safety Evaluation Report concerning this issue.
(
Reference:
Letttr USNRC to YYNPC (NYY 83-192), dated */19/83) s
- c. See the response to interrogatory No. 9, above. The qualifications of these people have altss y been produced for SOV's lampaction.
laterrogatory No.12.
LER 89-07 at page 4 of 5 states,
'There is reasonable assurance that, with the exception of a feedwater line break (in the same line as FDW-96A), there would have been enough time for the motor operated valves at the discharge of the high pressure feedwater heaters to be closed before there was any escape of containment atmosphere."
(emphasis added)
- a. State the measure or standard of ' reasonable assurance
- that Vermont Yankee has used to make this statement.
- b. Identify the calculation performed to demtinstrate this reasonable assurance.
- c. Has this calculation been reviewed and approved in accordance with YOQAP-1-A, Section Ill, Design Control? If your answer is affirmative, please state the date of approval and the name of the reviewer and approver,
- d. Has this calculation been submitted to the NRC staff for review?
If your answer is affirmative, please identify the document provided to the NRC staff.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregeing objection, but rather expressly relying upon the same, Vermont Yankee offers the following information:
References:
A. Letter, VYNPC to USNRC (WVY 80 132), dated 09/19/80 B. Letter VYNPC to USNRC (FVY 82-30), dated 03/26/82 C. Letter, USNRC to VYNPC (NYY 83-192), dated 08/19/83 D. L4tter, YYNPC to USNRC (FVY 81-148), dated 10/27/81 <
- a. The measure or standard of reasonable assurance used is the engineering judgment of engineers familiar with the operational characteristics of the plant and the facts.et forth in the response to laterrogatory No. II, above.
- b. The above assertion is not attributed to a formal calculation. It is bened on the high reliability of check valve operation and on the substantial feedwater inventory. It is further noted ti,at, in the above scenario, even if the motor-operated valves were left open, system operating pressure greater than P, can be maintained which will prevent leakage through the inboard and outboard check valves,
- c. No. - See response to (b) above,
- d. No. - See response to (b) above, leterrogatory No.13.
Is it Yermont Yankee's current licensing basis to assume *there would
[be) enough time for the motor operated valves at the discharge of the high pressure feedwater heaters to be closed before there was any escape of containment atmosphere?'
If your answer is affirmative, please provide a specific reference to the ' facility operating license (including Technical Specifications.
Applicable Commission Regulations Certain NRC orders (those amounting to license amendments)[or) Certain licensee commitments *
(quote from Vermont Yankee response to laterrogatory (Set No.1)
No. 6) within your current licensing basis which allows this assump-tion.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
hthe waiving its objection, but rather eapressly relying upon the same, Vermont Yankee offers the following information: please see NRC SER NYY 33-192 (3/19/33), at 4 (item 2).,
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i laterrogatory No.14.
Is it Vermont Yankee's current licensing basis not to assume 's J
feedwater line break (in the same line as FDW-96A)?' If your answer I
is anything other than an unqualified affirmative-I
- a. Please identify your calculation which provides the radiological consequence for this accident with the containment integrity in the "as found* condition described in BYY 89-64 (for the 1989 l
Type A, B and C tests),
- b. If no calculation has been performed which provides the radiological consequence for this accident with the containment f
lategrity in the "as-found* condition described la BVY 39 64 (for the 1989 Type A, B and C tests), please state the radiological consequences of this accident using engineering judgment, i
consistent with the assumptions of Vermont Yankee's current licensing basis.
- c. For the engineering judgment requested in the foregoing sub-part, please provide the technical qualifications (education, employment history, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the quallii-cations of the person) of any person on whose expertise Vermont Yankee relies for such judgment, Objection:
Vm. ont Yankee objects to this interrogatory on the ground that it is not I
reevant to the admitted contention.
Response
i Without waiving the foregoing objection, but tather expressly relying upon the same, Vermont Yankee supplies the following information:
The radiological consequences of a feedwater line break accident are
[
bounded by the design basis steam line break and loss of coolant accidents described in chapter 14 of the FSAR.
leterrogatory No.15.
BYY 89-64 at page 13 of 13 states,
' Vermont Yankee believes that there is reasonable assurance that this penetration [X-9B) will be water sealed after a sesign basis accident.' (emphasis added)
- a. State each and every fact on which your reason is baked. l l
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- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
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- c. For each reason, either provide the technical qualifications (education, employment history, liosases and oortificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the persos), of any peru. on whose empertise Vermont Yankee relies for the reason or state that i
Vermont Yankee does not rely upon the emportise of any person 1
for the reason.
j Objection:
Vermont Yankee obje. e to this interrogatory on the ground that it is not relevant to the admitted contention.
interrogateey No.16.
BVY 89-64 at page 13 of la states, i
' Vermont Yankee believes that there is reasonable assurance that this penetration [X-94 will be water sealed after a design basis accident"(emphasis adoed).
- s. State the measure or standard of ' reasonable assurance
- that j
Vermont Yankee has used to make this statement,
- b. Identify the calculation performed to demonstrate this reasonable assurance.
. c. Has this calculation been reviewed and approved in accordance with YOQAP-I-A,Section III, Design Control? If your answer is affirmative, please state the date of approval and the name of the reviewer and approver.
- d. Has this calculation been submitted to the NRC staff for review?
If your answer is affirmative, please identify the document provided to the NRC staff.
Objection:
Vermont Yankee objects to this laterrogatory on the ground that it is not relevant to the admittes scutention.
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Interrosatory No.17, is it Vermont Yankee's current licersing basis to assume 'this penetration [X-9B] will be water sealed after a design basis accident?'
If your ans uer is affirmative, please provide a specific reference to the " facility operating license (including Technical Specifications, Applicable Commission Regulations, Certain NRC orders (those t
amounting to license amendments)[or) Certain licensee commitments"
-(quote from Vermont Yankee response to laterrogatory (Set No.1)
No. 6) within your current licensing basis whkh allows this assump-tion M ?ctlon:
Ql Vermont Yankee objects to this laterrogatory on the ground that it is not l
relevant to the admitted contention.
Response
Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
Yes. See Letter, USNRC to VYNPC (NYY 83-192), dated 08/19/83.
Interrogatory No.13.
Does Vermont Yankee agree with the following statement
'The Vermont Yankee maintenance program had, as of
' February,1989, failed to maintain and/or determine and replace valve FDW-96A, found not to meet the current licensing basis (by exceeding technical specification 3.7.A.4 leakage lin.its) reported in LER 83-10, and again in LER 84-II, rnd again in LER 85-07; such that FDW-96A was found again in February,1989, not to meet the current licensing -
.i basis (by exceeding technical specification 3.7.A.4) in LER i
89 07."
If your answer is anything other than an unqualified affirmative, then please state every reason for your a awer, and for each reason:
- a. State each and every fact on which your reason is based.
- b. Describe all of the evidence in Vermont Yankee's v tsion or of which Vermont -Yankee has knowledge that V.
'at Yankee contends establishes each such fact.
- c. For each reason, either provide the technical qualifications (education, employment history, licenses and certificates,
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' experience, or other information that Vermont Yankee contends establishes the qualifications of the person). of any person on-whose expertise Vermont Yankee relies for the reason or state that -
- Vermont Yankee does not rely upon the expertise of any person for the reason,
Response
No.. The quoted statement advances the proposition that existence of leakage greater than the technical specification limits is considered a failure to meet the ' current licensing basis,' Vermont Yann
- believes this unusual interpretation of the applicable provisions to be e sus for the reasons set forth in the response to laterrogatory No. 6.
The maintenance history of the subject valve (FDW-96A) clearly shows an aggressive attempt to solve the problems with leak rate failures, in
- =
addition,'in each and every case when leak rate failure occurred the valve i
was repaired and passed retest prior to startup, q
- a. See above.
b See above,
- c. The institutional expertise of Vermont Yankee Nuclear Power Corpora-tion Yankee Atomic Electric Company, Nuclear Services Division, and i
the USNRC (See SER NVY 83-192,8/19/83).
j.
i laterrogatory No.19.
i Nt Vermont Yankee agree that the following statement from LER
. 7 at page 4 of 5 is true?
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'No similar events have been reported to the Commission on CA-8F in the last five years.'
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T wer is anything other than an unqualified affirmative, i
a rtate every reason for your answer.
~ :m..
.aont Yukee objects to this interrogatory on the ground that it is not rekvant to the admitted contention, Respo. se:
W. out waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yan; *. supplies the following information: u l
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No. As we believe SOY to be aware, after the preparation of the LER containing this statement, it was discovered that the most recent failure of u
valve CA-89C was just within the stated five year pe-iod. This was discussed with the NRC Resident laspector, and it was agreed that the 1984 failure would be identified in the 1989 Type A test report. The failure was reported as agreed on page 8 of it of that report.
laterrogatory No. 20.
MVY 89 64 at page 8 of 18 states,
' Vermont Rue does not believe that the leak rate history (of-valve CA-89C} wtrrtatt any further action at this time."
=
- a. Please state each and every reason why Vermont Yankee believes "that the leak rate history [of valve CA-897 warrants [no) further action at this time.'
- b. How many times must CA-89C fail the Type C itakage test before Vermont Yankee believes _*further action'is warranted?
- c. Please state every reason for your answer to the foregoing sub-part.
Response;
- a. As is discussed in the referenced portion of BVY 89-64, valve CA-89C did not pass Type C leak testing requirements in 1984 and again in 1989.
-Vermont Yankee's practice in evaluating occurrences such as this is to-evaluate similar occurrences during the previous five years. Occurrences that may repeat no more frequently than once in five years are generally not considered to be indicative of serious degradation trends or " problem' equipment. The determination that no further action pertaining to CA-89C was necessary after the 1989 test failure was consistent with this practice.
However, as an additional conservative measure, Vermont Yankee has added a planned maintenance item that requires this ' valve to be disassembled and inspected every two outages.
- b. See above.
- c. See above.
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i; Interrogatory No. 21.
Please' state whether - Vermont Yankee believes that calculated radiological consequences of the design basis accident (s) would expeed the limits of 10 CFR Part 100 for the 2-hour site boundary thyroid S-l and whole body doses using the following assumptions:
4 (1) TID-14344 fission product release fractions, m-i' (2) Standby gas system filter efficiency of 90% for halogens,95% for particulates.
(3) Loss of offsite power, i
(4) The worst effect single failure.
(5) Design Basis Earthquake, with failure of equipment and structures consistent with Vermont Yankee's current licensing basis.
(6) The "as-found" 1989 containment leakage rates (assuming no credit for isolation of the leakage from FDW-96A and assuming the worst effect single failure on the containment isolation function).
Type A leaka8e - 0.531%/ day Type B leakage - 0.15 %/ day Type C leakage -
FDW-%A Could not pressurize LRW-83 10 lbm/hr LRW-94 0.856 lbm/hr LRW-95 5.33 lbm/hr CA-89C Could not pressurize PCAC-6, -7, -6A, -6B; -7 A, -7B
> 25.12 lbm/hr PCAC-8, -9, - 10, -23 3.295 lbm/hr Other valves per BVY 89-64, Appendix C (7) Other assumptions consistent with Vermont Yankee's-current licensing basis.
If your answer is anything other than an unqualified affirmative, then -
please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based.
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that. Vermont Yankee contends establishes each such fact, h
- c. For each reason, either provide the technical qualifications (education, employment history, licenses - and certificates,
- f. :
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! 1 experience, or other informatihn 'that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rek apon the expertise of any person :
for the reason.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention, and on the further ground that it is not relevant to any licensing issue, for the reasons set forth below.
x
Response
Without waiving the foregoing objection, but rather expressly relying
- upon the same, Vermont Yankee supplies the following information:
This quest' ion seems to be asking for the radiological resul s of a design t
basis LOCA, combined with: multiple failures, anu with types B and C leakage results being added to the type A results. No such analysis is required nor has one been performed. Types A, B, and C leak rates are not; additive.- (See letter USNRC to VYNPC dated 6/16/37.) The type A test result is the integrated leakage result for the containment. EVY 89-64 calculated an "as-found* integrated leakage rate for the 1989 test based on.
repair work ' performed to penetrations and valves prior to the type A test.
The result was an 'as-found" leakage of.571%/ day, which is well below the
' leakage rate of 1.5%/ day, which.has been determined to meet the 10 CFR 100 dose criteria. See the response to Interrogatory No. 3, above, laterrogatory No. 22.
In the foregoing interrogatory, does Vermont Yankee believe that any of the assumptions (1) through (7) are not part of, or are not consis-tent with, the current licensing basis? If the answer is affirmative:
- a. Please state each assumption that Vermont Yankee believes is not part of, or not consistent with, the current licensing basis, b.' Please describe the ressor why Vermont Yankee believes each stated assumption is not part of, or not consistent with, the current licensing basis.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention... _. _
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laterrogatory No. 23..
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Each of the solenoid valves for isolation valves PCAC-6,'-7, -6A, -
f, : ~
6B, -7A,-78 -8, -9, -10 and -23 are indicated with the designation, i
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'VAC-A, CKT-12' on drawing G-191175, sheet I of 2.
- a. Does the designation 'YAC-A, CKT-12* mean that all of the
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solenoid valves for isolation valves PCAC-6, -7, -6 A, -6B, -7 A -
78, -8, 10 and -23 are on the same circult?
t
- b. If your answer to the foregoing sub-part is affirmative, does 6
choosing the assumed single failure to be 'not developing the 3
containment isolation signal in this 'same circuit'* alter your response to the foregoing interrogatory?,
- c. Please state every reason for your response to the foregoing sub-part.
Objection:'
-t Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention, j
Response
.Without waiving the foregoing objection,.but rather expressly relying l~
- upon the same, Vermont Yankee supplies the following information:
a.
The designation, if it were correct, would mean that all the sobject valves are powered from the same circuit.. However, upon review of this information, it was determined that this drawing (G-191175) is in error.
The applicable control wiring diagrams show;that power is provided to PCAC-6, -7, -9 and -23 from the vital AC bus, VAC-A CKTel2, and PCAC-6A, -6B, -7A, -7B, -8 and -10 are powered from the instrument
' AC bus, CRP 9-46, CKTs44. ' Actual wiring is lastalled in accordance 1
with the control wiring diagrams and one line wiring diagrams. The subject drawing (G-191175) is typically'used for information only and any design change or diagnostic wiring reviews would be done using the conol wiring diagrams. A drawing change is being made to Dws. G-191175 to reflect the actual condition,
- b. No response required.
- c. No response required.
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.leterrogatory No. 24.
Does Vermont Yankee agree with the following statement:-
j The Vermont Yankee maintenance program failed to maintain and/or determine and replace PCAC exhaust valves (penetration
?.
X-25), which were found to have aged to a point where they no longer met the safety standards applicable to Vermont Yankee in.
1987 by-exceeding the allowable leakage rate in technical specification 3.7.A 4, such that these name valves failed again in 1939 to meet the safety standards by exceeding the allowable leakage rate in technical specification 3.7.A 4 as stated in BYY-39-64,'the total penetration leakage could not be measured with-onsite testing equipment... the root cause of the torn seats-revealed that the damage was due to normal wear." (emphasis added).
s
' If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based.
' b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont-Yankee contends establishes each such fact.
- c.. For each reason, either provide the technical qualifications (education, employment ' history, licenses. and certificates, experience, or cther information that Vermont Yankee contends establishes the qualifications of the person), of any: person on j
whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
1' Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not
. relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying.
upon the same, Vermont Yankee supplies the following information:
The quoted statement is false. First, the included premise, that the
'i existence of leakage greater than the technical specification limits is con-sidered a failure to meet the
- current licensing basis,* is erroneous for the reasons set forth above in response to Interrogatory No. 6.
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!j The quoted statement is also false because it is based on inaccurate and
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- distorted accounting of the facts of record. The maintenance history of the :
' subject PCAC valves (penetration X-25) clearly shows an aggressive attempt -
A to solve the problems with leak rate failures. In addition, in each and every
-1 case when leak rate failure occurred the valve was repaired and passed retest prior to startup. As stated in the 1989 Primary Containment Laakage Rate Testing Report (Attachment to BVY 89-64), the PCAC system exhaust line is comprised of sin valves tested as a group. In 1987..the failure was
' attributed to PCAC-6 and PCAC-7 disc to disc seat misalisament. The 1989 ~
failure was caused by ' damage due to normal wear' of valve seats on two..
other valves (PCAC-6A and PCAC-6B) and a packing leak on a third valve n
(PCAC-7A). Thus, the implication in this question that.*the same valves failed again" is false and is shown to be so by the very document SOY cites.
Further, Vermont Yankee's maintenance program detected these problems -
took corrective action and the valves have passed retest. Beyond that, on account of Vermont Yankee's conservative decision-making and its commit-1 ment to safety, it went beyond the simple repair and retest of the com-ponent: and further committed to the " development of a preventative maintenance schedule for replacing the seats?
Finally, we note that the matters Jn question had nothing to do with
' aging?
laterrogatory No. 25.
Please describe in detail the ' plans to develop a preventive main-tenance schedule for replacing the seats (of the PCAC exhaust valves)"
t (quoted from BVY 89 64 at page 9 of 18).
- j
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Response
The commitment to develop the plan in question calls for a due date of l
11/15/90.
j laterrogatory No. 26.
For malotenance on the PCAC eahaust valves:
- a. Picase identify by Maintenance Request number and date all i
maintenance yrformed on these valves since February 1989.
- b. Please state which,if any, of the maintenance activities identified in the foregoing sub-part included replacing the valve seats.
e Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
03/23/89-MR 89-1102 SB16-19-6A Replaced Sest 03/23/89 MR 89-1103 SB16-19-6B Replaced Seat 03/23/89 MR 89-1104 SB16-19-7A 03/25/89 MR 89-1320 SB16-19 78 03/27/89 MR 89-1333 SB16-19-1l A 1
03/28/89 MR 89. I195 SB16-19-8 Replaced Seat 03/28/89 MR 39-0992 SB16-19-9 laterrogatory No. 2",
Does Vermont Yankee agree with the following statement:
'The Vermont Yankee maintenance program failed to maintain and/or determine and replace containment isolation valves LRW-
- 83, -94, -95, which were und to have aged to a point where they no longer met the sale.y standards applicable to Vermont Yankee in 1987 by exceeding the allowable leakage rate in technical specification 3.7.A.4, such that these same valves failed again in 1989 to meet the safety standards by exceeding the allowable leakage rate in technical specification 3.7.A.4 with the stated root cause identified in BVY 89-64 as,' wear of the seating surface [over time) resulted in the increased leakage."
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on tvhich your reason is based,
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
- . For each reason, either provide the technical qualifications (education, employment history, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.,
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~ Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not l-
' relevant to the admitted contention.
Response:-
Without waiving the foregoing objection, but rather expressly relying
)
upon the same, Vermont Yankee supplies the following information:
1 The quoted statement is false. First, the included premise, that the existence of leakage greater than the technical specification limits is con-sidered a failure to meet the ' current licensing basis,' is erroneous for the reasons set forth above in response to Interrogatory No. 6.
The maintenance history of the subject valves (LRW-83, -94, -95) clearly shows an aggressive attempt to solve the problems with leak rate failures, in addition, in each and every case when leak rate failure occurred the valve was repaired and passed retest prior to startup.-
4 As SOV is aware, and as is stated in the 1989 Leak' Rate Test Report.
l
'The leak rate history on these valves, prior to 1987, was excellent.' Also VY further committed to additional efforts "to improve this penetrations leak tightness." The disecvery through surveillance of this problem, the subse-quent repair and successful retest, and the commitment to the NRC to take additional steps in this area are examples of efforts that show, contrary to the' SOY assertion, the program at VY has succeeded and further that VY is committed to ensure that this will continue in the future.
' Interrogatory No. 28.
Please describe in detail all ' additional action [sf taken "to improve this penetrat. ion's [ sic - this refers to penetrations X-18 and X-19]
reliability"(quoted from BVY 89-64 at page 8 of 18).
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
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t Duilng the 1939 outage, the three subject valves (LRW-g3, LRW-94 and
- LRW-95) were refurbished and successfully retested. To further improve reliability of this penetration, Vermont Yankee plans to modify or recon -
figure or replace hardware during the 1992 refueling outage.
laterrogatory No. 29.
Please state' the date of each " additional action
- descilbed in the foregoing interrogatory.
Objection:
. Vermont Yankee objects to this interrogatory on the ' ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
Please see the response to the foregoing interrogatory.
Interrogatory No. 30.
Does Vermont Yankee agree with the following statement:
"The Vermont Yankee maintenance program failed to maintain and/or determine and replace containment isolation valves PCAC-g, -9. -10 and -23 (penetration X-26) which were found to have aged to a point where they no longer met the safety standards applicable to Vermont Yankee in 1937 by exceeding the allowable leakage rate in technical specification 3.7.A.4, such that these same valves failed again in 1989 to meet the safety standards by exceeding the allowable leakage rate in technical specification 3.7 A.4 by a greater amount."
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based.
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
- c. For each reason, either provide the technical qualifications (education, employment history', licenses and > certificates, experience, or other information that Vermont Yankee contends
6 establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
Objection:
. Vermont Yankee objects to this interrogatory on the ground that it is not 4 relevant to the admitted contention.
Response
Without walving the foregoing objection, but rather expressly relying-upon the same, Vermont Yankee supplies the following information:
The quoted statement is false. First, the included premise,'that the existence of leakage greater than the technical specification limits is con-sidered a failure to meet the " current licensing basis,' is erroneous for the.
reasons set forth above in response to laterrogatory No. 6.
The maintenance history of the subject valves clearly shows an aggressive attempt to solve the problems with leak rate failures. In addition, in each and every case when leak rate failure occurred the valve was repaired and -
passed retest prior to startup.
Moreover, in 1987,'the root cause of the failure was determined to be misalignment of the disc to disc seat on... PCAC-8.' In 1989, the root cause was identified to be " excessive seat leakage through.. PCAC-8. The investigation into the root cause revealed that the seating material was.
damaged." A new seat was placed in the valve in 9/5/87 using the manufac-turers authorized replacement parts. See the response to laterrogatory No. 33.
The change in seating material was the cause of the failure of the valves' new
. seats to last even one cycle. Since the seats that were leakir.3 were new, VY -
cannot agree with the SOY false assertion that these valves "were found to
. have aged to a point where they no longer met the safety standards appil-cable....' The VY maintenance program.was successful in determining that seat leakage existed, replacing the valve seats and further looking for the root cause of the problem to ensure appropriate corrective action was taken. This history, which is fully explained in BVY 89-64, abows that, contrary to SOV's assertion, VY's maintenance program has been very -
effective.
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'i Interrogatory No. 31.
Does Vermont Yankee agree with the following statement::
]
iThe root cause of the leakage [from valve PCAC-8]' revealed that i
E the sealing material was changed [by cr as a result of the Vermont a
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Yankee Maintenance Program)
The new-unsterial (was) a synthetic material which [was] not as soft or pliable as the previously installed seats.- This result (ed) in a less effective seal to resist leakage?
If your answer is anything other than an unqualified affirmativa, then please state every reason for your answer, and for each reason:
.i
- a. State each and every fact on which your reason is based, I
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee j
i contends establishes each such fact,
- c. For each reason, either provide the technical qualifications
~
(education. employment. history, licenses and. certificates,-
experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that
- Vermont Yankee does not rely upon the expertise of any person for the reason.
l
.0bjection:
' Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
.Without waiving the foregoing objection, but rather expressly relying
.upon the same, Vermont Yankee supplies the following information:
1 VY recognizes-this quote to be from the discussion regarding X PCAC, see pg. 9 of 13 of the Primary Containment 14akage Rate-Testing
- 1989 report, an attachment to BVY 89 64. Vermont Yankee agrees that the i
statements made in the original language of the report were true at the time
. the report was written and, to the extent we are aware, are still true. How-ever, a comparison of SOV's edited version of the statements and the facts, which are set forth in the response to Interrogatory No. 30, reveals how SOY has distorted the statements contained in the report, and obviously we do not agree with the message conveyed by the editorially distorted rendition.
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n Please identify by number and date all Maistenance Requests which allowed vaplacias the sosting an.orial of valve PCAC-8 with a asw l
- synthetic material which is not as soft or 4diable as the ansviously installed seau' Objection:
Varmant Yankee objects ID eis Jasseressenryan As gensadilhet h haot i
selevant to theadmitted contention.
Rerpense:
Without waiving the foregoing objection, but rather expressly relying' spon the same, Vermont Yankee supplies the following information:
No maintenance request " allowed vaplacing the seat'mgmaterial of vahe PCAC-3 with a new
- synthetic material which is not as soft or pliable as the previously i===tW seats." Twomaintenance vagoests callui for the replace-ment of aests with DEM-absmined parts that turned aut so cause the problem.
They were; 07/03/84 MR 84-1009 09/05/87 MR 87-1954 s.s n.,
Did Vermont Yankee receive concurrence for the vendor of valve 7CAC-8 prier to (orWar) veplacens the nestm3 insteral of valve-PCAC-8 with a new " synthetic sentarial which is not as soft or pliable as the previously installed seats?"
06Jswien:
.r Vermont Yankee objects to this interrogatory on the groand that it is not h
relevant to the admitted contention.
Response
Without waiving the foregoing djection, but anther espressly relying upon the same, Vermont Yankee supplies the following information-70ssse see the response ao Interrogstory No.~32. The crishmal equipment
- saanufacturer supplied all spare valve 1 posts for repair sad replacement of the PCAC valve seats with a Certificate of Comphance that the iteses supplied to 2
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I VY were equivalent to or a direct replacement for the original equipment j
L-previously provided.
laterrogatory No. 34.
If the answer to the foregoing interrogatory is negative, does Vermont Yankee agree that the replacement of the seating material of valve PCAC-3 with a new
- synthetic material which is not as soft or pliable as the previously installed seats" is an example of an instance where YYNPS did not have "the qualifications and expertise within its staff to make [this) type of assessment...* (quoted from Vermont Yankee response to Interrogatory (Set No.1) No. 53, sub-part b).
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
lL
- a. State each and every fact on which your reason is based.
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yanna has knowledge that Vermont Yankee contends establishes each such fact.
- c. For each. reason, either provide-the technical qualifications (education, employment history. licenses and certificates, i
j experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for th reason or state that Vermont Yankee does not rely upon the expertise of any person
.y for the reason.
Response
ti e
No answer is required by the terms of the interrogatory.
Interrogatory No. 35.
4 Does Vermont Yankee agree that'the failure of valve PCAC-g to maintain containment integrity: within the limits of technical specification 3.7.A.4 due to replacement of the seating material of
. valve PCAC-8 with a new
- synthetic material which is not as soft or pliable as the previously installed seats," is an example in which an i
action of the maintenance program caused a condition to occur in which the seating material of valve PCAC-g was found to have aged to a point where it no longer met the safety standards (due to exceeding technical specification 3.7.A.4 leakage rate) of the Vermont Yankee plant?
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based.
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- b. Describe all of the evidence in Vermont Yankee's possession or of 4
which Vermont Yankee has knowledge that Vermont Yankee
. contends establishes each such fact.
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- c. For each reason, either provide the technical qualifications (education, employment history, liosases and certificates, esperience, or other information that Vermont Yankee contends-1 establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason, i
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not F
relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying -
w upon the same, Vermont Yankee supplies the following information:
n No.. Please see our response to laterrogatory No. 6, which demonstrates that no Technical Specification provision was violated, in addition, as stated in the Primary Containment Leakage Testing 1989 Report (attachment to BVY 89-64), ?For this penetration, a containment isolation valve, in both I
potential leak paths, had leakage less [than) that allowed." Please also see our response to Interrogatory No. 30, which shows both that the 'cause" of matter in question was dehors the maintenance program,'as well as that the subject
-in question has nothing to do with aging. Therefore, the statement in the interrogatory is false, and we do not agree with it.
Interrogatory No.' 36.
Please describe in detail the " plans to access the availability of-returning to the previously installed seats or developing a preventive.
1" maintenance schedule using new seats [for the PCAC-8 valveT (quoted from BVY 89-64 at page 10 of 18).
Objection:
Vermont Yankee objects to this interrogatory on the grourid that it is not relevant to the admitted contention.
s
Response
Without waiving the foregoing objection, but rather expressly relying _
upon the same, Vermont Yankee supplies the following information:
Please see the response to Interrogatory No. 25.
Interrogatory No. 37.
l For maintenance on the PCAC-7 valve:
. a. Please identify by Maintenance Request number and date all maintenance performed on this valve since February 1989.;
f
- b. Please state which,if any, of the maintenance activities identified.
in the foregoing sub-part included replacing the valve seats.
Cbjection:'
1 Vermont Yankee objects to this interrogatory on the stround that it is not relevant to the admittec contention.
Response
L
.Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
03/23/89:
MR 89-1195 Seat Replacement leterrogatory No. 33.
l Please describe in detall.the ' staffing history of the maintenance i
department from 1972 to the present date. The description should L
include, but not be limited to, identification of the following for each and every major organisational element of the maintenance depart-ment (e.g., instrumentation & control, electrical, mechanical, etc.):
- a.. Average annual total number of personnel, including Vermont Yankee employees and contractors; l
- b. Average annual number of Vermont Yankee managerial and supervisory personnel;
- c. Average annual number of contractor personnel; and
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- d. Average annual number of other personnel, if any, who per-formed plant equipment maintenance, repair, replacement or-
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installation.
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Response
Please see Attachment 38-1.
Interrogatory No. 39.
Please describe in detail the staffing history of the technical services department from 1972 to the present date. The description should include, but not be limited to, identification of the following:
.m
- a. Average annual total number of personnel, including Vermont Yankee employees and contractors; b.- Average annual number of' Vermont Yankee managerial and supervisory personnel; and i
- c. - Average annual number of contractor personnel.
x
- Response:
{
- Please see Attachment 39-1. Please note that Vermont Yankee has no
' Technical Services Department? We have, however, interpreted this inter-
- rogatory to be seeking information reearding the staffing history of the
~
Engineering Support Department, and have provided such information on
- 9-l.
laterrogatory No. 40.
i h
Please describe in detail the amount of; relevant job experience possessed by each and every person in the maintenance and technical service departments. The description should include, but not be limited to,' the following for each and every person:
5 e
- a. Total years of relevant work experience;
- b. Total years of experience at commercial nuclear power plants;
- c. Total years of experience at Vermont Yankee;.
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- d. Total years in current position; and l'
- e. Anticipated retirement date.
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Response
Please see Attachment 40-1.
laterrogatory No. 41.
j Please - describe in ' detall Vermont Yankee's qualification and
- experience requirements for each and every position in the main-tenance and technical services departments.
Response
4 This question is duplicative of SOY laterrogatories (Set No.1) Nos. 2,3 and 4. This information can be derived from a review of job descriptions that have already been provided to SOY, laterrogatory No. 42.
l t
Please describe in detail Vermont Yankee's plans to maintain its
- desired experience level for each and every position in the main-tenance and technical service departments from now through the i
extended period.
Response
l Vermont Yankee will maintain the desired experience levels in the maintenance and engineering support departments now and in the extended period in several ways. This is and will be primarily done by maintaining competitive compensation programs with comparable industries and within the local community. This includes salary, bonuses and benefits, including health insurance, veestion, holiday and sick leave and retirement benefits.
in addition, training programs are adjusted as changes occur in the regulatory 7
requirements, technology, recruiting needs and the nature of the labor pool
}
available. These approaches have been successful in a6tintaining the desired experience levels in the past and are expected to produce the same result in the future. Please see also the response to laterrogatory No. 65(a), below, laterrogatory No. 43.
Please identify each and every documentation of Vermont Yankee's plans to maintain its desired experience level for each and every-position in the maintenance and technical service departments from now through the extended period.
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Response
. The subject plans are contained in the Vermont Yankee Nuclear Power c
Corporation planning document " Strategies for the-Future,'Section VI
(* Personnel").
laterrogatory No. 44.-
Does Vermont Yankee ' agree that limiting conditions of operation (LCO's) are not a current licensing basis, but rather LCO's are the lowest functional capability or performance levels of equipment required for safe operation of the facility such that when an LCO is not met the licensee shall shut down the reactor 7
+
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which you' reason is based; and r
= b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
- c. For each reason, either provide the technical qualifications (education, ~ employment history, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
Objection:
' Vermo a Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Re ponse:
s Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
The statement in the laterrogatory with which agreement or disagreement is invited is erroneous in two tespects. First, the truncation of the para-phrased language from'10 C.F.R. i 50.36(cXIXiiXbX2) erroneously posits that the'only option when an LCO is not met is to shut down the reactor. The actual prescription of the regulation is in these terms:,
i.
r L
' Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear -
reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition con be met.'
Second, the distinction between an LCO and the ' licensing basis
- that this V
question posits is also false. As set forth in our response to laterrogatory (Set No.1) No. 6, it)he YYNPS licensing basis is the set of requirements established by the following sources: Facility Operating License (including -
Technical Specifications)...." LCO's are contained in (and imposed by) the Technical Specifications, and therefore they constitute an integral part of the licensing basis.
laterrogatory No. 45.
Please describe in detail each and every reason why corrosion has been discovered during periodic inspections of the torus and drywell if inerting of tb i containment does, in fact, preclude the ' corrosion process during most circumstances' as asserted by Vermont Yankee in -
its response to Vermont Interrogatory (Set No.1) No. 94. The description should include, but not be limited to, identification of the following:
- a. Each and every reason for drywell and torus corrosion;
- b. Each and every document that defines the design basis and allowable limits for drywell and torus corrosion rate (s); and
- c. Each and every document that compares the actually observed drywell and torus corrosion rate (s) with the design corrosion
. rate (s).
Response
- a. Inerting of the containment with nitrogen does preclude the corrosion
= process during most circumstances, since oxygen is a needed lagredient in the oxidation or corrosion process. - However, the containment is not always inerted. An example of when the containment is not inerted is during refueling, when the nitrogen atmosphere is purged and replaced by air to facilitate refueling and in-containment maintenance activities.
During this time, and without any other mechanisms to preclude corrosion, containment atmospheric conditions would permit corrosion to occur, especially in the torus where a humid atmosphere exists. -During de-inerted conditions, corrosion of the containment shellis inhibited by the zine primer coating, which has been determined to provide excellent corrosion protection. Some very minor " spot corrosion" has been observed i i
E
-in the torus, and_these spots are the areas that Vermont Yankee has -
- maintained by preparation and touch-up with a aine-rich epoxy coating.
- b. There are no explicit corrosion rate allowances for the Vermont Yankee containment shell, due to the fact that it was designed to be coated.
.t Original General Electric Specifications 21 A5837 and 22Al l 82 verify this fact. Continued maintenance of the inorganic ainc primer is sufficient to preserve the wall thickness of the containment.
- c. Due to the fact that there is no explicit design corrosion rates for the Vermont Yankee containment, and the fact that corrosion has not been a i
problem at Vermont Yankee, there are no documents that compare the observed drywell and torus corrosion rates with the design corrosion rates.
Interrogatory No. 46.
Please describe in detail each and every documentation of Vermont Yankee 'following the efforts of EPRI' as asserted in Vermont Yankee's response to Vermont laterrogatory (Set No.1) No.105. The description should include, but not be limited to, identification of the following:
a.- Each and every individualinvolved;
- b. Each and every document produced; and
- c. Each and every method by which "significant aging mechanisms" were determined by following EPRI efforts.
Response
The VY Principal Engineer (H,-Metell) has the lead responsibility in following the EPRI work efforts mentioned above, and has been involved with the following individuals in this effort Maintenance Supervisor, VY' R. Lopriore Reactor and Computer Supervisor, VY B. Buteau Instrument and Control Supervisor, VY T. Watson.
Acting Engineering Support Supervisor, VY '
D. Phillips Plant Services Supervisor, VY-M. Varno Operations Supervisor, VY J. Herron Technical Services Superintendent, VY R. Pagodin Operations Superintendent, VY R. Wanczyk Vice President, Engineering, VY J. Pelletier Operations Support Manager, VY R. Sojka Information Systems Manager, VY S. Schreiner
.r'.
Plant Manager, VY
~
^
D. Reid W. Daley
- Director of Financial Analysis, Planning,~ VY J. Haseltine ~ Project Manager - License Renewal YSND Assistant Project Manager - License Renewal YSND W. Hinkle -
i-J. McCumber - License Renewal Engineering Manager, YNSD Imad Engineer Evaluations, YNSD L R. McCoy Nuclear Power Division - Industry Report Manager, R. Burke -
EPRI Chairman of the BWROG PLEX Committee, GPU J. Chardos Nuclear R. McNamara - BWROG PLEX Member, SPLEX Project Manager, Susquehanna BWROG PLEX Secretary / Member, General Electric M. Herrara
LWR Plant Life Extension, January,- 1987.
NP5002 BWR Pilot Plant Life Extension, May,1987.
NP5181-M BWR Pilot Plant Life Extension,' May,1987.-
NP5181-SP,1 NP5836-M Monticello BWR Life Extension Study Phase 2: Interim, October,1988.
PLEX Project Briefs, October,1988.
NP5388SP, R1 Plant Life Extension Study at Surry Unit 1 NP5289P July,1987.
Monticello BWR Life Extension Study Phase NP6541-SD,V3 2: Interim,- September 1989.
Monticello BWR Life Extension Study Phase
' NP6541-SD,V2 2: Interim, September 1989.
Monticello BWR Life Extension Study Phe:e1
- NP6541-M 2: Interim, September 1989.
Documents produced by Vermont Yankee in following the EPRI effort are as follows:
Vermont Yankee PLEX Plan,5/1/90.
Letter, Comments to BWR Containment Industry Report, Metell to Cozens, 5/11/90.
Letter, Comments to BWR ~ Primary Pressure Boundary Industry.
Report, Metell to Hinkle,6/18/90.
- c. EPRI License Renewal efforts provide information on significant aging mechanisms by publishing reports, supporting meetings, and answering questions via telecons. The VY Principal Engineer has reviewed the 33 -
1 I
t
. above-mentioned reports, attended meetings, and discussed issues relative -
to aging via telecon/ meetings with the above-mentioned personnel.
Interrogatory No. 47.
Please describe in detail each ar.J every example that demonstrates
. Vermont Yankee established the significance' of degradation byl evaluating 'the rate of degradation' as asserted in Vermont Yankee's response to Vermont Interrogatory (Set No.1) No.106. The descrip-tion should-include, but not be limited to, identification of the
'l following:
- s. Each and every individual involved;
)
- b. Each and every document produced; and
- c. Each and every method by which the rate of degradation was t
l.
evaluated by Vermont Yankee.
- Response:
L
' In response to SOY interrogatory (Set No.1) No.106.. Vermont Yankee stated that each case where ' age related* degradation (or any degradation) is observed, response and evaluation is on a case by case basis. The specifics of such evaluations are dispositioned and may be founa vm O Maintenance Request process or via the trending program as defined in AP 0200, both of which have previously. been made available for SOV's inspection. Some recent examples where the rate of degradation-not necessarily age-related degradation-was evaluated and caused some modification to the maintenance i
requirements of a particular component are:
l CA-89C (see the response to Interrogatory No. 20).
+
125 VDC Station Battery replacement.-
Establishment of shorter surveillance intervals for Scram Solenoid -
Valves.
l
- .Recire pipe IGSCC crack propagation evaluation.
Interrogatory No. 43.
. Vermont Yankee states, in part, in its response to Vermont Inter-rogatory (Set No.1) No.106 that aging mechanisms could "be significant from a safety perspective
- and " Typically, aging mechan-isms have not been determined to be significant from this perspec-tive...." Please describe in detail each'and every example that demonstrates Vermont Yankee determined aging mechanisms were not a !
f
r i
significant from a safety perspective. The description should include,
+
but not be limited to, identification of the following:
- a. - Each and every individual involved; b.'
Each and every document produced; and q-
- c. Each and every methsd by which aging mechanisms were evaluated by Vermont Yankee.
Response
SOY has distorted the statements made by VY in the response to Interrogatory (Set No.1) No.106 What we said was:
" Typically, aging mechanisms have not been determined significant from [a safety) perspective because of the ability of regular inspec-tion, surveillance, and maintenance programs to detect and correct such effects.*
(Emphasis added.) The evidente that exists to show this statement to be true is the ability of Vi continually to meet the requirements for system and component operability set forth in the VYNPS Technical Specifications, laterrogatory No. 49.
Vermont Yankee States, in part, in its response to Vermont Inter-rogatory (Set No.1) No.106 that 'An aging mechanism can also be significant from the perspective of cost...." Please describe in detail each and every example that demonstrates the cost significance of_
aging mechanisms. The description should include, but not be limited to, identification of the following:
- a. Each and every documentation of aging mechanism cost; and
- b. Each and every method by which aging.aechanism ' cost is determined.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not -
relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
rJ k
Y This statement was made to indicate that in some cases the evaluation of an t3ing mechanism for a particular component may lead to the conclusion that increased inspection or maintenance is= warranted. This increased' attention by the maintenance department may lead management to conclude that it would be more cost beneficial to replace the component in question.
rather than implement the augmented inspection and maintenance recommen-dation. A similar decision may be made with regard to ALARA. It may be more beneficial, from an'ALARA standpoint, to replace a component than to implement any new maintenance requirementa. Specifics of evaluations performed for any degradation of specific components can be found by -
looking at the individual MR's and/or the trend reports per AP 0200, both of which have previously been made available for SOV's inspection.
laterrogatory No. 50.
Please descritte in detail each and every reason why Vermont Yankee asserts in its answer to Vermont Interrogatory (Set No.1) No.110 there will be a "high degree of confidence" that the primary contain-ment has the ability to meet its design basis requirements. For each reason, please describe:
- a. Each and every fact upon which your reasons are based;
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes.
each such fact; and
- c. Either the technical qualifications (education. employment history, licenses and certificates, experience; or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
Objecilon:
Vermont Yankee objects to this interrogaton on the ground that it is not relevant to the admitted contention.
Interrogatory No. 51.
Please describe in detail what Vermont Yankee means by? essentially precluded" in its response to Vermont Interrogatory (Set No.1) No.
110 with regard to potential oxidation of the containment / surface.
The description should include, but not be limited to, identification of the following:
- a. Each and every fact upon which your statement is based; 43
d I
i
.j 0
- b. The eatent to which your statement applies to interict and exterior
-l surfaces of the primary containment; and -
-Yankee has knowledge that Vermont Yankee believes establishes each such fact.
j Objection:
U Insofar as this interrogatory refers to " exterior surfaces of the primary j
' containment,' Yermont Yankee objects to the interrogatory on the ground L
that it is beyond the scope of the admitted contention.
l
Response
s Insofar as this interrogatory refers te " interior surfaces of the primary containment,' please see the response to Interrogatory No. 45.
Interrogatory No. $2.
{
Vermont Yankee asserts in its response to Vermont laterrogatory (Set r
1 No.1) No.110 that the decision not to reapply topeost material over the inorganic sinc primer was appropriate,
- s. Please describe in detail each and every reason that demonstrates
?
-- this decision was appropriate;
~
b Please identify each and every individual involved in the decision;
- c. Plear identify each and every document produced concerning the t
_dec on;
- d. Please describe each and every basis for deciding not to reapply topcoat material; and
- e. Please describe each and every criterion used to determine if 4;
. reapplication of either primer or topcoat material will be required at a future date.
J i
Response
- a. The decision not to re-apply topcoat was based upon the conclusion that the existing inorganic sinc primer has provided and continues to provide -
3 adequate corrosion protection for containment surfaces dtring times that -
the containment is susceptible to corrosion effects (de-inerted condition),
and that a new topeost was not needed to maintain this capability.
k.
i
+
ll i
it
. b. The recommendation to not re-apply topcoat over the inorganic sinc?
primer was made by the following individuals at Yankee Atomic Electric.
2 Company: L.A. Tremblay, Senior Engineer; C.H. Hansen, Senior Engl-neer; D.E. Yasi,- Lead Systems Engineer;< J.K. Thayer, Engineering
' Manager; and S. Miller, Project Manager. Engineers at Yarkee Atomic ~
i were assisted in making this recommendation by R. Martia,~ Stone and Webster Coatings Specialist. The recommendation was accm'ed by D.K.'
McElwee, Engineering Program Manager, VYNPC, and was approved by '
D.A. Reid. Operations Support Manager, VYNPC.
- c. The following documents were produced concerning this decision:
l l
5'
- Memo, VYS 32/89, Tremblay to Miller, dated March 31,1989
}
- Memo, OPYY 250/89, Smith to Reid, dated April 5,1989 l
- Memo, VYB 39/165, McElwee to Miller, dated April 6,1989
(
,t
- d. See answer (a) above
- c. Insofar as this sub-part assumes that there is a presently existing set of.
criteria by which it will be determined in the future to reapply the topcoat 4
that has been determined not to be necessary, it is in error. With respect to ;
primer, the criterion that is expected to be used in the future is whether upon evaluation reapplication of primer is required in order to maintain the degree q
of corrosion protection provided by the existing primer.
1 i
Interrogatory No,53.
an
~
Does Vermont Yankee assert that its' evaluation of the effects of drywell paint degradation discovered in the 1989 refueling outage
- 1 conforms with the following:-
?The available interceptor area used in determining the design s
coolant velocity should conservatively account for blockage that may result." (quoted, but not interpreted as regulatory minima, i
from NRC Regulatory Guide 1,32 [ sic, for "I.32*), Rev.1," Water Sources for Long-term Recirculation Cooling Following a Loss-of-Cooling Accident")
q If your answer is anything other C,an an unqualified negative, then.
please state every reason why Vermont Yankee asserts its evaluation '
- is conservative, and for each reason:
- a. State each and every fact on which your reason is based; 4
- t t
. ~ - -.. -.
. ~... - - -. - - - -.. - -. _ -__- -
t 1
)
i
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee e
contends establishes each such fact; and -
- c. State either the technical qualifications (education, employment i
history, licenses and certificates, emperience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies f
for the reason or state that Vermont Yankee does not rely upon the empertise of any person for the reason.
Objection:
Vermont Yankee objects to this laterrogatory, on the ground that it is not relevant to the admitted contention.
Response
Without waiving the fores Ang objection, but rather empressly relytrig 3
upon the same, Vermant Yankee supplies the following information:
Yes, Vermont Yankee agrees that its evaluation conforms with the quoted assertion.
i
- n. The General Electric evaluation cf potential fibrous insulation debris I
(GE-VY. A6008,1/22/86) was performed utilising the gulcance provided in l
Regulatory Guide 1.82, Revision 1. This fact is stated on the very first page of the General Electric evaluation. YAEC Report 1696, which constitutes VY's Containment Paint evaluation, utilises the General Electric evaluation and expands upon it by considering the amount of NPSH marsia available at i
the ECCS suction strainers (* interceptors *) beyond that which is lost by p
blockage from the conservatively postulated amount of fibrous insulation-from the General Electric evaluation. Thus, Regulatory Guide 1.82, Revision I, criteria were utill ed to ensure that ECCS suction strainers (' interceptors')
are sised for the postulated blockage that may result.
- b. The 1939 peint evaluation effort h fully summarland in YAEC Report 1696, which has previously been provided to SOV.
l c, Messrv. Hansen, Tremblay and Yasi, identified in the response to later-rogatory (Set No.1) No. 77.
t 44 I
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__m____., _ __._ _ _____.__ ________ __ -,
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i laterregalery No. $4.
Vermont Yankee states, in part, in its response to Vermont later-togatory ($et No.1) No. Iil that the ' probability of significant paint chip transport to the ECCS svetion trainers in the torus is very low'.
- a. Please describe each and every reason why Versomt Yankee so states; i
- b. Please describe all of the evidemoe la Vermont Yankee's posesenion or of which Vermont Yankee has knowledge that Verssor.t Yankee believes establishes the probability of that event; j
- c. Please describe each and every calculation regarding the sig-
+
i nificance of paint chip transport to the ECCS suction strainers;
- d. Please describe each and every technical and quantitative bases (sic] for concluding such probability is very low; and
- e. - Please describe the potential consequences of significant paint chip i
transport, either alone or in combination with other potential debris, to the ECCS svetion strainers.
Response
The answers to this Interrogatory are discussed in detailin YAEC Report 1696, which has previously been provided to SOY.
i laterrogatory No. 85.
Please identify the Potentially Reportable Occurrence (PRO)
I evaluation performed for the drywell paint failures discovered during the 1989 refueling outage. If no PRO evaluation was performed, state each and every reason why it was not performed.
l Objection:
l-i Vermont Yankee objects to this interrogatory oo the ground that it is not relevant to the admitted contention.
laterrogatory No. $6.
Verment Yankee states, la part in its response to V6rmont later-rogatory (Set No.1) No,113 that the ' effectiveness of our main.
tenance program is demonstrated by a number of independent parameters, including... Independent assessments performed by...
NRC.'
Please identify each and every NRC audit, inspection, surveillance, report and other document that demonstrates the effectiveness of Vermont Yankee's maintenance program.
45 -
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I Objection:
i Vermont Yankee objects to this interro8 story, which enlis for the performance of research by it of publicly available materials, which is not a l
proper interrotatory request.
Response
7 l
Without walvin8 the fore 80in8 objection, but rather expressly relyin8 l
vpon the same, Vermont Yankee supplies the followin8 information (for l
recent years):
NRC Inspection Report INS 90-01 NRC laspection Report INS 88-06 NRC Inspection Report INS 89 80 NRC Inspection Report INS 88-05 NRC laspection Report INS $9-22 NRC laspection Report INS 88-03 NRC Inspection Report INS 89-21 NRC laspection Report INS 87-23
'l NRC Inspection Report INS 8912 NRC Inspection Report INS 87-21
[
NRC Inspection Report INS 89-09 NRC latpection Report INS 87-18 NRC inspection Report INS 89 07 NRC Inspection Report INS 87-16 NRC Inspection Report INS 89 03 NRC laspection Report INS 87-09 l
NRC Inspection Report INS $9 02 NRC laspection Report INS 87-08 NRC inspection Report INS 89-01 NRC Inspection Report INS 87-06 NRC Inspection Report INS 88 20 NRC Inspection Report INS 87-04 l
NRC Inspection Report INS 88-19 NRC laspection Report INS 87-02 y
NRC Inspection Report INS 88-16 NRC Inspection Report INS,86 25 NRC Inspection Report INS 88-14 NRC laspection Report INS 86-20 NRC laspection Report INS 88 10 NRC laspection Report INS 8618 NRC Inspection Report INS 88-08 NRC Inspection Report INS 86-15 i
e
. _ _. -.. _.... _ _ _,.. ~.. -. -. - -... -,.. _. _,... _,
i NRC laspection Report INS 8613 NRC inspection Report INS 86-10 NRC laspection Report INS 86 r6
' NRC Inspection Report INS 86 05 NRC laspection Report INS 86-04 i
NRC Inspection Report INS 46 01 SALP 07/01/88 through 09/30/89 i
l SALP.01/01/87 through 06/30/88 SALP 10/19/85 through 12/31/86 i
)
interrogatory No. $7.
For each and every document identified in Vermont Yankee's response to the preceding interrosstory, please describe in detail all findings, conclusions, recommendations, strengths, weaknesses, deviations and violations related to the effectiveness of Vermont Yankee's maintenance program.
7
Response
Please see the referenced documents, which are publicly available and routinely distributed to SOY, and which speak for themselves.
l v
Interrogatory No. 58.
Vermont Yankee states, in part, in its response to Vermont later-rogatory (Set No.1) No.113 that the
- effectiveness of our main-tenance program is demonstrated by a number of independent parameters... Independent assessments performed by,.. INFO?
Please identify each and every INPO audit, inspection, surveillance, report and other document that demonstrates the effectiveness of Vermont Yankee's maintenance program.
l Objection:
Vermont Yankee objects to this interrogatory for the reasons set forth in l
Its response to SOV's Document Requests (Set No. 2) and request for protective order concerning the same.
l [
r 1
~
1
-.- ~ _ - - -.
1 i
J laterrogatory No. $9.
For each and every document identified in Vermont Yankee's response to the preceding interrogatory, please describe in detail all findings, conclusions, recommendations, strengths, weaknesses, deviations and violations related to the effectiveness of Vermont Yankee's maintenance program.
Response
Vermont Yankee incorporates by reference its objection to the foregoing laterrogatory.
Interrogatory No. 60.
Vermont Yankee states, in part, in its response to Vermont inter-rogatory (Set No.1) No.113 that the ' effectiveness of our main-tenance program is demonstrated by a number of independent parameters, including... Independent assessments performed by...
YNSD.' Please identify each and every YNSD audit, inspection, surveillance, report and other document that demonstrates the effectiveness of Vermont Yankee's maintenance program.
Responsr:
l The independent assessments performed by YNSD-QA include audits and surveillances.
Audits of the maintenance program are performed on an annual basis.
Copies of these reports for 1985 to the present have previously been offered 5
to SOY and SOY requested copies of only the two most recent, which were provided. All ' conclusions, recommendations, strengths, weaknesses...'
related to the effectiveness of VY's maintenance program are documented in those reports.
The surveillance program is an intermediate level of activity between the inspection and audit functions. The objective of this program is to provide management assurance, through independent verification and assessment, that the predetermined requirements are being met. The results of these day-to-day activities are documented in surveillance reports. The reports will be produced for any portion of the period 1985 to the present at the offices of VYNPC, Brattleboro, upon request.
i _ _.
l 5
I d
leterrogatory No. 61.
For each and every document identified in Vermont Yankee's response to the preceding interrogatory, please describe in detail all findings, conclusions, recommendations, strengths, weaknesses, deviations and violations related to the effectiveness of Vermont G
Yankee's maintenance program.
i Response; Please see the response to the foregoing interrogatory.
i.l.rros.te,,
. 3.
Vermont Yankee states, in part, in its response to Vermont later.
rogatory (Set No.1) No.113 that the ' effectiveness of our main-tenance program is demonstrated by a number of independent 3
parameters, including... Independent assessments performed by...
i QA.' Please identify each and every QA audit, inspection, survell-lance, report and other document that demonstrates the effectiveness of Vermont Yankee's maintenance program.
Response
?
Please be advised that 'YNSD and 'QA' in the referenced response are one and the same thing. Please see the response to Interrogatory No. 60, j
above.
laterrogatory No. 63.
For each and every document identified in Vermont Yankee's response to the preceding interrogatory, please describe in detail all findings, conclusions, recommendations, strengths, weaknesses, deviations and violations related to the effectiveness of Vermont 3
i Yankee's maintenance program, l
Response
Please see the responses to laterrogatories Nos. 60 and 62, above.
1 laterrogatory No. 64.
Please describe in detail the process of Vermont Yankee ' continually assessing industry initiatives that would further enhance our pro-grams" as asserted in Vermont Yankee's response to Vermont Inter-rogatory (Set No.1) No.113. The description should include, but not be limited to, identification of the following:
l--
l
- a. Each and every industry initiative assessed by Vermont Yankee; 9.
~..
f, l
i 6
)
- b. The methodology for assessing each such initiative; i
l
- c. Each and every individual involved; and
- d. Each and every document produced as a result of such assessment.
Objection:
Vermont Yankee objects to this interrogatory, on the ground that it is not relevant to the admitted contention, and on the further ground that, for the reasons set forth below, the assembly of the information, sought would be vnduly burdensome.
Response
i Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee provides the following information:
t Vermont Yankee becomes aware of industry initiatives that might potentially improve our maintenance program in a number of ways, including through our association with and participation in the activities of INPO, EPRt. NUMARC and the GE BWR Owners Group. Usually, initiatives arising from groups such as these are assigned for evaluation via a formal
}
process that tracks the review and approval process to completion. The assessment is assigned by the department head to the appropriate technical personnel. The resulting assessment is reviewed and approved by the i
department head and the next higher level manager.
It is not feasible to list each and every industry initiative assessed by Vermont Yankee, the methodology used, the individuals involved, and each and every document produced as a result. The following, however, are examples of recent such assessments: the vendor manual program, the improved motor-operated valve preventive maintenance program, the check valve preventive maintenance program, and the improved erosion / corrosion monitoring program.
leterrogatory No. 65.
Vermont Yankee asserts, in rsrt, in its response to Vermont later--
~
rogatory (Set No,11) No.113 that the turnover rate in maintenance occupations for the five year period between 1985 and 1989 is indicative of a very stable workforce. Please describe in detail each and every reason why maintenance workforce stability will continue in the extended period. For each reason, please describe:
- a. Each and every fact upon which your reasons are beset.
.--a. -2.---.
a___ _ _ _. _.,,..,,,., _,,,
j il i
f 3
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Yortnont Yankee believes establishes each such fact; and l
- c. Eitherthetechnicalqualifications(education,employmenthistory, licenses and certificates, experience, or other naformation that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertlee of any person for the reason.
Response
According to Vermont Yankee employment records, our turnover rete i
i n.
in Maintenance occupations is very low. The average turnover rate j
of our Maintenance Mechanic staff for the five year period between 1985 and 1989 was 2.26%. The average turnover rate of our lastru.
ment & Control Technicians for the same period was 4.6%. Both rates l
are indicative of a very Wble workforce. We are aware of no a priert reason why this experience will suddenly change in the future.
Employment recosds for the Maintenance Staff indicate that over 70%
}
of the individuals hired in the 1985-89 period were from the local labor force. This promotes stability and retention over the long run.
I i
l Available statistics from the State of Vermont, Department of Em.
?
(
ployment and Training, Office and Policy and Information, of which we assume SOY is aware, reveal that the labor arrket population in t
the area has increased steadily over the years as has the overall labor market in Vermont (24.4% increase from 1978-1988). This data tends to indicate that local recruiting should continue to be at least stable, or even enhanced, in the future years.
I r
Chart 19 of the Vermont Annual Planning Information published by the State of Vermont indicates that,in 1938,22.4% of the experienced labor force in Vermont is concentrated in the precision craft and i
repair field. This data toads to confirm the availability in the local
(
area of qualified job applicants in the maintenance department.
l Chart 24 of the same publication shows a 1989 ratio of approximately i
3 applicants in the machine trade field for every I job opening. This data, published by SOY, also esads to confirm the availability le t.e local area of qualified job applicants in the maintenance departm *,.
0 h t
l Over the last 20 years, VY wages and employee benefits have remained competitive. We participate in and refer to the following surveys to insure that our wages and benefits continue to attract and retain workers:
Edison Electric laatitute Annual Nuclear Salary Survey.
Wage & Fringe Benefit Questionnaire - Vermont Departmaht of Employment and Tralalas, Office of Policy and leformation.
Brattleboro Area Personett Group Periodic Survey of Weges and Benefits.
Edison Electric Institute Annual Benefit Survey.
Towers, Perrin, Benefit survey of New England Nuclear Power Companies.
To foster retention VY benefit programs are designed to retain employees by providing service incentives. Our specific benefit plans with service incentive include: pension plan,401(k) Savirgs Plan, vacation entitlements and sick leave accrual.
YY maintains a file of certent applications for every functional area within the company. We retain applications for one year, and frequently have a waiting list of applicants for job openings.
From feedback received, Vermont Yankee is perceived by present and prospective employees to be a desireable organisation for which to wotk.
Southern Vermont is generally, and in our judgment with warrant, regarded to be a particularly desiroable place in which to live and work, an impression and a fact that VY promotes and, insofar as we can determine, SOY endor 's,
- b. See above.
- c. The foregoing information is not technicalin nature; much of the infor-motion consists of statistical data; and much of the data comes from SOY itself.
- $2 -
leterrogatory No. 66.
Please describe in detail the confirmation referenced in Vermont Yankee's response to Vermont laterrogatory (Set No.1) No.113 in connection with the Nucleonles Week article. The descriptiou should include, but not be limited to, identification of the following:
- a. The person (s) who conducted the investigation;
- b. The person (s) who provided the information;
- c. A full description of the information; and
- d. A full description of all other facts leersed.
Objection.
To the entent that this interrogatory might call for the contents of laterviews by counsel for Vermont Yankee with the personnel involved.
Vermont Yankee objects to this interrogatory on the grounds that such material is privileged from disclosure by 10 C.F.R. I 2.740(b)(2).
Response.'
To the extent not within the scope of the foregoing objection, Vermont Yankee responds as follows:
- a. Francis J. Helin
- b. Information was provided by letter from Margaret L.Ryan, Chief Editor, Nucleonics Week, to Francis J. Hella of VYNPC dated 3/27/90. In addition, Mr. Larry Ybartondo was contacted by telephone.
- c. The extent of the information learned from Ms. Ryan is included in the above cited letter (Attachment 66-1). Mr. Ybarrondo endorsed Ms.
Ryan's statements and stated very clearly that the subject of his discut-sion was the universities and a shortage of individuals in the higher degree programs, and not a shortage of people with the ski!Is SOY has called into question. On the basis of the foregoing information, it is clear that the statement for which SOY used the article as a " basis
- was not, in fact, either made by the article, intended by its authors to be com-prehended from the article, or supported by the factual information on which the article was based.
- d. See sub-part c., above. 4 1
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4 I
laterrogatory No. 67.
Vermont Yankee states, in part, in its response to Vermont later.
rotatory (Set No.1) No.116 that trends 'must then be analysed by knowledgeable people... with corrective action recommendations is i
sent to the Maintenance Supervisor.' Please describe in detail:
- a. Eitherthetechnicalqualifications(education employmenthistory, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for such analysis or state that Vermont Yankee does not rely upon the expertise of any person for such analysis,
- b. The criteria used to develop corrective action recommendations.
Response
i a) The individuals that review the trend information are the Maintenance Engineers. The qualifications of these individuals have been previously offered in response to SOY Document Production Request (Set No.1)
~
Nos. 2-4.
b) The criteria used for developing corrective action is a combination of engineering judgment and experience, a knowledge of the components
[
maintenance and operating history, and the specifics of the trend i
information being reviewed in addition. AP 0200 and the Maintenance r
Trending Program contain guidance with regard to the trend limits and their bases.
+
Interrogatory No. 68.
Please describe in detail each and every reason why Vermont Yankee asserts in its response to Vermont interrogatory (Set No.1) No.116 that trend analysis 'is based on conservative limits with conservative safety factors applied.' For each reason, please describe:
- a. Each and every fact upon which your reasons are based; b, All evidence in Vermort Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact; and
- c. Eitherthetechnicalqualifications(education,employmenthistory, licenses and certificates, experience, or other information that Vermont Yankee oosteeds establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon i
the expertise of any person for the reamou.
- $4 -
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Response
I The trend analysis limits are based on detection of a change la perfor-mance that is statistically real (I.e., not normal variation in equipment i
performance). Since plant equipment performance is significantly better than that required by the Technical Specification LCO limits, the detection of s
incremental declines in equipment performance proves an early warning of declining performance VY believes that malatalalas semipment reliability such that the operability provisions of the Tech. Spec. LCOs are not normally entered does indeed provide an additional level of conservatism over and above the conservative operability limits already establinhof la the Technical specifications. Evidence of the conservative asture of this approach is provided in the eatmples given in the response to laterrogatory (Set No.1)
No. I16.
- a. See above.
- b. See above.
- c. Vermont Yankee relies upon the collective staff of Malatennoce Depart-ment engineers and management that have the responsibilhy for im.
piementing this program. The qualifications of these individuals were provided in the response to Document Production Roquest (Set No.1) No.
2.
Interrogatory Nc. 69.
I Does Vermont Yankee agree that regulatory requirements for commercial nuclear power plant maintenance have increased since the Vermont Yankee plant was granted its original license?
4 If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
1
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's posasesion or of i
which Vermont Yankee has knowledge that Yermont Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention, and on the ground that, as framed, the interrogatory calls for a characterization of matters of pure law, which is an
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laappropriate query to propound by an laterrogatory, and on the further ground that the subject matter (historical change in regulatory requirements) is not relevant either to the admitted costantion or the pendias operating license smendment application, laterrogatory No. 70.
Does Vermot.t Yankee agree that ladustry knowledge of commercial nuclear power plant maintenance requirements has increened since the Vermont Yankee plant was granted its orignaal license?
If your answer is anything other than an saqualified affiranative, then please state avery reason for your answer, and for each reason-i
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contentien.
Response
Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee asys that because of the ambiguity and generality of the assertion, it is not able either to agree or disagree with it, except that, if the word 'requisements' refers to legal requirements, then Vermont Yankee disagrees. The industry was as aware in 1972 of the legal requirements of 1972 as it is today of today's legal requirements.
Interrogatory No. 71.
Does Vermont Yankee agree that commercial nuclear plant main-tenance technology has increased since the Vermont Yankee plant was granted its originallicense?
If your answer is anything othen than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermcat Yankee has knowledge that Vermont Yankee contends establithes each such fact.
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i Objection:
Vermont Yankee objecu to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
}
l Without' waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee says that because of the ambiguity and i
generality of the assertion, it is not able either to agree or disagree with it.
laterrogatory No. 72.
Does Vermont Yankee agree that a maintenance program found acceptable by the NRC licensing process at the time the Vermont Yankee plant was granted its original license is not necessarily an I
acceptable maintenance program for the extended period?
l i
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; and e
- b. Describe all of the evidence in Vermont Yankee's possession 4
which Vermont Yankee has knowledge that' Vermont Yankee contends establishes each such fact, i
Response
No. This question assumes that there are discrete licensing criterir applicable to a maintenance program, and that these criteria have changed during the specified interval. Vermont Yankee is unaware of the existence of such criteria. To the contrary, Vermont Yankee is aware that the Commission has under consideration, but has not acted upon, what would be, if enacted, the first ' maintenance rule' applicable to such decisions.
Beyond this limitation, the question assumes that a ' construction period recapture" operating license amendment must demonstrate that the facility will, as of the first day of extended operations, meet all of the licensing criteria that have been imposed subsequent to the grant of its original operating license Vermont Yankee believes that the Commission's policy, even in the case of license renewals, is quite to the contrary.
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leterrogatory No. 73.
Please describe in detail each and every reason why Vermont Yankee asserts in its response to Vermont laterrogatory (Set No.1) No.116 that it has 'high expectations for the benefits of the trending analysis?
t For each reason, piece describe:
- a. Each and every fact upon which your remons are based; f
Yankee has knowledge that Vermont Yankee believes establishes each such fact; and
- c. Eitherthetechnicalqualifications(eduontion,employmenthistory, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the r
1-person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yonkee does not rely upon l
the expertise of any person for the reason.
Response
i
(
.We have such expectations because the trending program has provided excellent performance to date. We have no reason to doubt that it will continue to do so, it would not be pactrical to marshall every example of this performance, and therefore we cannot supply '[e)nch and every fact" and '[alil of the evidence? However, some examples are set forth in the referenced response to Interrogatory No.116. Additional facts and evidence will be found in the reports sent to the Maintenance Supervisor pursuant to the Maintenance
[
Department Trend Program. Reliance is placed on the individuals identified i
In the response to Interrogatory (Set No.1) No.1.
i laterrogatory No. 74.
Vermont Yankee states, in part, in its response to Vermont later.
rogatory (Set No.1) No.117 *the fact that some components will not last for the duration of the plant's potential service life was antici.
pated by the original designers and by the Commission? Please describe in detail each and every component. that the original L
designers and the Commission anticipated wocid not last for the duration of the plant's potential service life. The description should l'
include, but not be limited to, identification of the following:
- a. Each and every such component; l
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- b. Each and every document that demonstrates the original designers anticipated that some components will not last for the duration of the plant's potential service life; and i
- c. Each and every document that demonstrates the Commission antbipated that some componena will not last for the duration of I
1 l,
the plant's potential service life, d
Objection:
t Vermont Yankee objects to this laterrogatory on the ground that it is not l
relevant to the admitted contention.
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Response
Without waiving the foregoing objection, but rather empressly relying upon the same, Vermont Yankee offers the following information:
No such complete list exists, and the preparation of one, were it possible, i
would require substantial laitial research. The point made in the quoted
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assertion was conceptual, and is conceptually true. An example of a I
component that was anticipated not to last for 40 years is lead acid storage j
batteries. See IEEE 450 (* Recommended Practice for Wintenance. Testing and Replacement of Large Lead Storage Batteries for Generating Stations and Substations *) and USNRC Regulatory Guide 1.129 (" Maintenance. Testing and Replacement of Large Lead Storage Battories for Nuclear Power Plants *).
h laterrogatory No. 75.
)
I Please describe in detail each and every reason why Veranoat Yankee asserts in its response to Vermont Interrogatory (Set No.1) No.117 l
that exclusive reliance is not placed upon design life when determin-ing if a component must be replaced, requalified or upgraded. The
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description should include, but not be limited to, identification of the following:
4.
The methodology used by Vermont Yankee to determine when a component r/ill encoed its service life; and
- b. '.ach and every procedure used to control the process for making such determinations.
Response
The short answer to this question is because we do not share the con-fidence that the question suggests others have that the original design and
)
designers latended to, or were capable of, anticipating all challenges to the continued functionality of structures, systems and components. To place the,
2
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hypotherised 'esclusive reliance' is the same as closing one's eyes to current i
evidence, a practice that is not consistent either the safe operation of a nuclear power plant or the Vermont Yankee approach to thiass.
i By analogy, one may (and often does) pay top dollar for automobile tires with a guaranteed life la units of miles. Smart folks do not, having done i
this, thereafter pay no attention to tread wear-or to glass in the road.
j a&b. See the Vermont Yankee Maintenance Program.
t leterrogatory No. 76.
Please describe in detail each and every reason why Vermont Yankee asserts in its response to Vermont laterrogatory ($et No.1) No.117 I
that ' industry programs have shown that many components are i
capable of lasting much longer than their original specified ' design f
life' with no loss of safety margin.' The description should include, but not be limited to, the following:
- a. identification of each and every industry program;
- b. Identification of each and every document describing such l
industry programs; and
- c. The methodology Vermont Yankee uses to incorporate such i
industry programs in its decision making process.
1
Response
l-l a.
EPRI Plant Life Estension programs as discussed in laterrogatory 46, L
above.
- b. See the response to Interrogatory 46, above.
- c. Vermont Yankee makes no claims with regard to the incorporation of this information into the YY maintenance decision making process beyond that made in the responses to interrogatories (Set No. 2) No.117 and (Set No. 3) No. 46.
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laterrogatory No. 77.
Please describe in detail each and every reason why Vermont Yankee L
asserts in its response to Vermont Interrogatory (Set No.1) No,117 l
that it is ' continually assessing industry initiatives that could further enhance the effectiveness of our programs.' The description should include, but not be limited to, the following:
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t a identification of each and every industry initiative that could f
further enhance Vermont Yankee's maintenance program
- b. Identification of each and every document describias such industry initiatives; and j
- c. The methodology Vermont Yankee uses to laoorporate such industry initiatives in its decision making process.
Response
e Vermont Yankee incorporates by reference its objection and response to Interrogatory No. 64, above.
leterrogatory No. 73.
Vermont Yankee states, in part, in its response to Vermont Inter-rogatory (Set No.1) No.120 that The maintenance of the structural integrity of plant structures is... accomplished by routine tours and inspections of the plant structures....' Please describe in detail all procedures related to tours and inspections of plant structures that include specific attributes and/or inspection criteria for plant structures, j
Objection' Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
\\
Response
Without waiving the foregoing objection, but rather expressly relying l
upon the same, Vermont Yankee supplies the following information:
The ' routine tours and inspections
- referred to in the response to Inter-rogatory (Set No..I) No.120 are conducted by the Operations Department as l
part of their normal daily responsibilities. These tours and laspections are conducted by the Avalliary Operators. The areas to be inspected, the acceptance criteria and the frequency of such tours and inspections are established in AP 0150 on forms VYOPF 0150.02 VYOPF 0150.05 and VYOPF 0150.06. The criteria used for inspection of non-specified areas of the plant are a function of operator experience and training in the recognition of off-normal conditions. Any off-normal condition is reported to the Control Room and documented on a Malatenance Request as required by AP 0021.
. 1 l
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L Vermont Yankee Procedure VYP-007 (* Vermont Yankee Masonry Wall Routine Surveillance *) contains the requirements for conducting routine surveillance walkdowns of masonry walls at Vermont Yankee to ensure continuing compliance with respect to the commitments of IE Bulletin 80-l1.
The YY ISI Program provides for inspection of component supports and restraints for Safety Class components. This portion of the program provides for inspection of some 500 such structural supports. la addition, other miscellaneous inspections such as the Technical Specifications-required CRD Housing Support System are conducted.
laterrogatory No. 79.
Vermont Yankee asserts in item 10 (dated March 17,1986) identified in its response to Vermont Interrogatory (Set No.1) No. 79 that 'NSD recommends that all loosely adhering paint be removed by hand scraping prior to start up.* Please describe in detail each and every action taken in accordance with this recommendation to
- preclude the possibility of degrading ECCS pump capability due to entrainment of paint fragments?
Response
Actions taken to remove loosely adhering topcoat from the upper drywell during the 1989 refueling outage are clearly discussed in YAEC Report 1696, which has previously been provided to SOY, and in the MRs identified in the response to the next interrogatory, laterrogatory No. 80.
Please identify each and every MR associated with either drywell or torus paint scraping at the Vermont Yankee plant at any time since January 1,1989.
Response
MR 89 1004 (drywell) and MR 89-1089 (torus).
laterrogatory No. 81.
Vermont Yankee asserts in item 18 (BYY 89 69, dated July 1,1989) identified in its iesponse to Vermont Interrogatory (Set No.1) No. 79 that YNSD ' recommended that all loosely adhering drywell palat be removed by hand scraping prior to startup from the outage? Please identify each and every supervisor who was responsible for drywell paint scraping activities at the Vermont Yankee plant at any time,
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since January 1,1989. As to each such person, provide the following i
information:
i
- s. What was his or her precise responsibility or responsibilities for paint scraping at the Vermont Yankee plant?
j
- b. Describe in detall the procles lastrisctions he or she received la the i
performance of the drywell sersping.
i
- c. Describe in detail the manner in which he or she received i
instructions.
I) Who provided the lastruction?
I
- 2) In what form was it provided?
i i
- 3) Identify all documentation that exists to verify that the instructions were provided and received.
- d. Identify his or her dates of employment by Vermont Yankee.
- e. For each person identified, state his or her qualifications and training, and provide the most current resume available.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is noi relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
P. Donnelly, Maintenance Superintendent at the time, and R. Mossey, Con.
struction Superintendent at the time. In addition, the persons identified on l-1-1 acted as supervisors for the contractor providing the craft l
labor.
l
- a. See above.
l
- b. Instructions for performips the work are contained in the MR.
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- d. Donnelly: 10/19/70 - 12/31/89.
Mossey: 5/25/40 - present.
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- e. See the response to laterrogatory ($et No.1) No. 2. The particular qualifications of the Mercury supervisors are not presently known, and in view the lack of need for special qualifications for the supervision provided by them, is not the subject of any investigation by Vermont J
Yankee.
I laterrogatory No. 82.'
Vermont Yankee asserts in item 18 (BVY 89-69, dated July 1,1989) i identified in its response to Vermont latertogatory (Set No.1) No. 79 that YNSD ' recommended that all loosely adherias drywell paint be removed by hand scraping prior to startup from the outage.' Please identify each and every craftsperson whc, did drywell paint scraping 1
activities at the Vermont Yankee plaat et any time since January 1 1989. As to each such person, provide the following information:
- a. What was his or her precise responsibility or responsibilities for i
paint scraping at the Vermont Yankee plant?
9
- b. Describe in detail the precise lastructions he or she received in the performance of the paint scraping.
- c. Describe in detail the manner in which he or she received instructions.
l
- 1) Who provided the instruction?
- 2) In what form was it provided?
- 3) Identify all documentation that exists to verify that the instructions were provided and received.
- d. Identify his or her dates of employment by Vermont Yankee.
- e. For each person identified, state his or her qualifications and 6
training.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not i
relevant to the admitted contention.
Response
Without waivin$ the fortsoing objection, tut rather expressly relying upon the same, Vermont Yankee supplies the following information:
The names and employment dates of the Mercury Company craft labor associated with MR 89-1004 are set forth on Attachment 82-1. ' hose person are hired from the applicable union halls on an as needed basis. Their skills i
l 64 -
and qualifications are documented via their valon standing. Each of the building trade sectors have their own apprenticeship programs to develop the personnel to a status of journeyman. The MR in question provides general lastructions for paint scraping. Attached to it are specific work orders issued by Mercury to the various craft supervisors, la turn, the craft supervision provides the lastructions to the craft verbally via pre-job briefings and direct monitoring of work being performed in process,
- s. $se above, j
- b. See above.
t
- c. See above.
- d. Not applicable.
- e. See above.
Interrogatory No. 33, Yermont Yankee asserts in item 13 (BVY 89-69, dated July 1,1989) identified in its response to Vermont Interrogatory (Set No.1) No. 79 that ' routine scraping of the torus topcoat was in progress at the time of the inspection.' Please identify each and every supervisor who was i
responsible for torus paint scraping activities at the Vermont Yankee plant at any time since January 1,1989. As to each such person.
provide the following information:
- a. What was his or her precise responsibility or responsibilities for paint scraping at the Vermont Yankee plant?
t
- b. Describe in detall the precise instructions he or she received in the performance of the drywell scraping.
l
- c. Describe in detail the manner in which he or she received i
instructions.
l
- 1) Who provided the instruction?
- 2) In what form was it provided?
- 3) Identify.all documentetion that exists to verify that the instructions were provided and received.
- d. Identify hl or her dates of employment by Vermont Yankee.
- e. For each person identified, state his or her qualifications and training, and provide the most current resume available.
l
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i Objection:
i Vermont Yankee objects to this laterrogatory on the ground that it is not relevant to the admitted contention.
Response
c Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
In response to laterrogatories Nos. 83 and 44, V7 incorporates by 1
reference its responses to laterrogatories Nos. 81 and 82, with only the following changes: substitute. MR 89-1049 for MR 891004, substitute
- 3-1 for Attachment 81-1, and substitute Attachment 341 for
! 2-1.
i laterrogatory No,34, Vermont Yankee asserts in item 18 (BVY 89-69, dated July 1.1989)
L identified in its response to Vermont Interrogatory (Set No.1) No. 79 that ' routine scraping of the torus topcoat was la prossess at the time t
of the inspection.' Please identify each and every craftsperson who i
was responsible for torus paint scraping activities at the Vermont l
Yankee plant at any time since January 1,1989. As to each such person, provide the following information:
- a. What was his or her precise responsibility or responsibilities for paint :craping at the Vermont Yankee plant?
- b. Describe in detall the precise instructions he or she received in the performance of the paint scraping,
- c. Describe in detail the manner in which he or she ' received instructions, e
- 1) Who provided the instruction?
l-
- 2) in what form was it provided?
E
- 3) Identify all documentation that exists to verify that the instructions were provided and received.
- d. Identify his or her dates of employment by Vermont Yankee.
- e. For each person identified, state his or her outlifications and training.
l l
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!l Objection.
i Vermont Yankee objects to this interrogatory on the ground that it is not 7
relevant to the admitted contention.
, Response.-
Without waiving the foregoing objection, but rather empressly relying upon the same, Vermont Yankee espplies %e following information:
Please see the response 10 the foregoing laterrogatory.
i laterrogatory No. 83.
l Please describe in detall each and every reason why Vermont Yankee asserts in item 10 (dated March 17,1936) identified in its response to Vermont Interrogatory (Set No.1) No. 79 that 'the primer coat wi'?
provide adequate corrosion protection as long as it as maintained in good condition.' The description should include, but not be limited to, the following:
- s. Identification of each and every program and procedure for l
primer coat inspection and maintenance;
- b. Identification of each and every area of the drywell and torus that are continually contaminated and/or wetted;
- c. Identification of each and every area of the drywell and torus that has no topcoat;
- d. Identification of each and every document describing programs intended to maintain the primer coat in good condition; and
- e. Identification of the criteria Vermont Yankee uses to determine if the primer coat is in
- good condition *.
Response
So long as the primer cost covers the substrate, corrosion of the substrate surface will not occur. Please see YAEC 1696 and the attachments thereto.
- s. Plant Procedure OP 4115 is the document utilised to inspect the laterior surfaces of the drywell and torus, in addition, at each refueling outage, an engineering inspection is made by YNSD engineers qualified to assess the state of these interior surfaces,
- b. The only portion of the primary containment that is continually wetted is the lower portion of the torus.
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- c. Areas of the drywell and torus that have no topcoat are identified in
]
YAEC Report 1696, which has previously been provided to SOV.
j
- d. See the response to sub-part (a) above.
- a. See OP di15.04.
j laterrogatory No. 86.
Does Vermont Yankee agree that 'any continually contaminated or wetted areas should have the Waterproof topoost to prevent con-tamination or water from beios absorbed *, as asserted in item 10 identified in Vermont Yankee's response to Vermont laterrogatory (Set No.1) No. 797 -
i If your answer is anything other than an unqualified affirmative, then -
please state every reason for your answer, and for each reason *
- a. State each and every fact on which your reason is based;
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and
- c. For each reason, either provide the technical qualifications (education, employment history, licenses and certificates, i
experience, or other informstion that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying i
upon the same, Vermont Yankee supplies the following information:
No, Vermont Yankee does not agree with this statement.
- s. All plant surfaces are considered with regard to their waterproof capability and decontaminability, as part of Vermont Yankee's ongoing radiation control program to mainimize the potential for transport of
1 4
b 4
radioactive contamination. However, the drywell and torus are areas that are not accessible during normal operation, and are controlled con-taminated areas when entry is permitted. Therefore, ease of decon-taminability of drywell and torus laterior surfaces is not of paramount
]
importance, in addition, there is no licensing basis that requires Vermont l'
Yankee to malatain ease of deoostaalasbility os any surfaceHloing so is simply a matter of good housekeeping practices to maintain easily decontaminated surfaces in areas that are routinely accessible.
i
- b. Decontamination practices are detailed in plant Radiation Protection procedures.
t c.
Radiation protection decisions are made by plant management personnel (qualifications previously provided).
laterrogatory No. 87.
Does Vermont Yankee agree that all continually contaminated or wetted areas of the drywell shell[ sic 7) have the Waterproof topcont?
]
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason-
- a. State each and every fact on which your reason is based;
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and
- c. For each reason, either provide the technical qualifications (education, employment history, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
Objection:
Vermont Yankee objects to this laterrogatory on the ground that it is not relevant to the adelited contention.
l
Response
Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following informatiore
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.i No. Please see YAEC 1696.
Interr;gatory No. 83.
I l
Please describe in detall each and every action taken to determine the a
root cause(s) of topcoat failure in the drywell and torus. The t
description should include, but not be limited to, identification of the following:
- a. Each and every root cause determined;
-]
- b. Each and every documentation of root cause(s); and
)
i
- c. Each and every action taken as a result of the root cause analysis, l
if any.
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Response
This question is answered in detail in YAEC Report 1696, which has 1
previously been provided to SOV.
laterrogatory No. 39.
Please state the qualifications and training, and provide the most current resume available, for the SWEC consultant, C. Hansen, who l
prepared mem9randum VYS 46/g6, Drywell Paint, dated March II, 1986.
i
Response
l Please see the response to interrogatery (Set No.1), No. 77.
l laterrogatory No. 90.
l Does Vermont Yankee agree that SWEC consultant C. Hansen is qualified to evaluate the Vermont Yankee plant's drywell paint?
If your answer is anything other than at. unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; E
- b. Describe all of the evidence in Verssont Yankee's possession or of l
which Vermont Yankee has knowledge that Vermont Yankee i
contends establishes each such fact; and
- c. For each reason, either provide the technical qualificatio:.s (education, employment history, licenses and certificates, i
experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on 70 -
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whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person f ar the reason.
Response
Yes.
Interrogatory No. 91.
Does Vermont Yankee agree that *allloosely adhering paint will come
[
off durir.3 a DBA-LOCA* and that "a small amount of paint could i
seriouly affect
- ECCS pump performance as asserted in item 10 l
identified in its response to Vermont laterrogatory (Set No.1) No. 797 If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which nur reason is based;
- b. Describe all of the evidence in Vermont Yankee's poonession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and
- c. For each reason, either provide the technical qualifications-(education, employment history, licenses and certificates, experience, or other information that Vermont Yankee contends e
establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
Response
I No. Vermont Yankee no longer agrees with this statement.
- a. The referenced memorandum, Item 10 from Vermont laterrogatory (Set No.1) No.79, was written based upon the limited amount of knowledge that was available conceralas the drywell paint issue at that time. la the 1989 outage, significant topoost failure was observed and, as a result, a more detailed evaluation was performed. In addition to the expertise that was available from Mr. Hansen and others in the Vermont Yankee / Yankee Atomic organization, a coatings specialist was hired (Mr. Martin) to provide a more in-depth review of the existing paint condition, failure mode, and long term ability to provide corrosion protection of the primary containement -
interior shell. His more detailed evaluation, combir.ed with a more thorough topcoat removal effort, has provided assurance that further topcoat failure will have no adverse impact on ECC3 pump operability, la addition, it may 9
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L' be that SOY is not aware of the fact that, for other reasons, the strainers to which Mr. Hansen referred in item 10 were ' replaced with the much larger O
strainers analysed in YAEC 1696.
- b. The subsequent and more detailed evaluation referred to above' is documented in YAEC Report 1696, which has previously been provided to SOV.
- c. Messrs. Hansen, Tremblay and Yasi, identified in the response to later-rogatory (Set No.1) No. 77.
Interrogatory No. 92.
Does Vermoc* Yankee agree that 'very little data is available concerning transportation of paint fragments in a Mark I configura-tion
- as asserted in item 10 identified in its response to Vermont Interrogatory (Set No.1) No. 797, 1
l' If your answer is anything other than an unqualified affirmative, then I
please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based;
-l L.
- b. Describe all of the evidence in Vermont Yankee's possession or of
.I 17 which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and
.l
- c. For each reason, either provide 'the; technical qualifications (education, employment his'ary, licenses and certificates, experience, or other info
- mat'an that Vermont Yankee contends establishes the qualifica'.pt of the person), of any person on i
whose expertise Vermont NN relies for the reason or state that l'
Vermont Yankee does ac aly upon the expertise of any person I
for the reason.-
l
Response
l.
l This statement was true at the time it was made, but in light of the subse-is quent Vermont Yankee evaluation of this issue, this statement is no longer l-
- valid,
- s. This statement was made in a preliminary assessmoot, prior to the more detailed evaluation that was performed in YAEC Report 1696, which sum-I matized the amount of industry-wide data that was available. This subse-quent in-depth evaluation utillied available data from insulation fragment p
transport physical testing (referenced in YAEC Report 1696) and General L
Electric methodology for Vermont Yankee for the resultant NPSH losses due l
to insulation debris (also referenced in YAEC Report 1696), and, taking into L !
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.1 account the similarities and differences between the avail'able transport data for insulation debris and paint chip debris, established a paint chip transport -
methodology. Thus the statement quoted in the interrogatory was true at the time it was made but has since been superseded by YAEC 1696.
- b. The more detailed evaluation referred to above is documented in YAEC Report 1696, which has previously been provided to SOV.
- c. Messrs. Hansen, Tremblay and Yasi, identified in the response to Inter-rogatory (Set No.1) No. 77.
Interrogatory No. 93.
Does Vermont Yankee agree that Nhere is no data available with regard to paint chip transport or plugging of strainers by paint chips,
- with or without combination with insulation fibers' as asserted in item -
.18 identified in its response to. Vermont Interrogatory (Set No.1) No.
)
79?
If your answer is anything other than an unqualified affirmative, then i
I-please state every reason for your answer, and for wach reason:
- s. State each and every fact on which your reason is based; P
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and
- c. For each reason, either provide the technical qualifications (education employment history, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on
= whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
Response
No. Vermont Yankee does not entirely agree with this statement.
E
- a. Transport is discussed above in our response to Interrogatory 92. There p
- is no physical testing data available on the effect of paint chips in plugging strainers utilizing a Mark I design. with or without combination with l3 lasulation fibers; howevr2, this point is moot since YAEC 16% shows that 3
l Vermont Yankee's ECCS pumps have sufficient NPSH margin above that required to accommodate the postulated fibrous insulation debris due to a design basis accident.
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.1696, which has previously been provided to SOV.
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- c. Messrs. Hansen, Tremblay and Yasi, idtatified in the response to inter-rogatory (Set No.1) No. 77.
lL laterrogatory No. 94.
i Please state the' qualifications and training, and provide the most current resume available, for the SWEC consultant, R.L. Martin, who prepared letter J.O. No. 18973.00 Drywell and Tecus Coatings -
1
- Vermont Yankee Station Yankee Atomic Electric Company, dated ;
j April 4,1989.
I
Response
Please see the response to Interrogatory (3et No.1), No. 75.
Interrogatory No. 95.
Does Vermont Yankee agree that SWEC consultant R.L. Martin is -
qualified to evaluate the Vermont Yankee plant's drywell and torus coatings?
1 If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- s. State each and every fact on which your reason is based; L
L
- b. Describe all of the evidence in Vermont Yankee's possession or of L
which Vermont Yankee has knowledge that Yermont Yankee l;
contends establishes each such fact; and
- c. For each reason, either provide the technical qualifications -
(education employment history, licenws and certificates, experience, or other information that Vermont Yankee contends l-establishes the qualifications of the person), of any ptenon on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
Response
Yes.
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Interrogatory No. 96.
Does Vermont Yankee agree that 'the topcoat materials failed by r
delamination and produced chips as large as one square foot.
7 Transport of these chips to the safety system suction strainers could
- potentially result in partial blockage of the strainers? as asserted in
[F item 13 identified in its response to Vermont laterrogatory (Set No.
}
- 1) No. 797,
if your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
?
- a. State each and every fact on which your reason is based,
- b. Describe all of the evidence in Vermont Yankee's possession er of which-Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and
- c. For each reason, either provide the technical qualifications (education,' employment history, licenses and certificates, i
experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on
~
i-whose expertise Vermont Yankee relies for the reason or state that l.
Vermont Yankee does not rely upon the expertise of any person for the reason.
' Response:
Yes. Vermont Yankee agrees with this statement as an initial observation of the as-found condition of the upMr drywell topcost during the 1989 refueling outage, and, in particular, of 4. concern warranting further analysis
("could potentially result *). But taken out of context, these statements could p;
be misleading.
The referenced nport is a summary.of a trip report during an initial inspection of the Vermont Yankee drywell, which was performed by Mr.
1 Martin. This trip report details Mr. Martin's initial thoughts and/or concerns
- with regard to this issue. During the course of the evaluation, these initial thoughts were further refined, proven to be true or false, and finallaant in his final report to Yankee Atomic, which is included in YAEC Report 1696 and p
which is already in SOV's possession. His final report concluded that failed L
topcoat would break into small pieces due to its brittle nature, and that due to the nature of the scenario, not enough failed topcoat would find its way k
to the ECCS suction strainers to adversely affect pump performance.
y l'
Consequently, while YY agrees that the trip report _ sagely identified a
' potential" concern warranting resolution, it also agrees (with Mr. Martin) that su' bsequent analysis resolved the concern.
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- t 1eeerrogatory No. 97.
e Does Vermont Yankee agree that, *du to the instalianian of fiberglass leasiation on the r=plar====t venetor coolant re:irculation piping, the amount of loose topcoat mater *al that falls freer. the drywell and torus -
surfaces has now become an even more important factor in the i-strainer blockage analysk foraVBA/1DCA steat" as userted la item 13 identified in its response so Vermont Intersosatory (Set No.1) No.
797-Y youranswer is anything other than an unqusBfled affirmative, then please state every reason for your answer, and for each reason:
- a. Esate and and every feet on which your season is based;
- b. Describe all of the evidencein Ver.noat Yankse's possession or of which Vermont Yankee has knowledge that Vermont Yankee ea=nenwie stablishes each such fact; and
- l
- c. Por och semann, either provide the tschaical qualifications t-(education,- employment history, l' censes and certificates, grzperience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on irhose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person l.
for the reason.
Response
WliDV islasking whether we believe the gooted statement accurately armmariusthe tesults of the evahation,our response is negative. See YAEC A696. If EDV is asking whether we believe that the quoted statement pradently Idsstified a potential concern to be resolved, our response is in the afGreative.
Emeonesseury N s. 93.
Please describe in detail all touchup repairs made to the exposed primer of the drywell and torus. The description should include, but act be halted so, identification of the following-3.
Each and every repair, including date of the repair;
- 4. Each and every dae====emeiam of such sepair(s);
- c. Each and every procedure that sentrois the repair work; d.' The analification and training requirennents for each and every i
individual performing the repair work; and i
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s e Each and every assessment or evaluation of the probable long term 1
success of such repairs.
Objection:
- Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
a) The specific details of such touch up repairs are included in maintenance requests 86-1332 and 86-1213, as well as in any other MR's for repairs not specific to paint touch up that may.have included paint touch up as a requirement to complete the job.
t b) See subpart a, c) See subpart a.'
a d) Please see the responses to Interrogatory (Set No.1) Nos. 23,33, and 43 e) None.
o l
Interrogatory No. 99.
Please describe in detail what Vermont Yankee means by "relatively small'in item 13, page I, identified in iu response to Vermont Inter-rogatory (Set No.1) No. 79 with regard to the amount of top coat.
material that has loosened between scrapings. Please describe in detail all the bases for such statement, including, but not limited to, the 1
following:
1 a. ' Each and every fact upon which your statement is based;
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact; and j
- c. For each reason, either provide the technical qualifications (education, ' employment. history, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on -
whose expertise Vermont Yankee relies for the reason or state that Yermont Yankee does not rely upon the expertise of any person for the reason. -.
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Response
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.a.
The term re at ve y small' rom item 1 Page 1, dentified in Vermont Yankee's response to SOY Interrogatory (Set No.1) No.79 refers to the amount i;-
of topcoat material that had loosened from the interior of the forms between i
scrapings, as evidenced by the varying degrees of oxidation of the exposed
'I inorganic sinc primer. Since the following paragraph in the reference deals with the amount of topcoat that was found to have loosened in the drywell, 1
it is intuitively obvious that the amount of topcoat loosened in the torus is being compared in the reference relatlye so the amount that had loosened in the drywell (i.e.. there was very little loosened topcoat found in the torus j
when compared to that found in the drywell).
I
- b. The as-found conditions of the drywell and torus interiors is fully discussed in YAEC Report 1696, which has previously been provided to SOV.
l
- c. Messrs. Hansen, Tremblay and Yasi, identified in the response to Inter-rogatory (Set No.1) No. 77.
j laterrogatory No.100.
Please describe in detail what Vermont Yankee means by a 'si-snificant amount" in reference to the topcoat loosely adhering to the-i drywell walls in item 13, page 2, identified in its response to Vermont '
Interrogatory (Set No.1) No. 79. Please describe in detail all the bases for that statement, including, but not to be limited to, the following:
- a. Each and every fact upon which your statement is based;
.j
Yackee has knowledge that Vermont Yankee believes establishes each such fact;
- c. For each reason, either provide the technical' qualifications '
(education. employment history, licenses ' and certificates, experience, or other information that Vermont Yankee contends establishes-the qualifications of the person), of any person on l
whose expertise Vermont Yankee relies for the reason or state that l
Vermont Yankee does not rely upon the expertise of any person for the reason; and
- d. Each and every potential consequence of a significant amount of topcost becoming loose during a DBA - LOCA event.
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I Response::
- a. The term *a significant amount
- from Item 13. Page 2, identified in
. Vermont Yankee's response to SOY laterrogatory (Set No.1) No.79 refers to the amount of failed topcoat that was obsercod la the upper drywell during the 1929 refueling outage, the last scraping effort having been performed two outages before. Since the previous paragraph in the reference deals with the l
amount of topcoat that was found to have loosened in the torus, the reader should conclude that the amount of topoost loosened in the drywell was found to be significant when compared to the as-found condition of the torus topcoat (I.e., there was significantly more loosened topcoat found in the upper -
drywell than in the torus).
l
- b. The as-found conditions of the drywell and torus interiors is fully L
discussed in YAEC Report 1696, which has previously been provided to SOV.
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- c. Messrs. Hansen, Tremblay and Yasi, identified in the response to Inter-rogatory (Set No.1) No. 77.
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- d. See YAEC 1696.
l i
l laterrogatory No.101, i
Stone & Webster's coating specialist asserts in item 13 identified in Vermont Yankee's response to Vermont laterrogatory (Set No.1) No.
79 that "In a DBA/LOCA event, the topcoat remaining on the surface may delsminate from the primer." Please describe in detail the significance of topcoat delamination and/or p.teling in terms of the i
(
potential to degrade ECCS pump capability due to entralament of paint fragments either alone or in combination with other potential debris.
Response
This sentence is taken out of context. If one were to read the remainder
~
of this reference, one would see that Mr. Martin was making a statement of a potential problem, and then continues on to evaluate the problem statement i
and conclude that it in fact is not a problem with regard to ECCS pump operability.
The evaluation of the significance of topcost failure is discussed in detail-in YAEC Report 1696, which has previously been provided to SOV.
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i laterrogatory No.102.
Stone & Webster's coating specialist asseru in item 13 identified in ~
a Vermont Yankee's response to Vermont laterrogatory (Set No.1) No.
79 that " adhesion strength of the topcoat to the primer"is one of the four factors that directly affects the amount of topoost material that may be removed from the drywell during a DBA-LOCA. Please j
. describe in detail the bases for that assertion, including, but not to be limited to, the following:
j a.- Each and every fact upon which the assertion is based; 1
- b. : All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact;
'C
- c. For each reason, either provide the technical qualifications (education, employment, history,. licenset and-certificates, experience, or other information that Vermat Yankee contends g
f establishes the qualifications of the person), of any person on i
whose expertise Vermont Yankee relies for the reason or state that.
Vermont Yankee does not rely upon the expertise of any person u
for the reason; and -
L
- d. Each and every documentation of adhesion strength tests and/or -
measurements.
Response
- a. Please see Reference 13: "If the differential pressure exceeds the top-
.7 coat's adhesion strength, the topcoat is lifted from the primer... ?
- b. The proposition in question is analytic, not empirical, and therefore not U
based on evidence.
..'l
- c. The technical qualifications of Mr. Martin have been previously trans-i mitted to SOV.
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- d. No such tests or measurements were performed.. or necessary to be-performed, for the purpose of the conclusions reached in item 13.
~
Interrogatory No.103..
l Stone & Webster's coating specialist asserts in item 13 identified in Vermont Yankee's response to Vermont laterrogatory (Set No.1) No.
79 that "a break in the coolant recirculation piping in the lower portion of the drywell may not remove large amounts of topcoat by impingement? Please describe in detail the bases for that assertion, L
including, but not to be limited to, the following:
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- a. Each and every fact upon which the assertion is based;-
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Yankee has knowledge that Vermont Yankee believes establishes each such fact;
- c. For. each reason, either provide the technical qualifications (education employment history, licenses and certificates,
)
esperience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on-whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the espertise of any person for the reason; and
- d. The significance of-loosening "large amounts" of topcoat and fiberglass insulation during a DBA-LOCA in terms of the potential to degrade ECCS pump capability due to entralament of paint fragments and other debris, t
Response
L
- a. The basis for this assertion'is found in the same paragraph of the same reference that this quote was taken from,
- b. See evaluation in YAEC Report 1696, which provides the references used to perform this evaluation. YAEC Report 1696 has been previously provided to SOV.
- c. Messrs. Hansen, Tremblay and Yasi, identified in the response to Inter-rogatory (Set No.1) No. 77.
- d. The significance of loosening 'large amounts
- of topeost and fiberglass insulation during DBA-LOCA in terms of the potential to degrade ECCS pump operability due to entrainment of paint fragments and other debris had r
not been evaluated, since General Electric evaluated in detail for Vermont Yonkee the amount.. of fiberglass debris that. would conservatively be produced from this event (Reference I from YAEC Report 1696), as d because large amounts of topcoat failure have been evaluated not to occuc due to the reasons stated in YAEC Report 1696. Thus, evaluation of a condition of 'large amounts" of loosened topcoat and fiberglass insulation during a DBA-LOCA would not be appliceble to Vermont Yankee.
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1 laterrogatory No.134.
- Stone & Webster's coating specialist asserts in item 13 identified in Vermont Yankee's response to Vermont laterrogatory (Set No.1) No.
79 that " failure of the topcoat in the upper section of the drywell was related, in part,' to thermal aging by long term esposure to elevated temperatures (approximately 180 - 200 F).*
- a. Please describe in detail each and every reason why failure of the topcoat was related, in part, to thermal aging by. long term exposure to elevated temperatures;
- b. Describe sach and every reason for the elevated temperatures;
- c. Identify each and every document that describes the elevated temperatures;
- d. Please describe in detail all evidence either in Vermont Yankee's possession or of which Vermont Yankee has kocwledge that Vermont Yankee believes identifies topcoat failure mechanisms; and
- e. Identify each and every component and/or structure that may be affected by thermal aging due to elevated drywell temperatures.
. Response:
a.
Thermal aging of coatings is -an established failure. mechanism of coatings.- it is Mr. Martin's opinion due to physical inspection that failure of the topcoat in the upper drywell is thermally induced. This opinion is based '
on observed drywell topcoat conditions, i.e. darkened color (compared to the topcoat below the spray ring), brittleness, cracking, and loss of adhesion, in the area above the spray ring, which are indications of thermal aging of the
- topcoat,
- b. The term
- elevated temperatures" es it is used in the reference document refers to a comparison of the mean temperature in the upper drywell and the mean temperature in the lower drywell. " Elevated temperature" la the upper drywell.does not mean that tempersteres in the drywell are above design conditions or are abnormally high, contrary to the implicit assumption of this sub-part of the interrogatory. The upper drywell historically has always been at a higher temperature than the lower drywell, due to the configuration of the Mark I containment, and the fact that a nuclear reactor is located in it,
- c. Please see the response to sub-part b, above.
& 3 7,
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- d. The only document that addresses topcoat failure mechanisms is the.
SWEC report referenced in this interrogatory, which is an enclosure to YAEC
. Report 1696 and which has previously been provided to SOV.
[
- e. Please see the response to sub-part b, above.
1 laterrogatory No.105.
Please describe in detail each and every reason why Stone' A Webster's coating specialist asserts in item 13 identified in Vermont Yankee's response to Vermont Interrogatory (Set No.1) No. 79 that the coating failure mechanism caused by condensation "can be controlled with regular maintenance." Please describe in detail the basis for that assertion, including, but not limited to the following:
- a. Each and every fact upon which the assertion is based;
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact; and c.'
Each and every regular maintenance activity performed on the sinc primer.
Response
a.~ The localized coating degradation caused by condensation can be monitored with periodic (c.t., every refueling outage) inspections. Those areas requiring coating repair can be identified during the inspections for immediate action,
- b. The document referenced in this interrogatory establishes this fact.
l
Interrogatory No.106.
q
. Stone & Webster's coating specialist asserts in item 13 identified in i
Vermont Yankee's response to Vermont Interrogatory (Set No ' I) No.
l' 79 that in a touchup repair situation the torus coating material *will
. eventually peel in the overlap around the periphery of the touchup area.* Please describe in detail the significance of such peeling in terms of the potential to degrade ECCS pump capability due to entrainment of paint fragments either alone or in combination with other potential debris, j.:
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t Respese:
The effee of any paint chip debris resulting from peeling of the topcoat -
overlap onto the scorganic sinc primer, relative to ECCS pump capacit>, is addressed in item 16 of Ve mont Yankee's response to Vermont laterrogatory 1
o
. (Set No.1), No. 79 (YAEC 1696, previously provided).
Interrogatory No.107.
Please describe in detail each and every reason why Stone & Webster's coating specialist asserts in item 13 identified in Vermont Yankee's J
response to Vermont laterrogatory (Set No.1) No. 79 that "It is probable that the drywell topcoat material was KAL E-1 od [ sic] D-M i Series epoxy." Please describe in detail the basis for that assertion, i
including, but not to be limited to, the following:-
i a ' Each and every fact upon which the assertion is based; and l
l-
4 o
Yankee has knowledge that Vermon! Yankee believes establishes each such facti
Response
' a. K&L E-1 and D-1 Series epoxies have been Keeler & Long's recom-j; mended topcoat materials for nuclear applications. Keeler & Long appeared to' be the coating manufacturer of choice for field coating work at the Vermont Yankee station,
- b. No exhaustive search for such documentation has been performed.
Tc': phonic inquiries with Keeler & Long, the usual supplier of such matsrials, confirmed that they supplied E-l or D-1.to Vermont Yankee I
L during the period in question, and this information was deemed sufficient.
confirmation of the expected information.
Interrogatory No.103.
Please describe in detail osch and every reason why Stone & Webster's coating specialist asserts in item 13 identified in Vermont Yankee's response to Vermont Interrogatory (Set No.1) No. 79-that the
" decontamination process will remove some of the = sinc coating.
thickness." Please describe in detail the basis for that assertion, including, but not limited to the following:
j g
- s. Each and every fact upon which the assertion is based; and
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-Yankee has knowledge that Vermont Yankee believes establishes J
sach such fact.
Response
il
, s. Decontamination of the inorganic sinc primer could require the use of
.j mechanical action such as scrubbing or brushing. Such mechanical action can
- l reduce the thickness of the primer, which consists of a slac silicate matrix,
- b. The foregoing is based upon analytical assessment and common know-ledge, not upon ' evidence.'
laterrogatory No.109.
L:
Stone & Webster's coating specialist asserts in item 13 f*ntified in l
Vermont Yankee's response to Vermont Interrogatory (Set No.1) No.
79 that the ' decontamination process will remove some of the zinc coating thickness." Please state:
- a. The significance of removing some of the mine coating thickness;
'i
- b. The minimum allowable zinc coating thickness and the criteria for that minimum;.
- c. The date, based on the current zinc coating thickness and estimated future zinc coating thinning from each and every cause, when generalized repair and/or replacement of the zinc coating will be required; and
- d. The sufficiency of zine coating for the extended period.
~
Response
- a. The significance of removing some of the inorganic sinc coating thickness during decontamination activities would require assessment at the time of the decontamination. Assessment would be based on factors such as: remaining coating thickness; physical condition of the remaining coating and expected' service conditions for the coating following decontamination. Related maintenance, modification, and operational activities that could affect the remaining coating or the intended sei ice conditions of the coating also -
v would be included in the assessment.
- 5. There is no established minimum allowable zioc coating thickness.
Nominal thicknesses are stated in previously discussed coating specifications.
See YAEC 1696.
~ e ir c.
No such date has been established.
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- d. As stated in the final report of the Stone & Webster coating specialist, the exposed sinc primer provides adequate corrosion protection for the inside surfaces of the containment. The recommended long-term approach was to t
, continue the current short-term approach, which includes removal of loose -
topcoat, allowing the primer to remain un-topcoated, and to make touch.-
l up repairs to the primer in locations where the primer may become damaged or where sporadic corrosion has occurred. This approach would hold true for '
i-the extended period as well.
Interrogatory No.110. -
Stone & Webster's coating specialist asserts in item 13 identified in Vermont Yankee's response to Vermont laterrogatory (Set No.1) No.
79 that
- Failure of the exposed inorganic sinc primer will not produce chips that could potentially cause blockage of safety system suction i
strainers." Please describe in detail the bases for that assertion, including, but not limited to, the following:
a.
Each and every fact upon which the assertion is based; and
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact.
Response
- a. The failure mode of the inorganic aine primer is addressed in item 13 of Vermont Yankee's response to Interrogatory (Set No.1) No. 79: "the failure i
mode of the primer is granulation rather than peeling or delamination."
i
- b. See YAEC 1696'and item 13 referenced therein.
Interrogatory No.111.
Please describe in detail each and every mason why Vermont Yankee asserts in item is identified in its response to Vermont Interrogatory (Set No.1) No. 79 that General Electric Report MDE-134-0855, DRF AOO-01713, Revision I,' Effects of Fiberglass insulation Debris on Vermont Yankee ECCS Pump Performance", dated January,1986 is a conservative assessment of the p>tential reduction in ECCS pump NPSH which may occur as a result of a DBA-LOCA. The description should include, but not be limited to,-identification of the following:
- a. Each and every fact upon which your statement is based;
}
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes estr.blishes each such fact; and i
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- c. Eitherthetechnicalqualifications(education,employmenthistory, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the-person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely on the expertise of any person for the reason.
Respanse:
- a. - Quoting from the referenced General Electric report " Conservative.
calculations were made of the volume of debris generated..the short term and long term transport of debris to the suppression pool, the bead loss through a layer of debris on the intake screens and the ' clean screen' NPSH margin of the Vermont Yankee ECCS pumps.' Thus Vermont Yankee's assertion is based upon the very same assertion made in the referenced General Electric -
- report,
- b. The above statement is based upon information provided by General Electric in the referenced report. This report was utilized as part of Vermont Yankee's evalustion YAEC Report 16%, which has previously been provided to SOY,
- c. _ The technical qualifications of those individuals involved in the subject evaluation effort have previously been provided to SOV.
Interrogatory No.112.
Please describe in detail each and every reason why Vermont Yankee asserts in item 18 identified in its response to Vermont laterrogatory (Set No.1) No. 79 that The existing primer provides excellent protection of the underlying metal surfaces." The description should-include, but not be limited to, identification of the following:-
- a. Each and every fact upon which your statement is based;
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact; and
- c. Either thetechnicalqualifications(education,employmenthistory. -
licenses and certii'icates, experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely on the
- expertise of any person for the reason..
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Response
i Please see the response to laterrogatory No. 85, above.
Interrogatory No.113.
Please describe in detail each and every reason why Vermont Yankee asserts in item 18 identified in its response to Vermont Interrogatory (Set No.1) No. 79 that inspection of the torus scraping effort on March 17,1989 concluded ' satisfactory results." The description should include, but riot be limited to, identification of the following:
- s. Each and every fact upon which your statement is based; and
Yankee has knowledge that Vermont Yankee believes establishes each sch fact.
Response
Subsequent inspection failed to reveal any evidence of unremoved loose i
L paint.
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- a. This conclusion was based upon physical inspection of the scraping and ~
maintenance activities performed in the torus, i
- b. MR 89-1089.
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laterrogatory No.114.-
Please describe in detail each and every reason why Vermont Yankee asserts in item 18 identified in its response to Vermont Interrogatory (Set No,'!) No. 79 that ' paint dislodged from either the drywell or torus surfaces would be of no consequence with regard to ECCS strainers and ECCS pump performance."- The description should include, but not be limited to, identification of the following:
- a. Each and every fact upon which your statement is based;
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes t
l each such fact; and
- c. Eitherthetechnicalqualifications(education,employmenthistory, licenses and certificates, experience, or other information that u
Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state thet Vermont Yankee does not rely on the
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expertise of any person for the reason.
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Response
The reasons, facts and evidence on which the statement is based are contained in YAEC 16%, and the technical qualifications of those individuals involved in the subject evaluation effort have previously been provided to SOV.
laterrogatory No.115.
Please describe in detail each and every reason why Vermont Yankee.-
asserts in item 18 identified in its response to Vermont Interrogatory (Set No.1) No. 79 that ' insulation fibers would be more apt to remain -
in suspension in the torus and be swept onto an ECCS intake screen than would paint chips." The description should include, but not be limited to, identification of the following:
- a. Each and every fact upon which your statement is based; and
- b. All evidence in Vermont Yankee's possession or of which Vermont '
Yankee has knowledge that Vermont Yankee believes establishes each such fact.
Response
The reasons, facts and evidence on which the statement is based are contained in YAEC 1696, and the technical qualifications of those individuals involved in the subject evaluation effort have previously been provided to '
SOV.
Interrogatory No.116.
Please describe in detail each and every reason why Vermont Yankee asserts in item 18 identified in its response to Vermont laterrogatory (Set No.1) No. 79 that.*the probability of significant paint transport to the torus in the first 30 seconds is very low.* The description
- should include, but not be limited to, identification of the followin8:
- a. Each and every fact upon which your statement is based; and
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact.
Response
- The reasons, facts and evidence on which the statement is based are contained in YAEC 1696, and the technical qualifications of those individuals involved in the subject evaluation effort have previously been provided to
. SOV.
Interrogatory No.117.
Please describe la detail each and every reason why Vermont Yaakes asserts in item 18 identified in its response to Vermont laterrogatory (Set No.1) No. 79 that.* paint chips would not be within the high velocity 1.OCA flow stream, it would be expected that the majority of failed paint chips would remain on the drywell floor.' The -
description should include, but not be limited to, identification of the following:
- s. Each and every fact upon which your statement is based;
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact;
- c. Each and every documentation of estimates of the amount loose paint and other debris currently in the drywell and/or torus; and
- d. Each and ew.f documentation of estimates of the amount loose
. paint and other debris that will be generated in the drywell and/or torus during the extended period.
Response
The answers to these questions are discussed in detail in YAEC Report 1696,' which has,previously been provided to SOV.
> Interrogatory No.118.
Please describe in detail each and every reason why Vermont Yankee asserts in item 18 identified in its response to Vermont laterrogatory (Set No.1) No. 79 that 'A pipe break in either region could result in significant debris from either fibrous insulation damage, or the dislodging of a quantity of loose paint from the upper drywell, but not in both.' The description should include, but not be limited to, identification of the following:
- a. Each and every fact upon which your statement is based; and
- b. ' All evidence in Vermont Yankee's possession or of which Voimont Yankee has knowledge that Vermont Yankee believes establishes each such fact.
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Response
a,
The answers to these questions are discussed in detail in YAEC Report s
1696, which has previously been provided to SOV.
t Interrogatory No.119.
Please describe in detail each and every reason why Vermont Yankee I
t asserts in item is identified in its response to Vermont laterrogatory
~
(Set No.1) No. 79 that "a break of a main steam line in the upper -
m 1
drywell region could directly affect loose paint in this region... thus there could be paint debris but no gross failure of NUKON lasula-tion? The description should include, but not be limited to, iden-tification of the following:
- s. Each and every fact upon which your statement is based; and
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact,
Response
l l
The main steam lines are covered with mirror (metallic) insulation, not NUKON lasulation; therefore, a break in the upper drywall nesion would not c'
-yield fibrous insulation debris. This fact is discussed in detail in YAEC Report 1696, which has previously been provided to SOV.
c 1
Interrogatory No.120.
Please describe in detail each Lnd every reason why Vermont Yankee asserts in item 13 Identified in its response to Vermont Interrogatory
~
(Set No.1) No. 79 that "as long as essentially all loosely adhering topcoat is removed by the start of the operating cycle... it would be reasonable to assume that most of the remaining topcoat would remain intact long after the first 30 seconds into LOCA? The description.
. should include, but not be limited to, identification of the following:
w
- a. Each and every fact upon which your statement is based;
- b. - All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes
- each such fact; and -
- c. Eitherthetechnicalqualifications(education,employmenthistory, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the
- person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely on the expertise of any person for the reason. 4 a,
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- Resporse:
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The answer to this interrogatory is contained in detail in YAEC Report 1696, which has previously been provided to SOV.
Interrogatory No.121.
Vermont Yankee asserts in item 18 identified in its response so Vermont Interrogatory (Set No.1) No. 79 that the RHR and core
.[
spray pumps have a " clean screen NPSH margin.' Please describe in detail the NPSH margin that would exist based on current ECCS strainer cleanness and the postulated ECCS strainer blockage caused F
by insulation, paint chips and other debris.
Response
l No such calculation has been performed, because, for the reasons set forth l
above (see the response to Interrogatory No.119), debris from. fibrous
' insulation and debris from paint chips in material quantity are not additive.
In addition, in order to make any such calculation,- SOY would have to provide specifications for 'other debris,' as Vermont Yankee bus been unable to hypothesire any other debris that would be produced by the accident scenarios analyzed.
i i
Interrogatory No.122.
Vermont Yankee asserts in item 18 identified in its respoese to Vermont Interrogatory (Set No.1) No. 79 that 'The lower portion of lt the torus (under the water line) does not appear to be experiencing much failure of topcoat.' Please describe in detail the topcoat failure
- in the lower portion of the torus ' The description should include, but not be limited to, identification of the following:
a.
Each and every fact upon which your descriptics is based;
Yankee has knowledge that Minont Yankee believes establishes each such fact;
- c. 'The extent of topcoat failure anticipated to occur during the' extended period; and
- d. The significance of each and every potential topcoat failure mode (e.g., delsminating, peeling, flaking, etc.)-
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' Response:
An laspection of the lower section of the toras (under the waterline) was conducted during the 1989 refueling outage. This inspection was conducted by divers from Underwater Construction of Essex, Connecticut. The results of the inspection were given verbally to the Maintenance Department manager in charge of the job, who then relayed this information to the -
Operations Department.~ The satisfactory results were document on VYOPF 3
4115.04 dated 3/19/89.
i The divers' inspection revealed that the topcoat paint in the lower torus -.
area (under the waterline) was in very good condition with no deterioration identified.
l Based on the condition of the topcoat paint in this location to date, and =
the near constant environmental conditions of the lower section of the torus
_l l
(under the waterline), no rapid deterioration of the topcoat paint would be
- anticipated between the normal inspection intervals of approximately 18 months.
a., b., c. and d. See above, f
-L Interrogatory No.123.-
Please describe in detail each and every reason for the assi'mption in reference I (General Electric Report MDE-184-0355 Revision 1 Effects of Fiberglass insulation Debris on Vermont Yankee ECCS Pump Performance, dated January 1986) of item la identified in its response to Vermont Interrogatory (Set No.1) No. 79 that " shredded d
[NUKON insulation) debris is assumed to be uniformly distributed throughout the suppression pool." The description should include, but not be limited to, identification of the followine:
- a. Each and every fact upon which your statement is based; id,
' Yankee has knowledge that Vermont Yankee believes establishes each such fact.
Response
Please see MDE-lg4-0285, Rev.1, page i1:
l
'Most of the insulation shreds generated by impinsement of the two-phase jet will become entrained in the high velocity steam and air flow field in the drywell and will be carried along through the vent system to the torus. Since the steam and air flow are nearly evenly.
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x distributed to the 8 vents, it is expected that the debris will also be nearly evenly distributed.' The insulation will be blown'out of the vents and into the pool along with the air and because of the motion of the pool during pool swell, can be expected to be well distributed -
in the water."
Interrogatory No.124.
Please state each and every reason why Vermont Yankee states in its
. response to Vermont Interrogatory (Set No. 2) No. I that " financial or ~
other incentives offered to such [ future maintenance] personnel" are
- such a small component" of overall costs. For each reason, please; 3
i
- n. State each and every fact upon whleh your reason is based;-
- b. Describe all the evidence in Vermont Yankee's possession or of I
which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact; and 7
- c. For each reason,- either provide = the technical qualifications (education. employment. history.- licenses - and - certificates, 1-experlence, or other information that Vermont Yankee contends-estat.ishes the qualifications of the person), of any person on whe e expertise Vermont Yankee relies for the reason or state that Ver.nont Yankee does not rely on the expertise of any person for.
the reason.
~
Response
l SOV. appears to have failed to understand our response to Interrogatory (Set
- No. 2) No.1, which explained the methodology by which forecasts of overall future costs of power are calculated and why,~ given such a methodology, no discrete ' sum could be ascribed to (or had been calculated for) a minor; constituent. - What we said was:
The projected 8.6 ' cents per kilowatt, hour-figure to which ly-reference is made includes an amount of 1.3 cents per kilowatt hour.
for the aggregate of "O&M" (operations and maintenance) expense, i.
This value is a surrogate for the projected cost of the items included within it, and is estimated by applying econometric trend factors to:
historically-determined O&M costs. Specifically, the cost projections utilized 1987 power costs as a basis for projecting power costs through the year 2012. In the projection.1937 power costs for the above three categories were escalated, beginning in 1933, at annual inflation rates equivalent to those provided in the State of Vermont 20 year Electric Plan in effect during 1937: 4.92% for 1988,4.34% for 1989, 5.27% for 1990,~ 5.77% for 1991 and beyond, it* f l
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- This method of estimating future power costs (as opposed to a method that attempts to project the finite cost of each constituent)is used because, while uncertainties affecting the projection of such specific items so distant in the future tend to produce a result of deceptive precision, experience shows that over-time the various
. uncertainties tend to offset one another such that the application of-.
econometric values more accurately predicts the aggregate cost of-future O&M. Given the manner in which the figure was calculated, no specific portion of it can properly be attributed to such a small -
component as the one specified in this interrogatory.'
In this context, the pending interrogatory is just a way of repeating the; question: What is the dollar amount assigned to this item for the future years?
There is no deterministic answer to this question, as our prior response made '
t reasonably clear, Moreover, it is accepted amongst professionals in the field of power cost forecasting that any attempt to isolate and quantify such minor constituents is a futile pursuit leading to a false perception of precision of the result.-
As was stated in the original response to Vermont laterrogatory (Set 2)
No.2, the projected KWH Cost in 2007 of 8.6 cents is derived from the Company's Long Range Financial Model. The basic methodology behind this model is to use historical (recent) actual costs to project future costs by making some assumptions on econonic parameter such as inflation and interest rates. As part of this process, individual expense items are grouped into larger expense categories to facilitate the modeling of future years expenses. As stated in a previous response, to do otherwise would produce a result for individual expense items portraying a false sense of accuracy.
'While over time individual expense items may vary, projecting expenses of items as a group tends to offset this variability.
Qualitative confirmation that the particular item in question will be small, however, can be derived thus: As a component, salaries comprised ap-proximately 8% of expenses in 1989, overtime comprised approximately 1%
of expenses in 1989, and premiums paid to individuals for special licensing requirements comprised approximately 0.4% of expenses in 1989.' From this one might conclude that approximately 0.4% of estimated power costs in the year 2007 ($300.2 million), or $1.2 million, is the amount of such premiums, some fraction of which might be allocated to personnel involved in main-tenance acJ~ities, in fact, we advance no such quantitative response; only that this item vill be so small.
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Interrogatory No.125.
Please state each and every reason why Vermont Yankee states in its response to Vermont laterrogatory (Set No. 2) No. 2 that component refurbishment or replacement costs are 'such a small component" of.
overall costs. For each reason, please:
- a. State each and every fact upon which your reason is based;-
- b. Describe all the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yanke:;
believes establishes each such fact; and
- c. ~ For each reason, _either provide the technical' qualifications (education, employment history, licenses and certificates.
_ experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely on the expertise of any person for the reason.
Objection:
Vermont Yankee objects to this interrogatory, on the ground that it is not --
relevant to the admitted contention.
Response
Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee offers the following information:
- No such statement was made. Rather, the response to Interrogatory No.
2 was intended to refer the reader to the prior (,xplanation of the forecast methodology, from _which it could be concluded that no explicit quantifica-tion of such a component can be derived.
~ The individual component costs referred to are for financial projection -
purposes-grouped into the larger category Operating & Maintenance Expense, which represents the aggregate of a myriad of expense components relating to maintenance, operations, radiation protection, and the like, that individually on a relative basis are a small component of overall power cost.
The projection. included a level of $15.8' million in.1988 for these expenses, growing to $44.7 million in the year 2007, for an aggregate of
$801.9 million over the projection period. These costs are operating expenses, and do not include capital expenditures, which were projected at
$14.2 million in 1988.
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Interrogatory No.126.
Please define the phrase " fundamental changes' as it is used by=
Vermont Yankee in its response to Vermont Interrogatory (Set No. 2)
No. 3.
Response
The phrase " fundamental changes
- was used with its ordinary English meaning.
]
Interrogatory No.127.
Please define the phrase " discrete changes
(
Response
]
)
The clause 'no discrete changes or additions to the existing maintenance capacity; were required to account separately for the extended operating period" was used with its ordinary English meaning.
J l
laterrogatory No.123.
Please describe in detail the meaning of the phrase 'to account separately" as is used by Vermont Yankee in its response to Vermont Interrogatory (Set No. 2) No. 3.
l
Response
}
The clause 'no discrete ch:nges or additions to the existing maintenance capacity were required to account separately for the extended operating l
period" was used with its ordinary English meaning.
l laterrogatory No.129.
l Does Vermont Yankee consider Revision No.17 of AP 0021 (6/1/90),
in which the entire system of processing and controlling preventive and corrective maintenance requests is changed, to be a fundamental i
change to the methods of its maintenance program? -
If your answer is anything other than an unqualified affirmative, then
. please state every reason for your answer and for each reason, please.
- a. State each and every fact on which your reason is based; L
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i bc Describe all of the evidence in Vermont Yankee's possession or of iI which Vermont Yankee has knowledge that Vermont Yankee i
contends establishes each such fact; and E
- c. For each' reason, either provide the technical qualifications
)
H (education, employment history, licenses and certificates, experience, or other information that Vermont Yankee oostends
)
establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that
. Vermont Yankee does not rely on the expertise of any person for the reason.
Objection:
Vermont Yanket objects to this interrogatory on the ground that it is not relevant to the admitted contntion.
Response
Without waiving the foregoing objection, but rather expressly relying-upon' the same, Vermont Yankee offers the following information:
It is not a fundamental change in either the mission of the maintenance program or the methods by which that mission is accomplished, as the phrase was used in the context in which it was used, it is, rather, an evolutionary-enhan:ement to the maintenance program, the implementation of which was l
I and is unconnected to the prospect of cor:tinued operation in the period 2007 h-to 2012.
L laterrogatory No.130; Please describe in~ detail each and every basis for the generalization
- stated at page 27 of Attachment 2 of the application,"[m)any of the active (moving or rotating) mechanical components... are expected i
to wear cut and be f triodically replaced during the plant's operating
(.
E lifetime? For every basis for the statement, please:
L
- a. State each and every fact on which your reason is based; i
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that-Vermont Yankee -
. contends establishes each such fact; and
- c. For each. reason, either provide the technical qualifications
- (education, - - employment. history, licenses and c;rtificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that
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'i Vermont Yankee does not rely on the expertise of any person for 4
the reason.
Response
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Please see the response to laterrogatory (Set No. 2) No. 7.
1
+
- That ' active (moving.or rotating) mechanical components
- experience wear is a precept of such common knowledge, based on the phenomenon called friction, that we would have no idea where to begin noting 'ench And.
every basis-for the generalization? ~ Referring to a source previously identified, thef Naval Training Command " Machinist's Mate 3&2' Rate i
Training Manual NAVTRA 10524-D, states in the chapter regarding pumps on page 81:
"Because of high rotational speed and the necessarily close clearc 7, the running' surfaces of both the impeller hub and the casing at that point are subject to relatively rapid wear."
(Emphasis added.) This is the reason that pump manufacturers include separate wear rings for replacement at substantially lower cost than replace -
l ment cf the pump itself, laterrogatory No.131.
Vermont Yarikee states at page 2? of Attachment 2 of the application,
'[m)any of the active (moving ar rotating) mechanical components...
are expected to wear out and be periodically replaced during the plant's operating lifetime." In response to Vermont laterrogatory (Set.
No. 2) No. 7. It is stated that "no exhaustive list was in mind or
'available when the generalization cluoted was made, and to prepare such a list would require extensive original research? Please describe in detail each and every reason why Vermont Yankee believes that g,
" mechanical components.. expected to wear out" will be "periodi-l cally' replaced during the plant's operating lifetime" when no list of such ' expected" components is maintained. For each reason, please:
-f
- a. State each and every fact on which your reason is based;
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and e
- c. For each reason, either provide the technical. qualifications (education, employment history, licenses and certificates, m
experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on 3
' whose expertise Vermont Yankee relies for the reason or state that 99 n,.
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Vermont Yankee does not rely on the espertise of any person for l
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the reason.
l
Response
Please noe the response to laterrogatory (Set No. 2) No. 7.
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laterrogatory No.132.
l 5
Please describe in detail each aswl every eeulpment with a probability of being replaced prior to 1988 as identified in the Termont Yankee 1'
Nuclear Power Corporation, Plant Equiperent Depreciation Study.
Final Report, September 24,1984* (referonos: Vermont Yankee's response to Vermont Interrogatory (Set No. 2) No. 7).
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relesant to the admitted contention.
Response
Without waiving the fots ing objection, but rather espressly relying o
upon the same, Vermoni Yankee supplies the following information:
}
Please see the document referred to.
I laterrogatory No.133.
{
Vermont Yankee asserts in its response to Vermont Interrogat>>ry (Set No. 2) No. 8 that experience with aggressive inspection and main-tensnee programs in the Fossil Fuel Electrical, Nuclear Submarine and Weapons Grade Nuclear Production industries indicates that a service life w 'll' excess of 40 years can be anticipcted. Please describe in det. 4 he is for that assertion. The description should include, but not be limited re. Identification of the ? sliowing:
- a. Each and every fact upon which four statement le h,ed; i
- b. All evidence in Vermont Yankee % possession or of a t.ich Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact;
- c. Differences between the commercial nuclear power industry and the 'other* Industries; and 4
- d. Each and every component subject to aggressive inspection and maintenance programs in the 'other" industries that is substantially
+
- 100 -
I
~
4 simliar to componenu in the Vermont Yankee nuclear power plant.
Objection:
Vermont Yankee objects to this laterrogatory on the ground that it is overly broad, unduly burdensome, and if answered literally would require the
' performance of extensive original research.
Response
Without waiving the foregoing objections, but eather emptently relying upon the same, Vermont Yankee offers the following information:
The precept in question is, insofar as we are aware, universally accepted by those experienced in the nuclear power field. One (but by no means the only) basis for this assertion can be determined from a review of the documents cited in SOY laterrogatory (Set 2) No. 8.b. Additional bases can be derived from research amongst the available literature in the field, which is plentiful, in general, the only ' differences' between nuclear power plants and the other industrial applications that have contributed to this aggregate esperknee are those components that are subject to special, nuclear-related At Vermont degradation phenomena, namely high neutron flux fields.
Yankee, the only components that are subject to such esposure are the reactor pressure vessel and internals. Apart from such special considerations, however, pumps, motors, valves and piping at Vermont Yankee perform essentially the same functions, are exposed to essentially the same degradation phenomena, and are expected to demonstrate essentially the same capacity to cutlive ' design lives
- as pumps, motors, valves and piping at non nuclear facilities,
- a. Our response to SOY Interrogatory (Set 2) No. 3.b provides the references that supply the facts and bases for our statement,
- b. Our response to SOY laterrogatory ($et 2) No. 3.b provides the references that supply the facts and bases for our statement.
- c. The commercial nuclear power industry derives the heat necessary to prodsce electricity from nuclear fuel. The fossil fuel electric industry derives the host necessary to produce electricity from the combustion of fossil fuels._ The Weapons Grade Nuclear Material Production ladustry derives weapons grade materials from nuclear fuel and target material.
All three industries, however, use similar equipment, for which simliar inspection techniques are employed, such as:
- 101 -
I I
I L
- Pumps, Heat exchangers,
- Valves,
- Pipes,
- Motors,
$witchgear, 1
- Belays, i
- Cables, Support / structural steel, Instrumentation.
l
- d. See above.
laterrogatory No.134.
Please define the' phrase ' current design condition
No. 8.
L
Response
The quoted phrase means the as-designed condition or capacity, as from time to time applicable.
laterrogatory No.135, f
Please describe in detall every specific method by which the Vermont Yankee maintenance program " demonstrates the capacity to preserve l
the equipment in its current design condition' as Vermont Yankee uses this phrase in Vermont Interroptory (Set No. 2) No. 8. State each and every reason why you believe each method makes such a.
demonstration, and foi each reason, please:
- n. State each and every fact on which your reason is based;
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and j
- c. For y* reason, either provide the technical qualifications
'educaton, employment history, licenses and certificates, 1
experience, or other information that Vermont Yanisse contends establishes the qualifications of the wraon), of any person on whose expertise Vermont Yankee relies for the reason or state that Yermont Yankee does not rely on the expertise of any person for the reason.
l t
- 102 -
i
i Objection:
Vermont Yankee objects to this interrogatory on the grouni that, as framed, it is overly broad and unduly burdensonne, and virtually impossible to answer.
Response
Without walving the foregoing objection, but rather empressly relying upon the same, Vermont Yankee offers the following information:
Vermont Yankee has demonstrated the capacity to maintain (or replace) equipment over the last 18 years. The method. employed at the moment are those contained in the Vermont Yankee Maintenance Program. The methods that will be employed are those, together with such additions, deletions, modifications and improvements as from tire to time Vermont Yankee determines should be niide. Evidence of the sm'ess of Vermont Yankee in maintaining equipment includes the lifetime VYNPS capacity factor, the low level of LCO required shutdowns, and SALP assessment scores.
Interrogatory No. IM.
Please describe in detail each and every case in which vibration analysis may detect the chemical and biological effects age degrada-tion meel,anism (reference: Vermont Yankee's response to Vermont Interrogatory (Set No. 2) No.10).
Response
Vermont Yankee incorporates by reference its objection and response to Vermont Interrogatory (Set No. 2) No.11, which this interrogatory appears to duplicate.
Interrogatory No.137.
Please describe in detail each and every reason why Vermont Yankee asserts in its response to Vermont laterrogatery (Set No. 2) No.17 that current oil change frequencies have been developed in part *to assure that equipment failure due to an oil related cause is quite unlikely.' The description should include, but not be limited to, identification of the following.
=
- a. Each and every fact upon which your statement is based;
- b. All evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee believes establishes each such fact;
- 103 -
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i
- c. The methodology used by Vermont Yankee to determine the likelihood of equipment failure due to an oil related cause; and
- d. Each and every criteria used by Vermont Yankee to determine the acceptable level of equipment failure potential due to an oil j
related cause, j
Objection:
l Vermont Yankee objects to this interrogatory, on the ground that it would appear to be a complete duplication of laterrogatory ($et No. 2) No.17, the response to which is contained therein.
Response
i Without waiving the foregoing objection, but rather expressly relying j
upon the same, Vermont Yankee notes that the reason why it has asserted the
)
)
quoted motivation for developing oil change frequencies is because such was i
and is the case.
]
I leterrogatory No.133.
j Please describe in detail each and every docume ntation of YNSD's i
evaluation of infrared thermography for Vermont Yankee (reference:
)
Vermont Yankee's response to Vermont laterroget try (Set No. 2) No.
21). The description should include, but not be lim 'ted to, ihntifica-tion of the following:
)
- s. Each and every document produced;
]
- b. Each and every individual involved;
- c. Eitherthetechnicalqualifications(education,employmenthistory, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the
- 1 person), of any person on whose expertise Vermont Yankee relies for the evaluation or state that Vermont Yankee does not rely upon the expertise of any person for the evaluation; and
- d. Each and every method by which infrared thermography is evaluated by YNSD.
?
Objection:
Vermont Yankee objects to this laterrogatory on the ground that it is not relevant to the admitted contention.
- 104 -
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p Aessoue.
Without waiving the foregoing objection, but rathe expressly relying upon the same, Vermont Yankee supplies the following h. formation:
- a. Memo, R.D. Lucler to A. C. Kadak, ENO SRV M/85 *laftsrod Survey of Vermont Yankee - January 28,1985', dated February 14,1985.
Memo, R.D.Lucier to A.C.Kadak, ENG SRY 299/85 *lafrared Survey of Vermont Yankee 18-85', dated October 23,1985.
. l Memo, R.D.Lucler/E.A. Sawyer to S.R. Miller ENO SRY 62/86 'Em-bcdded 1.att Evaluations', dated March 17,1986.
Memo, R.D.Lucier/E.A. Sawyer to S.R. Miller, ENG SRV 174/86 ' infrared Survey - August 29,1986, dated September 24,1986.
t Memo, R.D.Lucier/E.A. Sawyer to S.R. Miller, ENG SRV 65/87 ' March j
I 27,1987 Infrared Survey *, dated April 6,1987.
i Memo, R.D.Lccler to S.R. Miller, PED 155/89 'IR Survey At Vermont Yankee On April 14,1989*, dated May 2,1989.
1 Memo, R.D.Lucier to S.R. Miller, PED 229/89 ' Inspection of Vermont Yankee's UPS-A', dated July 5,1989.
- b. See authors identified in response to part (a) above.
- c. There are no nationally recognized standards, qualifications, or certifica-tior.s for thermogaphers. Yankee persos.nel are trained and provided with on-the-job training in identification and interpretation of images as well as I
photographic techniques. Minimum requirements for personnel performing thermographic surveys for Yankee Atomic Electric are:
l l
Bachelor of Science degree or Equivalent Experience 3
l 5
l Completion of an Infrared Operator Training Course of a duration of 32 i
hours minimum f
=
30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of on the-job training while performing a survey l
l
- d. YNSD used two quantitative modes of evaluatho, employing the Inframetrics Model 525 infrared scanner; l.
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. V
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i Isotherm - latensifies areas of the name temperature using a onlibrated i
marker that indicates the temperature difference with the scene being l
acanned.
l 1
l Line Scan - Presents a thermal profile of any horisontal line in the scene j
ahowing temperatore differences on the horisostal lies.
laterrogatory No.139.
Please describe in detail each and every case in which bearing temperature trending sky detect the vibration age degradation snochanism (reference: Vermont Yankee's response to Vermont later.
3 togatory (Set No. 2) No. 31).
i Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
i
Response
Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
Please see the response to SOV's laterrogatory (Set No. 2) No. 32.
.I laterrogatory No.140.
Please describe in detail the methodology employed and identify the procedures used to evaluate bearing temperature trends for the purpose of predictive maintenance (reference. Vermont Yankee's response to Vermont Interrogatory (Set No. 2) No. 31).
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
e Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee offers the following information:
PROCEDURES:
+
- 106 -
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DP 4153 Operations Departu.ent Procedure Plant Performance Monitoring
- 2. OP 0150 Responsibilities and Authorities of Operations Department Personnel
- 3. AP 0021 Maintenance Requests
- 4. Conduct of Malatenance Activities METHODOI.OGY:
Attached is a flowchart showing the flow of information concerning bearing temperature trending for the purpose of predictive maintenance. 40 1. The following describes the procedural requirements and methods used to identify degraded or failed bearing temperature results, collect data, generate trends, evaluate results, lasse corrective maintenance L
requests, and revise the preventive maintenance program.
Operatioes Department Procedure DP 4133 Plant Performance l
l Moellorlog.
l' The purpose of this procedure is to establish the Plant Performance i
Monitoring Program. This program's function is to monitor various plant parameters to detect process inefficiencies so that corrective action can be l
planned, and to monitor equipment / system performance.
]
This involves analysis of specific parameters to determine the existence and cause of any adverse trends in those parameters. The Shift Engineers are responsible for generating those methods considered necessary for the j
collection, processing, and analysis of the data used, l
This methodology is detailed in the Plant Performance Monitoring Methods Manual. This manual is approved, lasued, and periodical;, reviewed by the Senior Operations Engineer.
Bearing Temperature trends for some pumps (Reactor Feed Pumps, Condensate Pumps Cire. Water Pumps, and Cire. Water Booster Pumps) were incorporated into the Plant Performance Monitoring Program October 1989.
However, the trend data covers the period from August 1933 to the present.
The Shift Engineer obtains the pump bearing data from the OD printout each week the plant is operating at full power.
The method used to monitor the condition of the pump bearings h to monitor the temperature difference between bearings in similar service. An example of this is N Reactor Feed Pumps. The temperature difference
- 107 -
~
i 1
i between the Outboard and laboard Bearings, the Motor Outboard and Motor l
Inboard Bearing and the Outboard and Forwa a. Thrust Bearings are used for l
the Reactor Feed Pump. Individual temperature points for each pump are compared to each other to identify any change la ladividual bearing temperatures. A representative copy for the 'A' Reactor Feed Pump is attached. (Attachment 140-2.)
)
Once per month the Shift Engineer visually inspects all graphs to deiermine if a change in ne normai i,e.ds or ao -, -im 6.
1 occurred. It a change from the moriral trend has occurred he will alert the
~
Maintenance Department so that they may develop plans for the future repair l
work. He will also alert Operations Departenent Management so they may j
develop a plan for continued plant operation.
A monthly Plant Performance Report is generated which includes the bearing temperature trends. This report is distributed to various plant personnel' for review. The personnel include Ops. Management, and Maintenance Management.
Operstless Procedure OP0lS0 Responsibilities and Authorities of i
t Operstless Department Pernoemel.
.t OP 0150 delireates the responsibilities and authorities of members of the Operations Department dwing all phases of plant operations.
This procedure requires the licensed operators to review current plant
?
i conditions via trend recorders, strip charts, alarm typer printouts, and other plant parameters as required.
l Certain bewing temperatures are monitored via trend charts on Control Room Panel 9 21. These points have high alarm limits which result in annunciation of annunciators and a typed alarm message on the control room alarm typer. ERFIS also monitors the condition el those computer poluts.
The operator may request a list of all points in alarm condition. The ERFIS computer has a trend build function which allows an operator to quickly
+
build a special historical trend for any eclected computer points including l
bearing temperatures.
The operator has the ability to visually trend the bearing temperatures on CRP 9 21 recorders for a thirteen hour period. If a longer visual trend is desired uslag strip charts, the operator may unroll the strip chart without interrupting the trend recorder to the period when new strip chart paper was 4
inserted into the recorder. Used strip charts are stored in the rear of the control room. Periodically the Operations Administrative Assistant sends the t
- 108 -
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i strip charts to Document Control for processing per AP 6407 as these strip charts are life of plant documents.
I The Operators tre trained to identify changes in plant equipment trends.
if a trend change is identified, the operator investigates the change (down--
i scale point, or increase in bearing temperature, erratic reading, failed i.
recorder) e MR is submitted per plant procedure AP 0021 Maintenance Requests. He will then attach a yellow sticker to the recorder identifying that s MR has been submitted on the piece of equipment.
i AP 0021 Malateannee Regnests, t
These provide direction and means for the identification, assignment, planning, approval, tracking and documentation of maintenance efforts associated with plant equipment. The procedure has been divided into two distinct sections; Corrective Maintenance and Preventive Maintenance.
Anyone wurking at the Plant site who identifies a need to have corrective maintenance performed on a piece of plant equipment will initiate this r.rocess by filling out the applicable information on the Corrective Main-j tenance Request Form, AP 0021.01.
I Preventive Maintenance is initiated by the responsible department using the Preventive Maintenance Request Form. AP 0021.02.
it should be understood that this procedure only describes and controls the maintenance effort. There are a number of additional administrative procedures that interface with the work process.
AP 0200 Conduct of Malatesance Activities.
+
i This outlines the Maintenance Department program. The Malatenance L
Program is intended to be dynamic in that the program is reviewed periodl.
cally by the Maintenance Supervisor and other Department personnel to l
Identify needed changes in the preventive raalatenance, surveillance, and specific component maintenance requirements as identified through the equipment trending, Root Cause Failure Analysis, NRC, INPO, and original equipment manufacturer directives, and through changes identified by personnel performing maintenance.
l The Maintenant:e Department Record System (Visi-Record Cards) is l'
designed to provide a current record of scheduled and unscheduled main-tenance and modification activities performed on equipment in the plant.
- 109 -
a j
I laterrogatory No.141.
Please describe in detail each and every lastance, not limited to 'in-leakage" as defined by Vermont Yankee, in which leakage detection
- may be used for predictive maintenance (reference:
Vermont l
Yankee's response to Vermont laterro story (Set No. 2) No. 33). The description should include, but not be led to, identification of the l
following:
- a. Each and every structure, system or component for which leakage i
detection is performed; j
- b. Each and every procedure in which leakage detection is required I
for predictive maintenance;
- c. The date(s) that the requirements for leakage detection was(west) f incorporated into the praedures-
- d. Each and every documentation of leakage detection evaluation used for predictive maintenance within the past five years; and
- e. Each and every age degradation mechanism that is believed by Vermont Yankee to be identified by leakage detection and the j
applicability to each and every structure, system or component.
Objection:
l Vermont Yankee objects to this interrogatory on the ground that it is not A
relevant to the admitted contention.
l
Response
L Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
- a. Since the scope of this interrogatory covers instances 'in which leakage detection may be used,' the conter.t of the response must be very broad to t
cover all lastances. Clearly, leakage can occur in any instance where a i
pressure differential exists. Therefore, rather than attempt to identify all such instances, the following exemples of leakage-related predictive main-tenance are provided.
- 1) lastrument line excess flow check valves (various systems).
- 2) Hydraulic Shock Suppressor, t
- 3) Control Rod Drive Accumulators.
1
- 110 -
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- 4) Reactor Recirculation Pump Seal Leakage.
t
$) Reactor Pressure Yeasel Head Saal Lankage.
t
- 6) Primary Containment Penetration Leakage.
it is further noted that, per the Vermont Yankee Surveillance Preventive and Corrective Maintenance Program, evidence of leakate is evaluated during the performance of all surveillance procedures and appropriate action is laisinted.
- b. 1) OP 4378.
- 2) OP $20).
- 3) OP 4111.
- 4) OP 2110.
$) RP 4399
- 6) OP 4029 & 4030.
Note: Surveillance, preventive and corrective maintenance pra:tices are covered in AP 0310 and AP 0200.
t
- c. Since leakage detection is a basic surveillance technique applied in the j
above examples, it has been generally in use at YY since the origin..] issuance L
of these procedures.
- d. Documentation is contained in completed surveillance sheets maintained i
for the above-cited procedures, in completed MRs and in the documentation associated with the Appendix J Leak Rate Test program, and perhaps elsewhere as well, i.
- e. The intent of the above leakage surveillance is to determine the integrity lL of the subject pressure boundaries on an on solas basis. As such, pressure boundary degradation will be detected regardless of the degradation mechan-i ism. Age degradation mechanisms espected to be detected include such things as long-term vibration induced degradation and long-term radiation or thermal embrittlement degradation of flexible sealing materials.
- 111 -
I i
leterrogats,ry No.142.
' l Please describe in detall each and every case in which insulation resistarice (meggering) evaluation may detect the chemical and biological effects age degradation mechanism (reference: Vermont Yankee's response to Vermont laterrogatory (Set No. 2) No. 37).
Objection:
b t
Vermont Yankee objects to this iteerrogatory on the ground that it is not relevant to the admitted contention.
j
Response
Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
Please see the response to Interrogatory (Set No. 2) No. 38, i
laterrogatory No.143.
j Vermont Yankee identified, in its response to Vermont Interroga-r tory (Set No. 2) No. 55, twenty-one recommendations for enhance-ment of the maintenance program. Vermont Yankee further stated in response to Interrogatory No. $$ that "[t)he implementation of each of these recommendations is underway." For each recommendation, please:
i t
t.
- a. Describe in detail how each recommendation is being imple-mented.
}
- b. State the completion date for the implementation of each recommendation;
- t
- c. Describe in detail the current status of the implementation of each recommendation,
- d. Describe l'. detail the impact such recommendations will have on l
j.
the maintenance program during the extended period.
Response
RECOMMENDATION A) - Expedite implementation of MEL develossent.
- a. The issue of MEL implementation was assigned to a Superintendeit and L
tracked via our commitment tracking process.
l
- 112 -
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- b. The safety classification of all components appearing on PalD's has been
'I completed and safety classification worksheets prepared. This information is in the process of being eatered into the computerised data base (*QLISP).
This data entry is scheduled to be completed by the end of 1990.
- c. See response to b.
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post-2007 period. Any impact it will have will be indistinguishable from its impact in the pre-2007 period, and by the year 2007, other and different specific program: and procedures may be in place.
RECOMMENDATION B) - Develop an in Service Testing procedure for vibration analysis. Program to include pume vibration testing including establishment of baselines, testing and analysis of data, and maintenance of
- records,
- s. This issue was assigned to the responsible departmenu and tracked via our commitment tracking process.
- b. Plant procedures OP 0202, AP 0206 and AP 0164 were reviewed, revised and/or developed ~ as a result nf this effort. Those procedures provide -
guidance in the recommended areas.
- c. See response to b.
- d. It is not expected that implementation of this recommendation will have l'
any particular impact on maintenance durini; the post-2007 period. Any 4
impact it will have will be indistinguishable from its impact in the pre 2007 j
period, and by the year 2007, other and different specific programs and procedures may be in place.
RECOMMENDATION C) - Review present trending efforts and document -
tasks into formal program. Establish mechanism to r.asure data is reviewed i
and analyseo on a periodicity most beneficial to the site's needs. A feedback for potential changes to Preventive Maintenance functions needs to be emphasised,
- n. Procedure changes have been made to address this recomme.wdation.
Section 4.6 of AP 0200 Tonduct of Maintenance Activities' was devoicoed c-to specifically describe the trending process used by the Maintenance Department. Similarly Section B of procedure - AP 0310, ' Surveillance,
- 113 -
i
.- ~
I l
Preventative and Corrective Maintenance Program' descrites the lastrumen-tation & Control Department setpoint trending process,
- b. The aforementioned procedure changes have been completed,
- c. n/a i
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post.2007 period. Aty Impact it will have will be indistinguishable from its impact in the pre 2007 period, and by the year 2007, other and different specific programs and procedures may be in place.
RECOMMENDATION D)- Determine the need for expansion of the existing 4
valve repacking program to include critical valves outside the Drywell.
- n. The recommendation is being implemented by expanding the existing valve repacking program to include critical valves outside the drywell.
- b. The program was implemented by the issuance of Vermont Yankee Valve Packing PM Schedule (printout of 7/12/90).
- c. Revisions to the program are complete. The program is an ongoing.
i
- activity,
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post 2007 period. Any impset it will have will be indistinguishable from its impact in the pre 2007 period, and by the year 2007, other and different specific programs and procedures may be in place.
RECOMMENDATION E) - Perform a detailed assessment of the existing PM program to validate present periodicities in view of operating history, f
trends, industry experience, and vendor recommendations. Review should also identify areas where effectiveness can be maximl ed and additional components and systems be included. Furthermore, efforts abound be expended to formally document the programs via procedure.
- s. Periodicities are implemented through AP 0200 Conduct Of Maintenance
- Program,
- b. Completed by the issuance of AP 0200 Rev.12 (4/30/90).
1
- c. Not applicable.
- 114 -
i g i
d 'It is not expected that implementation of this recommendation will have.
any particular impact on maintenance during the post 2007 period. Any impact it will have will be indistinguishable from its impact in the pre-2007 period, and by the > ear 2007, other and different specific programs and 1
procedures may be la place.
RECOMMENDATION F) - Develop a centrallaed work listing that correlates outstanding 1&C and Maintenance activities. Listing abound provide a level of detail and management review to ensure control of work backlog. This work schedule can also be used for planning activities for forced outage contingencies.
.i
- a. This issue is included in the scope of our Improved Information Tech-nology effort. Interim plans are in place that use our Operations Planning Coordinator and daily meeting process to plan for outage contingencies,
- b. Vendor proposals are currently being evaluated,
- c. Evaluation of vendor proposals is expected to be complete in ap-proximately 1 month. The development of VY specific acreens and the data base is expected to be essentially complete by mid-1991.
- d. It is not expected that implementation of this recoinmendation will have any particular impact on maintenance during the post-2007 period. Any impact it will have will be indistinguishable from its impact in the pre-2007 period, and by the year 2007, other and different specific programs and procedures may be in place.
RECOMMENDATION G) - Develop cost / benefit analysis concerning an automated maintenance / management system, which will include a com-puterised system with the ability to sort work requests by priority, MR date
.... A further enhancement would include development of an automated Visi Card records system,
- s. This issue is included in the scope of our Improved Laformation Tech-nology effort.
- b. In progress.
- c. Approximately 12/31/90 or before,
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post-2007 period. /.av
- 115 -
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m_.
___m_.__
I i
/
)
J impact it will have will be ladistinguishable from its impact in the pre-2007 period, and by the year 2007, other and different specifie programs and procedures may be in place.
RECOMMENDATION H) - Develop a Malatenance Request prioritization
)
system consistent with the needs of Operations.
4 s
- a. A method of ensuring MR prioritiantion consistent with the needs of Operations has been developed and is currestoy in use. As set forth la the l
latest revision of AP 0021 (' Maintenance Requests'), one of the primary I
responsibilities of the Operations Planning Coordinator is,the priorittaation
{
of MRs.
- b. See response to a, l-
- c. See response to a.
l
- d. It is act expected that implementation of this recommendation will have any particular impact on maintenance during the post-2007 period. Any impact it will have will be indistinguishable from its impact in the pre-2007 i
period, and by the year 2007, other and differerit specific programs and procedures may be in place.
i RECOMMENDATION I) Evaluate the esisting MR procedure and provide recommendations to resolve problems existing in delays in processing flaws
.... Development of planning guidelines and PMT guidelines may provide a more consistent package,
- s. A task force was assigned to address these issues.
- b. The task force effort is complete and the p.xedure was revised and l
l.
issued on 6/1/90.
- c. See response to b.
l
- d. It is not espected that implementation of this recommendation will have any particular impnet on maintenance during the post-2007 period. Any impact it will have will be indistinguishable from its impact in the pre-2007 period, and by the year 2007, other and different specific programs and procedures may be in place.
RECOMMENDATION J) - Using the centralised work list, identify priority items that can be worked during a forced outage and develop work packages accordingly. A periodic review should oe done to verify status.
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l d
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- a. An additional responsibility of the Operations Planning Coordinator is the j
identification of 'stop list' items. The purpose of this *stop list' is to establish a list of mainteoni;;e activities that may be accomplished during any unplanned outt.ge. Work packages are prepared by the appropriate repair l
departments for items on this list. In addition, the list la reviewed periodi.
cally.
t
- b. See response to a.
l
- c. See response to a.
i
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post 2007 period. Any impact it will have will be indistinsulshable from its impact in the pre-2007 period, and by the year 2007, other and different specific programs and procedures may be in place.
I PtECOMMENDATION K) - Develop a blanket or umbrella tagging process for outage system related work.
e
- a. This recommendation was addressed via a task force effort.
- b. Plant procedure AP 0140 allows umbrella / blanket tagging.
- c. n/a T
- d. It is not expected that implementation of this recommerdation will have any particular impact on maintenance during the post 2007 period. Any impact it will have will be indistinguishable from its impact h the pre-2007 period, and by the year 2007, other and different specific programs and.
procedures may be in place.
t RECOMMENDATION L) - Redefine the existing MR process to ensure that all packages associated with safety related equipment be reviewed in hard copy form prior to declaration of system operability. There is a need for a better system of turnover of MRs from Maintenance and IAC to Operations.
- a. A task force was assigned to address those issues.
- b. The task force effort is complete and the procedure was revised and isss.ed on 6/1/90,
- c. n/a. See response to b.
- 117 -
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post 2007 period. Any impact it will have will be indistinguishable from its impact in the pre-2007 period, and by the year 2007, other and different specific programs and procedures may be in place.
RECOMMENDATION M) - Develop enhancements to the Maintenance Request process in the area of post malatenance tasting using INPO Good Practice 37-028 as a guide.
- s. A task force was assigned to address these issues,
- b. The task force effort is complete and the procedure was revised and lasue' o: 6'l/90.
- c. n/a See response to b.
- d. It a not espected that implemenation of this recommendation will have any particular impact on maintenance during the post 2007 period. Any impact it will have will be ladistinguishable from its impact in the pre-2007 period, and by the year 2007, other and different specific programs and procedures may be in place.
RECOMMENDATION N)
Assess the need for assigning a dedicated individual the task of Preventive / Predictive Maintenance Coordinator,
- s. This recommendation is still under consideration.
- b. Efforts are underway to reassess the Maintenance department organlas-tion. included in this assessment will be a review of the need for the escommended position, or similar position.
- c. It is expected that the evaluation will be completed by the end of the
- year,
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post-2007 period. Any impact it will have will be indistinguishable from its impact in the pre-2007 period, and by the year 2007, other and different specific programs and procedures may be in place, RECOMMENDATION 0) - Develop a site guideline for determination of root cause analysis.
- 118 -
4 i
- n. YY's ' User's Guide for Root Cause Analysis' has been developed and was re-issued for plant wide use on 4/4/90.
- b. See response to a.
t
- c. See response to a.
- d. It is not expected that implementation of this recommendation will have ony particular impact on maintenance during the post 2007 period. /.ny impact it will' ave will be indistinguishable from its impact in the pre.2007 period, and by the year 2007, other and different specific progrr.as and procedures may be in place.
RECOMMENDATION P) - Develop a formal planning guideline and PMT matrix checklist.
a.
A task force was assigned to address these issues.-
- b. The task force effort is complete and the procedure was revised and issued on 6/1/90,
- c. n/a. See response to b.
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance durlag the post 2007 period. Any impact it will have will be indistinguishable from its impact in the pre-2007 period, and by the year 2007, other and different specific programs and procedures may be in place.
RECOMMENDATION Q)- Perform a manpower / workload assessment of the Maintenance and 1&C groups to identify need for additional resources,
- a. An assessment of manpower / workload is done both on an annual and continuing basis. On an annual basis it is done as part of the Company budget prooses, and on a contlaving basis it is done as reviews of workload indicate that additional resources are needed.
l
- b. See response to a,
- c. See response to a,
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post-2007 period. Any I
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impact it will have will be indistinguishable from its impact in the p e 2007 period, and by the year 2007, other and different specific programs and i
procedures may be in place.
I i
RECOMMENDATION R) - Provide a broad based spare parts essessment i
including a review of the existing process for procurement, indealas and j
.i storage.
l
- a. Vermont Yankee has recently completed a review of the procurement function.This review resulted in the establishment of a separate organisation I
to accomplish the procurement enginwring function. The procedure changes that occurred have resulted in a method for broad based'anesesment of spare parts needs and ensures proper stocking levels are maintained, j
- b. See the response to subpart a.
- c. See the response to subpart a.
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post 2007 period. Any impact it will have will be indistinguishable from its impact in the pre 2007 period, and by the year 2007, other and different specific programs and
. procedures may be in place.
1 RECOMMENDATION S) - Establish a program to identify obsolete equip-ment and develop necessary documents for replacement.
- a. Under advisement. P2 ease see the response to SOY interrogatories Set !
l No. 65 and 66.
- b. See the response to subpart a.
- c. See the response to subpart a.
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post-2007 period. Any impact it will have will be indistinguishable from its impact in the pre 2007 period, and by the year 2007, other and different specific programs and procedures may be in place.
l RECOMMENDATION T) - Revise AP 0021 to reflect the actual method each department updates the equipment history records.
t
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- s. AP 0021 has been reviwd to more specifically identify the method to be used for updating equipreent history records. This issue will also be re-visited during the implementation of our computerised malatenance/ materials management system, i
- b. See response to a;
- c. The revised AP 0021 procedure was issued on 6/1/90.
- d. It is not expected that implementation of this recommendation will have any particular impact on maintenance during the post 2007 period. Any impact it will have will be indistinguishable from its impact in the pre 2007 period, and by the year 2007, other and different specific programs and procedures may be in place.
RECOMMENDATION U) - Prior to development of a centrallied work list, ensure establishment of a clear methodology of development and acceptability based on a review of the existing planning and scheduling roles and the interface with Operations,
- s. This is within the scope to of the Maintenance / Materials Management effort. A specification has been developed with Operations Department input and recognition of current work processes. This issue will be specifically emphasized during the implementation phase of the project.
- b. See response to a.
- c. The MMM project is expected to be implemented by mid-1991.
- d. It is not expected that implementation of this recommendation will hase any particular impact on maintenance during the post-2007 period. Any impact it will have will be indistinguishable from its impact in the pre 2007
)
period, and by the year 2007, other and different specific programs and 1
procedures may be in place.
laterrogatory No.144.
State all the safety standards that Vermont Yankee asserts are applicable to the resolution of this proceeding.
Response
j l
None.
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Vermont Yankee believes that the les.. standard by wl.ich the approval or disapproval of this application should be made is contained in 10 C.F.R.
I 50.92, which in turn incorporates the legal standards applicable to an original operating license to the extent that such standards are implicated by the proposed change in the license in question. The legal standards applicable to the grant of an openting license are, in the first instance, stated in 10 C.F.R. ) 50.57(a), plus scch other sections of the ratulation as may be incor-porated by reference therein. Section 50.57(a) contains 6 numbered sub-sections, of which 1-2 and 4-6 are topically not implicated by the proposed operating amendment, governed by the findings of the Commission in connection with the original grant of the Vermont Yankee, operating license, and therefore need not and may not be reconsidered in connection with this proceeding. The remaining subsection (10 C.F.k. i 50.57(aX3)) contains two subsections, to wit:
That there is reasonable assurance that the activities authorized by the operating license can be conducted without undue risk to the health and safety of the public, and That there is reasonable assurance that the activities authorized by the operating license will be conducted in accordance with the regulations of this chapter.
As to the first, the activities authorized by the operating license, as amended,is the coatinuance of the operation of VYNPS that has already been authorized, upon a finding that it can be conducted without undue risk to the health and safety of the public, through the year 2007 and that has already been conducted since 1972. In the absence of some change in the operations, or other physical coattraint snat would make such additione.1 operation not capable of being conducted without such undue risk-of which we know of none and of which none has been included within the scope of any admitted contention in this proceeding-this finding, too, need not and may not be reconsidered in connection with this proceeding.
As to the second, assessment of this legal standard is logically and legally impossible absent identification of sonne other Commission promulgated regu-lation that, ex Appothesi, will not be followed in the future. In the context of the admitted contention in this proceeding, SOY has not identified any other Commission regulation that establishes programmatic minima for the maintenance function ara we are (i) not aware of any and (ii) aware that the Commission is of the view that it has not yet promulgated any. Conse-quently, while i 50.57(aX3Xil) might be implicated given a reason to believe
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a that operation in the post 2007 period would not be conducted in accordance with some identifiable Commission regulation by an operating license amendment application seeking no other change la a license but empiration date, in this case it is not implicated because the subject of the contention is not also the subject of such a regulation.
. Please note that the two components of 10 C.F.R. I $0.57(aX3) are asymmetrical. The absence of a promulgated regulation authoritatively rotolving any debate on some technical parameter (for lantance, containment wall thickness) leaves a residuum for contention (under 10 C.F.R. 6 $0.57(aX3Xi)) that, absent a contended-for characteristic (such as four-foot thick containment walls), the facility is not capable of being operated v
without such undue risk. With respect to programmatic operational con-siderations that are the subject of i $0.57(aX3Xil), however, the regulation does not afford a corresponding residuum of authority to litigate the necessity of as-yet unestablished (by the Commission) requirements. Vermont Yankee believes, given the words chosen by the Commission, that this asymmetry was intentional.
As Vermont Yankee understands SOV's Contention Vil,it is based on the assumption that a condition precedent to the approval of the pending operating license amendment is a finding by the Commission or its tribunal that:
'That there is reasonable assurance that the activities authorised by the operat!ng license will be conducted without undue risk to the health and safety of the public,"
that is to say, a finding constructed by assembling the subject and verb of 10 C.F.R. ( $0.57(aK3Xil) to the object of 10 C.F.R. I 50.57(aX3Xi). (See, inter alia, the very next interrogatory.) Vermont Yankee believes that such a contention does violence to the grammar and logic of the regulation as promulgated. Vermont Yankte believes that,if the Commission had intended a requirement of such a finding, it would have included it in the regulation it promulgated, and Vermont Yankee believes that, had the %mmission intended such a requirement, it would not have promulgated i SLi?(aX3Xil) in the form in which it did. Vermont Yankee therefore believes that no such finding need be made.
Prescinding from the foregoing, were the adequacy of a program, such as the maintenance program, a litigable topic (given a cognizable, duly-promulgated regulatory standard), Vermont Yankee believes that the methodology for annessing whether there is reasonable assurance that the program conforms to the standard consists of an analytical comparison of the program to the standard, together with the commitments (if any) of the
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operator to comply with the Commisalon's regulations as from time to time promulgated, amended and authoritatively interpreted.
laterrogatory No.145.
Describe in detail the methodology that Vermont Yankee asserts will demonstraie that there is reasonable assurance that its malatenance O
program will provide adequate protection to the public health and i
safety in the extended period.
Response
At and for the reasons set forth in the rsaponse to foregoing inter.
[
rogatory, Vermont Yankee does not believe that such a finding has to be made, and consequently it is not prepared to state a position on the method-ology by which such a finding would be made, were such a finding to be made. To the contrary, Vermont Yankee has sought, repeatedly but without success, to elicit from SOY the methodology by which such a finding (or its negative) might be made, and SOY has alw been unable to answer the question.
1 laterrogatory No.146.
Please provide each and every reason why MR 90-0173, initiated on January 22, 1990, was presetted to Vermont in discovery on form VYAPF 0021.01, AP 0021 Rev.17, which did not 30 into effect until.
June 1,1990.
Objection:
Vermont Yankee objects to this interrogatory an the ground that it is not relevant to the admitted contention.
laterrogatory No.147.
i Please identify each and every maintenance request before June 1, 1990, which has been processed with foran VYAPF 0021.01, AP 0021 Rev.17.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
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Y
I-laterrotatory No.148.
Please describe in detail each and every reason why Vermont Yankee AWits VY 88 M and VY.89-MA did not uncover tH maintenance discrepancies or weaknesses described in Westec,Inc.'s S$FI findings, LRS Reports (as stated in sub-part j to Contention Yll) or the NRC healassaance Team Report. For each such reason, please:
- a. State each and every fact on which your reason is bued;
- b. Describe all of the evidemoe in Verssont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends estabinhes each such fact; and
- c. For each season, either provide the technical qualifications (education, employment history, liceanos and certificates, esperience, or other information that Vermont Yankee coatsads establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely on the expertise of any person for the reason.
Objectio.,
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention, laterrogatory No.149.
In response to Vermont's request for documents No,23, dated June 19,1990, Vermont Yankee provided form VYOPF 411*,04, Rev.18 Visual Inspection of Primary Containment Surfaces Data Sheet, dated September 29,1987. That form indicates 'some paint scalint above the upper spray ring header
- Stone & Webster's coating spxialist -
asserts in item 13 identified in Vermont Yankee's response to Vermont interrogatory (Set No.1) No. 79 that 'According to Yankee Atomic personnel, the loose coating bad been scraped off the walls two outages prior to the inspection but not during the last outage."
Did Vermont Yankee remove kil loose topcoat du* sng the 1987 outage?
- a. 8%te each and every fact on which your reason is based;
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Yermont Yankee contends establishes each such fact;
- c. Identify each and every documentation of Vermont Yankee's paint scaling evaluation (s) done as a result of laspection(s)le 1987; and
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- d. s.,.... M !c dan 45 and every neceptance criteria for visual inspection of prin..try contalament surfaces.
Responst:
No.
- a. Vermont Yankee did not remove paint from the drywell during the 1937 outage. This fact is established by the very information the $0V cites in this laterrogatory (completed form 4115.04).
- b. See the response to subpart a.
- c. See the response to subpart u.
- d. The formal acceptance criteria for drywell laspection is contained in OP 4115. It must be recognlied that the drywell inspection and closecut is performed by an experienced individual within the operations department.
Interrogatory No.150.
Does Vermont Yankee believe that removal of all loose topcoat material in the drywell and torus shouid be done during every outage that includes the opportunity to do an inspection of the drywell and/or torus?
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge th;t Vermont Yankee contends establishes each such fact.
Response
No.
- a. Based upon the amount of topoost that has been evidenced to fall between refueling outages, the recommendation from our evaluation work was to fully inspect and scrape any loose topcoat from the drywell and torus each refueling outage.
- b. The above referenced evaluation is documented in YAEC Report 1696, which has previously been provided to $0V.
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laterrogatory No.151.
Does Vermont Yankee believe that failure to remove allioow topcoat material in the drywell and torus, during every outage that includes the opportunity to do an inspection of the drywell and/or torus, has safety significance and has the potential to impair ECCS pump performance?.
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- s. State each and every fact on which your reason is based; and f
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
Response
No. See answer to laterrogatory No.150.
Interrogatory No.152.
l.
Does Vermont Yankee believe that failure to remove allloose topcoat
(.
material in the drywell and torus, during every outage that includes the opportunity to do an inspection of the drywell and/or torus, is indicative of "an aggressive inspection and malutenance program?'
If your answer is anything other than an unqualified negative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee' possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
L
Response
Yes. See answer to Intenosatory No.150, in addition, Vermont Yankee notes that the results of the most recent inspectiosi(September 12,1990) of these surfaces revealed very little addit!9nal peeling paint. This evidence tends to indicate that the Vermont Yankee program has been more than ade-
~'
quote and typically conservative.
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y Interrogatory No.183.
3 In response to Vermont's request for documents, Vermont Yankee
?
prov!ded the Visirecord preventive maintenance system form S-801, Preventive Maintenance Work Order, for 16' NBS check valves V2-
~
27A,28A,28B and 96A. That form requires 'stilman seal replace-ment at the end of every cela? Please state overy reason for this requirement, and for each retson:
t
- a. State each ead every fact t.n which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowleds. hat Variaont Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Interrogatory N.,154.
Please wacribe in detail the qualified life of the stilman seals for 16' NBS check valves V2-27A,28A,28B and 964.
Objetrwn:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Interrogatory No.155.
Identify all documents pertaining to the qualified life of the stilman -
seals for 16' NBS check valves V2-27A '28A,23B and 96A, Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
laterrogatory No.156.
In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-303 A, Machine Repair Record, for 16' NBS check valves V2-27A, 28A,28B and 96A. That form contains no stilman seal replacement during the operating cycles ending in 1987.
- 128 -
+
2]
s e
- n. Did Vermont Yankee perform the required seal replacement in 1987? If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- 1. State each and every fact on which your reason is based; y
- 2. Describe all of the evidence in Vermont Yankee's possession k
or of which Vermont Yankee has knowledge that Vermont 1
Yankee contends establishes each such fact; l
- b. Identify each and every documentation of Vermont Yankee's replacement of Stilman seals for 16' NBS check valves V2-17A.
28A,28B and 96A in 1987; and 4
^
- c. ' If the seals were not replaced 1987, describe in detail each and
- j every reason why the seals were not replaced in 1987.
j Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying ;
upon the same, Vermont Yankee supplies the following information:
There was no requirement of Stilman seal replacement in 1987. Stilman seal replacement each cycle for 16' NBS check valves -27A and -96A became 1
a requirement after the 1989 outage. Valves -28A and--28B did not have I
stilmen seats.
laterrogatory No.157.
Does Vermont Yankee believe that failure to replace the stilman seals
-i in 16" NBS check valves V2-27A,28A,28B and 96A at the end of every operating cycle has safety significance due to the potential to degrade containment integrity?
If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of j
which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
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?
m Objection:
r n
' Vermont Yankee objects to:this interrogatory on the ground that it is not -.
relevant to the admitted contention.
. Respone:
t Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
No. See NRC letter to VYNPC, NYY87-192, 8/19/83 and to Inter-rogatory No.'156, above.
leterrogatory No.158.
Does Vermont Yankee believe that failure to replace the stilman seals in 16' NBS check valves V2-96A at the end of every operating cycle.
L contributed to the failure in 1989 to initially pass its containment local leak rate test?
i If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of
' which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
I i
Objection:
l V rmont Yankee objects to this interrogatory on the ground that it is not.
relevant to the admitted contention.
7
Response
y I
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
?
No. See Vermont Yankee Primary Containment Testing,1989, at page 7.
j, Interrogatory No.159.
i Does Vermont Yankee believe that failure to replace the stilman seals in 16' NBS check valves V2-27A,2sA,28B and 96A at the end of every operating cycle is indicative of "an aggressive inspection and j
maintenance program?"
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I
);,
f
'If your answer is anything other than an unqualified negative, then please state every reason for your answer, and for each reason:
si-State each and every fact on which your reason is based; and =
b' Describe all of the evidence in Vermont Yankee's possession or of
y
Response
Please see the response to Interrogatory No.158.
p Interrogatory No.160.
In response to Vermont's reqv it for documents, Vermont Yankee provided the Visirecord preven ve maintenance system form S-801, Preventive Maintenance Work Order, for 16' NBS check valves V2-27B and %B That form requires"visualinspection of valve internals
- c' at the end of every cycle and directs the reader to "see check valve PM program file for actualinspection schedule and details."
- a. Please describe the requirement (s) for such visual inspection and t
l' state every reason for the requirement (s), and for each reason:
I
- 1. State each and every fact on which your reason is based; and t
- 2. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact,
- b. Describe in detail the valve PM program file,
- c. Deseribe in detail each and every inspection schedule and de:all f
for 16' NBS check valves V2-27B and 96B.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
\\<
Response
Without waiving the foresdag objection, but rather expressly relying upon the same, Vermont Y'akee supplies the following information:
This interrogatory is based on a false premise. The PM form does not g
L require visual inspection of valve internals at the end of every cycle. The L
PM form directs the Maintenance Clerk to initiate action for Maintenance e
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E Engineering to review the Check Valve Program File to determine which check valves are due for inspection during each refueling outage.
a, _ Requirements for check valve maintenance were developed based on VY-plant experience, using EPRI NP-5479, Application Guidelines for Check Valves in Nuclear Power Plants, January 1988, as a reference.
l 6, Infor'mation concerning inspection requirements for Y2-278 and -96B can be found in the Check Valve PM program file The check valve PM program file contains the Check Valve Inspection Check List, inspection Schedules,laspection Results, and background material.
- c. V2-27D: Unscheduled inspecilon in 1939; scheduled laspections in 1993 and 2003, Y2-96B: Unscheduled laspection in 1939; schedule inspections 1993 and 2003, laterrogatory No.161.
Please describe in detail the qualified life of the valve internals for.
16' NBS check valves V2-27B and 96B.
l l
Objection:
I l-Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Interrogatory No.162.
'l Identify all documents pertaining to the qualified life of the valve internals for 16' NBS check valves V2-27B and 96B.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention, laterrogatory No.163.
l In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-301, Preventive Maintenance Work Order, for containment isolation valves V20-32, 33, 94 and 95. That form lists no inspection and main-tenance requirements. Please describe in detail the requirement (s), if any, for such inspection and maintenance and state every reason for L
the requirement (s), and for each reason:
- 1. ' State each and every fact on which your reason is based; and l
1
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- = -. -.. -
1 1
1 L.
2.'
Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact, i
Objection:
l Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
l Without wal~ing the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
These valves are inspected and leak rate tested each outage as part of a Plant Technical Specification surveillance requirement.
Interrogatory No.164.
Does Vermont Yankee believe that failure to indicate the required preventive maintenance operations for containment isolation valves t
V20-82,33,94 and 95 on Visirecord preventive maintenance system
{
L form S-801, Preventive Maintenance Work Order, is indicative of 'an aggressive inspection and maintenance program?"
If your answer is anything other than an unqualified negative, then b
~ please state every reason for your answer, and for each reason:
l a.'
State each and every fact on which your reason is based; and b; Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee 1:
contends establishes each such fact.
y Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
i
?'
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
The Visirecords in question are records of the Maintenance Department, while the tests in question are within the responsibility of Engineering
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f
. Support Department. = The omission to record something not required'or.
g Intended to be recorded seems to us to have no relevance to whether or not 1
the maintenance program is aggressive.
laterrogatory No.165.
In response to Vermont's request for documents,' Vermont Yankee 4
prov'.ded the Visirecord preventive maintenance system form S-303 A, Machine Repair Record, for containment isolation valves V20-at 4. 94 and 95. That machine repais record indicates that no
.mpection and maintenance was done on those valves during the period November 12,1981 through September 9,1987. Does Vermont Yankee believe that failure to perform inspection and maintenance on cor.tair. ment isolation' valves V20-81,83,94 and 95 during a period of nearly six years is indicative of 'an aggressive inspection and maintenance program?"
If your answer is anything other than an unqualified negative, then please state every reason for your answer, and for each reason:
- n. State each and every fact on which your reason is based; and b.~ Describe all of the evidence in Vermont Yankee's possession or of l
which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
i.
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:-
L l-The question is based on a false premise; please see the' response to
(
Interrogatory No.163.
Interrogatory No.166.
f In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-t01, Preventive Maintenance Work Order, for containment isolation valves
- SB-16-19-7A,' 7B, 8, 9 and'10. That form lists no inspection and L
maintenance requirements. Please describe in detail the require-
}
ment (s), if any, for such inspection and maintenance and state every j
reason for the requirement (s), and for each reason:
4
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a.' State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; Objection:
t Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
1, Without waiving the foregoing objection, but rather expressly relying ~
upon the same, Vermont, Yankee supplies the following information:
These valves are inspected and leak rate tested each outage as part of a c
Plant Technical Specification surveillance requirement.
Interrogatory No.167.
Does Vermont Yankee believe that failure to indicate the required preventive maintenance operations for containment isolation valves SB-16-19-7A,7B,8,9 and 10 on Visirecord preventive maintenance.
system form S-801, Preventive Maintenance Work Order, is indicative of *an aggressive inspection and maintenance program 7*
If your answer is anything other than an unqualified negative, then please state every reason for your answer, and for each reason:
i a, ~ State each and every fact on which your reason is based; and
.t
- b. Describe all of the evidence in Vermont Yankee's possession or of which Ver;nont Yankee has knowledge that Vermont-Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
-1
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
The Visirecords in question are records of the Maintenance Department,.
while the tests in question are within the responsibility of Engineering 4
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~ Support Department. The omission to record something not required or -
a' intended to be recorded seems to us to have no relevance to whether or not the maintenance program is aggressive.
laterrogatory No.168..
1 In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-803A, Machine Repair Record, for containment isolation valves SB-16-19-7A,78,8,9 and 10. That machine repair record indicates that.
no inspection and maintenance was done on valve SB-16-19-7A during the period June 17, 1973 through. March 22, 1989. Does
. Vermont Yankee. believe that failure to perform inspection and maintenance on conta;nment isolation valve SB-16-19-7A during a period of nearly sixteen years is indicative of 'an aggressive inspec-tion and maintenance program?"
If your answer is anything other than an unqualified negative, then please state every reason for your answer, and for each reason:.
- a..' State each and every fact on which your reason is based; and-
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
. Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
,1 Please see above. The assertion that no inspection was performed is not correct.
Interrogatory No.169.
]
in response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-303A, Machine Repair Record, for containment isolation valves SB-16-19-7A,7B,8,9 and 10. That machine repair record indicates that no inspection and maintenance was done on valve SB-16-19-7B prior to March 25, 1989. Does Vermont Yankee believe that failure to perform inspection and maintenance on containment isolation valve
- 136 -
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$8-16-19-7B^ during a period of more than seventeen years is
- indicative of "an aggressive inspection and maintenance program?'
-If your answer is anything other than an unqualified negative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont. Yankee contends establishes each such fact, j
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not i
relevant to the admitted conteation.
l'
Response
b Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information.
Please see above. The assertion that no inspection was performed in not correct.
leterrogatory No.170.
In response to Vermont's request for documents, Vermont Yankee l,
provided the Visirecord preventive maintenance system form S-l.
303 A, Machine Repair Record, for containment isolation valves SB-16-19-7 A,7B 8,9 and 10. That machine repair record indicates that no inspection and maintenance was done on valve 58-16-19-9 during the period June i1,1962 through March 27, 1989. Does Vermont Yankee believe that failure to perform inspection and maintenance on containment isolation valve SB-16-19-9 during a period of-nearly seven years is indicative of N sagressive inspection and main-tenance program?"
If your answer is anything other than an unqualified negative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; snd
- b. Describe all of the evidence in Vermont Yankee's possession or of i
1which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
i
- 137 '
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i $bjection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
~ Response:
~
Without waiving the foregoing objection, but rather expressly relying.
upon the same, Vermont Yankee supplies the following information:
Please see above. The assertion that no inspection was perfoe:Jed in not correct.
laterrogatory No.171.
o In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-303 A, Machine Repair Record, for containment isolation valves SB-16-19-7A,7B,8,9 and 10. That machine repair record indicates that l
. no inspection and maintenance was done on valve SB-16-19-10 since -
July 25,1977. Does Vermont Yankee believe that failure to perform inspection and maintenance on containment isolation valve 5B 19-10 during a period of nearly twelve. years is indicative of "an s
aggressive inspection and maintenance program?"
If' your answer is'enything other than an unqualified negative, then please state every reason for your answer, and for each reason:
4
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of L
which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
i Objection:
4 Vermont Yankee objects to this interrogatory on the ground that it is not l
relevant to the admitted contention.
l l
-\\
Response
\\
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
,s.
Please see above. The assertion that no inspection was performed in not j
correct.
-ii
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n Interrogatory No.172, l
In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preveritive malatenance system form S-801,
' Preventive Maintenance Work Order, for containment isolation valves SB 16-19-6A and 6B. That form lists no inspection and maintenance requirements. Please describe in detail the requirement (s),if any, for -
such inspection and maintenance and state every reason for the 0
requirement (s), and for each reason:
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
. j Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not
- relevant to the admitted contention.
Response
l' Without waiving the foregoing objection, but rather expressly relying-l' upon the same, Vermont Yankee supplies the following information:
l
~ These valves are inspected and leak rate tested each outage as part of a Plant Technical Specification surveillance requirement.
interrogatory No.173.
Does Vermont Yankee believe that failure to indicate the required preventive maintenance operations for containment isolation valves SB-16-19-6A and 6B on Visirecord preventive maintenance system-form S-801, Preventive Maintenance Work Order, is indicative of 'an aggressive inspection and maintenance program 7' r
L If your answer is anything other than an unqualified negative, then.
L please state every reason for your answer, and for tch reason:
I
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
- 139 -
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4 Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
L
, Response:
Without waiving the foregoing objection, but rather expressly relying i
upon the same, Vermont Yankee supplies the following information:
i n
The Visirecords in question are records of the Maintenance Department,'
while' the te.m question are within the responsibillry of Engineering Support Department. The omission to record something not required or intended to be recorded seems to us to have no relevance to whether or not the maintenance program is aggressive, laterrogatory No.174.
'In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-803A, Machine Repair Record, for containment isolation valves SB-l 16-19-6A and 6B. That machine repair record indicates that no
- inspection and maintenance was done on valve SB-16-19-6A during the period October 19,1973 through March 22,1989. Does Vermont-Yankee believe that failure to perform inspection and maintenance on containment isolation valve SB-16-19-6A during a' period of more than
- fifteen years is indicative of "an aggressive inspection and maintenance program?'
If your answer is anything other than an unqualified negative, then
~
- please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; and
- b. : Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont' Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
~
Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
- 140 -
6 I
I i
s Please set above. The assertion that no inspection was perforsned in not
- correct.
I laterrogatory No.175. -
in response to' Vermont's request for documents, Vermont Yankee ji' provided the. Visirecord preventive maintenance system form S-L 303A, Machine Repair Record, for containment isolation valves SB-L 16-19-6A and 6B. That machine repair record indicates that ne L
inspection and maintenance was done on valve SB-16-19-6B during the period October 1 1977 through March 22,1989. Does Vermont Yankee believe that failure to perform inspection and maintenance on 7,.
contsiument isolation valve SB-16-19-6B during a period of more than eleven years is indicative of "an' aggressive inspection. and maintenance program?'
If your answer is anything other than an unqualified negative, then please state every reason for your answer, and for each reason:
l
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
l:
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
j.
Response
~
.Without; waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
Please see above. The assertion that no inspection was performed in not correct.
Interrogatory No.176.
I In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-801, Preventive Maintenance Work Order, for containment isolation valve SB-6. That form indicates a requirement for seat ring inspection and adjustment or replacement, if-necessary,' on a' refueling outage frequency. The Visirecord preventive maintenance system form S-
- 803A, Machine Repair Record, for containment isolation valve SB-6 indicates that no inspection and maintenance was done on that valve
- 141 -
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'during the 1989 outage. The Vistrocord preventiv<, maintenance y
system form S 303B, Summary of Preventive Maintenance done, for
-I containment isolation valve SB-6 indicates 'PM cancelled due to m*
corrective maintenance performed during :1989 outage?
Does
. Vermont Yankee agree that such inconsistencies in maintenance records are indicative of a breakdown in the maintenance program?
- ^
If our answer is anything other than an unqualified affirmative, then p.
- state every reason for your answer, and for each reason:
-E
- a. wate each and every fact on which your reason is based; and 1
- b. Describe all of the evidence in Vermont Yankee's possession or of C
which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
s Objection:
Vermont Yankee objects to this intterogatory on the ground that it is not relevant to the admitted contentioor
[
y'
Response
p s
j Without waiving the foregoiq ebjection, but rather expressly relying -
upon the same, Vermont Yankee supplies the following information:
t.
y
- Containment isolation valves SB-16-19-6 and 7 comprise one set of 3 sets
{
j of parallel isolation valves, which att leak rate testad each outage as part of y
~ the Plant Technical Specifications reqairement for penetration X-25. If the b,
penetration fails the leak rate test, the.*M Work Order directs the Depart-lJ ment to inspect the seat rings and adjus' or replace them'as necessary, in 4
j 1987, penetration X-25 passed the local leak rate test 'after' corrective H
maintenance on SB-16-19-6 and 7. In 1981, the penetration passed the leak rate test, after corrective maintenance was performed on the four other s;
valves in the penetration. Therefore, no other maintenance was required for
?
SB-16-19-6 and 7.
t Vermont Yankee recognizes that the entry on the PM Record Card is am-W biguous and does not clearly record the scope of the maintenance performed on penetration X-25 during the Tech. Spec. surveillance in 1989. Ambiguity
[
la the entry of one of the many maintenance records os file is not indicative lt of a breakdown in the maintenance program. However, in an effort to L
improve the maintenance record process, the Department has created the position of Maintenance Technician and filled that position in 1990. Part of L
his responsibility includes review of the PMR and CMR closeout records to 3
ensure improved documentation ~on the VISI record.
- 142 -
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s
. l The absence of a history of repeated maintenance'on the containment isolation valves is indicative of a successful inspection and maintenance program. The absence of corrective maintenance during any period indicates that _the work performed was effective in restoring those valves to their original condition.-
f laterrogatory No.177.
In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-303A, Machine Repair Record, for containment isolation valves SB-
- 6. That machine repsir record indicates inspection and/or main-tenan.;e was done on valve SB-6 only once since February 3,1960.
Does Vermont Yankee believe that failure to perform inspection and maintenance on containment isolation valve SB-6 more than once during a period exceeding ten years is' indicative of "an aggressive inspection and maintenance program?"
If your answer is anything other than an unqualified negative, then please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont. Yankee supplies the following information:
Please see the response to laterrogatory No.176. The premise of this question is factually incorrect.
Interrogatory No,'178.
In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-801, Preventive Maintenance Work Order, for containment isolation valve 1 SB-1. That form indicates a requirement for seat ring inspection and adjustment or replacement, if necessary, on a refueling outage
- 143 -
1 1
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frequency. The Visirecord preventive analatenance system form S-303A, Machine Repair Record, for containment isolation valve SB-7 indicates that no inspection and mainte;see was done on that valve j
during the 1939 outage. The Visirec.h preventive maintenance system form S-303B, Summary of Prr<entive Maintenance Done, for containment isolation valve SB 7 andicates *PM cancelled due to corrective maintenance perforrad during 1939-outage."
Does -
Vermont Yankee agree that such inconsistencies in maintenance E
record are indicative of a breakdown in the maintenance program?
If your answer la anything other than an unqualified affirmative, then
' I please state every reason for your answer, and for each reason:
i
- a. State each and every fact on which your reason is based; and I
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee -
L contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying -
upon the same, Vermont Yankee supplies the following information:
l L
- Please see the response to Interrogatory No.176.
I L
Interrogatory No.179.
In response to Vermont's request for documents, = Vermont Yankee provided the Visirecord preventive maintenance system form S-303A Machine Repair Record, for containment isolation valves SB-L 7.
That machine repair record indicates that inspection and/or-maintenance was done on valve SB-7 only once since February 3, 1980. Does Vermont Yankee believe that failure to perform inspec-tion and maintenance on containment isolation valve SB-7 more than i
once during a period exceeding ten years is indicative of "an aggres-sive inspection and maintenance program 7*
L If your answer is anything other than an unqualified negative, then please state every reason for your answer, and for each reason:
j
- a. State each and every fact on which your reason is based; and i
- 144 -
L
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I
~
1
- b. Describe all of the evidence in Vermont Yankee's possession or of j
which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to this laterrogatory on the ground that it is not 1
d
. relevant to the admitted contention.
j l
Response
0 Without walving the foregoing objection, but rather espressly relying l upon the same, Vermont Yant:ee supplies the following information:
Please see the response to Interrogatory No.176.
Interrogatory No.130.
In response to. Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-301, i
Preventive Maintenance Work Order, for 3" NBS gate valve V2-77.
That form requires valve inspection ' approx. every third refueling."
Please state every reason for this requirement, and for each reason:
- s. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of -
which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
l Objection:
i l
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
l.
Without waiving the foregoing objection, but rather espressly relying-upon the same, Vermont Yankee supplies the following information:
V2-77 is a motor operated, main steam, drain valve and the every third refueling cycle inspection pertains only to the motor operator.- The periodic-ity of motor operator inspection derives from the inception of operations, was l'
based on the judgment of the Maintenance Department at the time, and has been validated by experience since. The valve is leak rate tested each outage as part of Technical Specification requirements. Our recently improved inspection procedure for the motor operator using MOVATS is designed for the eighteen month refueling cycle.
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- 145 '
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laterrogatory No.181.
l Has Vermont Yankee reviewed and determined to be correct, since
[
Vermont Yankee adopted a refueling outage cycle of approximately e
once each eighteen months, the required inspection frequency
(* approx. every third refueling *) for 3' NBS sete valve V2-777 If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
- a. Statt each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of
- [
Objection:
Vermont. Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
kuponse:
Without walving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
Yes. See the response to Interrogatory No.180.
Interrogatory No.132.
In response to Vermont's request for documents, Vermont Yankee provided the Visirecord preventive maintenance system form S-801, Preventive Maintenance Work Order, for 1-1/2' Circle Seal check l
valves V72-89B,89C and 103. That form requires
- visual inspection of valve internals' at the end of every cycle. Please state every reason for this requirement, and for each reason:
- s. State each and every fact on which your reason is based; and l
E
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not r
relevant to the admitted contention.
4
- 146 -
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Response
With'out waiving the foregoing objection, but rather expressly relying.
upon the same, Vermont Yankee supplies the following information:
SOV misreads the preventive maintenance requirements as not iorsa on the VISI Record Form S-801. The form requires the following:
' Perform visual inspection of valve internals. Completion of ' Check Valve Visual Inspection Checklist' is required. See check valve PAf program for actual inspection schedule and details.'
(Emphasis added.) The check valve PM program requires periodic inspection on a interval determined by the prior maintenance history of these valves.
Further, f or valve V72 89C, an additional maintenance requirement has been added based on the leak rate history of this valve. See the response to Interrogatory No. 20.
Interrogatory No.183.
In response to Vermont's request for documents, Vermont Yankee provided the-Visirecord preventive maintenance form S-803A, Machine Repair Record, for 1-1/2' Circle Seal check valves V72-89B,89C and 103. That form contains no record of inspection and maintenance prior to March 16,1989. Does Vermont Yankee believe that failure to perform inspection and maintenance on containment isolation valves V72-89B,89C and 103 prior to March 16,1989 is
. indicative of "an aggressive inspection and maintenance program?"
If your answer is anything other than an unqualified negative, then-please se every reason for your answer, and for each reason:
a, State each and eury fact on which your reason is based; and
- b. Describe all of the evideee in Vermont Yankee's possession or of which Vermont Yankee h.:,s knowledge that Vermont Yankee
- contends establishes each such fact.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving the foregoing objection, but rather expressly relying upon the same, Vermont Yankee supplies the following information:
- 147 -
1
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i As we believe SOY to be aware (and, indeed, to possess copies of), two a
. Machine Repair Records exist for the subject valves. One for contains the March 16,1989 entry identified in this interrogatory. The second form lists -
L other valves in addition to the subject valves and.contains records of ~
l.
maintenance performed on these valves prior to March 16,1989. In addition,~-
these valves are included: within the Vermont Yankee 14ak Rate Test
+
t Program and are leak rate tested each refueling outage. Therefore, the.-
assertion in the interrogatory that VY has " fail [ed] to perform inspection and maintenance en containment isolation valves V72-898,89C and -103 prior L
to March 16,1989' is demonstrably false.
l
?
Interrogatory No.184, in response to Vermont's request for documents,' Vermont Yankee provided the Visirecord preventive maintenance system form S-301 Preventive Maintenance Work Order, for 1-1/2' Circle Seal check valve V72-89C. That form requires disanembly and inspection of
. valve internals and replacement of O-rings "every two outages?
-3 Please state every reason for this requirement, and for each reason:
- a. State each and every fact on which your reason is based; and
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee-contends establishes each such fact.
N Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention, e
' Response:
Without waiving the foregoing objection, but rather expressly ' relying upon the same, Vermont Yankee supplies the following information:
This PM is a new (1989) maintenance requirement created as a result of Vermont Yankee's experience during 1984 and 1939 regarding particulate loading of this particular valve. Further, SOY erroneously reads this PM to require replacement of O-tings every two outages. The PM requires that the O-rings be ' replace [d] as necessary?
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Interrogatory No.186.
t Has Vermont Yankee reviewed and determined to be correct, since Vermont Yankee adopted a refueling outage cycle of approximat 'y.
once each eighteen months, the required inspection frequency ('evt v two outages") for 1-1/2" Circle Seal check valve V72-89C?.
3 If your answer is anything other than an unqualified affirmative, then please state every reason for your answer, and for each reason:
a.-: State each and every fact on which your reason is based; and i
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee h
contends establishes each such fact.
Objection.' -
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
l' j.-
.Without waiving the foregoing objection, but rather expressly relying l>
upon the same, Vermont Yankee supplies the following informat. ion:
l Yes. Please see the response to Interrogatory No.184. This 'PM was established as a result of the leak rate history of this valve..The current i
outage cycle is consistent with the requirements of this PM.
I Interrogatory No.186.
Please describe in detail the qualified life of the O-rings for 1-1/2" Circle Seal check valve V72-89C.
Objection:
l L
Vermont Yankee objects to this interrogatory on the ground that it is not
' relevant to the admitted contention, laterrogatory No.137.
Identify all documents pertaining to the qualified life of the O-rings.
~
for 1-1/2" Circle Seal check valve V72-89C.
i
- 149 -
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3 Objection:
- Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
]
Interrogatory No. ISS.
J Please describe in detail how the " excessive seat leakage,' listed as the
' Description of Problem / Symptom' on Maintenance Request 87-0787 J
for Valve FW-288, was determined to exist.
c Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
d
. ithout waiving the foregoing objection, but rather expressly relying.
W t-t upon the same, Vermont Yankee supplies the following information:
p p
j.
Exceulve seat leakage was identified by Opemtions during leak rate.
testing of FW-96A, No quantitative estimate of the leak rate was determined or documented. Senior Operations personnelidentified the leak. MRs 85-2007 and 87-0787 and the Operations MR Los book are the only documents which identify the leak. Please see the response to laterrogatory No.192, below.
Interrogatory No.189.
Please identify the maintenance craftsperson(s) who determined the L
existence of the.* excessive seat leakage" listed as the ' Description of b
. Problem / Symptom' on Maintenance Request 87-0787 for Valve FW-28B.
.)
{
Objectie ni L
[
l' veiLat Yankee objects to this interrogatory on the ground that it is not.
E relevant to the admitted contention.
(
L Interrogatory No.190.
' Please identify all documents which record the existence of the L
" excessive seat leakage" listed as the ' Description' of. Problem /
Symptom' on Maintenance Request 87-0787 for Valve FW-28B.
L i
- 150 -
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..l Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
laterrogatory No.' 191.
Please describe quantitatively the rate at which the valve seat of Yalve FW-0238 was leaking:
- a. At the time Maintenance Request 87-0787 was initiated on April 27,1987.
,f j
- b. At the time just before tl.e work of Maintenance Request 87-
=
0787 was accomplished in March,1989.
- Objection:
Vermont Yankee objects to this interrogatory on the ground shat it is not relevant to the admitted contention.
Response
Without waiving this objection, but rather expressly relyits upon the same, Vermont _ Yankee provides the following information:
Valve FW-28B is neither required to be leak rate tested nor (during the times in question) capable of being leak rate tested. Consequently, the quantification sought by this interrogatory is not available. Moreover, contrary to the implication of this interrogatory, it is not known that the valve (or the " valve seat") was " leaking" in the leak rate test context; please see the response to Interrogatory No.192, below.
laterrogatory No.192. -
Please state each and every reason why the seat leakage of Valve FW-028B was not repaired in the 1987 teiueling outage. For each reason, please:
y
- a. State each and every fact on which your reason is based;
- b. Describe all of the evidence in Vermont Yankee's possession or of which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and
- c. Eitherprovidethetechnicalqualifications(education, employment history, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the
- 151 -
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person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon i
the expertise of any person for the reason.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving this objection, but rather expressly. relying upon the tsine, Vermont Yankee prosides the following information:
As noted above, valve FW-28B is not required to be, and is act cape.ble l:
of being, leak rate tested. However,in October of 1985, another valve (valve I
L FDW 96A) was being leak rate tested pursuant to a procedure that called for (i) closure of an upstream isolation valve (valve V-29B), and (ii) draining of the line to be tested, inadvertently, valve V-29B was apparently not fully closed.~= During the ensuing attempt to drain the line in preparation for the e
leak rate test for valve FDW-96A, it was noticed that some liquid back-leakage was flowing through valve FW-28B. Because of a number of factors, including the source of the differential pressure being experienced (as a result of liquid head alone), the design of the. valve, the probable fSw rate -
N through -29B, and others, this indication of liquid backleakage dd not necessarily indicate that valve FW-28B was incapable of performing its design containment isolation function. Nonetheless, a maintenance request (MR 85-2007) was written for the inspection of the valve, MR 85-2007 did not appear on the 1985-86 Outage Work List. The reasons for this omission are not presently known.
1 In 1987, the MR 85-2007 was rewritten as MR 87 0787 pursuant to the-revision to procedure AP 0021. It did appear on the 1987 Outage Work List.
with a priority of '3'(the lowest priority) but it was not performed because (i) of the existence of iteers with a higher priority and (ii) of an indication on the 1987 Outage Worktht that not all of the pressure retaining parts that.
~
might be required r.
a' ailable. The MR was performed during the 1989 outage.
Vermont Yankee also observes that, during the current refueling outage.
valve FW-28B is belns replaced with a different design of valve that is capable of being leak rate tested.
- 152 -
t
[
. (i-t, laterrogatory No.193.
- Plena state each and every reason why the seat leaka6e of Valve FW-028B, discovered in April 1987, was not repaired before March 1989, considering FW-028B is an inboard containment isolation valve. For
. each reason, please:
- a. State each and every fact on which your reason is based;
- b. Describe all of the evidence in Vermont Yankee's possession or of 4
which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and
- c. Eitherprovidethetechnicalqualliications(education. employment histor), licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the person), of any person on whose expertise Vermont Yankee relies -
for the reason or state that Vermont Yankee does not rely upon i
the expertise of any person for the reason.
Objection:
Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention.
Response
Without waiving this objection, but rather expressly relying upon the same, Vermont Yankee provides the following information:
Please see above. The only ' leakage" that was discovered (in 1985, not.
1987) was that described in the response to laterrogatory No.192.
laterrogatory No.194.
Does Vermont Yankee agree with the statement from LER 89-07 at page 3, as it was meant to apply to the as-found condition of containment penetration X-9B:
'The inboard isolation valve V2-288, even though not tested, will provide an isolation function in combination with V2-96A."
If your answer is anything other than an unqualified negative, then please state every reason for your answer considering Maintenance Request 87-0787, and for each reason:
L
- a. State each and every fact on which your reason is based;
- 153 -
t
":j i
R b
- b. Describe all of the evidence in Vermont Yankee's possession or of
- J 4_.
which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and 1
L
- c. Eitherprovidethetechnicalqualifications(education, employment-history, licenses and certificates, experience, or other information -
that Vermont Yankee contends establishes the cualifications of the
.y person), of any person on whose expertise Vermont Yankee relies for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
Objection:
[
Vermont Yankee objects to thi.s interrogatory on the ground that it 4 not
- relevant to the admitted contention,
Response
~
Without waiving the foregoing objection, but rather expressly relying -
Upon the same, Vermont Yankee supplies the following information:
Please see SER NYY 83-192, August 19, 1983, and the response to interrogatory No.10, above.
4 Interrogatory No.195.
Does Vermont Yankee believe that failure to correct the " excessive
' seat leakage" of containment isolation valve FW-028B for 23 months
- (from April 1987 until March 1989) is indicative of 'an aggressive inspection and maintenance program?"
i If your answer is anything other than an unqualified negative, then
. please state every reason for your answer, and for each reason:
- a. State each and every fact on which your reason is based; i
- b. Describe all of the evidence in Vermont Yankee's possession or of
'which Vermont Yankee has knowledge that Vermont Yankee contends establishes each such fact; and
- c. Either provide the technical qualifications (education, employment history, licenses and certificates, experience, or other information that Vermont Yankee contends establishes the qualifications of the -
nerson), of any person on whose expertise Vermont Yankee relies i
for the reason or state that Vermont Yankee does not rely upon the expertise of any person for the reason.
i
- 154 -
I
ff:
Dil
.j
+
.J e
i Objection:
)
3 Vermont Yankee objects to this interrogatory on the ground that it is not
. relevant to the admitted contention.
Response
6
. Without waiving this objection, but rather expressly relying upon the name, Vermont Yankee provides the following information:
o 3
L Yes. As described above, the condition asserted in the interrogatory is an inapt description of the conditbn that resulted in the writing of the MR.
't That an MR was written at all for the condition observed in 1985 does L
demonstrate 'an aggressiv:: ficpection and maintenance program?
l t.
'f l
lr j -.
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i A
5 k
3 u
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i
- 155 -
i 1
l l
f
i l
ttack. vets l
)$ 1 Average Annual Employment History of VY Mainteamace tr'> art-ment.
l 39 1 Average Annual Employment of Engineering Support De>.artment.
I 40-1 Maintenance / Engineering Support Job Emporience.
66 1 Letter from Margaret L. Ryan, CMer Editor, Nucleonics Week, to Francis J. Helin of VYNIYl dated 3/27/9?.
t i
81-1 Mercury supervision.
82-1 Mercury craftsmen.
83 1 Mercury supervision, t
84 1 Mercury craftsmen.
140 1 Flowchart showing the flow of information concerning bearing temperature trending for the purpose of predictive tnaintenance.
140 2 Representative copy for the 'A' Reactor Food Pump.
y t
i L
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1
- 156 -
L L
l 1
~i; s SEF-14-1990 11:41 FRO'1 W 3.nkee Corp TO P.01 t
3p i?
gggggg,gg, 1 Jones P. Polistlw, helts first duty swert, de depees had ety that the fewing esewere are true, essept insofte u they are based en information thtt le synllable to Verment Yankee Noelett Power Corportties but 404 within my pereenal knowledge, as to whleh I honed es sesh informaties believe them to be true.
_k74 5.. ] -
famosl,Polieder State of Yarment
)
County we then appeared Ismes P. Pelletier, before and g\\ g Me k 1
personally known to me, who, being (Aret duly rn, a h that the fores s statement is g2 4
PUSUC Notary PublIc g
My Comaluion expires:
g*0 As to objeetleas' U
D t
wm R. K. Oad a /
Jeffrey P. Treet Rapse A Orey etes laternetlenal Place Bostos. neesseehusetts 02140
~4-Telephone:617 9517820 i
D6ted: Septombor !990.
~
137 l
4 TOT 4. P.M
I 8-1 Average Annual Employment History of VY Maintenance Department Year a) Number of b) Number of c) Number of d) Number of Personnel Supervisors Contractors Other Personnel 1972 18 6
1 1973 Data is unavailable for this year 1974 0:ta is unavailab1'e for this year 1975 Data is unavailable for this year 1
1.976 34 8
1977 36.5 8
1978 40 9
1979 43 9
1980 46.5 10.5 1981 47 11.5 1982 53 12 1983 56.5 14 1984 60 15 1985 58 12.5 1986 63.5 15 1987 64 14.5 1988 71.5 18 20 1989 73 19.5 57.5 7/90-73 19.5 16.75
- Vermont Yankee did not track the average number of :Jontractors prior to 1988 and does not curreatly track the average number of "other personnel".
See the response to SOV Interrogatory (Set No.1) No. 4 for additional information regarding contractors.
JPtAtf.XD l
i J'
i i
j i
a r
i l 9-1
' Average Annual Employment of Engineering Support Department j
Year a) Number of b) FJher of c) Number of personnel supervisors Contractors 1972 10 1
t
)
197' sta is unavailable for this year
- 197, Data is unavailable for this year 1975 Data is unavailabin for this year r
3976 9-2 1977 12 2
1978 12 2
1979 9
2 1980 10 2
+
1981 11 2
1982 13 2
1983 11 2
.t 1984 12 2
1985 13 3
1986 14 3
1987 17 3
1988 19 5
6.75 1989 20 5
8.5 t
7/90 19 6
2.5
- Vermont Yankee did not track the average number of contractors prior to 1988.
See the response to sov Interrogatory (set No.
- 1) No. 4 for additional information regarding contractors.
JFTATTAO.XO 1
)
n
?l :-
t (page 2 of 5) 0-1 a.
b.
c.
d.
e.
Total Years Total Years Total Year)
Total Years Ahticipated Related Exp. at Comm Experience in Current Retirement Experience Power Plants at VY Position Date at 65 Yrs.
Anderson, Phillip L.
14 11
.5
.5 10/9/15 Atkins, Harvey F.
32 20 20 5
7/9/05-Barber, Rae S.
15 9
3 1
10/13/22 Benedict, George G.
Il 3
3 3
6/24/27 Boguslawski, Henry 40 20 20 5
3/5/95 Bristol, Alan F.
10 10 10 3
5/15/10-(
Chancey, Shirley J.
15 7
2 2
7/14/21 Chapin, Donald C.
13 13 A
4 7/14/20 Chapin, L awrence H.
34 13 12 4
1/20/01 Clark, Anthony A.
21 9
3 3
3/12/16 Christmas Williac A.
1 9
9 3
6/5/11 2
Coburn, Leah 9
8 8
7 1/15/29 Conkey, Edward W.
28 28 10 1
2/26/06 Corey, Gail M.
5 3
3 1
8/5/31 Curren:, Robert A.
17 11 4
4
$/4/20 Faulknee, Gor dcn A.
31 21 ib 5
5/22/05 Field, Howard A.
23 4
4 3
7/1/08 Fortin, Henry F.
35 16 16 8
5/3/95 Garland, Matthew A.
12 4
4 3
3/8/23 Caspardino, Alan A.
20 6
6 4/4/08 Gleason, Randall F.
9-5 2
2 6/22/28 Golonka, Joseph W.
16 14 14 1
12/10/1b l
l l
l
(page 2 of 3)
[
i i 0-1 l
f a.
b.
c.
d.
e.
i l
Total Years Total Years Total Years Total Years Anticipated Related Exp. at Comm Experience in Current Retirement Experience Power Plants at VY Position Date at 65 Yrs.
l Gouin, Wilfred L.
?
?
9 1
9/7/09 f
Graves, Jeffrey A.
18 8
8 8
10/17/18 t
Gregor, Roy O.
14 8
1 1
12/23/19 Halvey, James J 28 20 20 9
2/19/05
{
Heilman, Harry S.
24 12 12 4
3/3/12
~
Hopte, Dennis W.
12 8
8 2
7/23/11 Jarvis Jr., Donald P.
18 8
8 1
7/19/13 Jenks, Leigh R.
18 5
5 4
7/11/19 Kelleher, Laura J.
23 13 13 13 5/21,'13 L
rellem, James F.
16 16 5
5 6/30/17 P
Kingsley I!!, Carl W.
25 5
5 4
7/28/08 Knechtly, Darrell L.
15 9
9 5
3/6/21 r
Leach, Kevin M 15 1
1 1
5/10/17 I
Levesque, Norman 17 13 12 8
4/20/20 l-Louttit, Ralph L.
1A 5
5 5
12/3/17 kisc kin, T imotiiy E.
16 10 1
1 12/12/21 McKinnon, William J.
23 20 10 5
6/8/16 l
Metevier, Dennes E.
29 6
6 1
2/8/08
\\;
Niedzwiecki, David J.
19 19 13 3
2/18/14 l
Painter, DoJglas R.
11 3
2 2
5/13/23 Paust, Norman T.
11 3
2 2
3/31/03 Perry, Michael G.
13 4
4 3
11/12/15 Pond, Gary G.
15 3
3 3
2/17/20 L
i (page 3 of 5) i 0 1 l
l a.
b.
c.
d, i
Total Years Total Years Total Years Total Years Anticipated t
Related Exp. at Comm Fxperience in Current Retirement
?
Experience Power Plants at VY Position Date at 65 Yrs.
Pond, Gary G.
15 3
3-3 2/17/20 Primavera, Stephen W.
17 16 1
1 12/10/14 l
Prokowich, Nicholas 44 11 11 3
1/22/94 i
Robert. Michael S.
15 9
9 4
11/22/18 Rose, Christopher C.
20 6
6 6
1/14/13 Sak, Roger C.
22 12 11 3
7/28/13 Smith, Stephen P.
11 5
5 4
2/18/<.6 Snyder, Alan V.
16 5
3 3
12/22/13 St. Pierre Sr., Robert S. 30 10 10 2
2/8/04 Strysko, Edward C.
2?
2 2
2 7/10/16 Taintor, Edward C 11 4
4 3
8/19/19 Taylor, Douglas A.
24 30 20 5
2/23/12 Tietze, Brain J.
20 8
8 5
11/20/16 Turner, James A.
11 5
5 4
3/1/27
.Vertanen, Dennis W.
14 7
4 4
9/?6/09 Weed, Joseph K.
12 6
1 1
3/03/26 Wender IV, Samuel A.
10 10 8
5 11/16/16 Williams, John M.
12 4
4 4
~9/4/23 Wright, Lawrence E.
33 22 16 4
11/1/99 Yeaw, Merrill R.
27 17 17 5
9/4/06 Ziguloski, Josepn H.
14 2
2 2
8/26/20 P
e
.g
U 1
L (page 4 of.5)
]
l-
') 0-1 8-3 e.
b.
c.
d.
e.
Total Years Total Years Tr'.a1 Years Total Years Anticipated 1
Related Exp. at Come Experience in Current Retirement Experience Power PlantF, at VY Position Date at 65 Yrs, Arensmeyer, Jack W.
36 19 19 6
10/2/00 Donnelly, Patrick J.
27 20 20 5
3/17/10 Finne11, Wayne F.
32 21 19 3
10/5/04 Legere, Dennis J.
18 10 10 4
7/9/15 Lipinski, Frank P.
12 6
6 2
4/17/20 Lopriore, Richard P.
20 20 12 5
9/30/14 Nict.ols, Ctaig J.
9 9
5 1
10/6/27 Phillips, David L.
25 12 10 8
6/17/08 Selb/, Robert A.
27
?1 19 0
12/30/11 W tren,ttichae* T.
24 17 8
3 3/2/10 Watson, Terril A.
26 12 12 5
3/31/02 p
1 5
1 i.
l i
5
---v.,
-ge-
_--m,-,--
y
e l
(page 5 of 5) t e 0-1 s.
b.
c.
d.
e.
Total Years Total Years Total Years Total Years Anticipated Related Exp. at Comm Experience in Current Retirement Experience Power Plants at VY Position Date at 65 Yrs.
- t Anson, Louis W.,
Jr.
27 21 21 5
12/2/06 i
Ball, Michael A.
17 11 4
4 3/21/20 t
Blanchard, Wilfred 12 12 12 5
5/8/17 Burger, Frederick J.
23 17 17 3
2/6/10 Cappuccio, Gary 16 10 10 4
6/3/15 Corbett, Patrick 14 14 6
6 1/11/18 DeMarco, Carmen A.
25 5
4 4
7/27/09 DeVincentis, James M.
7 7
7 7
9/2/23 Orouin, Timothy 2
2 2
1 8/5/32 Girroir, Dennis C.
10 13 13 7
3/8/16 McCullough, Richard E.
16 11 a
4 6/4/18 McKenney, Patrick 6
6 6
6 6/16/28 Mete 11, H. Michael 18 10 10 1
11/19/15 Osmond, John F.,
III 18 9
2 2
7/2/17 Pegodia, Richard D.
12 I?
11 3
7/lu 21 5
? bill:,t, David L.
? !,
12 10 6
6.*17/05 t
Porrovecchio, Carl J., Jr.20 20 20 8
2/4/03 Stello, Mark A.
17 17 5
2 9/2/16 Taintor Jr., Edward J.
11 4
4 3
8/19/19'
.Thurman, Norman C.
28 14 1
1 J/30/01 Walsh, Judith L.
14 (Clerical) 8 8
8 7/1/09 I
l-
-5
Attochm3nt 66-1 t"
a McGraw HillNuclearPublications 1120 Vermont A,e. NW 1eiephone 2021463 1651 4
wasNngtos DC. 20005 ef March 27,1990 Francis J. Helin APR 2 90')
Project Engineer Vermont Yankee Nuclear Power Corp.
Ferry Road OPS. SUPPORT Brattleboro VT 05301 Dcar Me, Helin:
I have read your lener of rebmary 20 and its attachments about your application to change the eflective date of youi operating license.
As you know, I am in no position, as a joumalist, to comment on the validity of any pany's position. I did look again at our special repon, Outlook on Skilled Personnel, which was refer-enced by the State of Vermont, and I do believe it speaks for itself to the issues.
First,it expresses the concem of experts that,in the next decade or two, the U.S. could lose its personnel skilled in design, construction, and engineering of nuclear plants 'There was less concem expressed about finding and keeping personnel in skills that do not h.volve advanced college degrees, the skills that are no less importat but are generally taught to workers by utilitics directly, and that involve an the job tr tining as an important component. 'The later area was seen as far more under utility control than finding personnelin the advanced engineering specialties, for the foreseeable future.
Second, the special repon gemed people involved wi'h personnel in seversl countries as saying that recruiting skilled, quality persorusel needed for safe operation of nuclear plants is going to be difficult-but not impossible. It is (see page 4, the section headed " Golden Handcuffs") going to be more expensive, the expens think, and going to require more commitment on management's pan to create con *tions that encourage good workers to stay. Good people will still be avall-able-the competiuon for them is simply expected to be stiffer, in sum, I believe our Special Repon presents a balanced and reasonable view, and I hope it is of some assistance in illuminating the facts during your upcoming hearing on the license extension.
Very truly yours,
, u f,. :
3
?-
tG C.' L A_
Mar 5areLL. Ryan - 3 Chief Editor Nucleonics Week New Watt emce:
1221 A4 W the Ame cas New York NY 10020 Teepve 212/512-6410. los-Free 800'223 4180 Teen ROA232365 Wire TWx 7105814B79 1
Oerseas Cab 6e MCGRAWHILL NEW ORK European omoe:
a 128 rue os Fasbourg SanHdnord 75008 Pans Fra ce 5
leephone 331>42 8403 80 Tees 642230F
[
f, U-Attachments 81-1 and 82-1 i
YT tot #CWY CoefpANY OF NORWOOO.sNC 1
., uw. ::...
if IL 2dl 70708 DRYWELL PAINT SCRAPING MR 69-1004 (RGM) l TOTAL 1989 NAME CIASS.
HOURS EMPI4Y. DATES BARNES, RAYMOND ASST CONST SUPT 33 6-22-87 I
-KABICH, JOSEPH PROJECT ENGINEER 17 10-20-86
. O'BRIEN, PHILIP ENGINEEn 61 10-17 4-7-89/ 6-11-90 CLINE, RICHARD SENIOR ENGINEER 7
8-26 85 i
DUDA, ALEXANDER CONSTR SUPT 10.5 6-24 *
. TPOMBLEY,: PATRICK
,h CONSTR SUPT 16 11-15-82 2
a LEH, JULIAN SITE SUPT 2
8-18-80
]
ECKERT, HOWARD if,)
ASST CONSTR SUPT 13 12-5 4-1-89/ 4-30-90
- R.
CURTIN, DONALD ASST CONSTR SUPT 1.5 11-21 5-26-89 WILSON, RONALD ASST CONSTR SUPT 44 1-30 3-31-89 i
GILLOOLY,'NEIL JL LRCP 30.5 10-31 2-23-89/ 3-12-90 PARKER, CRAIC~
LRCr 32 6-22 6-30-89 TEDFORD, GEORGE LRCT 48 1-16 6-30-89 JUDGE, JOSEFd LRGF 4
10-20 2-22-90
_ MINER, CEORCE ASST CONSTR SUPT 1
7*20-87 CLAY, THEODORE LR 10 11-14 4-1-89 LAMARRE, PETER LR 32.5 2-6 4-1-89 L
POTASH, TIMOTHY LR 3
1-30 4-1-89 I
.PRESWAR, ALLEN LR 33 1-16 5-26-89/ C-25-90 i
' PROVOST, WILLIAM LR 25 11-14 4-7-89 ROTOLLO, TIMOTHY LR 10 2-20 2-23-90/ 3-12-90 BARTON,. BRIAN Eb,(.
LR 44 1-25 4-7-89 1 CLARKE, MICHAEL LR 44 2-15 3-31-89/ 6-12-90
- R RARRINGTON, PHILIP LR 23 2-20 4 89 RARTWELL, EDWARD -
LR 23 2-20 4-1-89
.KUT, JOHN LR 2
11-27 1-5-90 LAWSON, GERALD LR 44 2-8 4-7-89/ 6-26-90
- R MOORMAN,' JERRY LR 17 2-18 4-7-09
- QUISN, !*?.NJ11 LR 44 11-14 4-1-89 OVERLAUGH, GLENN LR 17 2-e 3 31-8!.
PALLOS, MICHAEL LR 20.5 2-15 4-7-89 LEVEILLE;, TUCMA3 LF 10 I-22 3 2v-e9
-NORTON, GEORGE LR 20 11-28 4-7-89 WHEATON,, MICHAEL LR 10 11-16 4-7-89 ALEXANDER, WALTER LR 15 11-16 4-10-89 KASSEN, JACK:
LR 24.5 2-8 4-1-89 GIGLIOTTI, PETER LR 15 2-20 5-26-89 1
CAVATTARO, KEITH LR 10 2-20 4-7e89/ 6-12-90
- R
- MURPHY, DANIEL LR 2
2-8 4-1 89/ 6-12-90
- R l
i
- a CURRENT EMPLOYEE
- R = CURRENT ROWE EMPLCYEE L
4 s
- -..------.. -.---u
i i
y.
s.
Attachments 83-1 and 84-1 MERCURY COMPANY OF NORWOOD iNO TT 4
,, u u:. nw es.
YW$
i 1
f 70710 TORUS PAINT CLEANUP MR 89-1089 (WDF)
W3' lI*%
('t*b TOTAL 1989 NAME' CIASS.
HOURS EMPLOY. DATES TROMBLEY, MICHAEL PROJECT MANAGER 1
5-8-78
.LEH, JULIAN SITE SUPT 2
8-18-80 t
KELLEY, EARL CONSTR SUPT 3
10-24 3-29-89/ 5-21
- R BARNES, RAYMOND ASST CONSTR SUPT
' 39.5 6-22-87 i-MINER, GE N E ASST CONST9 SUPT 10 7-20-87
.i DARRY, BE..JAMIN ENGINEERING SUPT 2
3-12-84 HABICH, JOSEPH PROJECT ENGINEER 36 10-20-86 O'DRIEN, PHILIP ENGINEER 44.5 10-17 4-7-89/ 6-11-90 CLINE, RICHARD SENIOR ENGINEES 5
8-26-85 HORAHAN, CHARLES LRGF 22 M,,g 7-1 6-9-89/ 7-10-89
- R.
e DERMODY, )RTHUR LRCF 5.5 10-24 EB 20-89/ 5-29 90
' R I
CLAY, THEODORE LR' p
5 11-14 4-1-89 i
PARZICK, SHAUN-LRCP 34 10-24 3-31-89/ 6-4-90
- R
. JUDGE, JOSEPH LRGr 4
10-20 2-22-90
-i TEDFORD, GEemer LRCr 31.5 1-16 6-30-89
~ GIGLIOTTI, PETER LR 4.5 2-2v 5.T-6is HASSEN, JACK LR 5-2-8-89 4-1-89 BAR1CN, SRIAN LR 52.5 1-25 4-7-89 BONN, WILLIAM LR h'
2 11 21 88 7-89 CRANDALL, SHANE LR y
8 11 21 4-7789 CROSIER, HEAL LR 24 2-23 3-22-90 GRANDE, FRANK LR-30 2-23 4-7-90
'IANGER, KIRK.
LR 2
11-27 1-26-90 ttVEILLEE, THOMAS LR 1
2-23 3-29-89 MOORMAN, JERRY LR 19.5 b4 4-7-89
.biURPHY, DANIEL LR 46 2-8 4-1-89/ 6-10-00 (Ultm, I h aC'?
LR 4P 11-14e6C 4 !!9 WHEATON, MICHAEL LR 31 ll-16i88 - 4 1-US
.! CR"C4 NA*,TER
- R 59.5 2-20 4-7-89 i
' KI:4NAS, John-LR 13 2-8-39 3t19-89 50TASH,- TIMOTHY LR 22 1-30-8tir 4-1-89 PROVOST, WILLIAM LR 18 11el4 4-7 89
[
ROTOLID, - TIMOTHY-LR S
2-20 2-23e90 / 3-12-90 1
SHUGRUE JOSEPH LR 29 1 23 4-1-89 TAYLOR, ROBERT LR -
6 11-16 88, 4-1,89 / 6e6-90
- R
'A VERGILIO, FRANK LR 9
2,8-89 g 4 ele 89 e
TROMBLEY, PATRICK CONSTR SUPT 5
11 15-82
- ? - CURRENT EMPLOYEE
- R = CURRENT R0"E EMP. 3YEE a
s
~
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i Attachmsnt 140-1 i
REACTOR FEED PUt#S,CONDESATE PUWS CIRC WATER PUW4, CIRC. WATER BOOSTER PUMPS BEARNG TEWER <RJRES 1!
l If if if 1f I '
NA MI i
OORTRDLROOM ALARM R30M PERFORMJCE EFFIS TYPER l
LOCATION CRP F21 TR.2 2 3 D N 53 TR 23115 qr ALARM I
I
+
TR 1H.25
(
PoliJT
~ T. ARM ALARM PUMP 7MOTOH JTA(US A
l'4 C'I.AFFD hCNTHIY
~
~ ~~
TRIIP i
TREND qr BUILD SHIFT EMBEER if if if g
+
POINT
SUMMARY
STATUS OPEMTOR FEVIEW 1V 1P 1f YELLOW STICKER OOFVECTTK PLANT ATTACHED TO MAINTENANCE CE FEOLEST IONTHLY j
MOOR)ER IDENTFYING MR AP0021,01 0
SUIMTTED SUBMrTTED if OPEMTIONS PL#NNG g
' f vsetCTNE YELLOW STICKER MANTENANCE VISI CARD EhCVEDFROM O
PEFFORED
= iervsn E00F0ER AP0021.01 AP0200 DENTFYING MR if if pRevEgnvE PREVENTNE MAINTENANCE MAINTENANCE 4
FEQlESTED PROGMM AP0021.02 REVISON
f Attachmont 140-2 (pago 1 of 2)
A REACTOR FEED PUMP BEARING DIFFERENTIAL TEMPERATURES
}
30
}
r
?
20 p
f l
/%
/%
~
<T mm m
m
%/
/
\\
WO28 WO27 10 WO28-WO29 WO32 WO31-DMF M,P 4[i kHMp 4tdMMM
%p,. 4 b,,4 ;- C :
0- (Mk r 1
1 1
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lHMqp
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Mi M
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immr1 t
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t E ! E. B. E. E E. E. E. I E. !. G. E ! !, S, B, 5 i. 5. 5 E E-!. 6. E ! ! G B i E
~~~
t i
WD27: A RFP INBOARD BEARNG TEMP WO90: A RFP OUTBOARD BEARWG TEMD WCg9; A RFP IY!D THRUST BEARING TEMu WO31: A RFP MOTOR NBOARD BEARING TEMP WO32: A RFP MOTOR OUTBOARD BEARING TEMP t
a h
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DATE s
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000KETED USNRC a
'90 SEP 20 P2 :43 ABLAB.FA.v mRGABFAX.YY pri cE 'Jr EEcat it.P tzGCl'.!I '.C \\ sin'i'Cf t
!4 wCu Certifieste of Servlee t k-I, R. K. Gad at, hereby certify that on September 1990,I sande service of 4
the within answers to interrogatories, by mailing copies thereof, firrt class mall, postage prepaid, as follows:
4 kebert M. I no. Esgi'in.
Jciry R. Fliist Chairman Administrative Judge Atoinic Safet/ anu Licensing Bcard Atomic Terety ant'. Li enting Board U.S.N.R.C.
U.S.N.R.C.
Washington, D.C. 20555 Washington, D.C. 20555 Frederick J. Shon Adjudicatory File Administratise Judge Atomic Safety and Licensing Board '
Atomic Safety and Licensing Board Panel U.S.N.R.C.
U.S.N.R.C.
Washington, D.C. 20555 Washington, D.C. 20555 Anthony Z. Roisman, Esquire Ann P. Hodsdon, FA,oire Cohen, Milstein & Hausfeld Patricia A. Jehle, Esquire Suite 600 U.S.N.R.C.
1401 New York Avenue, N.W.
Washington, D.C. 20555 Washington, D.C. 20005 James Volz, Esquire Vermont Department of Public Service 120 State Street
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Montpelier, Vermont 05602 O
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