ML20101T382

Responds to 841227 Generic Ltr 84-24 Re Environ Qualification of Electric Equipment Important to Safety for Nuclear Power Plants,Per 10CFR50.54

ML20101T382
Person / Time
Site:	Vermont Yankee
Issue date:	01/31/1985
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
FVY-85-11, GL-84-24, NUDOCS 8502060130
Download: ML20101T382 (12)

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VERMONT YANKEE NUCLEAR POWER CORPORATION

. RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 Ygg8f11 y -

ENGINEERING OFFICE 1671 WORCES TER ROAD

• FRAMINGHAM. MASSACHUSETTS 01701

' TELEPHONE 817-872-8100 January 31, 1985 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Office of Nuclear Reactor Regulation Mr. D.G. Eisenhut, Director Division of Licensing

References:

a) -License No. DPR-28 (Docket No. 50-271) b) Letter, VYNPC to USNRC, FVY 84-34, dated 4/11/84 c) Letter, VYNPC to USNRC, FVY 84-74, dated 6/29/84 d) Letter, VYNPC to USNRC, FVY 84-81, dated 7/10/84 e) Letter, VYNPC to USNRC, FVY 84-90, dated 7/19/84 f) Letter, VYNPC to USNRC, FVY 84-92, dated 7/25/84 g) Letter, USNRC to VYNPC, NVY 84-179, dated 8/2/84 h) Letter, VYNPC to'USNRC, FVY 84-98, dated 8/10/84 i) Letter, VYNPC to USNRC, FVY 84-127, dated 10/30/84 j) letter, USNRC to VYNPC, NVY 84-263, dated 12/12/84 k) Letter, USNRC to All Licensees of Operating Reactors, (Generic Letter 84-24) NVY 84-268, dated 12/27/84 l) . Letter, USNRC to VYNPC, NVY 83-75, dated 4/11/83

Subject:

Certification of Compliance to 10CFR50.49, Environmental Qualification of Electric-Equipment Important to Safety for Nuclear Power Plants (Generic Letter No. 84-24)

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By Generic Letter No. 84-24 [ Reference k)] and pursuant to 10CFR50.54(f),

you requested that each licensee of an operating reactor submit a Certification of Compliance to 10CFR50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants. This letter provides Vermont Yankee Nuclear Power Corporation's (VYNPC) response to that request.

Specifically, you requested certification that:

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.- 1U.S.; Nuclear Rsgulatory Commission January 31, 1985 Page 2 VERMONT YANKEE NUCLEAR POWER CORPORATION 3

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o The utility;has in place and is implementing an Environmental a)_

Qualification (EQ) Program that will satisfy the requirements of *

>: 10CFR50.49 within the currently approved schedule for the plant

.g without -further extension; b) The plant has at least one path to safe shutdown using fully qualified equipment, or has submitted a Justification for Continued Operation (JCO) pending full qualification of any equipment not fully qualified; and c) ~ All other equipment' within the scope of 10CFR50.49 is either fully qualified or a JC0 has been submitted pending full qualification.

You'further requested that the certifications described in References a),

b) and c) above should specifically address all IE Bulletins and Information

. Notices that identify EQ problems, to the extent that 'such Bulletins and Notices are:relevantito the licensee's facility. You considered the following ~ Bulletins  ;

. and Information Notices . applicable to these certifications: IE Bulletin 82-04,

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'IE1Information. Notices 82-11, 82-52, 83-45, 83-72, 84-23, 84-44, 84-47, 84-57, J 84-68 and'84-78.

With respect to certifying .a), b) and c) above, Vermont Yankee has submitted

.a . comprehensive; upgraded program for ensuring . environmental qualification of safety-related electrical equipment in accordance with the provisions of.

10CFR50.49.; .The details:of our-Environmental Qualification Program (EQP) are Ldescribed in References b), c),.d), e), f) and:g). The NRC . subsequently. issued a

? Safety Evaluation Report.(SER) dated December 12, 1984 [ Reference j)],-which concluded.that'the_ Vermont- Yankee EQP was in compliance with the requirements of u 10CFR50.49;1that the ' proposed resolution; for Leach of the'_ environmental qualifi-cation deficiencies identified in'the April. 11, 1983 Franklin Research1 Center

Technical Evaluation; Report' [ Reference 1)] was ' acceptable; and, the continued Loperation ofithe. Vermont' Yankee Nuclear Power. Station would not present undue

_1 riskf to publie health and safety.

nBylletter dated-July 25,L1984, we(request'ed an extension from the 'schedu -

l ;1.ar3 requiremen.ts .of: 10CFR50.49(g) for: replacement oftcertain _ equipment that -

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tg icould not- beLeompleted during.~our: 1984 refueling outage.- Our letter, requested

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-extensions 1until thefend of theinext refueling outage, which is scheduled to

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, commence 11niSeptember?1985 and extend.into 1986, and included Justification for

Continued Operation during theLinterim period.~ The NRC subsequently reviewed-

and. approved our requests as detailed in.a letter

to us dated August 2,1984-

'[ Reference g)]; however,-schedularf relief was ' granted until' no later than

Movember"30,11985L consistent 'with the schedular limitations prescribed-byi

'10CFR50.49(g).

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. . U.S. Nuclear Regulatory Commission January 31, 1985 Page 3 VERMONT YANKEE NUCLEAR POWER CORPORATION We will replace all equipment identified as requiring environmental quali-fication which is not presently fully qualified, as identified in Enclosure 1, during our next outage, scheduled to extend from September 1985 into 1986. Due to the schedule of work associated with this outage, we cannot assure that the remaining components will be replaced by November 30, 1985. Therefore, we will be submitting a formal request for schedular relief to the Commissioners to complete the remaining component upgrades no later than start-up from our 1985 pipe replacement / refueling outage. This extension request will be submitted by

- March 1, 1985. _The additional time is justified given that the plant will be in a refuel mode and no potential harsh environmental conditions exist until startup '

.. in 1986. 1 It should also be noted that the list of yet to be qualified electrical l components provided in the NRC's December 12, 1984 SER was inaccurate. First, the _SER did not .!st certain ASCO Solenoid Operated Valves which were included in our July 25, IC84 extension request and approved in the NRC's August 2,1984 response: letter. Second, the SER incorrectly lists MOV-12-15. As listed in our July _25, 1984 request, the correct component tag number is M0V-13-15. Finally, the scope of our JDly 25, 1984 request reflected certain co.rpeneats taat were subsequently replaced during' ti e 1964 refuel ' outage with qualified counterparts.

At the time of our request we were unsure as to whether the qualified replace-ments would be received on-site in time to be installed during that. outage. As a result, we have updated the list provided in the SER to accurately reflect the remaining components that need to be replaced at Vermont Yankee. This list is

- provided in Enclosure 1 and includes a reference to the associated JCO.

r In _ addition to the electrical equipment covered under the scope of the b . Vermont Yankee E0P, we have recently completed our Regulatory Guide (RG) 1.97

- assessment which is1one, facet of our Integrated Response Plan for NUREG 0737, Supplement I, Emergency Response Capability. _A report' detailing our assessment.

was provided to the NRC by letter dated October 30, 1984 [ Reference 1)] and is cur'rently under review. As stated in our submittal, it is our present intent to

' upgrade certain RG 1.97 instrumentation which fall within the senpe of

, 10CFR50.49,- prior to startup fran;our 1985 refuel outage. The NRC's December

-12, 1984 SER for Envirenmental Qualification acknowledges the ongoing review of -

- our submittal and states that when the RG-1.97 report and equipment lists con-

- tained therein have been finalized and accepted by the' staff, anpropriate equip-

- ment not already in 10CFR50.49 will be added in accoadance 51th the RG 1.97

- implementation schedule. It should be noted th&c our current' schedule for. the EQ-related components is predicated on our timely receipt of the NRC's approval

- of our RG 1.97 assessment, such that sufficient- time exists to order necessary

--replacement components in time for our 1985 refuel outage.

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.- . d.S;JNucleariRegulatory Commission

.lanuary 31, 1985

'Page 4 VERMONT YANKEE NUCLEAR POWER CORPORATION LAll components required as part of our upgraded EQP were fully qualified upon startup from our 1984 refueling outage [ consistent with the schedular pro-visions of 10CFR50.49(g)] except for the components listed in Enclosure 1. Once

the ASCO Solenoid Valves (component Tag Nos. SE-70-4A, 4B,14C and 4D) listed in the. Enclosure are fully qualified, Vermont Yankee will have at least one path to-achieve safe shutdown using fully qualified equipment. In the interim the JC0's referenced in Enclosure 1, which have been reviewed and approved by the NRC, ensure'that'we satisfy the intent of 10CFR50.49.

Vermont Yankee has administrative controls in place to address instances c where any component required by our EQP becomes inoperable, or when plant designLfeatures1necessary to maintain environmental conditions (e.g., doors, shielding, fans, etc.) are degraded.

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Vermont Yankee has' conducted a thorough review of the I&E Eulletins and -

LInformation Notice: referenced-above. .The summary results of our review of each

• - ;of the notifications is; providedlin Enclosure 2. . We will continue to review and

f assess. the results of- future I&E Bulletins and Information Notices related. to

. environmental qualification. Where applicable, we will, factor the results of.

,our assessment into our Environmental Qualification Program.

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To~ ensure ' designated environmentally qualified ~ equipment is properly main-tained' through the expected life ~of that equipment, and that any. change to the

. expected life 11s recognized and compensated for programmatically, we expanded t our' Maintenance 'and -Surveillance . Program to ' provide specific . identification of

, Environmentally; Qualified- Equipment, ~as' described in' our letter dated August'10, E , :1984-[ Reference h)]. Vermont: Yankee is presently fo'rmulating a dynamic, t integrated' Environmental' Qualification Maintenance and Surveillance Program that

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will-provide the necessary. control to maintain user department-component files pgs '

Lcurrent.and a'ccurate. Component ~ file completion,; review and approval of proce-

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idures 'and fu111 implementation will Jbe completed approximately: 90 days following lfinaiization of'the controlled-source documents which is scheduled for March

1385. During this transitional period, the existing Maintenance and ,

E- ' Surveillance-process, augmented by interim administrative actions to meet the intent Lof ~10CFR50.49(d), will ' continue to be utilized.

Based onLthe.above,-Vermont Yankee Nuclear Power Corporation.herein cer-

, [i fies .that:-

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U.S. Nuclear Rzgulatory Commission

. January _31, 1985 Page 5 VERMONT YANKEE NUCLEAR POWER CORPORATION a) Vermont Yankee f.23 in place and is implementing an Environmental Qualification Program (EOP) that will satisfy the requirements of 10CFR50.49, as described in References b), c), d), e), f) and g) except that:

1) the schedule for completing our remaining component upgrades is no later than startup from our 1985 pipe replacement / refuel outage, which is later than the November 30, 1985 deadline pro-vided.in the August 2, 1984 NRC letter approving extension requests. As discussed above, a formal request for additional schedular relief will be submitted to the Commissioners by March p 1,.1985.

2) the schedule for completing RG 1.97 EQ-related component upgrades

, is dependent upon the NRC's approval of c w RG 1.97 assessment report in a timely manner.

.The schedules detailed in 1) and 2) assume no unforseen difficulties in the procurement and installation of necessary replacement com-ponents or the receipt of associated vendor qualification

_ documentation.

b) The plant will have at least one path to achieve safe shutdown using fully qualified equipment once the' ASCO Solenoid Valves (Component Tag Nos. SE-70-4A, 4B, 4C and 4D)' listed in Enclosure 1 have been qualified. A JC0 for these valves was submitted as part of our July 25, 1984 request for. schedular extension and approved by the NRC as

. described in their letter-dated August 2,1984.

c) All other equipment within the scope of 10CFR50.49, as described in our upgraded EQP, was fully qualified upon startup from our-1984 refueling outage except for those components listed in Enclosure -1.

JC0's for these components were submitted as part of our July 25, 1984 request for schedular extension and approved by the NRC as described in their. letter dated August 2, 1984.

Finally, as statediin previous submittals, our Environmental Qualification Program is an ongoing and evolving program. Future facility design modifica-tions will be evaluated to assure that their impact, if any, is adequately reflected in' our program. In addition, as we become aware.of any engineering

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,. . U.S. _ Nuclear Regulatory Commission January 31, 1985 Pag; 6 VERMONT YANKEE NUCLEAR POWER CORPORATION information (e.g., vendor information, NRC I8E Bulletins and Information Notices,. engineering analyses, etc.) which could putentially impact particular aspects of our program, such information will also be evaluated to determine if programmatic changes are warranted.

We trust that this information is deemed _ satisfactory; however, should you have any questions or desire additional information, please contact us.

Very truly yours, VERMONT YANKEE NLCt. EAR POWER CORPORATION f$

Warren P.' Murphy h

f Vice President and V Manager of Operations WPM /dm' STATE ~0F VERMONT)

)ss WINDHAM COUNTY' )

. _Then personally appeared before me, Warren P.. Murphy, who, being duly

sworn, did state that he'is Vice President and Manager of Operations of Vermont

' Yankee Nuclear Power Corpo' ration,:that_ he is duly authorized to execute and file the' foregoing document in the name and _on the behalf of Vermont Yankee Nuclear

" Power Corporation and that the statements therein are true to the best of his knowled a belief.

7 fs 5 j lG Diane M. McCue ' Notary Public

-My Commission Expires February 10, 1987 NOTARY l

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7 ENCLOSURE 1 JUSTIFICATION FOR CONTINUED OPERATION EQUIPMENT LIST JC0 NO. DESCRIPTION 29- General Electric Control Rod Drive Mechanism (Position Indication, Switches, Cables, and un Conncetors) 39'- General Electric Local Power Range Monitor System (Neutron Detectors, Indication, Cables, and

i. Electrical Connections) 14 3 - Limitorque SMB-00 Assembly for M0V-10-32 (RHR Head Spray Isolation) 46 Limitorque SMB-000 Motor for MOV-13-15 (RCIC

, Inboard Steam Isolation)

.69- Limitorque SMB-0-Motor for MOV-10-39A (RHR "A" Torus Cooling and Spray Outboard Isolation) 66 ASCO Solenoid Operated Valves,' SE-70-4A, 4B, 4C and 4D (Residual Heat-Removal ~ Service Water Cooling)

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. . ENCLOSURE 2

SUMMARY

OF VERMONT YANKEE'S ASSESSMENT OF EQ RELATED BULLETINS AND INFORMATION NOTICES 18E BULLETIN 82-04 Vermont Yankee.has no Bunker Ramo electrical penetrations. Further, there are no plans to install any in safety-related systems in the future.

IAE INFORMATION NOTICE 82-52

= This Notice addressed the items of equipment discussed below:

Limitorque Valve Operator, Type SMB, Size 00: The failure reported in this Information Notice is attributed to the severe requirement imposed by the Westinghouse PWR temperature profile. Vermont Yankee does not . consider this Notice applicable to the Limitorque Valve Operators installed in BWR's where the temperature profile is less severe.

-ITT Barton Westinghouse lot 4 Transmitters, Group A: Vermont Yankee does not utilize these transmitters in applications which are required to meet the . Environmental Qualification Rule. .

D.G. O'Brien Electrical Penetration Assembly, Model K Connectors:

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Vermont . Yankee does not utilize this equipment in applications which are required to meet the Environmental Qualification Rule.

Dresser Safety Valve, Model 31709NA: Vermont Yankee does not utilize this equipment in applications which are required to meet the Environ-mental Qualification Rule.

Dresser' Safety Valve, Model 31739A:1 Vermont Yankee does not utilize this equipment in-applications which are required .to meet-the Environ-L mental-Qualification Rule.

, Dresser Power-Operated Relief. Valve (PORV), Model 31533VX-30: Vermont

, Yankee does not utilize this equipment in applications which are required to meet the Environmental Qualification Rule.-

Target Rock Power-Operated Relief Valve'(POR'V)~, Model B0X-006-1:

Vermont-Yankee does not utilize this equipment in applications which -

me  :,. 'are required to meet the Environmental' Qualification Rule.

-Control Comionents, Inc. (CCI),' Power-Operated Relief Valve (PORV):-

. Vermont Yan cee does not utilize.this equipment in applications which!

- 'are ' required to meet the Environmental Qualification Rule.-

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Crosby Safety Valve 3K6: Vermont Yankee does not utilize this equip-ment in_ applications which are required to meet the Environmental Qualification Rule.

- ASCO Solanoid Valves, NP-1 Series: Vermont Yankee utilizes ASCO NP-1 Solenoid Valves including those with Viton Elastomer Seals as

. described in the I&E Information Notice. In all cases, these valves have been verified to be located in areas where the radiation environ-

. ment is less than 20 megarads.

, I&E INFORMATION NOTICE 82-11 This Notice' describes potential problems with equipment supplied by

Westinghouse Electric Corporation to owners of Westinghouse Nuclear Steam Supply Systems. The Vermont Yankee . facility, a General Electric boiling

, water-reactor,.does not utilize Westinghouse instrumentation in applications

required to _ meet _ the Environmental Qualification Rule.

IAE-INFORMATION NOTICE 83-45 This' Notice deals with failure of. General! Electric Model CR-2940 selector switches following exposure to:37 megarads. Vermont Yankee does not uti-

,lize this model selector switch in any application, required to meet the

.Eny'ironmental. Qualification Rule where it will be subject to radiation doses as'high as 33.5 megards.

IAE:INFORMATION NOTICE 83 The equipment discussed below is listed in this Notice:

Anaconda Flexible Conduit: Vermont Yankee does not use.this equipment to seal qualified equipment from the LOCA' environment.

Rockwell-International Post-LOCA Hydrogen Recombiner (Subcomponents as listed below):-

-o ITT Barton Pressure Transducer', 4-20 mA, Part_No. D4R-29098:

. Vermont Yankee does .not utilize this-equipment in applications which are required to meet'the Environmental Qualification Rule. _

.or .'Microswitch, DPST Toggle Switch, Rated 15A,125-250 V ac,1/2 HP, .

125 V ac,JPart No. 12TSI-2: Vermont Yankee does not utilize this-L' '

equipment in applications which are required to meet the-Environmental -Qualification Rule.- 1 s

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o Square D Disconnect Switch, 3 Pole Non-Fusible Unit, 30A, 15 HP at'480 V ac, or 20 HP at 600 V ac, Part No. 9422-RC-1: Vermont

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Yankee does not utilize this equipment in applications which are

required to meet the Environmental Qualification Rule, j

/o Timetrol SCR Power Controller, 3-Phase,1066Z Series, Part No.

2053C-125K: Vermont Yankee does not utilize this equipment in applications which are required to meet the Environmental Quali-fication Rule.

Jo . Automatic Timing and Control (ATC) Time Delay Relay,120 V ac, 1

50-60 Hz, Part No. 3198006010, IEEE 21A: Vermont Yankee does not utilize this _ equipment in applications which are required to meet the' Environmental Qualification Rule.

Jo ITE Gould Circuit Breaker, 3-Pole, 600 V ac, Fully Enclosed,

-Thermal Magnetic, Part No EF3-8015, IEEE 79: Vermont Yankee does not-utilize this and other Gould circuit breakers in applications which are. required to meet the Environmental Qualification Rule.

Qualification of these circuit breakers is documented in our QDR 3 2.3 ITE/Gould Motor Control Centers. In all cases, the maximum

- accident' temperature for_ Gould circuit breakers is less than

-1160F =and our_ analysis demonstrates-that the breakers will not open under these temperatures.

.ITT Barton Electronic Transmitters:' Vermont Yankee does,not' utilize this equipment in applications which are required to meet the Environ-mental Qualification -Rule'.

- Barksdale Pressure Switches: Those Barksdale pressure switches which were utilized in applications required to meet-the Environmental Qualification Rule were replaced with environmentally qualified switches made by other manufacturers during the 1984 refueling outage.

D -Static-0-Ring' Pressure Switches: Those Model SN and 12N Static-0-Ring Lpressure switches which were utilized in~ applications required to. meet-

the Environmental Qualification Rule were replaced Lwith environmentally -

qualified -Static-0-Ring pressure switches during the~1984 refueling Loutage.

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ITT'Bartori Electronic Transmitters, Models M'-763 and M-764: Vermont

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Yankee does not utilize this equipment-in applications which are required to meet the. Environmental Qualification Rule.

Limitortue Valve 03eratorsi The concerns'raisedLin this Notice have

been adt ressed by Jermont Yankee's Equipment Qualification Program.

.The. field verification program and QDR 3.1 Limitorque valve operator -

-addresses the concerns'of this Notice.

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E I&E Information Notice 84-23 This Notice deals with the results of testing conducted by Franklin Research -Center for the NRC and involves some naturally aged ASCO Model NP-8316 and NP-8344 solenoid valves. The Vermont Yankee facility does not utilize the Model NP-8344 valves in applications which are subject to the Environmental Qualification Rule. Those NP-8316 valves utilized in appli-cations subject to the Equipment Qualification Rule have been assessed against~Isomedix AQS Report No. 21678/TR-Rev. A. In all cases, we have

~ found that using the Isomedix Test Report we are able to confirm Environ-mental Qualification of these valves.

IAE~INFORMATION NOTICE 84-44 This Information Notice reports problems with the Rockbestos Company Environmental' Qualification Program. lne problems were discovered during a' NRC audit and all reflect quality assurance and documentation problems during the test process. The concerns do not indicate a deficiency in the equipment. Our qualification files for Rockbestos cable address this Notice. Vermont Yankee and Yankee Atomic Electric Company are _ continuing to_ work with the manufacturer to resolve these apparent concerns.

Rockbestos has_ committed to a program of revalidating their cable qualifi-cation tests. Vermont Yankee is following the progress of this effort and will update the qualification files when the issue is resolved.

IAE INFORMATION NOTICE 84-47 ,

This Notice reports the results of tests conducted by Sandia National Laboratories on various. terminal block installations during simulated steam

- exposure. Leakage current-to-ground was measured _in each test and it was o independent of circuitLvoltage. The tests concluded that terminal blocks in a steam environment may introduce significant error in low level cir-cuits (4-20 ma), such that the safety' function is jeopardized.

Vermont Yankee has reviewed the application of all terminal blocks and has

- documented in our files that the blocks are either not used in ' low level circuits or errors introduced as a result of leakage currents would have no

'effect on the safety function.

L I&E INFORMATION NOTICE 84-57 ,

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This Notice alerts licensees:of a potentially significant problem per-taining to moisture intrusion into_ safety-related equipment. Vermont Yankee's Equipment Qualification Program considered the concerns of:this

. Notice by:

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1) addressing cable / raceway sealing requirements in the qualification documents; 2). performing a Field Verification Program which ensured' that conduit seals and gaskets were installed when required; and

.3) addressing moisture sealing requirements in the Maintenance and Surveillance Program.

I&E Information Notice 84-68 This Notice deals with damage to. field cable connected to Valcor solenoid valves. The cause of the failure was the use of 900C cable connected inside the valve housing which was subjected to higher temperatures

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. generated tyr the solenoid coil . At the Vermont Yankee facility, the only solenoid. valves utilized in applications required to meet the Environmental Qualification Rule which have field terminations inside the solenoid housing are Target Rock valves. We have discussed this matter with. Target Rock and have determined that the temperatures inside the housing where the terminations are made do.not reach temperatures which exceed the qualifica-tion of-the cable utilized.

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I&E Information Notice 84-78 LThis Notice deals with underrated terminal blocks in Limitorque Model SMC-04 valve' actuators. Vermont Yankee does not utilize this equipment in

- applications 'which are required to meet the Environmental Qualification

, Rule.:

, 'VermontiYankee will continue to review and assess-the results ofifuture I&E Bulletins and -Information Notices.related to environmental nualification. .Where -

' applicable, we will ' factor the results of these'into our Environmental Qualifi-cation Program..

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