ML20117D974

Forwards Operability Requirements for Environmentally Qualified Equipment & Components.Describes Administrative Controls Instituted & Specific Actions to Be Taken in Event Environ Qualification Status Becomes Uncertain

ML20117D974
Person / Time
Site:	Vermont Yankee
Issue date:	05/03/1985
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	Vassallo D Office of Nuclear Reactor Regulation
References
FVY-85-40, NUDOCS 8505100281
Download: ML20117D974 (4)

Text

ERMONT YANKEE NUCL8AR POWER CORPORATION FVY 85-40

. RD 5, Box 169. Ferry Road, Brattleboro, VT 05301 ggggy 70; y ENGINEERING OFFICE 1671 WORCESTER ROAD

. FRAMINGHAM, MASSACHUSETTS 01701

. TELEPHONE 6174724100 May 3, 1985 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Office of Nuclear Reactor Regulation Mr. Domenic B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing

References:

a) License No. DPR-28 (Docket No. 50-271) b) Letter, VYNPC to USNRC, FVY 85-11, dated 1/31/85

Subject:

Operability Requirements for Electrical Equipment Requiring Environmental Qualification By letter dated January 31, 1985 [ Reference b)], Vermont Yankee certified to you that the Vermont Yankee Nuclear Power Plant was in compliance with the requirements of 10CFR50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants. This letter stated that Vermont Yankee has administrative controls in place to ensure environmental qualifica-tion status of Vermont Yankee.

Attachment A, Vermont Yankee Operability Requirements for Environmentally Qualified Equipment and Components, is provided for your information, and describes the. administrative controls instituted by Vermont Yankee and specific actions Vermont Yankee will follow in the event the environmental qualification status of a componennt becomes uncertain.

Should you desire additional information, or have any questions, do not hesitate to contact us.

Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION d.4t:a /** '

Warren . Murph Vice P sident and Manager of Operations WPM /dm yTJa Bi89h1 i j P

. ATTACHMENT A VERMONT YANKEE OPERABILITY REQUIREMENTS FOR ENVIRONMENTALLY QUALIFIED EQUIPMENT AND COMPONENTS It is the policy of Vermont Yankee's corporate management that all equip-ment and components which are addressed by Vermont Yankee's Environmental Qualification Program shall be maintained operable and fully environmentally qualified at all times, commensurate with the status of the plant.

However, it is anticipated that situations will arise where, although the as-installed equipment at the Vermont Yankee plant is operable, the environmen-tal qualification status of the equipment cannot be confirmed. This may be the result of changes or ambiguities in the qualification documentation for the equipment or components, the result of as-installed deficiencies discovered during the course of maintenance and surveillance activities, or the result of qualified equipment failure. Vermont Yankee recognizes that these situations are significant and should be addressed in a timely and responsive manner, but does not believe that they warrant immediately declaring the component inoper-able.

There are three general classifications of equipment and components which are important in terms of. assuring the environmental qualification of the Vermont Yankee plant, in accordance with this Plan and the bases inherent in the Environmental Qualification Program documentation. These are:

o Environmentally qualified equipment and comonents which are also covered by the Vermont Yankee Technical Specifications; o Environmentally qualified equipment and components which are not covered by the Vermont Yankee Technical Specifications; and o Equipment not requiring environmental qualification or structural features which are relied upon to maintain defined environments for qualified equipment or components during and following postulated design basis accidents.

Each of these classifications of equipment and components are addressed separately.

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1. Operability of Environmentally Qualified Equipment or Components Covered by Vermont Yankee Technical Specifications 1.1 Failure of Equipment Whenever equipment or components which are both environmentally qualified and covered by Vermont Yankee Technical Specifications fail (are not operable), the operability requirements of the Technical Specifications shall apply.

1.2 Lack of Assurance of Environmental Qualification Whenever equipment or components which are both environmentally qualified and covered by Vermont Yankee Technical Specifications remain operable, but assurance cannot be provided that the equipment or component is fully environmentally qualified (due to questions of either the qualification documentation or the as-installed status of the equipment or component), disposition of the discrepancy shall be provided within seven (7) days in accordance with approved procedures for generation and approval of Non-Conformance Reports. The Non-Conformance Report shall include a Justification for Continued Operation (JCO). At the end of seven (7) days where continued opera-tion is not justified, the equipment or components shall be declared inoperable and the operability requirements of the Vermont Yankee

' Technical Specifications shall apply.

2. Operability of Environmentally Qualified Equipment or Components Not Covered by Vermont Yankee Technical Specifications 2.1 Whenever safety class equipment or components which are environmen-tally qualified but are not covered by Vermont Yankee-Technical Specifications fail (are not operable), or assurance cannot be pro-

.vided th;t the equipment or component is fully environmentally qualified (due to questions of either the qualification documentation or the as-installed status of the equipment or component), disposition of the discrepancy shall be provided within thirty (30) days in accor-dance with approved procedures for generation and approval of Non-Conformance Reports. The Non-Conformance Report shall include a Justification for Continued Operation.

2.2 Non-Safety Class Equipment or Components Whenever non-safety class equipment or components which are environmen-tally qualified, but are not covered by Vermont Yankee Technical Specifications fail (are not operable) or assurance cannot be provided that the equipment or component is fully environmentally qualified (due to questions of either qualification documentation or the as-installed i

status of the equipment or component), the component shall be returned to operable status or assurance of full environmental compliance shall be provided within the following thirty (30) days. If the component cannot be made operable or assurance of full environmental compliance cannot be provided within thirty (30) days, a memorandum shall be prepared and directed to the Vermont Yankee Manager of Operations within the next seven (7) days justifying continued operation in the existing condition, proposing a corrective action plan to correct the existing condition and proposing a corrective action schedule.

The Vermont Yankee Manager of Operations shall review the memorandum for the appropriateness of continued operation, corrective action completed and schedule for additional corrective action. The Manager of Operations shall concur in the continued operation of the plant, the corrective action, and the schedule; or shall direct alterr.ative actions based upon his review of the specifics of the condition.

3. Operability Requirements for Equipment or Structural Features Relied Upon for Maintenance of Environmental Conditions Assumed Durina and Followina Postulated Desian Basis Events Equipment and structural features, as specifically identified, shall be in the required status to assure maintenance of required environmental con-ditions assumed during and following postulated design basis accidents.

Deviations from the required status shall be corrected within thirty (30) days. If the deviation cannot be corrected and returned to the required status within thirty (30) days, a memorandum shall.be prepared and directed to the Vermont Yankee Manager of Operations within the next seven (7) days justifying the continued deviation, proposing a corrective action plan to correct the deviation and proposing a corrective action schedule.

The Vermont Yankee Manager of Operations shall review the memorandum for the appropriateness of continued operation, corrective action completed and schedule for additional corrective action. The Manager of Operations shall concur in the continued operation of the plant, the corrective action, and the schedule; or shall direct alternative actions based upon his review of the specifics of the condition.