ML20154L319
| ML20154L319 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/19/1988 |
| From: | Gad R, Reid D ROPES & GRAY, VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | VERMONT, STATE OF |
| References | |
| CON-#388-7130 OLA-2, NUDOCS 8809260143 | |
| Download: ML20154L319 (54) | |
Text
%
AELU ED CORREtif'ONDE N,CR 9/1h, [8k.f.D Fi1ed UNITED STATES OF AMERICA NUCLEAR REGUIATORY COhMISSION
'88 SEP 22 A10:14 before the M%..
uwa w,,
njq ATOMIC SAFETY AND LICENSING BOARD M 'W '
)
In the Matter of
)
)
Docket No. 50-271-OLA-2 VERMONT YANKEE NUCLEAR
)
(Testing Requirements for POWER CORPORATION
)
)
(Vermont Yankee Nvelear
)
Power Station)
)
)
~
APPLICANT'S ANSWERS TO STATE OF VERMONT'S FIRST SET OF INTERROGATORIES AND REQUESTS FOA THE PRODUCTION OF DOCUMENTS TO VERMONT YANKEE NUC m R POWER CORPORATION
,Jnterrocatory No. 1 Question:
1.
Please identify all persons who participated in the preparation of answers to these interrogatories and production requests, and identify the portions of your response to which each person contributed.
Resoonse:
Don A. Reid, VYNPC (Interrogatories Nos.
8, 9,
10, 12, l
16, 17, 18, 23, 24, 26 & 28).
John T. Herron, VYNPC (Interrogatories Nos.
5, 6,
8, 9,
10, 12, 13, 14, 15, 16, 17, 23, 24, 26, 28 & 29).
l Ron M. Keith, VYNPC (Interrogatories Nos.
8, 9,
10, 12, 13, 14, 15, 16, 17, 23, 24, 26, 28 & 29).
Jay K. Thayer, YAEC (Interrogatories Nos. 10, 12, 17, i
19, 24 & 28).
I Kevin J. Burns, YAEC (Interrogatories Nos. 10, 11, 17, 19, 20, 21, 22, 24, 25, 26, 27, 28, 30 & 31).
l 8909260143 800919 D
DR ADOCK O 2 1 O
'o d
Interrocatory No. 2 Question:
2.
Provide an estimate per event of the man-hours and cost of complying with the surveillance require-ments which are proposed to be deleted.
Responset vermont Yankee objects to this interrogatory on the ground that the information sought is irrelevant to the admitted contention in this proceeding.
Interroaatory No. 3 t
Question:
1 3.
Provide an estimate of the man-hours and cost to effect the proposed amendment.
Include, but do not limit, costs tot Cor.ts to respond completely to all regulatory a.
agencies and satisfy completely all regulatory processes.
b.
Costs of all analyses.
c.
Costs for modification of all documents.
d.
Costs for modification of all plant proce-dures.
e.
Costs for retraining of all personnel for modifications.
l Resoonse Vermont Yankee objects to this interrogatory on the i
ground that the information sought is irrelevant to the admitted contention in this proceeding.
1 i
I i
1 2-i
O Interrocatory No. 4 Question:
4.
Discuss the cost effectiveness of the proposed amendment for the balance of plant life.
Do not assume as cost, any instance of planned inoper-ability of components where surveillance can be doubled for requirements other than those proposed to be deleted by proper scheduling. Neither assume as cost any outage or shutdown as a result of the testing proposed to be deleted since identification of a subsystem which is on the verge of failure, while its redundant subsystem is inoperable, can only be considered a benefit.
Resoongst vermont Yankee objects to this interrogatory on the ground that the information sought la irrelevant to the admitted contention in this proceeding.
Interrocatory No. 5 Questient 5.
Provide a legible set of Piping and Instrumentation Diagrams (P&ID's) for each system or subsystem which is affected by the proposed amendment.
Resoonset The requested documents will be made available for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Road, Bruttleboro, Vermont, at a date and time mutually convenient to counsel in this proceeding.
Interrocatory No. 6 Question:
6.
Provide a legible set of One-line Wiring Diagrams for Station one-line, 4160 V Auxiliary one-line.
Emergency 4160 V Auxiliary one-line, BOP 4160 V
> l
j Auxiliary one-line, and Emergency 480 V Auxiliary one-Line.
EtfWUlE.11 The requested documents will be made available for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Road, Brattleboro, Vermont, at a date and time mutually convenient to counsel in this proceeding.
Interroaatory No. 7 ouestient 7.
For each system or subsystem affected by the proposed amendment, provide a failure mode analysis showing each potential failure mode (passive and active) which would prevent the system from per-forming its safety function, and the consequences i
of such f ailstre.
ResDonse Failure mode analyses for the Core Spray and Diesel Generator systems are contained in the report entitled "Impact of Alternate Testing on Component and System Avail-ability" submitted by Vermont Yankee on July 15, 1988 (here-inafter, the "Report").
The Report also sets forth the basis for the judgment of Vermont Yankee that the components of the other systems affected by the proposed amendment are suffi-ciently similar as to warrant extrapolation of the conclu-sions of the detailed studies of these two systems to the balance of the affected systems.
However, no detailed failure mode analyses of the balance of the affected systems was performed or is availablo to Vermont Yankee.
Insofar as this interrogatory might be construed as calling for the development of such studies, Vermont Yankee objects to it on the grounds that (i) calls for original research projects are impermissible discoveryl and (ii) the J
request would be unduly burdensome.
It has been estimated for Vermont Yankee that the additional detailed failure mode analyses called for would require approximately 2 man-years to prepara and cost approximately $250,000.
Interrocatory No. 8 I
Questiont 8.
For each system or subsystem affected by the proposed amendment, identify each active component i
or device necessary to perform the safety function of the system (include by special note, each com-ponent or device which becomes active only during the testing which is proposed to be eliminated).
For each identified device or component, provide a table or computer printout of the followings a.
Mark number of system identification b.
Component or device name or description c.
Manufacturer / Supplier d.
Model Number e.
Safety Classification f.
Applicable Manufacturing Code 9
Applicable Environmental Qualification (IEEE-323) Report h.
Qualified Service Life (in both time and num-ber of demands) 1 See, 3.g., Pennsvivania Power & Licht Co. (Susquehanna Steam Electric Station, Units 1 and 2), A LAB-613, 12 NRC 317, 334 (1980); Houston Liahtino & Power Co. (South Texas Project, Units 1 and 2), LBP-80-11, 11 NRC 477, 478 (198).
Ranconse The response to this interrogatory is presented in Attachment A to these answers.
I Interroaatorv No. 9 Ouestion:
9.
The Vermont Yankee submittal of December 7,
- 1907, proposes to amend the Bases of the Technical 'Jpeci-fication by removing the present daily testing Basis and replacing it with:
"Assurance of the availability of the remain-1 ing systems is demonstrated by ter. ting per-e formed in accordance with the requirements of l
l t
For each component or device tabulaced in Inter-
[
rogatory No. 7 above, identify the ASME Section XI
{
reference which establishes test requirements.
5 Responset l
This information is contained in, and can be extracted from, ' he document entitled "Inservice Testing program, c
i Revision 9" transmitted to the NRC Staf f by letter of Vermont Yankee dated July 28, 1988 (TVY 88-63) and a copy of which was served upon the Board and parties to this proceeding by l
letter of counsel dated August 4, 1988.
I interroaatory No. 10 I
{
Ouestient 10.
For each deleted or amended surveillance require-4 I
ment pror,osed in the Vermont Yankee submittal dated December 7,
- 1987, p
after" tabulation.p-evide the following "before and A tabulation should be made for I
each "echnical specification surveillance section I
proprsed for revis n.
i s
a.
Each cnnponent or device responsible for pro-viding safety function (from Interrogatory No.
i 1 1
O 7 above) for this specific surveillance re-quirement.
b.
Surveillance frequency for each component listed in a. above which in proposed to be deleted.
c.
Surveillance frequency for each component in above without the surveillanco requirement a.
which is proposed to be deleted.
d.
Reference for the surveillance identified for
anonse:
The information requested by this interrogatory is contained in, and can be extracted from, the document referred to in the response to Interrogatory No. 9, together with the table contained in the application for the license amendment that is the subject of this proceeding (submitted by the letter of Vermont Yankee to the NRC dated December 7, 1988 (TVY 87-112) (hereinaf ter, the "Application")), together with the Vermont Yankee Technical Specifications sections referred to in the Application.
Interrocatory No. 11 Question:
11.
Describe the availability of Manufacturer and Model Specific f ailure rate information for the compo-nents and devices affected by the proposed amend-ments.
Identify any applicable indust y reports.
Provide copies of your correspondence with the suppliers identified in Interrogatory No. 7 above requesting Manufacturer and Model Specific failure rates, and their responses.
l l
l l
l 1 I
Responset Vermont Yankee is not aware of any manufacturer and model-specific f ailure rat's information for the components and devices affected by the proposed amendment that is in the public domain.
Vermont Yankee does not possess or have
^
1 r
access to any such proprietary information from individual i
j manufacturers.
Some information can be gleaned from the Nuclear Plant Reliability Data System maintained by INPO.
The information i
used in preparing The Report will be made available for in-spection and copying at the offices of Yankee Atomic Electric l
Company, 580 Main Street, Bolton, Massachusetts, at a date
]
and time mutually convenient to counsel in this proceeding.
Interroaatorv No. 12 Qgestient 12.
Identify any I&E Bulletins, circulars and Informa-tion Notices, and any NRC Gennric letter which are applicable to components and davices identified in Interrogato n No. 7 above (Manufacturer and Model Number, or minilar models).
Prcvide Vermont Yankee responses to identified items.
Responset Vermont Yankee does not possess records listing closed I&E Bulletins, Circulars and Information Notices (1 3.,
such documents as to which Vermont Yankee's review, assessment and response (if any) has been completed) by the component af-facted.
Consequently, compiling the information requested by this interrogatory would require original research among the set of I&E Bulletins, circulars and Information Notices,
'I which documents are available to the Intervenor as public documents, and the burden of compiling which information would be essentially the same for the Vermont Yankee as for i
the Intervenor.
(See Ted. R. Civ. P. 33(c).)
Consequently, Vermont Yankee objects to this interrogatory for the reasons i
set forth sucra at note 1.
l i
The response subtitted by Vermont Yankee to any I&E Bulletin, circular or Information Notice will, upon the t
identification by the State of Vermont of any particular I&E l
i Bulletin, Circular or Information Notice for which it wishes to inspect the response, be made available for inspection and copying at the offices of Vermont Yenkee Nuclear Power Corporation, Terry Road, Brattleboro, Vermont, at a date and time mutually convenient to counsel in this proceeding.
I Interroaatory No. 13 i
l Questient i
J i
13.
Provide a chronological identification of failures or reportable events in any of the systems or subsystems affected by this proposed amendment.
For each item identified, provide the followings 3
a.
Date of the Event
]
b.
System l
c.
Event Report Number l
d.
Component or device (by navk number) respon-sible or affected by the event i
Repair / Replacement time for the component or
[
e.
device responsible for the event Prcvide a copy of each event report identified l
above.
I 9
t t
i l
t l
O Responset Vermont Yankee aoes not possess recordo containing the information requestod by Interrogatories Nos. 13 and 14 in readily available form.
The information is contained in, and can be compiled and extracted from, voluminous plant records (which records will be made available for inspection and copying at the of fices of Vermont Yankee Nuclear Power Cor-poration, Ferry Road, Brattleboro, Vermont, or Vermont Yankee Nuclear Power Station, Governor Hunt Road, Vernon, Vermont, depending upon the location of the records in questoin, at a date and time mutually convenient to counsel for the par-l ties), and the burden of compiling and extracting the I
information would be essentially the same for Vermont Yankee j
as for the Intervanor.
(See Fed. R. Civ. P. 33(c).)
Consequently, Vermont Yankee objects to this interrogatory on j
the grounds (i) set forth supra at note 1, and (ii) on the grounds that the ef fort required to research the information requested by this interrogatory would be unduly burdensome.
Vermont Yankee has estimated that compiling and extracting the information called for by this interrogatory would require approximately 0.5-0.75 man-years of effort and cost approximately $60,000-$90,000.
Notwithstanding and without waiving this objection, Vermont Yankee has compiled the requested information for the past 5 years, which is presented in Attachment B to these interrogatories.
10 -
Interrocatory No. 14 Qg311;1gnt 14.
Identify the following for each proposed deletion of testing requirements:
Number of anticiented (planne6 maintenance or a.
repairs, etc.) instances in the life of the plant in which this testing requirement has been invoked.
h.
Number of unanticinated (unplanned events) instances in the life ol' the plant in which this testing requirement has been invoked.
Provide event reports and all related documentation for these unanticipated events.
Provide documenta-tion from plant records (operator's logs, procedure checklists) which demonstrate the results of invoking these testing requirements.
Number of instances in either group a. or b.
c.
above in which testing of alternate systems produced a failure and caused power reduction.
Identify the date of occurrence and Event Report Number.
Provide all related documenta-tion, such..a operational logs, procedure checklists, repair records, etc.
d.
Number of inotances in either group a. or b.
above in which the Limited Condition of opera-tion (LCO) timi limit expired, and power re-duction occurred.
Identify the date of occur-rence and Event Report Number.
Provide all related documentation, such as operational logs, procedure checklists, repair records, etc.
Responset Vermont Yankee does not possess records containing the information requested by Interrogatories Nos. 13 and 14 in readily available form.
The information is contained in, and can be compiled and extracted from, voluminous plant records (which records will be made available for inspection and copying at the offices of Vermont Yankee Nuclear Power Cor-poration, Ferry Road, Brattleboro, Vermont, or Vermont Yankee Nuclear Power Station, Governor Hunt Road, Vernon, Vermont, depending upon the location of the records in questoin,at a date and time mutually convenient to counsel for the par-ties), and the burden of compiling and extracting the information would be essentially the same for Vermont Yankee as for the Intervanor.
(See Fed. R. Civ. P. 33(c).)
Consequently, Vermont Yankee objects to this interrogatory on the grounds (i) set forth suora at note 1, and (ii) on the grounds that the effort required to research the information requested by this interrogatory would be unduly burdensome.
Vermont Yankee has oJtimated that compiling and extracting the information called for by this interrogatory would require approximately.5.75 man-years of effort and cost approximately $60,000-$90.000.
Notwithstanding and without waiving this objection, Vermont Yankee has researched the requested information for the past 5 years in connection with its preparation of Attachment B to tr.ese interrogatories and provides the following informations
- a. + b.
During the period covered, the records reviewed revealed that alternate testing has been invoked 175 times.
Vermont Yankee is unable to supply the disaggregation of this total requested by sub-parts u. and b. because (i) the interrogatory fails to define the classifidation re-quested with sufficient precision, (ii) because, insofar as O
I alternate testing might (under the exinting provisions) be required on account of a maintenance decision, maintenance decisions can be too subjective to be readily classifiable in 1
the manner suggested by this interrogatory, and l'
a records reviewed do not permit such classificat c.
of the instances referred to in the t
.e to f
sub-part a., alternate testing "produced a failure and caused l
(1 3., the failure required under applicable guidelines) i power reduction" 6 times, i
l d.
Of the instances referred to in the resgsnee to sub-part a., no instanca was discovered in which the i
"Limit (ing) condition of operations (Leo) time limit ax-pired".
b i
The documents reviewed for this project will be made available for inspection and copying at the offices of Vermont Yankee Nuclear Power corporation, Ferry Road, Brattleboro, Vermont, at a date and time mutually convenient to counsel in this proceeding.
L Interroaatory No. 15 j
Ouestion I
15.
How are the testing requirr.ments which are proposed to be deleted presently incorporated into plant procedures?
Identify and provide copies of all operating, maintenance, emergency and/or other L
procedures incorporating these test requirements.
i ResponseI f
The VYNPS Technical Specifications, in their present f
r form, dictate when alternate testing is required.
The i
f 12 -
t i
I L
I
procedures to be used for conducting the tests are contained in the appropriate test procedures, which, with the exception of diesel generators, are the same as the procedures employed for conducting reutine surveillance tests.
(For diesel l
generators, the alternate tests consist of one hour in lieu of eight hour rung.)
The documents requested by this interrogatory will be made available for inspection and copying at the offices of i
i Vermont Yankee Nuclear Power Corporation, Terry Road, Brattleboro, Vermont, at a date and time mutually convenient
?
to counr.a1 in this proceeding, l
t Interroaatory No. 16
[
Questient l
l I
16.
Describe the anticipated surveillance. and main-tenance activities of the components affected by i
l I
this proposed amendment.
Specifically:
l What is the maintenance frequency of each a.
component?
t t
l b.
How is the maintenance scheduled?
Now often does the testing the alternate sys-l c.
ten requirement come into effect?
j d.
What, if any, verification and surveillance of t
the alternate systen takes place before taking a component out of service for maintenance?
Is this pre-maintenance surveillance required I
e.
by Technical specifications?
If so, identify the references.
f.
Is this pre-naintenance surveillance covered f
in maintenance and operation procedures?
If i
so, provide copies of the procedures and identify the applicable section(s).
i L
f l
[
I I
L
I g.
Provide all checklists and maintenance records since the last scheduled outage for the com-ponents and devices affected by this request.
7 Responset
- a. + b.
Maintenance frequency and schedule varies i
depending upon any one or more of the following factors i
Vendor recommendations.
Shift supervisor and plant management judgment.
Location of components.
Severity of the condition of :vrVnents.
l l
Time of the year (1.h, winte/ m: summer).
l Time into the operating cycle.
Other equipment out of service.
Scheduled outages, i
l Maintenance history of components.
Consequently, fixed answers by components cannot be given.
f c.
Alternate testing is performed whenever one of the components listed in the response to Interrogatory No. 4 is inoperable.
d.
Per VYNPS Procedure AP-0025, the shift supervisor l
determines what verificati.on or surveillance, if any, will be performed prior to a componwnt or system being removed from i
t service for maintenance.
This decision is based on one or more of the following factors
[
shif t supervisor evaluation of the situation.
j When the last surveillance or testing was performed.
(
Doration of the maintenance.
l f
i
{
i i
l i
Other Technical specification equipment that may be out of service.
i e.
No.
- f. + g.
Procedure AP-0025 and the documents tiquested by sub-part g. will be made available for inspection and copyin7 at the of fices of Vermont Yankee Nuc'aear Power Corporation, Terry Road, Brattleboro, Vermont,. at a dnte and time mutually convenient to counsel in this proceeding.
Interroaatory No. 17 r
Questient 17.
The Vermont Yankee submittal of December 7,
- 1987, i
prcposes to amend the Bases of the Technical speci-
{
fication by removing the present daily teJting i
Basis and replacing it, in part, with!
Assurance of the availability of the remaining systens is demonstrated by... verifying the system.is in an operable status."
a.
Describe the bypassed and inoperable status i
indications available to the control room i
I operator for each system or subsystes affected by the proposed amendment.
s l
l b.
Describe the degree of compt (ince with Regula-i tory Guide 1.47, "typassed an:3 Inoperable
[
Status Indication for Nuclear Power Plant I
Safety Systems."
(
1 I
c.
If manual operatio7s or acticns (novement of i
toggle switches, etc.) are necessary for the n
systems or subsystems affected by the proposed i
amendmont, provide copies of procedures con-l trolling those who must take those actions, i
d.
Identify any instance in the life of the plant in which bypassed and inoperable status in-(
dicatica has not been set correctly.
Irovide
[
all re; tsd docuneatation.
l e.
The subject of bypassing safety systems is
(
identified as an area of concern in NUREG-1251, "Implications of the Accident i;t Cher-i
= 16 -
4 nobyl for Safety Regulation of Commercial Nuclear Power Plants in the United States,"
August 1987.
In the report Section 1.3.2, it I
is stated, "The current effort under way at NRC to revise RG 1.47 was recommended in NUREG/CR-3621 (which) identifies some of the tasks associated with monitoring the status of bypassed safety systems (e.g., updating status boards and determining system status during all medes of operation) which are prone to human errors.
These human factors con-siderations are being reviewed for possible inclusion in RGl.47."
Describe Vermont Yankee's awareness of and involvement with this NRC program.
f.
Discuss why Vermont Yankee believes it to be prudent to alter the present safety Basis of the plant to a Basis which is curreatly an NRC concern and being revised.
Why would it not be more prudent to withdraw the present request until the Bypassed and Inoperable Status Indication issue is re-solved?
Resconse:
a.
VYNPS control room operators have available for their use a number of indications for determining the bypassed and inoperable status of systems, sub-systems or components affected by the proposed amendment.
These include:
1.
Individual component status lights, which may be rad, green or (in some cases) amber, located in the control room and providing information on position and power availability.,
1 2.
Automatic alarms sounding in the control room provide a wide range of indication, the bulk of which is used in determining operability status.
3.
Procec'ure AP-0140 ("Switching and Tagging Pro-cedure") is used, in conjunction with the require-ment of shift supervisor permission, to control the raystem and component status and maintenance done on any VYNPS system.
The tags employed give direct indicaticn to control room operatora of individual component status and the status of the r,ystem.
4.
Procedural controls and operating practices require 4
that the shift supervisor be informed and give permission for working on any plant equipment.
b.
Regulatory Guide 1.47 has not been committed to by Vermont Yankee and is not part of its regulatory basis.
Consequently, Vermont Yankee does not possess any readily available study of the dagree to which, were it applicable, the guidelines of Reg. Guide 1.47 would be met.
Vermont Yankee objects to this interrogatory to the extent that responding to it would require original research, for the reasons set forth at note 1, supre.
The methods utilized to s
monitor the status of bypassed and inoperable equipment are described in the respense to sub-part a.
c.
Vermont Yankee does not comprehend what information is being requested by this interrogatory, and consequently cannot respond to it. I L
d.
Vermont Yankee objects to this interrogatory on the same grounds as are stated above in response to Interroga-tories Nos. 13 and 14, and on the further ground that the interrogatory does not provide a sufficiently precise engineering definition to permit a categorical response.
Notwithstanding and without waivina this objection, Vermont Yankee has researched this information for the last 5 years during the process of preparing Attachment B to these interrogatories, and provides the following information:
1.
While there have been instances involving calibra-tion errors and literal non-compliance with tagging requirements, no instance where system unavail-ability could only have been determined by alter-nate testing was detected, and the answer to the question, as most likely intended, is therefore "None."
2.
The documentation reviewed for this project is provided in a prior response.
3.
The intervenor r.ay wish to refer to LER's 83-32 and 84-05.
Vermont Yankee is generally aware of the on-going e.
NRC program referred to.
It is not involved in any way in that program.
f.
Vermont Yankee objects to this interrogatory, on the grounds (i) that as phrased is it mere argument and not a request for information, and hence is not a proper use of the discovery provisions of the Commission's Rules of Practice, and (ii) that the information called for is irrelevant, in that the standard for approving or disapproving this amend-ment is whether it conforms to the Commission's regulations, not whether it is "prudent."
Notwithstanding and without waiving this objection, Vermont Yankee points out (i) that the basis for proposing this amendment is the fact that implementation of the amendment will eliminate testing that is both unnecessary and a contributor to the unavailability of the affected safety systems, and (ii) contrary to the implicit assumption of this interrogatory, reference to control room status indicators is not the only effort taken by Vermont Yankee to verify the operability of redundant systems in the event of the unavailability of a system train.
As a consequence, the desirability of this ar.cadment is, in Vermont Yankee's judgment, not dependent upon any outcome that might someday eventuate from Staff consideration of possible amendments to Reg. Guide 1.47.
Interrocatory No. 18 Ouestion:
18.
Why are the Surveillance Sections of the Technical Specifications which are proposed to be deleted not replaced with statements requiring operators to verify immediately the operability status of the redundant system?
Resconse Vermont Yankee believes that, perforce the provisions of the Technical Specifications establishing LCOs, the operators are required to be continuously cognizant of the status of the systems referred to, whether or not an event that heretofore has triggered alternate testing requirements has occurred.
Vermont Yankee therefore believes that the additional language suggested by this interrogatory would be, at best, mere surplusage, and that it might possibly be misleading.
Interrocatory No. 19 Question:
19.
On July 15, 1988, Verac7t Yankee responded to an NRC request for additional information by submitt-ing the report, "Impact of Alternate Testing on Component and system Availability (hereinafter called "The Report"). "
Indicate who prepared "The Report," Pickard, a.
Lowe and Garrick, Inc., or Yankee Atomic l
Electric Company.
Indicate the relationship l
between Yankee Atomic Electric Company and Pickard, Lowe and Garrick, Inc.
b.
"The Report" is a document whicn affects quality and safety, falling under the require-ments of 10 CFR 50, Appendix B, Section VI, "Document Control," which states that such documents must be "reviewed for adequacy and approved for release by appropriate person-nel."
However, "The Report" provides no indication of review or approval.
Provide documentation demonstrating that such review and approval took place, including the names of all reviewers and approvers; and copies of review, comment and approval copies from all reviewers and approvers.
c.
Provide a copy of the Quality Assurance l
procedure governing the preparation, review l
and approval of "The Report."
d.
Identify the qualifications of all preparers, reviews and approvers, and specifically their background and experience in the preparation of pRA analyses. _
Resconse:
The report was prepared by personnel from Yankee a.
Atomic Electric Company (YAEC) and Pickard, Lowe and Garrick, Inc. (PLG).
The relationship between YAEC and PLG was that of two independent contractors working together under the direction of Vermont Yankee Nuclear Power Corporation.
b.
Vermont Yankee's request to change the Technical Specifications regarding alternate testing was submitted on December 7, 1987 and contained the licensees' conclusion that the proposed change did not involve a': unreviewed safety question as described in 10 C.F.R. 5 50.59.
During NRC's review of this proposed change, supplemental information was requested of the licensee in the form of "additional informa-e tion to complete our (NRC) review."
"The Report" was prepared in response to this request and provided a quantita-tive basis documenting the conclusion in the amendment request that removing the current alternate testing require-ment results is a measurable plant safety enhancement.
This supplemental information provided in response to an NRC question, supports a prior Vermont Yankee determination and is therefore not a design record as defined by 10 C.F.R.,
l Part 50, Appendix B and the Vermont Yankee Quality Assurance i
j Program.
Therefore, the Vermont Yankee Quality Assurance Program was not required to be applied to "The Report."
The premise in this question is therefore not true and this l
l question cannot be answered.
l i l
c.
See response to Interrogatory No. 19(b).
d.
This information is provided in the table con-stituting Attachment C to these answers.
Interrocatory No. 20 Question:
20.
Section 5.2.1 of "The Report," as well as Sections 5.2.2 and 6.2, and Appendix C, make reference to
' Reference 4' for generic input data.
Section 11 identifies Reference 4 as Pickard, Lowe and Gar-rick, Inc., "Probabilistic Risk Assessment Data Base for Light Water Reactors," PLG-0500, August 1988.
a.
How can "The Report," submitted on July 15, 1988, use a reference published in August 1988?
b.
Since PLG-0500 is used as basis for safety-related conclusions, it appears it should also meet 10 CFR 50, Appendix B, Section VI, Docu-ment control requirements.
Provide an indica-tion of the level of Quality Assurance as-sociated with the preparation of PLG-0500.
Has Yankee Atomic audited this area of PLG's work?
Indicate the level of review of PLG-0500 by c.
Yankee Atomic personnel.
d.
Provide a copy of Reference 4.
ResDollag:
n.
By oversight, the words "expected publication" were omitted before the date of August, 1988.
b.
Inasmuch as this question is founded upon a premise that is not true, it cannot be answered.
See the answer to Interrogatory No. 19(b).
c.
Data from the PLG data base, which will be docu-mented in PLG-0500, that was used in The Report was reviewed by Yankee Atomic Electric Company for reasonableness and applicability.
This review was based on experience and engineering judgment.
d.
At the time The Report was issued, PLG-0500 was I
expected to be published in August, 1988; see the response to
{
sub-part a.
Publication has not yet occurred, and therefore a copy of PLG-0500 cannot be provided.
Actual data values used in The Report are provided in The Report.
Interroaatory No. 2A Que s t io.D 8 21.
Several areas of "The Report" should have referen-ces added:
a.
At page 1, line 1, identify a reference for "the Vermont Yankee Inservice Testing Pro-gram," and provide a copy.
b.
At pages 6, 7,
27 and 28, references are not provided for equations.
Identify the referen-ces and provide copies.
Resconses The document referred to is "Inservice Testing a.
Program, Revision 9" transmitted to the NRC Staff by letter of Vermont Yankee dated July 28, 1988 (FVY 88-63) and a copy of which was served upon the Board and parties to this pro-ceeding by letter of counsel dated August 4, 1988.
b.
The equation on page 6 can be found in NUREG-0492, "Fault Tree Handbook."
The equation on page 7 is derived on page 7, based on the cefinition of a mathematical integral.
The equations on page 27 are definitions. -
r
The equation on page 28 is derived based on the text and equations on pages 26 and 27.
Interrocatorv No. 22 Question:
22.
At page 1, lines 20-22 of "The Report" it is indi-cated, "Analyses were parformed to quantify the impact of alternate testing on the availability of affected systems.
The report presents the results of these analyses."
Provide copies of these analyses and all supporting information.
ResDonse:
The requested documents will be made available for in-spection and copying at the offices of Yankee Atomic Electric Company, 580 Main Street, Bolton, Massachusetts, at a date and time mutually convenient to counsel in this proceeding.
Interroaatory No. 23 l
Question:
23.
At page 1, line 5 of "The Report" it is stated, "Most other Boiling Water Reactors (BWR) do not have these alternate testing requirements, since alternate testing is not part of the BWR Standard Technical specification."
a.
In order to make this statement, the testing requirements for all other BWRs must have been reviewed.
Based on this statement, identify all BWR plants which have any eart of the testing proposed to be eliminated which is more stringent than the Vermont Yankee proposal.
b.
Provide a tabular review of the BWR Standard Technical Specifications comparing (for each surveillance test proposed for elimination):
4 1)
Vermont Yankee LCO "out of service times" before power reduction with those from the Standard Technical Specifications. W
2)
Any areas where the standard Technical Specifications require testing upon a "component out of service" which are not included in the Vermont Yankee proposal, Provide justification for any item in part b.
c.
above in which the Standard Technical specifi-cation is more stringent than Vermont Yankee proposal.
If there are either LCO or Surveil-lance Testing requirements which are more T.estrictive in the Standard Technical Specifi-cations, explain what is meant by the state-ment in the Vermont Yankee proposal letter of December 7, 1987, at page 3, paragraph 3, "The change is.
consistent with the testing requirements contained in the BWR Standard Technical Specifications."
Resconse:
Noting that the statement by which this intsr-a.
rogatory is preceded is true neither as a matter of fact nor logic, Vermont Yankee is aware of no such plant.
b.
Vermont Yankee does not have the information called for by this information in any compiled form.
However, che information called for by this interrogatory is contained in, and can be extracted and compiled bv. comparison of, the BWR Standard Technical Specifications, which is a publicly avail-able document, and the Vermont Yankee Technical Specifi-cations, of which the Intervenor is believed to have a copy and which will be provided for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Road, Brattleboro, Vermont, at a date and time mutually convenient to counsel for the parties.
The burden of ex-tracting and compiling the information from these documents would be essentially the same for Vermont Yankee as for the _. _ _ _ _
1 Intervenor.
(See Fed. R. Civ. P. 33(c).)
Consequently, Vermont Yankee objects to this interrogatory on the ground set forth puera at note 1.
c.
See response to Interrogatory No. 23(b).
Interrocatory No. 24 Question:
24.
In Attachment 1 to the Vermont Yankee proposal of December 7, 1987, it is reasoned that daily sur-veillance should not be performed based on the increased chance of component failure or degrada-tion due to testing.
It is further mentioned in "The Report" at page 4, "Reduced reliability due to equipment degradation from excessive testing."
What is considered to be "test degradation?"
a.
Is it failures caused by the testing or is it the increased potential for demand failures required from misalignment in the event cf an accident?
b.
For each system or subsystem affected by this proposed change, discuss whether design changes are possible or desirable to allow the required testing to be accomplished safely.
IEEE-323 and Regulatcry Guide 1.89 require c.
that safety-related electrical equipment and components are tested to the envircnment and service conditions in which they are expected to function.
For each component identified in of Vermont Yankee letter, December 7, 1987, provide copies of the applicable Environmental Qualification test reports and identify a section reference in the report which indicates how this surveil-lance testing han been taken into account in the qualification.
d.
Dis ~ cuss why a requirement to be at HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of an inoperable redundant component is not a more prudent action to protect public safety since it is stated that the testing presently required is unsafe. -._ _
e-Resconset a.
"Test degradation" refers to component wear or damage that occurs as a result of a test demand.
Degradation that is repaired after the test is referred to as "test-related failure" and is considered in the analysis presented in The Report.
Degradation that does not manifest itself as failure and is not repaired after tha test is the "test degradation" referred to on page 4 of The Report.
b.
Vermont Yankee does not understand what the pro-ponent of this information means by the phrase "to be accom-plished safely," and does not understand what the design q;als would be, and consequently does not understand what is requested by this interrogatory.
c.
Vermont Yankee is unaware of an connection between the testing required (if any) to establish the environmental qualification of electrical equipment and the alternative testing roquirements that ate the subject of this amendment, and consequently Vermont Yankee does not understand what information is sought by this interrogatory.
Vermont Yankee will make the Environmental Qualification reports for any component available for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Roed, Brattleboro, Vermont, or such other place as such reports may customarily be kept, at a date and time mutually convenient to counsel for the parties and upon specification by the,
l
Intervenor of the component for which it wishes to inspect the Environmental Qualification report.
d.
Vermont Yankee objects to this interrogatory on the ground that, as phrased, it is not relevant to the admitted contention in this proceeding.
Notwithstanding and without waiving this objection, Vermont Yankee provides the following information:
As Vermont Yankee understands this interrogatory, it asks why any form of continued operation of the plant follow-ing the unavailability of one train of a redundant system should be countenanced, that is to say, why thould not all Limiting Condition of Operations ("LCOs") be zero as a matter of regulatory pclicy? As it thus understands the question, Vermont Yankee does not believe that it has anything to do with the conformity of the proposed amendment to the Commis-sion's Regulations, or with the desirability of the pending amendment.
Without regard to anyone's view of the compara-tivo desirability of zero period LCOs as a matter of policy, approval of the pending amendment makes sense because it would eliminate testing that is both unnecessary and a con-tributor to the unavailability of the systems being tested.
As for the judgment that permitting the continued operation of a plant following the loss of a redundant train, for a l
limited cine, both sound engineering judgment and history lead to the conclusion that the percentage of the time of one-train unavailability that the second train is also un-O available is very low, and the percentage of the time that any system may be called upon to ensure the public safety is also very low.
The compound probability of both conditions is, therefore, even lower.
On the other hand, requiring unnecessary plant shutdowns is costly to society, both in economic terms and in terms of unavailable power (or demands upon finite sources of power), and such shutdowns pose their own potential challenges to plant systems.
Consequently, Vermont Yankee believes that the jucgment inherent in the regulatory philosophy that this interrogatory questions is tnat the risk that might be avoided by the alternative philosophy that this interrogatory may he advocating is far outweighed by the costs and risks of that alternative philosophy.
Interrocatory No. 25 Question:
25.
At page 6 of "The Report," it is indicated that the linear approximation is valid only when the condi-tion is met that the failure rate-time product is
'much less' than 1.
At page 7, the same condition applies, although it is not stated.
However, for the failure rate data provided on pages 31 and 32, and the time periods graphed on pages 34 through 38, it appears this condition may rot always be satisfied.
Describe how the results of the analysis would change if the failure rate-time product approaching 1 were taken into account.
Resoonset The function (lambda)t is an approximation to the function 1-e-(lambda)t.
At t=0, both functions give the same value (zero).
As t increases, the value of (lambda]t is (
i always greater than the value of 1-e-(lambda)t.
Thus, une of the function (lambda)t to approximate 1-e-(lambda)t will overestimate the unavailability due to time-related failures.
Use of the functica 1-e-(lambda)t would change the results by reducing time-related failures.
This produces an even larger gain in availability due to eliminating daily alternate tests.
Interrocatorv No. 26 Ouestion:
26.
At page 8 of "The Report," the second example indi-cates that the valve which fails the test would be declared inoperable and repaired.
a.
Why should it not rather real that, if the valve fails the test, the unit is brought to a safe shutdown condition?
b.
If it is the practice to attempt repair when both redundart trains are inoperable, provide a comparison between Vermont Yankee and BWR Standard Technical Specifications of the time allowed for this repair before LCO shutdown is required.
Provide this comparison for each surveillance test which is proposed for deletion or modification.
c.
provide an explanation and basis if, for any system, the comparisen indicates the BWR Standard Technical Specification is more restrictive than thes Vermont Yankee Technical Specifications.
Besponses a.
The second example on page 8 of the report was intended to illustrate the definition of test-related failure.
If a valve fails a cost, tha subsequent action depends on the, Technical Spa.cification requirements, t i
Technical Specifications do not require the unit to be brought to shutdown whenever a valve fails a test, b.
Such is not the practice.
Initiation of an "LCO l
shutdown" is required at VYNPS whenever redundant trains are inoperable, and this requirement will not be changed by the proposed amendment.
c.
No answer required.
Interrocatory No. 27 Question:
27.
The anomaly presented in the graphs on pages 34, 43 and 45 of "The Report" is purely a function of the attempt to repair while both redundant trains are inoperable instead of bringing the plant to an im-mediate safety shutdown condition.
This is con-firmed by statements in Sections 5.3.1 and 7.0 of "The Report."
This is an anomaly because it seems to indicate it is more desirable to n21 discover a failure by testing (if the failure is to occur on the next demand), but rather to discover it in an accident event if one were to occur.
The anomaly is removed from the results if it is assumed the plant immediately proceeds to safe shutdown instead of repair, a.
Describe how shutdown situations are treated in the analyses described by "The Report."
If the repair period extends beyond the LCO limit, how is this accounted for?
Does your analysis account for unavailability because the plant is in an outage?
b.
Provide the graphical representations on pages 34, 43 and 45, assuming immediate shutdown in-stead of repair.
For this analysis, to assure conservatism, choose and justify a minimum value for Demand Failures and a maximum value for time-related failure rate.
c.
Comparing the results from part b. above with the graphs on pages 34, 43 and 45, discuss the prudency (sic) of a policy of proceeding j
immediately to safe shutdown.
l l l
e d.
If a failure is to occur on the next demand (and the redundant train is inoperable), is it more desirable to discover this by test or in an emergency situation?
Responset A shutdown LCO is entered whenever two ECCS subsyn-a.
tams are declared inoperable.
The LCO requires that the unit be in shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Repair times used in the report on page 32 are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Thus, although the Technical Specifications would allow an unavailability for up i
to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the analysis limited the unavailability to the repair duration.
No unavailability was considered after the plant was shut down.
b.
As discussed in Part a above, the analysis in the report already considered the Technical Specifications for shutdown given that two ECCS subsystems are declared in-operabla.
Since ne change in the duration of the Techn!
1 Specification shutdo' ' LCO is being sought by this amendment, further analysis discussing different shutdown I40 durations is not meaningful.
c.
As discussed in Part b above, discussions of the i
shutdrwn LCo duration is not weaningful.
d.
The report assumes that the demand-related failures are random.
Thus, the probability that a demand-related failure will occur on the next demand is assumed to be the same as the probability that a demand-related failure will occur on the second or third or fourth or the nth demand. 1
Thus, for demand-related failures, the probability of failure upon an actual accident demand is the same before and after the test (or after repair if a demand-related failure occurred at the test).
If a failure is to occur on the next demand, then by definition, the probability of a demand-related failure is 1.0 for the next demand, and some other value for subsequent demands.
This is inconsistent with the random nature of a demand-related failure as applied in the report.
Thus, the appropriateness of testing given a demand failure probability of 1.0 is not meaningful.
Interroaatory No. 28 Questient 28.
Discuss how the inoperable state of the standby Liquid Control System which existed from July 11, 1984 to February 8, 1986, is taken into account in the analysis described in "The Report."
Resoonset The interrogatory refers to the SLC System "Squib" (explosive) valves, which failed to detonate during annual surveillance testing.
Detonation of the squib valves is not (and could not be) within the scope of alternate testing, and this failure, therefore, is not within the scope of the testing to be deleted by the proposed amendment.
The Report is limited specifically to the testing to be deleted by the proposed amendment, and conceptually to testing capable of being performed while the reactor is operating.
Detonation )
e of the squib valves, therefore, is not, could not be, and should not have been "taken into accourit" by the Report.
Interroaatorv No. 29 Question:
In Section 8.0 of "The Repot't," it is indicated:
"Th.
identif. cation of patentiel common cause com-ponent gr.'ups and developp),'A of procedures to sys-temL2ical. r evaluate events for the root causes and coupling 9 '10r.'r; e is an effective method for minimizing tni occurrence of u_nanticipated multiple failures."
For the.ife of ti.) plar.t, tabulatt each potential f
common cause which has been identified by your proca-dures.
Include date, descriptions, and event reports numbers.
Provide a copy of all avant reports identify-ing common causes.
Response
Vermont Yankee objects to this interrogatory on the same grounds as are stated above in response to Interrogatories Nos. 13 and 14.
Notvithstanding and without waiving this objection, Vermont Yankee has researched and provide this information for the last 5 years during the process of preparing Attachment B to these interrogatories, and provides the following information:
Potential common cause events are evaluated by one or more of the following methods:
Investigation and follow-up of a Potential Reportable Occurrence" and resulting "Licensee Event Report" by engineering personnel (Procedure AP-0010).
Review and follow-up of the periodic review of equipment history by maintenance personnel (Procedure AP-0200).
4 Investigation and follow-up by the shif t supervisor and associated maintenance personnel.
Only the first two methods are formally documented in plant records.
LERs 84-22, 86-04, Pros 88-34 2nd 88-60, and certain AP-0200.03 forms have been determined to be poten-tially responsive to this interrogatory and these documer.ts will be made available for inspection and copying at the offices of Vermont Yankee Nuclear Power Corporation, Ferry Road, Brattleboro, Vermont, at a date and time mutually convenient to counsel in this proceeding.
Interroaatory No. 30 Ouestiont 30.
In EPRI NP-5475, "Identification and Classification of Technical Specification Problems," December 1987, the statement is made in Section 4.2, Impli-cations for the Use of Risk Based Methods in Tech-nical specification Improvement:
"There are at present no generally accepted means of directly associating levels of risk and risk changes with the requirement of any technical specification."
Why it would not be more prudent to withdraw the present amendment at this time pending establish-ment by the Industry of "generally accepted means,"
endorsed by the NRC?
Resoonse Vermont Yankee objects to this interrogatory on the ground that it is not relevant to the admitted contention in this proceeding, which is to be decided on the basis of whether the proposed amendment conforms to the Commission's Regulations and not whether someone might think it prudent to withdraw it.
Notwithstanding and without waiving this objec-tion, Vermont Yankee provides the following information:
36 -
The statement:
"There are at present no generally accepted means of directly associating levels of risk and rish changes with the requirements of any Technical specification."
refers to cuantitative levels of absolute risk and ouantita-tivq changes in risk.
It reflects the lack of established numerical criteria for acceptable risk, even though levels of risk and changes in risk can be calculated numerically.
Note that the following is also stated in Section 4.2, EPRI NP-5475:
"At present, the most objective and direct means available for assessing the public safety impact of Technical Specifications is the use of risk-based methods."
The strength of these risk-based methods is their ability to perform relative comparisons.
That is, will a given change increase or decrease safety?
When the results show a safety benafit, which is consistent with engineering judgment and experience, then Vermont Yankee believes it is prudent to proceed with the change.
Interrocatory No. 31 QMistion:
31.
Demonstrate that the "out-of-service times," during which it is proposed nQt to verify redundant sub-system availability by test, do not cause unneces-sary risk to public health and safety and the environment.
ResDonse:
This demonstration is contained in the Report.
O 9.
19.
88 04 18PM
-VCAMoNT YANMEE PCWER PO; N
hd h b
7i y l
l signatures Donald A. Reid, being first duly sworn, states that the foregoing answers are true, sucopt insofar as they are based on information that is available to Versent Yankee but not within his personal kaswledge, as to which he, based on such in,.
.i.n,
.u.ve..
..,e.
., oi. c any.,.e,.
tomber, 1348.
Donald A. Reit
'Then personally appeared Donald A. Reid, before and sena11y known to me, who, being first duly e
, made
'Cvg that the foregoing statement is true, this,],3,,
y of tamber, 1988.
r L
D Al Notary publio
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OUC MycommissioneWpir,ecty((1 la in nhinatianas qt
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1 Page 1 ATTACHMENT A MANUPACTURER/
COMPONENT SUPPLIER MODEL No.
SAPETY CLASS P46-1A(18)
Singham Motor 2
SK4329XL5A Pump Type CVOS CS 5A(58)
Walworth 5204-WE 2
Reliance Frame K40 Phil Gear Corp.
SMS-000 CS-12A.;128)
Walworth 527 7PSB-Wt 1
Reliance 215R2/215TR2 Phil Gear Corp.
SMS 2 CS-11A(118)
Walwortn 5247-WE 2
Reliance Frame 215R2 Phil Gear Corp.
$MS 2 CS-26A(258)
Walwortn A-5790 M-38 2
Reliance Frane P 56 Phil Gear Corp.
SMS-1 HPC1 Pump 10x12x15 DVMX 2
Syron Jacksen 12x14x23 DVS Turbine Stop Schutte & Koerting 60-XC-71 2
Valve Turbine Control Rooert Show E-9403-62 2
Valve HPCI 14 Welworth 2
Peerless Preme 052248 Phil Geer Corp.
$Me-3-00 HPC! 50A AFC Indwatries 73 53-3 OH 2
MPCI 25 Walworth A-9533 11-54C 2
Peerless Frame 02020 Phil Seer Corp.
SMS-1 HPCI-19 Walworth 2
Peerless Preme 0225N Phil Gear Corp.
SMS 4
O s.
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Attachment A Page 2 MANUPACTURER/
COMPONENT SUPPL!tR MODEL No.
SAFETY CLASS HPCI 20 Walworth 5247 PS-WE 2
Peerless Frame 022SN Phil Gear Corp.
SMS-4 HPCI-21 Walworth 2
Peerless Frame 02918 Phil Gear Corp.
SMS-3 HPCI-24 Walworth 5247 PSS-HE 2
Peerless Frame 020f4 Phil Gear Corp.
$MS-1 HPCI-57,58 Walworth 3343s4 2
Peerless Prame 0554 Frnae OE6H Phil Gear Corp.
$MS-1 HPCI-17 Walworth 5202-WE 2
Re11ance Frame RSS Phil Gear Corp.
SMS-0 HPC! 42,43 AFC Industries 70-14 1 ORTFS 0
)
R$-192794 HPCI-39,40 Black, Sir 11s & Bryson 0
HPCI 83 AFC Industries 70-18 1 OATFS 2
HPCI 84 Black, Stra11s & Sryson 2
REF-2A(28)
Chicago Olower 2
Allia Chalmers 27-10-12 SB-4A(45)
Oynatrol 00616-1 2
Robot Are Actuation SS 5 Dynetrol Robot Arm Actuation 00618 4 2
S07-1A(18)
Dynetrol I
Robot Arm Actuation 00616 4 2
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Attachment A Page 3 NANUPACTURER/
COMPONENT
$UPPLIER MODEL NO.
SAFETY CLASS 50T-2A(24)
Oynatrol Ro ct Arm Actuation 00818-5 2
$0T-3A(38)
Dynatrol Robot Arm Actuation 00616-7 2
PT-1A,0,C,0 Byron Jackson 14 KXH 3
Westinghouse Frame lot P24
- 1 Pan, West Fluor Products 28-4 3
Tower Westinghouse Frame 0135 PWC-35 (Gear)
R$W 49A/B Walworth 45334 4 g/M 3
535759 Reliance Frame 313R2 Phil Gear Corp.
GMS-2 P8-1A,8,C,0 Byron Jackson 3
Westinghouse Frame 5805 P30 00 1-1A (18)
Fairbanks/ Morse 38T04-1/4 2&3 P92-1A(1)
Tuth111 Co.
3 RHR-30A/B Walworth 2
Re11ance Frans.. r Phil Gear Corp.
SNe-00 RHR 34A/S Welworth 10 Glob CS 2
Reliance Freme T56 Phil Gear Corp.
SMS-2 RHR-26A/S Walworth 2
Reliance Frame T86 Phil Gear Corp.
SMS 0 RHR-31A/6 Welworth 2
Reliance Frame T56 Phil Gear Corp.
SMS*0
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88 04 : ;9PM
-VORMONT *IANECC POWDR PO U
Attachment A Page 4 MANUPACTURER/
COMPONENT SUPPLIER MODEL NO.
SAPETY CLASS RHR-39A/S Walworth 12 CATE CS 2
Peerlena Prame P12M Phil Gear Corp.
SMS 0 RHR 16A/S Walworth 102430 2
Reliance PrJoe LES Phil Gear Corp.
SMS-00 RHA 65A/B Walworth 5261-WE 2
Reliance Frame 256 UR4 Phil Gear Corp.
SMS-?
RHA-15A,8,C,0 Walworth 33436-4 2
Reliance Frame PS6 Phil Gear Corp.
SMS-2 RNA-13A,B,C,0 Walworth 33438-4 2
Reliance Frame P58 Phil Gear Corp.
SMS 2 RHR-183 Walworth 33438-4 2
Reliance Prame PSG Phil Gear Corp.
SMB-0 RHR-144 Walworth 33430-4 3
Reliance Frame PS6 Phil Gear Corp.
SMS-0 RHR-64 Walworth 4 CATE CS 2
Reliance Frame K44 Phil Gear Corp.
sMe-000 AMR-87 Welworth 330422P Q
Reliance Frame 00500 Pht) Gear Corp.
SMt=00 RMR 27A/S Rockwell 114tJMy 1
Elec. Apparatua Co.
Preme C256Y Phil Gear Corp.
SMS-4T RMR 25A/S Walworth C48215 1
Reliance Frame 2544R)
Phil Gear Corp.
SMG-3 J
09.
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88 04: ;SPM
-VCRMONT YANMOC POWCR POS
($V i Attachment A Page 5 i
MANUFACTURER /
COMPONENT SUPPLIER M00tL N0.
SAFETY CLASS P10-1A.0,C,0 Singham 16x18x26 CVic 2
GE Triolad Frame 4346 P42 P46-1A(18)
Union Pump Co.
Triplex Pos. Dise.
2 GE Tricled Freee 329Y RCIC-1 Gimpel 80-13738 A 2
RCIC-12 ACF Industries 70-14-2 RH 0
RCIC-13 ACP Industries 70-14-2-RH 0
i ACIC-20, 21 Walworth A9491-M-102F 2
Peerless Prese 056C Phil Gear Corp.
SMS 00 I
RCIC-30 Walworth A-9533-N-5-E 2
Peerless Prese 056F i
Phil Gear Corp.
SMS-0 RCIC 132 C. esser 7150W1 2
Relier,ce Frame 086 Phil Gear Corp.
SMS-00 d
i 2
RCIC-27 Dresser 71gCW1 Reliance Freee 086 l
Phil Gear Corp.
SMS 00 RCIC-131 Welwerth C-44099 2
Peerless Freee 00500 Phil Seer Corp.
SMS 00 RCIC-32 Block, Stra11s & Bryson 10 14-1 OATS 2
RCIC-34 516ck, Siralls a Bryson 70-10-1 DR75 0
RC!C-38 51ack, Sire 11s & tryson 70-10 1 ORTS 0
RCIC-te Welworth A-7848 M-1640 2
Peerless Frepe Ol8A Phil Over Corp.
SMS-00
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COMPONENT SUPPLIER MODEL NO.
SAFITY CLASS
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RC!C-41 Walworth
$206-WE 2
Peerless Frame DSSA Phil Oser Corp.
SMS-000 RCIC 39 Walworth 8206 WE 2
Peerlese Frame 056A Phil Gear Corp.
SMS-00 P47 1A Singhen 4x6x90 M60 2
-277/440 Special I
l Notes 1.
The specific manufacturing code applicPD1e to these coeponents at the time they were specified is not readily available without sutetential effort. Vermont Yankee wt11 make the docues.nts from which auch information can be extracted eve 11able for 164pection at the of fices of Yankee Atomic Electric Company, 540 Main Street, Bolton, Maatschusetts, upon the specification of any particular component or componentW.
2.
The applicable Environmental Que18fication Report 9 11 to available in the Document File at Vermont Yankee on /6.*ry Road, Brattleboro, Vermont.
3.
All components are genere11y designed for a service life nf 40 years unless specifically stated otherwise in the Invironmental Qualification Reports.
4.
None of the above componente "becomes active only during the testing which is propcaed to be eliminated."
~
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- VERMONT VANMC5 POWCR P;;
'77:1396 6 4 7Pp Atto::htent B Page 1 INDEX OF SYS?!M STATUS (1) REPAIR CATE REPLACEMENT EVENT REPOR?
- .YSTEM COMPONENT CF EVENT
?'WE NtJMBER HPCI WPCI 8-9-83 1 Day N/A V4 RHR 384 8-16-83 1 Day LER 83-11/3',
Diesel
'B' 3/0 8-24-83 1 Day LER 83-2C/19 Core Spray Core Spray 78 4-24 83 1 Cay LER 43-20/IP RWR
'C' RHR Pump 8-27-83 1 Day N/A RCIC RC!C 9-1A-43 2 Days PRO-44
$80T
'A' S30T 9-29-83 1 Day N/A
$$0T
'B'
$8GT 10 5-83 2 Oays N/A
$80T
'B' 553T 10-11-83 1 Day N/A
$407
'A' SBOT 10-11-83 1 Day N/A Oiesel
'A' 04esel 10-12-83
- Day LER 83-27/IP Core Spray
'B' Core Spray 10-12-83 1 Oey LER 83-27/18 RHR
'D' RhR Pums 10-14 83 1 Day LER 33-28/3L RCIC R0!C 11-1F-83 2 Cays 1.!R 83-32/IP HPCI WPCI-20 11-17-83 1 Day LER 83 32/1*
Diesel
'A' Diesel 12-1-83 1 Oay N/A l
Diesel
'S' Diesel 12-1-83 1 0)y N/A RCtc RCIC 12-14 83 1 Day N/A l
$807
'A' SBOT 12-19-83 1 Day N/A y*S
'A' UPS 12-21-83 2 Days N '/t.
l RCIC RCIC 1-6-84 1 Cay LER 84-01 l
553T
'B' S8GT 1-10-84 1 Day N/A Core Spray
'A' Core Soray 2-9-84 1 Day N/A t
J
e 03, t 6.
66 0 2.
- J. $ P M
-VCRMONT */ANMOG POWCC P ?; 3 Attachment S Page 3
~
(f,) REPAIR OA~E R E P'. AC!M E N T EVEN! #EPOS7 00MDONENT OF EVENT TIME NewBER SYSTEM RHR Service Water
'A' RWR $/W 11-2-84 1 Oey N/A Diesel
'A' 0/0 11-27 84 1 Day N/A Diesel
'S' 0/0 11-28-84 1 Oay N/A
$407
'A'
$507 12-4-8A 1 Day N/A 4
SBOT
'O' 5907 12-5-84 1 Day N/A
$50T
'A' 5807 12-18-84 2 Days N/A Service Water
'A' 5/W Pump 12-31-84 4 Days N/A Diesel
'B' 0/0 1-7-85 1 Cay N/A 560T
'B' SSOT 1-0-85 1 Day N/A
$LC
' A ' S'.C Pur.o 1-16-85 1 Oays PRO-5 Diesel
't' Pael Oil 1-24-85 1 Oay 2R0-6 XFR Pyme Service Wtter
'C' S/W Pume la18-85 2 Oays N/A Diese)
'A' 0/0 2-14 85 1 Day N/A Diesel
'B' D/0 2-15-85 1 Oay N/A Core $g. ray
'A' C/S 2-10 85
- Say N/A Core $;2 ray
't' C/P 2-1'0-85 1 Ony N/A Diesel
'A' 0/0 2-21-85 1 Day N/A UPS
'B' UPS 3-5 85 1 Osy N/A RHR RHR 86 3-20-85 1 Oay N/A Diesel
'S' D/0 4-19-45 1 Oay N/A 7
i l
Diesel
'A' */0 4-23-85 1 Osy N/A Cooling To.,er el Wstst Fan 5-1-85 2 Oays N/*
Serv?ce Water
'O' S/W Puto 6-10-05 1 Osy N/A t
09.
- 9.
66 02: 2spM
_VORMONT
- A N 3C O O Powam Attacntent 8 Page 2 (5) REPAIR CATE REPLACEMENT EVENT A!PO47 SYSTEM OOMPONENT
.05 EVENT 7tME Nuwsta Service Water
'A' S/W Pumo 2-13-84 8 Days N/A R0!C RCIO 3-13-84 2 Cays N/A RHR RHR-315 3/16/84 1 Day N/A
$40T
'3' SBOT 3-30-84 1 Day N/A RHR R8R 39-A 4-3-84 2 Oays PRC-$
'O' S/W Pump 4-12-84 1 Day N/A HPCI Trie Throttle 4-20-84 1 Day LER 84-05 Valve SLC
'S' SLC Pumo 5-4-84 1 Oay N/A Relief Valve LPS
' A '
t,' P S 5-4-84 1 Oay N/A I
Diese)
'A' 0/0 5-8-44
' Day PRO-10 i
Service Wate-
'O'
$/W Sumo 5-14 84 1 Oey N/A i
RCIC Flow XM'R 5-15 84 1 Oay 840-13 Otesel
'A' 0/0 5-21 84 1 Oay N/A l
$33T
'A' SBOT 5-31-54 1 Day N/A l
Oore Scray
'A' C/S Pumo 8-6 84
". Oay
- RC-15 StGT
'8'
$437 6 7-84 2 Days N/A l
$337
A" SBOT 6-28-84 1 Cay N/A RCIC RCIC-15 9-4-84 1 Oay
'.!R 84 20 SEGT
'S' 553T 10-17 84 1 Oey N/A i
S6GT
'A' 583T 10 17-84 1 Oey N/A Diesel
'A' O/G 10 22-84 2 Oays LER 84-22/910-45 Diesel
'8' 0/3 10-23-84 1 Day
'!R 84-72/ pac-45
- - - +, -_
_~
M
c S.
S.
e6 01: 2 S P:4
- V O R M O N *!'
Y A N 3C O O POWOR
?O4 page 4 I
(<.) REPAIR DATE REPLACEMENT EVENT REPCRT Sv5 TEM COMPONENT OF EVENf T!ME NUMBER
$50T
'A' 5807 6-10-85 1 Day N/A RCIC RCIC-18 6-12 85 1 Day PRO-19 and 20 Diesel
'O' 0/0 6-25-85 2 Days N/A Diesel
'A' Q/0 6-27-85 1 Day N/A S807
'82 $80T 7-10-88 1 Day N/A RCIC Suction Pressure 7-17-65 1 Day PRO-26 Switch HPC!
Fittirg Leak 7-18-85 1 Day PRO-26 HPCI MPCI 8-5-65 3 Days N/A Diesel
'A' 0/0 0-28-85 1 Day PRO-31 Diesel
'S' C/G 8-28 85 1 Day PRO-31 Diesel
'5' 0/0 8-29-85 1 Osy
- RC 31 service Water
'A' $/h Pumo 8-30 65 2 Days N/A Diesel
'B' 0/0 8-31-85 1 Day N/A Service Water
'A' 5/W Pwmo 10-2 85 18 Oays N/A Service Water
'A' 6/W Pump 7 3-86 12 Days N/A RCIC RCIC 7-15 86 1 Oay N/A Service Water
'O' S/W Pump 7-15-86 1 Day N/A Service Water
'B' 5/W Pyro 7-17-86 1 Day N/A Service Water
'C' S/W Pump 7-18-86 1 Day N/A Ciesel
'B' 0/0 7-27-86 1 Cay N/A UPS
'B' UPS 7-30-86 1 Day N/A Coolirg Tower s1 Fest fan 6-1-86 1 Oay N/A J
c a.
- e.
es 02: 2sPM v0RMONT tANxc0 PowCm 705 Page 5
($) REPA1R j
CATE REPLACEMENT EVENT REPORT SYSTEM QCf80NENT OF_ EVENT
'IME NUM8ER HPCI HPC:
8-15-86 1 Day N/A HPCI 01 erd Seal 4-14-66 1 Day 86-56 Cord Pump l
'8' UPS 9-4 86 1 Day 86-58 SLC
'B' SLC Pump 10-24-86 1 Day N/A SLC
'B' Squib 10-24-86 3 Days 84-61 Continuity RCIC R0!C 11-13-86 1 Day N/A
$53T
'S'
$307 12-1-06 2 Days N/A Service Water
'C' S/W sump 12-2-86 1 Cay N/A Core Spray
'B' C/S Pump 12-8-86 1 Day N/A Core Spray
'B' C/S Pumo 12 19-86 1 Day 86-67
$507
'A' S6GT 1-12-87 1 Day N/A Service Water
'A' S/W Puts 1-12 87 22 Cays N/A Core Spray
'B' C/S Pump 1-20-87 2 Days N/A StGT
'A' $537 1 20-47 1 Day N/A l
Service Wster
'O'
$/W Pump 2-4-67 27 Days N/A Diesel
'8' 0/0 2-4-87 1 Day 67-06 Diesel
'8' 0/0 2-11-87 2 Oays N/A Diesel
'A' 0/0 2-26 47 1 Cay N/A Service Water
'8' S/W Pump 3 10-87 1 Oey 87-11 Servict Water
'C' 5/W Puso 3-10 67 1 Cay 67-11 Service Water
'A' S/W pump 3-10-87 1 Oay 67-11 S80T
'A' SSGT 3-27 87 1 Day N/A
s
O C.
- 8.
96 00: 1OPM -VORMONT Y A N 3C O G POWGR P09 e
AttaCorent S
- age 8 (f) REPAIR CATE REPLACEMENT EVENT REPORT SYSTEM COMPONENT 08 EVENT TIME NUwsER Service Water
'O' S/W Pumo 3-31-87 21 Days N/A Core Spray
'l' C/S Pute 4-2-87 1 Day N/A RHR
'B'
.9HR Dump 4-20-87 9 Cays N/A Gervice Water
'C' 5/W Ptro 4-24-87 1 Cay N/A t
'O' RHR Pumo 5-4-87 8 Days 87-21A/8 Service Weter
'A' S/W Pump 5-4-87 15 Days N/A RHR
'A' RHR Pump 5-11-87 5 Days 87-21A/S RHR
'C' RHR Pump 5-18-87 5 Cays 87-21A/8 RHR
'O' RHR ' ump 5-28-87 1 Day 87-21A/8 SBOT
'A'
$807 8-9-87 1 Cay N/A HPCI HPCI 8-10-87 4 Days 07-27
$80T
'8'
$807 6-30 87 1 Day N/A RHR
'O' RHR Purp 8-30-87 1 Osy N/A RCIC RCIC 10-21-47 1 Cay N/A HPCI Flew XMTR 11-5-87 1 Oay LER 87-16 ACIC RCIC 11-9-87 1 Day N/A RCIC Exhaust Check 11-14-87 5 Oays LER 81-18 Valve
$60T
'O'
$40T 11-28-87 1 Day N/A
$40T
'A' 5837 11-25-87 1 Cay N/A f
Diesel
'A' D/0 12-7-87 5 Days N/A Core Spray C/S SA 12-11-87 1 Day N/A l
NPCI MDCI 12-14-87 1 Day N/A Diesel
'S' 0/0 12-15-87 1 Day N/A l
l
o 09.
- s. C e 0;* 28 P2!
-VGOMONT YANMOG POWOA PO" page 7 (1) REPA!A OATE R! PLACEMENT EVENT #Ep0RT OOMPONENT I __CF EVENT TIME NUwSER SYSTEM RHR RHR-28A 12-15-87 1 Oay 87 84 RHR
'8' RHR 12-29-87 1 Day N/A RMR Service Water
'B' R>R S/W 1-5-88 1 Day 88-01 RCIC RCIC 1-12-84 1 Day 88-03 HPCI Glend Seal 1-14-84 1 Day 88 05 Vacuum Pleo RCIC ROIC 1-14-88 1 Oay 88-04 Service Water
'8' S/W Pump 1-18 88 17 Days N/A UPS
'A' VPS 2-2-84 1 Day 48-04 SLC
'O' SLC Pumo 2-9-14 1 Cay N/A HPCI kPCI 2-12 04 1 Day N/A Core Spray
'A' C/G 2-12-88 1 Day N/A UPS
'B' UFS 2-18-88 1 Day N/A
$807
'A' 553T 2-22-88 i Oay N/A S5GT
'B' SSCf 2-23-88 1 Oey N/A
$80T
'A' 553T 3-14-88 2 Days N/A 580T
'A' 5807 3-28 88 1 Day N/A UPS
'B' UPS 3-19 88 3 Oays 64 20 Core Spray C/S-118 3-31-88 3 Days 88-19 Service Water
'S' S/N Pump 4-5-88 1 Oey N/A Service Water
'O' S/W Pleo 4-5-88 9 Cays N/A UPS
'B' UPS a-9-88 1 Oay 88-24
o o C.
- 9.. 68 02
- IfPM
=VORMONT YANMOD POWOm P: +
e Attachtent 8 Dage 8
($) REPAIR CATE REPLACEMENT EVENT REGORT SYSTFM COMPONENT O' EVENT _.
?!*f NUM8ER UPS
'8' UPS 4-10 48 1 Oay 48 27 5807
'B'
$8GT 4
.'.1 88 1 Day N/A RCIC RCIC 1 4-11 88 1 Oay 48 21 Service Water
'A'
$/W Pumo 4-14 88 1 Day N/A Service Water
'3'
$/W Pump 4 15-48 1 Day N/A RCIC R0!C 4-19-88 1 Day N/A RHR Service Water
'O' RMR $/W Pump 4-28-84 1 Day 88-34 RNR Service Water
'A' RHR S/W Pump 5 4-08 1 Oay
$4-34 Service Water
'C' S/W Pute 5-9-88 1 Oay N/A l
RCIC Trip Solenoid 5 11-88 2 Days 84-35 HPCI PPCI-14 5-13-88 1 Oay 83 36 i
HPCI HPC 5-18-88 1 Day N/A Diesel
'8' 0/0 5-24-84 2 Oays N/A RHR RHR-18 8-25 88 1 Day 88-42 Diesel
'A' 0/0 8-9-48 1 Oay N/A Diesel
'A' U/3 8-17-88 1 Osy N/A Diesel
'A' 0/0 0-23-84 1 Osy N/A i
RHR Service Water RHR S/W 88A 8-24 48 2 Days 88 80 Diesel
' A ' D/ fi 9-1-88 3 Days 88 61 i
t l
l 1
o 4 o ATTACllME?rr C l
Bole in Years' Emperience Nemes Cogeny Study Gus11fications Position Tetst FRA-Related Kevin Burns YAEC Freparer M.S.. Nuclear IAad Engineer 8
2 Eagineering. AIT for Vermont Yankee in Safety Assessment Group Andrew Dykes FIC Freparer Ph.D., belear Consultant for 24 4
Engiacering. MIT FRA ana*ysis at PLC Vrna Dimitrijevic YAEC Reviewer Ph.D.. EcIcar Engineer. Safety 12 12 Engineering. MIT Assessment Croup James Chapman YAEC Reviewer M.S.. Engine: ring.
Manager. Safety 15 9
RFI Assessment Group 6475R/20.705 s
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o o
0 L
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VYN-135 (OLA-2)
'88 SED E MIQSLB - Reg. Mail RxCCoSRG.vy CERTIFICATE OF-SERVICE
'U M [.y. g j n Ni.
hPthaton I, R.
- x. Gad III hereby ce S
September 19, 1988, I made service of the within document in accordance with the rules of the Commission by mailing a copy thereof postage prepaid to the following:
Charles Bechhoefer, Esquire, Samuel H. Press, Esquire chairman vermont Department of Administrative Judge Public Service Atomic Safety and Licensing 120 State Street Board Panel Montpelier, VT 05602 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Glenn O.
Bright George B. Dean, Esquire Administrative Judge Assistant Attorney General Atomic Safety and Licensing Department of the Attorney Board Panel General U.S. Nuc12ar Regulatory One Ashburton Place Commission Boston, MA 02108 Washington, DC 20555 Mr. James H. Carpenter Ann P. Hodgdon, Esquire Administrativs Judge Office of the General Counsel Atomic Safety and Licensing U.S. Nuclear Regulatory Board Panel Commission U.S. Nuclear Regulatory Washington, DC 20555 Commission Washington, DC 20555 Adjudicatory File Atomic Safety and Licensing Board Panel Docket (2 copies)
U.S. Nuclear Regulatory Commission Washington, DC 20555
(
1
_ g R.
K. Gad III
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