ML20155A809
| ML20155A809 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 09/30/1988 |
| From: | Press S VERMONT, STATE OF |
| To: | VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| CON-#488-7206 87-567-04-OLA, 87-567-4-OLA, OLA, OLA-2, NUDOCS 8810060083 | |
| Download: ML20155A809 (19) | |
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- i earag3ptwgg yp0b RELATED CORREWiN 00CKEilD UWC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION T8 OCT -4 A11
- 37 BEFORE THE ATOMIC SAFETY AND LICENSING BOAR,D In tile Matter of
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VERMONT YANKEE NUCLEAR
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Docket No. 50-271-OLA-2 POWER CORPORATION
)
(Testing Requirements for
)
(Vermont Yankee Nuclear
)
(ASLBP No. 87-567-04-OLA)
Power Station)
)
)
STATE OF VERMONT'S SECOND SET OF INTERROGATORIES AND REQUESTS EOR THE PRODUCTION OF DOCUMENTS TO VERMONT YANKEE NUCLEAR POWER CORPORATION INSTRUCTIONS FOR USE The following interrogatories are to be answered in writing and under oath by an employee, representative or agent of the Applicant with personal knowledge of the f acts or information requested in each interrogatory.
Please note the obligation to supplement answors to interrogatories, pursuant to 10 C.F.R.
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2.740 (e).
1.
Please identify all persons who participated in the preparation of answers to these interrogatories and production requests, and identify the portions of your responao to which each person contributed.
2.
Do any of the American Society of Mechanical Engineers (ASME)
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inservice testing provisions from which the Applicant was i
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granted relief, pursuant to 10 CFR 50.55a(g), in 1980 (as being "impractical") relate to testing of Emergency Core Cooling System (ECCS) or Standby Liquid Cooling (SLC) System components?
3.
For each component for which tests are proposed to be eliminated, what are the testing intervals under the ASME inservice tecting program?
4.
Are there any differences in the types of tests carried out under the ASME inservice testing program and the tests which are proposed to be eliminated?
Describe any differences.
5.
What is the historic out-of-service frequency for each valve or component for which testing is proposed to be eliminated?
6.
What is the projected service life, in both time and number of occasions used, for each valva or component for which testing is proposed to be eliminatod?
7.
Aro any of the valves for which testing is proposed to be oliminated "check valves", within the meaning of I&E Bulletin 83-03 (March 10,1983)?
8.
On the list of activo components and devices necessary to perform the safety function of the systems (Attachment A of
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"Applicant's Answers to Stato of Vermont's First Set of
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,..~..-u s & A Interrogatories and Requests for the Production of Documents to Vermont Yankee Nuclear Power Corporation," - hereinafter, "Applicant's Answers"), identify which items are instrumentation and control items.
9.
Are there any instrumentatioa and control items (sensors, actuation devices, relays, logic devices, etc.) not listed on Attachment A of "Applicant's Answers" which are part of the systems for which testing is proposed to be eliminated, and whicht Are required to perform the safety function of the a.
system?
Identify these instrumentation and control items in the same format provided in Attachment A of "Applicant's Answers."
b.
Could fail and cause inoperability of the system?
Identify these instrumentation and control items in the same format provided in Attachmont A of "Applicant's Answers."
c.
Aro all of the instrumentation and control itoms identified in paragraphs a. and b. abovo tested under the testing of alternato systems requirements which are proposed to bo doloted?
If there are instrumentation and control items which are not tested under current
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e requirements, identify each item and describe why it is not presently tested.
d.
Since Applicant's proposal is to amend the design bases of the systems to rely on the ASME XI testing program in lieu of testing the alternate system in the event that one redundant train is out-of-service, are any of the instrumentation and control items from paragraphs a. and
- b. above not included in the Applicant's Inservice Testing Program?
If so, identify which items are not included.
For these items, explain why Applicant considers it acceptable to eliminate their testing from the design bases.
13.
Are there any items listed in Attachment A to "Applicant's Answers," which are tested at frequencies greater than once overy three months?
If so, identify each item.
11.
Section 5.3.1.1.2 ("Uso of Time-Rolated Models") of NUREG/CR-2300, "PRA Procedures Guide," January 1983, contains the following statomonts:
"Standby components aro usually subjected to periodic testing, which occurs, for examplo, once a month or perhaps once a year.
The timo betwoon tests is the longth of timo the component is exposed to failure without detection, and hence the term "fault-exposure time."... The fault-exposure time is usually determined f rom plant procedures, but somo caution should be used when examining a system for tost intervals.
As an oxamplo, considor (a system that) is testod in various plocos; that is, the logic is testod once a month, as.
are the spray pumps.
Tho sensors are calibrated onco a year and tested onco a year through the logic.
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This results in a specific contact never being tested during the life of the plant."
a.
Are there any portions of the systems for which testing of the alternate system is proposed to be eliminated which contain a combination (sensor -> logic -> Device),
as indicated in Section 5.3.1.1.2 of NUREG/CR-2300, which is not tested during the life of the plant?
Identify each case, b.
If there is a portion of a system which is not tested (oither never, or over a long period) is it not possible that tho timo-related unavailability, Q, could be t
largo enough to obscure the effects identified in Figure 5-1 of "Tho Report?"
If this were the case, what would be the value of elim'nating testing of the alternate system when the overall offect on system (un) availability would be negligible?
l c.
For each portion of the Coro Spray System identified in paragraph a. above, identify how the fault exposure time was datormined for the analysis in "The Report."
d.
Describo how Applicant would perform a Probabilistic Risk Assessment (PRA) on the portions of systems in paragraph a. which are not tostod.
If thoro are any differences betwoon your mothod and that described in
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Section 5.3.1.1.2 of NUREG/CR-2300, please explain the differences.
e.
In Section 9.5 of "The Report," it is stated, "Because of the similarity in types and numbers of components that must actively function during a true demand, conclusions based on quantitative results for the Core Spray Cystem are used in the evaluation of testing for other pumping systems."
This requirements appears to be inconsistent with your response to Interrogatory No. 28, "First Set," where it is stated that a portion of the SLC system is not tested.
How would the system unavailability curve for the SLC system differ from that of the Core Spray System, considering the high time-related failure unavailability, Q '
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the "squib" valves?
Provide qualitative and quantitativo responses.
f.
In response to Interrogatory No. 28, "First Set," it is stated that "the squib valves...could not be, and should not have been 'taken into account' by the Poport."
But does not Section 5.3.1.1.2 of NUREG/CR-2300 identify how tho squib valvos 'could' and 'should' have boon taken into account in the Report?
12.
The Applicant's analysis described in the report entitled "Impact of Alternato Testing on Component and System
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Availability (hereinafter, "The Report"),"
does not explain how the "Time-Related Fractions," in Tables 5.7 and 5.8, are used in the time-related failure rate equations on pages 6, 7 and 27.
i a.
Provido an explanation.
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b.
Industry time *.? lated failure rates are provided for pumps and valves, respectively, in NUREG/CR-1205, l
Revision 1, Data Summaries of Licensee Event Reports of Pumps at U.S. Commercial Nuclear Power Plants, January 1982, and NUREG/CR-1363, Revision 1, Data Summaries of l
Licensoo Event Reports of Valves at U.S. Commercial Nuclear Power Plants, October 1982.
Why were these l
values not used instead of time-related fractions?
l c.
Does the use of time-related fractions result in the l
expected increase over time in O, unavailability due t
to potential timo-related failure.
Explain specifically j
how this is so.
13.
For t!;o outago events described in Attachment B to l
"Applicant's Answers:"
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a.
Which items are on the llat because they woro out of service for planned provontativo maintenance?
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b.
Which items are on the list because they were out of service due to non-operability /non-functioning in a test?
i c.
Which items are on the list because they were out of j
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service due to failure while running (a running pump or fan fails, a modulating valve fails)?
d.
On Attachment B of "Applicant's Answers," which are the l
six (6) items identified in response to Interrogatory No. 14c, "First Set," as occurrences in which testing of the alternato system resulted in failure which caused power reduction?
Please identify the causes for each failure.
14.
Of the 175 times in 5 years that testing of alternate systems i
has boon required (Attachment B of "Applicant's Answers):
r How many timos did the alternate system fail?
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a.
i b.
How many times did the alternate system fail and repair l
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of tho alternato system was accomplished beforo power was reduced?
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How many times did the alternato systos fail and repair
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of the alternato syetem was not accomplished before i
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How mcny times did the alternate system fail and repair t
of the original system was accomplished before power was reduced?
15.
Table 5.6 and Appendix B of "the Report" contains a description of Observed Failures for Vermont Yankee Core Spray System.
The data used for the analysis are based on these failures.
Yet Attachment 8 to "Applicant's Answers" t
lists Core Spray failures which are not identified in Table i
5.6 or Appendix B.
a.
Provido a description in the Appendix B format for each of the following:
1)
Coro Spray 7B out-of-service, 8-26-83 2)
'B' Core Spray out-of-service, 10-12-83 3)
'A' Coro Spray out-of-sorvice, 2-9-84 4)
'A' C/S, ' B' C/P out-of-servico, 2-20-85 5)
'B' C/S Pump out-of-norvico, 12-8-86 6)
'B' C/S Pump out-of-servico, 12-19-86 7)
- B' C/S Pump out-of-sorvico, 1-20-87
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'B' C/S Pump out-of-service, 4-2-87 9)
C/S SA out-of-service, 12-11-87 10)
'A' C/S out-of-service, 2-12-88 b.
Why were the above out-of-service events omitted from "the Report?"
c.
Does consideration of the events listed in paragraph a.
above alter the data used in Tables 5.7 and 5.8 of "the Report?"
If yes, please explain how the data is altered.
d.
Does consideration of the events listed in paragraph a.
above alter the results of Figure 5-1 of "the Report?"
If yes, please explain how the results are altered.
!!ow many other failures and out-of-service events have e.
occurred in the Cccu be 3y System over the life of the c
plant which should bo inc.uded in "the Report?"
f.
Why are the following failures listed in Tablo 5.6 and Appendix B of "the Report" not identified in Attachment B of "Applicant's Answers?"
For each failure listed, indicato why it did not result in testing of tho t
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alternate system in accordance with the Technical Specification?
1)
C/S V-11A failure, 9-5-87 2)
C/S V-5A failure, 12-8-87 3)
C/S V-26A failure, 2-3-88 g.
Are there instances of Diesel Generator failure identified on Attachment B of "Applicant's Answers" which should have been l'aluded in Report, Appendix C, Vermont Yankee Diesel Generator Failures?
If so, do these omissions affect your data, results and/or conclusions?
16.
Concerning maintenance of the Core Spray systems a.
Describe the maintenance required for Valves V-11, V-10, V-5 and V-26.
What is the maintenance frequency of these valves for the past 5 years?
How often, or in what perc(ntage of maintenance activitios, does maintenance result in declaring the system inoperable and thus requiring testing of the alternate system?
How aft or in what percentage of maintenance activities,
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Describe the maintenance required for a Core Spray Pump.
What is the maintenance frequency of this pump for the past 5 years?
How often, or in what percentage of maintenance activities, does maintenance result in declaring the system inoperable and thus requiring testing of the alternate system?
How often, or in what percentage of maintenance activities, is the maintenance able to be scheduled during plant outage.
c.
For an overall syster unavailability analysis, what is the value which should be used for number of outages due to maintenance (per time period)?
17.
Were "the Report" and "Applicant's Answers" prepared under an applicable Quality Assurance program or under applicable procedures?
Provide the procedures.
If Applicant believes this request to be burdensome, then summarize the requirements of the program or procedures.
Were these procedures followed in the preparation, review and approval of these documents?
18.
In order to meet a Technical Specification Limiting Condition for Operation (LCO) to be in COLD SHUTDOWN in 24 hoars, when must the decision be made to begin reducing power.
When must actual power reduction begin?
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ha 19.
In response to Interrogatory No. 27b, "First Set," Applicant declined to provide an graphical representation showing the sensitivity of results to the assumption of trying to repair a f ailed component while both trains were out-of-service, i
rather than proceeding immediately to safe shutdown.
This evaluation has been performed, with results shown in Attachment A.
This evaluation was performed using data and equations from "the Report" except that time-related failure a
rates ware used from the NUREG's identified in Interrogatory No. 12b above.
Results are plotted as in Table 5.1 of "the Report," and are shown for two cases:
1-Remaining at power when the second train fails, and i
attempting repair (the case evaluated by the Applicant), and j
2-Proceeding immediately to safe shutdown upon failure of the second train (in this case the repair unavailability is inactive because the unit j
is shutdown).
a.
Since Applicant's response the Interrogatory No. 26b, "First Sete" states it is not the practice to attempt repair when both redundant trains are inoperable, why is the immediate shutdown plot (Item 2 above) not the proper result of the evaluation instead of Figure 5.1 of j
"the Report?"
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The results in Attachment A correctly show the benefit from daily testing of the alternate system.
When the repair portion is removed, it is seen that elimination of daily testing and resorting to 30-day ASME XI tests roughly doubles the unavailability of the second train, assuming the first is already out of service.
Considering this change, why is the correct risk l
avoidance decision for public health and safety not 1
rather to retain the presently required daily testing of alternate systems and instead proceed directly to safe shutdown without repair, as stated in Applicant response to Interrogatory No. 27b, "First Set?"
20.
In the application for elimination of testing of alternate systems from the Vermont Yankee Technical Specifications (VY-TS), dated December 7, 15b7, Applicant states, the olimination of testing of alternate systems "is consistent with the testing requirements contained in BWR Standard Technical Specifications (BWR-STS)."
However, the testing requirements in the BWR-STS, or lack of them, are predicated on meeting other requirements of the BWR-STS, as well as system and component design to the state-of-the-art at the I
time of issue of the BWR-STS (Revision 3, December 1980).
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a.
In BWR-STS Section 3/4.7.1.1, daily testing of the l
alternato system is not required for the residual heat l
removal service water system.
However, in 3.7.1.1.c the i
system is only allowed to remain inoperable without thfs
..n testing for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before shutdown is required.
Vermont Yankee-TS Section 3.5.C.3 allows the system to be inoperable for a full 7 days before shutdown is required. If testing is proposed to be eliminated in accordance with the BWR-STS, why should not vermont Yankoo adopt the more stringent LCO ci the BWR-STS?
b.
In BWR-STS Section 3/4.7.1.2, daily testing of the alternato system is not required for the plant service water system.
However, in 3.7.1.2.a.3 the system is only allowed to remain inoperable without this testing for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before shutdown is required.
Vermont Yankee-TS Soction 3.5.D.2 allows the system to be inoperable for a full 15 days before shutdown is required. If testing is proposed to be eliminated in accordance with the BWR-STS, why should not vermont Yankoo adopt the more stringent LCO of the BWR-STS?
c.
In BWR-STS Section 3/4.8.2, daily testing of the alternato system is not required for the 480 V Uninterruptible Power Systems.
However, in 3.8.2.1.a the system is only allowed to remain inoperable without this testing for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> before shutdown is required.
Vermont Yankeo-TS Section 3.10.B.4, which refers to Section 3.5.A.4, allows the system to be inoperable for a full 7 days before shutdown is required. If testing is proposed to be eliminated in accordance with the l
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BWR-STS, why should not Vermont Yankee adopt the more stringent LCO of the BWR-STS?
d.
In BWR-STS Secticn 3/4.8.1, for the emorgency diesel generators, one diosol generator is only allowed to reinain inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> before shutdown is required.
Vermont Yankeo-TS Section 3.10.B.1, which refers to Section 3.5.!!.1, allows the system to be inoperable for a full 7 days before shutdown is required.
Further, the BWR-STS requires testing of the alternate diosol generator in Section 4.8.1.1.2.a.4 within one hour and at least once per B hours thereafter.
In the BWR-STS both the LCO and the testing requirements are more stringent than Vormont Yankoo-TS.
Why should not Vermont Yankee adopt those BWR-STS requirements?
Vermont Yankee-TS Section 3.5.C.3 allows the system to bo inoperable for a full 7 days beforo shutdown is required. If testing is proposed to bo eliminated in accordance with the BWR-STS, why should not Vermont Yankee adopt the more stringen 7 LCO of the BWR-STS?
Submitted by, OT^f bSb l
Sam'uel 11. Press Special Assistant Attorney General Direct for Public Advocacy Vermon' spartment of Public Service 120 Stc;9 Street Stato Office Building Montpolier, Vermont 05602 (802) 828-2811
- n t.liil UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges
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Charlos Bochhoofer, Chairman Glenn O. Bright Dr. James H. Carpentor In the Matter of
)
)
VERMONT YANKEE NUCLEAR POWER
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Docket No. 50-271-OLA-2 POWER CORPORATION
)
(Testing Requirements for
)
(Vermont Yankoo Nuclear
)
Power Station)
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)
CERTIFICATE OF SERVICE The undersigned cortifies that on September 30, 1988, copies of State of Vermont's Second Set of Interrogatories and Requesta for the Production of Documents to Vermont Yankoo Nuclear Power Corporation woro served on the following parties to this case by first class mail or as otherwise indicated:
Charlos Bochhoofer, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Glenn O.
Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. James H. Carpontor Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Secretary of the Commission Attnt Docketing and Service Section U.S. Nuclear Regulatory Commission Washington, D.C.
20555 (2 Copies)
Christine N. Kohl, Chairman Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 George Dean, Esq.
Assistant Attorney General Commonwealth of Massachusetts Department of the Attorney General One Ashburnton Place Boston, MA 02108 Ellyn R. Weiss, Esq.
Harmon & Weiss Suite 430 2001 S. Street, NW Washington, D. C. 20009 Ann Hodgdon, Esq.
Office of the General Counsel Bethesda U.S. Nuclear Regulatory Commission Washington, D.C. 20555 R. K. Gad III Ropes & Gray 225 Franklin Street Boston, MA 02110 Gary J. Edles Atomic Safety and Licensing Appeal Board U. S. Nuclear Roqulatory Commission Washington, D.C. 20555 Howard A. Wilber Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Geoffrey M. Huntington, Esq.
Office of the Attorney General Environmental Protection Agency State House Annex 25 Capitol Stroot Concord, NH 03301-6397 Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
-=
e Lando W. Zech, Chairman U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Frederick M. Bernthal U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Kenneth M. Carr U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Kenneth Rogers U.S. Nuclear Regulatory Commission Washington, D.C.
20555 j
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MM Samu' l $. Press e
Special Assistant Attorney General Director for Public Advocacy Vermont Department of Public Service 120 State Street Montpelier, VT 05602 (802) 828-2811 Counsel for State of Vermont
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