ML20155A965
| ML20155A965 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 06/02/1988 |
| From: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| FVY-88-45, IEB-85-003, IEB-85-3, NUDOCS 8806130039 | |
| Download: ML20155A965 (5) | |
Text
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VERMONT YANKEE NUCLEAR POWER CORPORATION FVY 88-45
(
RD 5, Box 169, Ferry Road, Brattleboro, VT 05301 RE PLY T O I
ENGINEERING OFFICE N
1671 WORCESTER ROAD FR AMINGH AM, M ASS ACHUSETTS 01701 TELEPHONE 617 672-8100 June 2, 1988 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
20555
References:
a)
License No. DPR-28 (Docket No. 50-271) b)
Letter, USNRC to All Holders of Nuclear Power Reactor Operating Licenses (OL's) or Construction Permits (CP's) for Action, NVY 85-250, dated 11/15/85 (IEB 85-03) c)
Letter, VYNPC to USNRC, FVY 86-45, dated S/14/86 d)
Memorandum, G. Grant (USNRC) to J. Pelletier (VYNPS), NVY 88-046, "Request for Additional Information Concerning Vermont Yankee's Response to IEB 85-03," dated 3/30/88 e)
Letter, USNRC to All Holders of Operating Licenses or Construction Permits for Boiling Water Reactors (BWR's), NVY 88-070, dated 4/27/88 (NRC Bulletin 85-03, Supplement 1) f)
Letter, VYNPC to USNRC, FVY 88-34, dated 5/5/88
Dear Sir:
Subject:
Vermont Yankee Response to NRC Bulletin 85-03, Supplement 1: Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings In accordance with the request set forth in NRC Bulletin 85-03, Supplement 1 (Reference e)], Vermont Yankee herewith submits a written report, enclosed as Attachment 1 to this letter, providing the subject information requested.
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VERMONT YANKEE NUCLEAR POWER CORPORATION i
l U.S. Nuclear Regulatory Commission June 2, 1988 Page 2 We trust that the attached information is responsive to the require-ments of the subject Bulletin; however, should you have any questions or require additional information, please contact us.
Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION fw e...
Warren.P. Murphy Vice President an Manager of Operations
/dm cc: USNRC Pagional Administrator, Region I USNRC Resident Inspector, VYNPC STATE OF VERMONT) l
)ss WINDHAM COUNTY )
Then personally appeared before me, Warren P. Murphy, who, being duly sworn, did state that he is Vice President and Manager of Operations of Vermont Yankee Nuclear Power Corporation, that he is duly authorized to execute and file the foregoing document in the name and on the behalf of Vermont Yankee Nuclear Power Corooration and that the statements therein are true to the best of his knowledge and belief.
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,e M.Mcp Diane M. McCue i
Notary Public 8
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ATTACHMENT 1 Vermont Yankee Response to NRC Bulletin 85-03, Supplement 1:
Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings
SUMMARY
The purpose of NRC Bulletin 85-03, Supplement 1:
"Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings,"
was to clarify:
- 1) which valves are to be included, and 2) the meaning of the phrase "... inadvertent equipment operations (such as inadvertent valve closures or openings)..." as used in the Bulletin.
Vermont Yankee included within its May 14, 1986 (Reference c)] response to the original Bulletin, all the motor-operated valves in the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) systems.
Accordingly, Vermont Yankee's response to the original Bulletin included all safety-related motor-operated valves in the selected systems and thus no other valves need to be added to address the scope of the supplemental Bulletin.
Reference c) also provided Vermont Yankee's commitment to evaluate valve mispo-sitioning at maximum differential pressure for events that are within the Vermont Yankee existing approved design basis. Additionally, in our letter to the NRC, dated May 5, 1988 (Reference f)], we recently provided clarification of our scope and schedule commitments in response to a NRC request (Reference d)].
The following itemized responses to each action item in NRC Bulletin 85-03, Supplement 1, together with our previous (References c) and f)] submittals, are intended to show that Vermont Yankee understands and is fully responsive to the requirements of the Bulletin and the clarifications noted in the supplement.
NRC Bulletin No. 85-03, Supplement 1, Required Actions for all BWR Holders of Operatino Licenses or Construction Permits:
For safety-related motor-operated valves in the high pressure coolant injection / core spray and rector core isolation cooling systems not included in the actions planned or completed in response to the original Bulletin, develop and implement a program to ensure that valve operator switches are selected, set, and maintained properly.
This should include the following:
Bulletin Item (a) Review and document the design basis far the operation of each valve. This documentation should !nclude the maximum differential pressure expected during both opening and closing of the valve for both normal and abnormal events to the extent that the events are included in the existing, approved design basis (i.e., the design basis documented in pertinent licensee submittals such as FSAR analyses and fully approved operating and emergency procedures, etc.).
In addition, when determining the maximum differential pressure for valves that can be inadvertently misposi-tioned, the fact that the valve must be able to recover from such mispositioning should be included.
Page 2 VY Response As discussed in the summary section above, all HPCI and RCIC motor-operated valves are included in Vermont Yankee's NRC Bulletin 85-03 program.
Table 1 of Reference c) provided the design differential pressure values for all HPCI and RCIC valves.
As stated in our response to Question 2 in Reference f),
Vermont Yankee is performing calculations for each valve to document the normal, abnormal, and accident differential pressures that could be applied to the valve.
The fact that the valve must be able to recover from inadvertent misposi-tioning will be considered when determining the maximum dif-ferential pressure that could be developed.
Bulletin Item (b)
Perform Action Item (b) of the original Bulletin for any additional valves identified above.
The intent is to provide assurance that a program exists for selecting and setting valve operator switches to ensure a high reliability of safety system valves.
If changing the switch settings is not sufficient to ensure the capability for repositioning a particular misposi-tioned valve, a justification for continued operation should be provided in the Bulletin response if the licen-see does not elect to implement additional actions, such as administrative or procedural controls or equipment modifications, to minimize the likelihood of valve malfunction.
VY Response Vermont Yankee's response (Reference c)) to the original Bullatin described in the program being developed to fully address the intent of Action Item (b). As clarified in our response to Question No. 4 in Reference f), Vermont Yankee intends to following existing Technical Specifications if, during testing, a valve is determined to be inoperable (i.e.,
unable to perform its required design function for design basis accidents).
If, during testing, it is discovered that the capability for repositioning a particular mispositioned valve cannot be ensured by switch adjustments, either a justification for continued operation will be provided in our final Bulletin submittal or additional actions such as administrative or pro-cedural controls or equipment modifications will be implemented to minimize the likelihood of valve malfunction.
Bulletin Item (c)
Perform Action Item (c) of the original Bulletin for any additional valves identified above.
l l
Page 3 VY Response The valve settings and testing required by Action Item (c) will be performed by the testing program being developed as pre-viously discussed in Reference (c) and clarified in Reference f).
Bulletin Item (d) Perform Action Item (d) of the original Bulletin for any additional valves identified above.
VY Response The procedure requirements of Action Item (d) which ensure that correct switch settings are determined and maintained through the life of the plant will be an integral part of Vermont Yankee's NRC Bulletin 85-03 program. As stated previously (Reference c)], Vermont Yankee's response to the original Bulletin included all valves required to be tested within the scope of the original 3u11etin and the subject supplemental Bulletin.
Bulletin Item (e) Within 30 days of receipt of this supplement, submit a written report to the NRC that, for any additional valves:
(1) provides the revised results of Item (a) above; and (2) contains a schedule for completion of Items (b) through (d) above.
VY Response This submittal constitutes Vermont Yankee's 30 day written report.
In summary, no additional valves were identified from our original submittal in that all HPCI and RCIC system valves were originally included.
Therefore:
1.
Vermont Yankee's commitment to Item (a) does not need revision; and 2.
Vermont Yankee's schedule for completion of Items (b) through (d) as discussed in References (c) and (f) remains unchanged.
Bulletin Item (f)
Revise the report requested by the original Bulletin to include any additional valves.
This revised report shall be submitted to the NRC within 60 days of completion of the program for the additional valves.
VY Response There are no additional valves identified from our original submittal, in that all HPCI and RCIC system valves were origi-nally included.
Therefore, the scope and schedule of the final report requested by the original Bulletin remains unchanged.
Our program is scheduled for completion by the end of our 1989 refueling outage and our final report will be submitted within 60 days after startup from our 1989 refueling outage.
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