ML20150E632

Responds to NRC 880222 Ltr Re Violations Noted in Insp Rept 50-271/87-19.Corrective Actions:Qualification Documentation Review Package Rev in Progress,Including Rev of Test Rept & Upgrade to File as Required

ML20150E632
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	03/28/1988
From:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
FVY-88-21, NUDOCS 8804010164
Download: ML20150E632 (5)

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. ' VERMONT YANKEE NUCLEAR POWER CORPORATION FVY 88-21

. ,- RD 5, Box 169. Ferry Road Brattleboro, VT 05301 %g ENGINEERING OFFICE 1671 WORCESTER ROAD y F R AMINGH AM, M ASS ACHUSETTS 01701

• ?t6tr o'd6174?t490 March 28, 1988 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Document Control Desk

References:

a) License No. OPR-28 (Docket No. 50-271) b) Letter, USNRC to VYNPC, NVY 88-019, "January 26, 1988 Meeting with the VYNPC, Re Environmental Qualification Issues", dated 2/9/88

) c) Letter, USNRC to VYNPC, NVY 88-025, "Inspection Report No. 50-271/87-19 and Notice of Violation", dated 2/22/88 Dear Sir

Subject:

Response to Inspection Report 87-19, Notice of Violation This letter is written in response to your Notice of Violation, dated 4

February 22, 1988 (Reference c)).

4 VIOLATION 1 As a rest It of the environmental qualification (EQ) inspection conducted on j

October 19-23, 1987 and in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy 1987), the following violation was identified:

10 CFR 50.49 paragraphs (f) and (g), and paragraph (k) (for DOR Guideline provision) require that each item of electrical equipment important to safety be qualified and that qualification must be completed no later than November 30, 1985. Contrary to the above on October 23, 1987:

i j 1. Qualification of the EP/Hypalon cables was not established at the time of the inspection in that the qualification test report was invalid because of problems identified in Information Notice 84-44 (inadequate QA program, test equipment not properly calibrated, test deficiencies j and test anomalies improperly documented, and test documents impro-perly controlled).

i 2. The qualification of 3M tape splices was not established at the time i of the inspection in that no type test report nor adequate similarity

! analysis was available in the EQ file to support the tape splices' l qualification, h Q

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VERMONT YANKEE NUCLE AR POWER CORPOR ATION l U.S. Nuclear Regulatory Commission March 28, 1988 Page 2

3. The qualification of Dings brakes in the Limitorque valve operator was not established at the time of the inspection in that the EQ file did not contain evidence to demonstrate the radiation qualification of the Dings brakes for application inside the drywell.

4. The qualification of GE EB-5 terminal block was not established at the time of the inspection in that 1) the type test report did not demonstrate that this terminal block can perform its safety functions because low insulation resistance values were observed during the tests and 2) no similarity analysis was available in the EQ file for GE EB-5 and GE CR 1518 terminal blocks.

5. The qualification of Rome XLPE/PVC cables was not established at the time of the inspection in that the test conditions did not envelope the required service conditions (303*F for four hours vs 325'F for three hours).

6. The qualification of Lewis PE/PVC instrumentation cables was not established at the time of the inspection in that no valid test report was available in the EQ file to support the qualification of this type of cables.

This is a Severity Level IV violation (Supplement I).

RESPONSE

The Vermont Yankee Nuclear Power Corporation response to the violation will address each of the six items described above separately as follows:

1. This item deals with Cerro cable. During the inspection, Vermont Yankee was able to obtain a Franklin Research Center test report which verified the qualification of the cables. A qualification documentation review (QOR) package revision is in progress to include this report and to upgrade the file as required. When the additional information is incorporated, this QOR will document, in accordance with the Division of Operating Reactor (00R) Guidelines, that equipment subjected to harsh environmental conditions will perform its intended safety function. This action will bring Vermont Yankee into full compliance with 10 CFR 50.49. This will be completed by May 1, 1988.

2. Item 2 involved 3M tape splices. During the inspection, Vermont Yankee was able to obtain a letter from Wyle Laboratories, dated October 21, 1987, summarizing testing that Wyle hb1 performed on 3M tape splices. Vermont Yankee has since obtained a copy of the Wyle Test Report No. 58316 docu-menting the qualification of the 3M tape splices. In addition to the above mentioned test report, Vermont Yankee has obtained a second Wyle Test

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4 VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission March 28, 1988 Page 3 Report #17947-01, which further tested 3M splices in various con-figurations. This test, which satisfies the intent of IEEE 323 1983, included LOCA and main steam line break testing which envelopes the Vermont Yankee application with margin. A QDR revision is in progress to upgrade the file as required. When the additional information is incorporated, this QOR will document, in accordance with Division of Operating Reactor (DOR) guidelines, that equipment subjected to harsh environmental con-ditions will perform its intended safety function. This action will bring Vermont Yankee into full compliance with 10 CFR 50.49. This action will be completed by July 1, 1988.

3. Item 3 involved the qualification of Dings brakes in Limitorque valve operators. It continues to be Vermont Yankee's position that the qualifi-cation of Limitorque valve actuators equipped with Dings brakes is ade-quately addressed in Vermont Yankee's existing EQ file. The Certificate of Compliance contained in our file states: "The brake motor supplied with special radiation resistant brake coils with materials equivalent to K8110 would be equivalent to, or superior to, the brake motor included in Limitorque Qualification Report 600198. The capability of the motor and brake coil to withstand radiation only can be supported by Qualification Report 600376A."

Qualification for radiation is clearly established by the Certificate of Compliance. Qualification Report 600376A tested an actuator with motor which was irradiated to a radiation dose of 2 x 10 8R, which exceeds our requirements with significant margin. During the meeting between NRC and Vermont Yankee on January 26, 1988, the acceptability of vendor documen-tation to demonstrate qualification was discussed in detail. At that meeting, NRC management concurred that Certificates of Compliance to a test report from a QA-approved viridor are acceptable to link qualification to the certified test report. In that Certificates of Compliance are the basis of nearly all nuclear documentation, a Certificate of Compliance in this instance is as acceptable, if not more so than a letter from a vendor.

Accordingly, it is Vermont Yankee's position that at the time of the inspection, the qualification file clearly established qualification and this item was in compliance. However, in order to fully address Inspection Item 50-271/87-19-06, we will upgrade our file to incorporate the addi-tional information obtained on the material composition of the Vermont Yankee Dings brake and the radiation threshold doses. A QDR revision is in progress. This will be completed by May 1, 1988.

4. This item involved the qualification of the GE EB-5 terminal blocks. As stated in the inspection report, Vermont Yankee obtained a memorandum from GE during the audit documenting the similarity of the EB-5 block and the CR-151B block. In addition, the EQ file had an overly conservative operating time leading to the auditor's conclusion that the 80119

, Limitorque test report did not demonstrate the qualification of the EB-5 block for required insulation resistance. A QDR revision is in progress to document the required operating time of the blocks and to include the simi-larity documentation obtained from GE. When the additional information is

VERMONT YANKEE NUCLEAR POWER CORPORATION U.S. Nuclear Regulatory Commission March 28, 1988 Page 4 incorporated, this QDR will document, in accordance with the Division of Operating Reactor (00R) Ouidelines, that equipment subjected to harsh environmental conditions will perform its intended safety function. This action will bring Vermont Yankee into full compliance with 10 CFR 50.49.

This will be completed by June 1, 1988.

5. This item involved the qualification of Rome XLPE/PVC cable. The inspec-tion report states that the peak temperature is not enveloped by actual Rome cable testing and that the file did not contain sufficient information to show similarity to the tests of other manufacturer's cable used by Vermont Yankee to qualify the peak temperature. Vermont Yankee provided additional operability time information during the inspection. The inspec-tion report concludes that based on the data furnished by Vermont Yankee during and after the inspection, the licensee would be able to establish qualificaiton. A QOR revision is in progress to incorporate the infor-mation provided to the NRC. In addition, Vermont Yankee will perform material and chemical composition testing on selected samples of cables to further establish and document the similarity of the Rome cable to the cables tested by other manufacturers. When the additional information is incorporated, this QDR will document, in accordance with the Division of Operating Reactor (DOR) Ouidelines, that equipment subjected to harsh environmental conditions will perform its intended safety function. This action will bring Vermont Yankee into full compliance with 10 CFR 50.49.

This will be completed prior to startup from the next refueling outage.

6. This item involved the qualification of Lewis PE/PVC cables. The inspec-tion report states that at the time of the inspection, no valid test report was available in the EQ file to support qualification. During and following the inspection, Vermont Yankee submitted additional information to the NRC to support the qualification of the Lewis cables. The inspec-tion report concludes that based on the additional information provided, the licensee would be able to establish qualification. A QOR revision is in progress to incorporate the information provided to the NRC, When the additional information is incorporated, this QDR will document, in accor-dance with the Division of Operating Reactor (DOR) Guidelines, that equipment subjected to harsh enviromental conditions will perform its intended safety function. This action will b.'ing Vermont Yankee into full compliance with 10 CFR 50.49. This will be completed by July 1, 1988.

l The Vermont Yankee EQ Program is a dyramic, ongoing program supported by 67 i volumes of documentation. The documentation supporting this program undergoes I revision based on new infornation obtained from a variety of sources including l

the NRC, utility groups, and lessons learned from other utilities and inspec-

, tions. This ongoing process will ensure future compliance with NRC rules and regulations precluding futuro violations.

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VliRMONT YANKEE NUCLEAR POWER CORPORATK)N U.S. Nuclear Regulatory Commission .

March 28, 1988 Page 5 i

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We trust that this infcrmation is satisfactory and fully responsive to your request. However, should you have any questions or require additional infor-  !

mation concerning this matter, please contact us.  ;

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Very truly yours, VERMONT YANKEE NUCLEAR POWER CORPORATION t t  !

Warren P. Murphy  ;

Vice President and i Manager of Operations  ;

/dm f cc W.V. /,ohnston, NRR  !

USNRf, Region I, Regional Administrator USNFC Resident Inspector, VYNPS ,

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