ML19316B146
| ML19316B146 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 05/30/1980 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Crews E SOUTH CAROLINA ELECTRIC & GAS CO. |
| References | |
| NUDOCS 8006110391 | |
| Download: ML19316B146 (8) | |
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UNITED STATES
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NUCLEAR REGULA TORY COMMISSION y
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Docket No. 50-395 Mr. E. H. Crews, Jr.
Vice President and Group Executive Engineering and Construci. ton South Carolina Electric and Gas Company P. O. Box 764 Columbia, South Carolina 29218
Dear Mr. Crews:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (Virgil C. Sumer Nuclear Station, Unit No.1)
To continue our review of your application for a license to operate the Virgil C.
Summer Nuclear Station, additional infomation is required.
The information requested is described in the Enclosures and covers the areas of Instrumentation and Control, Materials Engineering, and Quality Assurance.
Please inform us after receipt of this letter the date you anticipate providing an answer.
Sincerely l
rL l':4. WYb'ls i
A.'Schwencer, Acting Chief Licensing Branch No. 3 Division of Licensing
Enclosures:
Requests for Additional Information ccs w/ enclosures:
See next pages THIS DOCUMENT CONTAINS P00R QUAllTY PAGES 8006110 3 9 1
w-Mr. E. H. Crews, Jr., Vice President and Group Executive - Engineering and Construction
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South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 cc: Mr. H. T. Babb General Manager Nuclear Operations and System Planning South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 G. H. Fischer, Esq.
Vice President & Group Executive South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 hr. William C. Mescher President & Chief Executive Officer South Carolina Public Service Authority 223 North Live Oak Drive Moncks Corner, South Carolina 29461 Mr. William A. Williams, Jr.
Vice President South Carolina Public Service Authority 223 North Live Oak Drive Moncks Corner, South Carolina 29461 Wallace S. Murphy, Esq.
General Counsel South Carolina Public Service Authority 223 North Live Oak Drive Moncks Corner, South Carolina 29461 Troy B. Conner, Jr., Esq.
Conner, Moore & Corber 1747 Pennsylvania Avenue, N. W.
Washington, D. C.
20006 Mr. Mark B.'Whitaker, Jr.
Manager, Nuclear Licensing South Carolina Electric 8-Gas Company P. O. Box 764 Columbia, South Carolina 29218 Mr. O. W. Ofxon Group Manager, Production Engir.nering South Carolina Electric & Gas C oany P. O. Box 764 Columbia, South Carolina 29218
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' ' Mr. E. H. Crews, Jr.
4 cc: Mr. Brett Allen Bursey Route 1 Box 93C
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Little Mountain, South Carolina 29076 Resident Inspector /Sumer Power Station c/o U. S. Nuclear Regulatory Comission P. O. Box 1047 i
Irmo, South Carolina' 29063 4
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REQUESTFORADDITIONALINFORMA{IOf(
LEVEL MEASUREMENT ERRORS DUE TO ENVIRONMENTAL TEMPERATURE EFFECTS ON LEVEL INSTRUMENT REFERENCE LEGS T
On June 22, 1979, Westinghouse Electric Cor:poration reported to NRC, a pStential safety hazard under 10 CFR 21. Th;is e _. c addresses errors gen-erated in the steam generator level indicatidn sensors following high energy pipe break accidents inside containment.
Further, the report implies that previous analyses of peak containment temperature and pressure, may have been nonconservative. Breaks of this type can result in heatup of the steam gen-erator level measurement reference leg resulting in a decrease of the water column density with a consequent increase in the indicated steam generator water level (i.e., indicated level exceeding actual level).
IE Bulletin 79-21 includes further information on this problem and addresses appropriate actions which are to be taken by licensees of operating plants.
Applicants for an operating license' are requested to submit a response to the following questions and to revise their safety analysis report consistent with this response.
1.
Describe the liquid level measuring systems within containmeiit that are used to initiate safety actions or are used to provide post-accident monitoring information.
Provide a description of the type of reference leg used, i.e., open column or sealed reference leg.
2.
Provide an evaluation of the effect of post-accident ambient temperatures on the indicated water level to determine the change in indicated level relative to actual water level. This evaluation must include other sources of error including the effects of varying fluid pressure and flashing of reference leg to steam on the water level measurements.
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3.
Provide an analysis of the impact that the level measurement errors in control and protection systems (2 above) have on the assumptions used in the plant transient and accident analysis. This should include a review of all safety and control setpoints derived from level signals to verify that the setpoints will initiate the action required by the plant safety analyses throughout the range of ambient temperatures encountered by the instrumentation, including accident temperatures.
If this analyses demonstrates that. level measurement errors are greater than assumed in the safety analysis, address the corrective action to be taken. The corrective actions considered should include design changes that could be made to ensure that containment temperature effects are automatically accounted for. These measures may include setpoint changes as an acceptable corrective action for the short term.
I However, some form of temperature compensation or modification to I
eliminate or reduce temperature errors should be investigated as a long term solution.
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kUI 2-4.
Review and indicate the required revisions, af.necessary, of emergency procedures to include specific information obta'inedtfrom the review and evaluation of Items 1, 2, and 3 to ensure that the operators are in-structed on the potential for and magnitude of erroneous level signals.
Provide a copy of tables, curves, or dorrection factors that would be applied to post-accident monitoring 4ystems that will be used by plant operators.
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REQUEST FOR ADDITIONAL INFORMATION, STEAM GENERATOR MODIFICATIONS AND CONTROL R0D GUIDE PIN REPLACEMENT The information submitted by you in the FSAR has been reviewed by the Metallurgy Section of the Materials Engineering Branch, Office of Nuclear Reactor Regulation.
We require that you provide the following information:
Inspection Ports For some forms of steam generator degradation which have occurred, eddy current testing and tube gauging alone are not sufficient to assess and monitor tube and support plate degradation.
In order to perform adequate assessment and monitoring of these areas, we require that inspection ports be installed. These ports should be installed just above the upper support plate, and between the tubesheet and the lower support plate, wita both ports in line with the tube lane.
Under the ALARA concept we are requesting that all possible steam generator modifications be made prior to the start of operations.
Based upon experience we have determined that these ports can be installed in the generators after start of operations at a personnel exposure of 7.5 man-rem. The Radiological Assessment Branch has determined that this exposure is not significant enough to justify the delay of start up of the plant to permit the installation of inspection ports.
However, since the probability of secondary side contamina-tion will increase as the operating time increases, we require that these ports be installed prior to start up after the first refueling. Therefore, ycurcommit-ment to install these ports is requested.
In the event they cannot be installed prior to initial fuel load, it is our intention to place this requirement in the operating license.
Control Rod Guide Tube Support Pins On March 13, 1980, Westinghouse reported to the NRC that Inconel 750 control rod guide support pins that were given a low temperature solution heat treatment may be susceptible to stress corrosion cracking. This followed recent support pin inspections at a foreign plant which revealed stress corrosion cracks in Westing-bouse supplied pins. We believe that the existing guide support pins in the -
V. C. Summer Unit 1 internals may need to be replaced with new pins that have been given a heat treatment which produces a condition that is highly resistant to stress corrosion cracking.
Provide us with your intended plan of action and your justification therefore.
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f Request for Additional Infos ation_
from a recent discussion with our ISE personnel, we understand that 421.78 (1/.P.2) your wording in the iSAR and your interpretation of the quality-related regulatory guides described in Appendix 3Aof the V. C. Suuuier FSAR ray not necessarily nean a total coaulitrant to these quality-related regu-latory guides. L'ord:ng such as " complies with the reconmendations,"
"follows the guidance of" and " essential recom.endations are met" may lead to misinterpretations of these quality-related regulatory guides during the operatic.ns phase.
Therefore, to preclude any misinterpre-tatiens in the future, it is requested that you review the quality-related regulatory guides in Appendix 3A of the V. C. Suntner FMR and provide us with a clear comaitment regarding your intentions to comply with them.
Should you elect to comply with a guide, potentially ambiguous wording should be clarified.
Should you elect to take any exceptions to these guides, provide us with sufficient description and equivalent supporting detail.
421.79 Your revised QA program description does not clearly describe how or to (17.2.18)
" hat guidelines persennel performing audits /surveillances will be trained
- .nd qualified.
Specific guidance for qualifying auditors is provided in ANSI N45.2.23-1978, " Qualification of Quality Assurance Program Audit Persconel for Nucicar Power Plants" and a commitiaent to follow the guid-ance centained therein would be considered acceptable in order to satisfy
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our concerns.
If, however, you do not wish to comply with the guidance contained in ANSI N45.2.23, provide us with an alternative approach including sufficient detailed description of how personnel perfonning audits /surveillances will be trained and qualified.
j 421.80 A andment 18 to Section 17.2.18 of the V. C. Summer FSAR revises the (17.2.18)
SCE&G audit progran to consist of two sources of input; surveillance and audits.
From this revised description we are unable to determine if the use of surveillance will consist of all the programmatic aspects necessary to satisfy an audit, e.g., follow-up, objective review of Appendix B criteria and SCESG QA program, reporting findings to upper
- -anagement, quality tiends, qualified auditors, use of checklists, etc.
It is also not clear if the SCE&G interpretation of audits-and surveil-lances will be consistent with the definitions described in ANSI N45.7.10, ANSI N45.7.12, and N45.2.13.
If you do plan to substitute.urveillani es for audits, describe the' criteria that deterinine when an audit will be
-used and when surveillance will be used. Also, describe in iaore detail what a " Type II" surveillance is.
It is our position that if surveil-lances are to be used:in lieu of audits, they must satisfy the criteria delineated in Criterion 18 in Appendix B to 10 CFR-50 and ANSI N45.2.12 (Draft 4, Revision 2 - January 1976) to which you are comnitted through your' endorsement of Regulatory Guide 1.33, Revision 1 (January 1977).
421.81
_ It is our un~derstanding that your intent of complying with Regulatory
-Guide 1.33, Rev.1, January 1977 does not necessarily commit you to comply.
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with the guidance contained in ANSI U45.2.12 '9 raft 4, Pev. 2, J ouary
- 1976), "Rrquiiements for Auditing of Quality Assurence Pregrams for Muclear power plants."
It is our position that your commitment to comply with Regulatory Guide 1.33 (which endorses ANSI 18.7-1976)also commits you to ANSI H45.2.12.
Should your interpretation differ from our position, provide us with your rationale and explanation in equiva-lent detail.
421.82 Paragraph 17.2.18.2 of the FSAR has been revised whereby external _
'(1/.7.18) audits will be conducted on a triennial basis.
It is our position that triennial audits will be acceptable if they are implemented in accordance with Section 4 of ANSI /ASME N45.2.12-1977.
The triennial period should begin with performance of an audit when sufficient work is in progress to demonstrate that the organization is implementing a Quality Assurance Program having the required scope for purchases placed during the triennial period. When a subsequent contract or a contract modification that significantly enlarges the scope of activi-ties performed by the same supplier is executed, an audit should be conducted to the increased requirements, thus starting a new triennial period.
If, at any time of the pre-award survey, the supplier is al-ready implementing the same quality assurance program for other cus-tomers which he proposes to use on the auditing party's contract, then the pre-award survey if it was conducted in accordance with Section 4 of ANSI /ASME H45.2.12-1977 may serve as the first triennial audit.
Therefore, when such pre-award surveys are employed as the first tri-ennial audits, those surveys should satisfy the same audit elements and criteria as used on other triennial audits.
A documented evaluation of the supplier should be perfonned annually.
Where applicable,'this evaluation should take into account (1) review of supplicr-furnished documents such as certificates of conformance, non-conformance notices, and corrective actions, (2) results of pre-vious source verifications, audits, and receiving inspection, (3) operating experience of identical or similar products furnished by the same suppliar, and (4) results of. audits frc n other. sources, e.g.,
custo.ncr, ASME, or URC audits.
Modify your description to include the cbove position.
Correct / clarify the following:
a._ Figure 17.1 Typographical error in SCE&G Nuclear Site Manager title.
Ub.
Page 17.1 Paragraph (b), second sentence appears to have
. inadvertently omitted the complete title for. Gilbert QA function.
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Page 17.1-44 ?Pourth paragraph appears to have deleted SCfr.G QA c.
organization.
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Pages 17.2-15/15a - 1.ast sentence on.page 17.2-15 to first wnlinte d
on page_17.2-15a is incomplete.
e.
Page'17.2-51-- Pmginning sentence incomplete.
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