ML20127A194

Affidavit of RB Miller Supporting Applicant Motion for Summary Disposition of Joint Intervenors Contention 10.5 Re Environ Qualification of Asco Solenoid Valves.Certificate of Svc Encl

ML20127A194
Person / Time
Site:	Vogtle
Issue date:	07/26/1985
From:	Miller R GEORGIA POWER CO., WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:
Shared Package
ML20127A182	List: ML20127A179 ML20127A185 ML20127A188 ML20127A194 ML20127A200
References
OL, NUDOCS 8508050476
Download: ML20127A194 (30)

Text

T O

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD DXPETED In the Matter of [

GEORGIA POWER COMPANY, et ad3 ' 3 -2 P 1 RJ k t Nos. 50-424 50-425 (Vogtle Electric Generating  :

Plant, Units I and 2) r.,  :

I ,. ,, ) E

. n . '

COUNTY OF ALLEGHENY )

)

COMMONWEALTH OF PENNSYLVANIA )

AFFIDAVIT OF RICHARD B. MILLER I, Richard B. Miller, being duly sworn according to law, deposo and say as follows:

1. My name is Richard B. Miller. I am employed by Westinghouse Electric Corporation (" Westinghouse") in the position of Lead Engineer in Instrumentation and Control Systems Licensing for the Nuclear Technology Division. My business address is Westinghouse Electric Corporation, Monrooville Nuclear Contor, P. O. Box 355, Pittsburgh, Pennsylvania 15230. Attached to this affidavit as Exhibit A is a summary of my professional qualifications.

2. The purpose of this affidavit is to support the Applicants' Motion for Summary Disposition of Joint Inter-venors' Contention 10.5, which concerns the environmental 0500050476 050730 gDR ADOCK 0500o4p4 PDR

FI .

1 9

l qualification of solenoid valves used at the Vogtle l

Electric Generating Plant ("VEGP") manufactured by the Automatic Switen Company ("ASCO"). In this affidavit, I l l I will discuss the environmental qualification of the ASCO l solenoid valves having the model numbers NP8316 and  ;

206-381-6F that were provided to VEGP by Westinghouse.

This affidavit will describe the operation of those j E

valves, will review qualification testing that has been i l

performed on them by ASCO and Westinghouse, will discuss j other tests performed on the valves by Franklin Research I l

Center, and will address the environmental qualification j of the solenoid valves for use at VEGP in light of the f i

Franklin Research center test results. I have personal l

l knowledge of the matters set forth herein and believe them  !

(

to be true and correct.

I

!. Operation of the ASCO Solenoid Valves Supplied to  !

VEGP by Westinghouse.

3. Westinghouse has supplied two models of ASCO  ;

solenoid valves, model numbers NP8316 and 206-381-6F, to l VEGP for use in safety-related functions. ASCO model NP8316 and 206-381-6F solenoid valves are employed in l safety-related applications at VEGP as control valves for air operated process valves. Those ASCO solenoid valvos I i

control airflow to operators on air operated process

(

valves. By oither venting or providing air to the air l

t I

1 l

r e

o .

operators on the process valves, the solenoid valves f enable the process valves to open or close. The valvo configurations at VEGP performing safety-related functions that include ASCO model NP8316 and 206-381-6F valves are arranged so that the process valve will attain its required " safe" position, olther open or closed, if a loss of supply air were to occur. ,

4. The ASCO model NP8316 solonoid valve is a throo-way valve with one inlot port .ind two outlet ports. In a typical application, the inlet port is connected to a supply of pressurized air, the cylinder port is connected to the air operator of a procoss valvo, and the exhaust port is used as a dischargo vont to tho atmosphora.

Figure 10.5-1 depicts tho operation of the Np8316 valve with the electrical solenoid unorgized and de-onorgized.

The main orificos of tho inlot port and exhaust port are opened and closed by applying inlet air prosauro to one side (the control sido) of floxible othylono propylono clastomar diaphragms, which forcos the opposito side of the diaphragms against their orifices, closing their ports. The air prosauro on the diaphragms is controlled by inturnal pilot and blood orificos, which are opened and closed by the magnetic core of the solonoid. The cylinder port is always opon.

5. When employod in the norma 11y closed position shown in Figuro 10.5-1, tho inlot port .ind the pilot T

4 e

orifico are closed and the exhaust port and bleed orifice

! are open. In this position, the air operator of the pro-cess valvo is vented to the atmosphere. Wnen the solenoid l is energized, its magnetic core rises, opening the pilot orifice and closing the blood orifico. The open pildt orifice relieves the air pressure on the control side of the inlet diaphragm by releasing air to the outlet side of the valvo. Inlet pressure on the opposite (orifico) sido of the diaphragm pushes the diaphragm away from the main orifico, oponing the inlet port. Closing the bleed ori-fico closes the air colosso path from the exhaust port diaphragm allowing air pressure on the control sido of the diaphragm to build up to inlet pressure, closing the exhaust port. In this position, inlet air is supplied to refill the air operator of the process valvo. Because tho diaphragms are not mochanically hold open, but instead are

" floating" diaphragms, a minimum difforuntial air pressure of 10 psi across tho valvo is nocessary to hold the inlet diaphragm opon.

6. When the solonoid is do-onorgized, the pilot orifico is closed, the blood orifico is opened, and full lino prossauro is applied to the control sido of the inlot diaphragm. That pressuro providos a seating forco to ensure tight clonuro of tho diaphragm against tho inlot

e port orifice. The open bleed orifice releases air from the control side of the exhaust diaphragm, allowing the exhaust port to open.

7. Unlike the model Np8316 solenoid valve, the ASCO model 206-381-6F solenoid valvo has no internal pilot, but is a three-way direct acting solenoid valvo. In the model 206-381-6F valvo, the position of the moveable solenoid core directs air flow. As depicted in Figure 10.5-2, onorgizing the solonoid causos the core to lift up. This connects the inlet port to the cylinder port and isolatos the exhaust port. When the valvo is do-onorgized, the solenoid core falls, isolating the inlot port and con-nocting the exhaust port to the cylinder port.

II. The Joint Westinghouse and ASCO Environmental Qualificatton Tostinq prouram.

8. In 1980 and 1981, Westinghouse and ASCO jointly conducted an environmental qualification testing program for various ASCO solenoid valves. Included among the solenoid valvos testod woro valvos reproaontative of the model Np8316 and 206-381-6F ASCO solonoid valvos supplied by Westinghouse to VEGp for uso in safoty-rolated func-tions. The objectivo of tho qualification testing program was to demonstrate that. the ASCO solonoid valvos mot or excouded their safety rotatud performanco requiromonts whilo subjocted to simulated normal and accidont onviron-monts.

t

o

9. The joint Westinghouse /ASCO qualification program was conducted in accordance with the Institute of Elec-trical and Electronics Engineers ("IEEE") Standard l 323-1974, "IEEE Standard for Qualifying Class IE Equipment j for Nuclear Power Generating Stations;" IEEE Standard f 344-1975, "!EEE Recommended Practicos for Seismic Quali-fication of Class IE Equipment for Nuclear Power Genera-ting Stations;" and IEEE Standard 382-1972, "!EEE Trial-Use Guide for Type Test of Class 1 Electric Valvo Opera-tors for Nuclear Power Generating Stations." Addition-ally, the qualification program was performed in accor-dance with the methodology set forth in WCAp-8587,

" Methodology for Qualifying Westinghouse WRD-Supplied NSSS Safoty-Rotated Electrical Equipment."

10. The tests comprising the qualification program consisted of initial performanco tests; thormal, muchan-ical, and pressure aging; normal environment radiation testing; vibration aging, operating basis carthquako simulation, and resonance testing; safe shutdown carth-quake simulation; design basis ovant unvironmental  !

radiation testing; and high onorgy lino break (" HELD") ,

l unvironmental testing.

11. In the HELD onvironmontal testing the tost valvos l woro tostod undor conditions dotorminod by a composito of  !

the advorso onvironmontal conditions that would result l

l -o.

e from a loss-of-coolant accident ("LOCA") and a main steam line break ("MSLB"). Figure 10.5-3 profilos those condi-tions. To perform the HELB testing, Westinghouso mounted the test valvos on a test fixture, which it in turn mounted in the steam chamber. The electrical leads from the solonoids on the valves woro connected to a vented e

junction box after being passed through a metal conduit.

To simulato a typical in-service assembly, the valvo, conduit, and junction box woro installed in the pressuto chambor, 12, prior to initiation of the pressure and tom-potature transients, the valvos woro testod under load for proper functioning. To simulato pro-dosign-basis-ovent l

conditions, the valvon woro continuously energized at nominal voltago for four hours at a.etomporaturo of 140*F.

The initial atmosphoto of the test chambor consisted of a saturated stoam and air mixturo containing 0-2000 ppm boric acid.

13. The valvos woro than subjocted to two pressure and temperaturo transients. Tho atmosphoro during the pressuro and temperaturo transionts was suporhoated steam. The actual temporaturo and pressuro conditionn to l which tho valvos woro exposud envoloped tho conditions shown on Figure 10.5-3. A chemical spray comprisod of 2500 ppm boron bufforud with sodium hydroxido to a pH of i

l l

O 10.5 was initiated twelve minutos into the first tran-sient, continued for approximately five hours, discontin-ued, reinitiated three minutes into the second transient and continued for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the HELD ,

i environmental testing the valvos were onorgized and de-energized periodically. I

14. The test valvos representative of the model 206-381-6F valves successfully completed performanco tests before, during, and after the qualification testing por-formed in the joint Westinghouse /ASCO program. One of tho test valves representativo of the model Np8316 valvos encountered performanco problems, but not until well after completion of the portion of the test period simulating operation for one year attor a design basis accident, l

l which in the longth of timo that the valvos are required to operato after such an accident.

15. In the HELB onvironmental testing, a portod of i

3.6 days at 265'F following the second transient simulated l

ono year of actual post-accident servico. One of thu model t l

NP8316 valvos tonted would not actuato at the minimum DC voltago (90 VDC) whon tested soventoon days into the tost. When the voltaqo was increased to 125 VDC thu valvo actuated and continued to requito at lonst 110 VDC to actuato for tho romaindor of tho thirty day tost portod.

Lator inspection of tho valvo rovoaled that tSo incroano ,

i l

l l

I r

l .

r in the voltage needed to activate the valve had resulted from moisture and chemical spray entering the valve sole-noid enclosure and over timo reducing the coil insulation resistance. No similar moisture buildup occurred in any of the other valves tested. Based on the degradation of the model NP8316 valvo solonoid due to exposure to signif- i icant amounts of water, Westinghouse considers the ASCO valves to be qualified by type testing as long as the conduit hub on the solenoid onclosure is sealed when l installed in the field. The successful performance of tho other test valves whose solenoids did not experience moisturo exposure and subsequent degradation demonstratos that the subject ASCO valves are qualified as long as the

~

I solonoids comain essentially dry.

16. Another of the model Np8316 valves tostod por-formod successfully beforo, during, and after tho HELD onvironmontal testing. Upon disassembly subsuquent to tho HEL8 testing and the final operational chock, the dia-l phragm of the valve was found to be stuck to tho valvo body, which caused a tear in the diaphragm. This sticking of the diaphragm does not reprosont a tost failuro becauso it occurrod attor succonsful complotion of tho HELD testing and final operational tosts. Moroovor, the thirty l

l day testing period to which the valvos woro subjected in l

l .g.

l l

i l l

l

m s

the HELB testing simulates more than eight years of cer-vice after a design basis event, which provides a con-siderable margin over the one year period that the valves 1

are required to be operational following a design basis '

event.

17. The results of the joint Westinghouse /ASCO testing program qualified the ASCO model Np8316 and 206-381-6F solenoid valves to the environmental extremos of (a) a peak temperature of 420'F (b) pressure of 57 psig, and (c) a chemical spray of 2500 ppm boron bufforod r

• With sodium hydroxide to a pH of 10.5. The pressure and temperature extremen are profiled in Figure 10.5-3.

18. Westinghouse submitted the reports documenting r this joint Westinghouso/ASCO qualification program to the Nuclear Regulatory Commission ("NRC") staff for review.

On November 10, 1983 the NRC staff issued to Wostinghouse a Safoty Evaluation Roport accbpting the qualification  :

tunting mothodology outlinod in WCAp-8587 and the test rosults not out in the apocific toports concerning tho ASCO solonoid valvon.

111. Ibo3ranklin R.e_soa rch Cont!tr__Tostdna_ptagim

19. In 1981 Franklin Rosuatch Contor initiatud a tosting program on ASCO solonoid valvos on bohalf of tho l NRC staff. Among tho valvun tasted by Franklin Roscarch Contor woro two modol hp0316 valvos and ono modol l ,

i 1

! - 10 -

t l .

I 206-381-6F valve. Following functional tests, Franklin Research Center artificially aged one of the model NP8316 )

i I valves and the model 206-381-6F valve to simulato a four-year life at 140*F. Those valves were irradiated to l ,

l a total integrated dose of 50 megarads and then exposed to i

a tomrstature of 268'F for approximately fifteen days.

t l

! While it that olevated temperature the valves woro cycled [

2000 times. This artificial aging was much more severo ,

than that used in the Westinghouse /ASCO testing program, r

where the valves were cycled only 200 timos at elevated

' temperatures and 1800 times at room temperature. The other model NP8316 valve had been naturally aged by ASCO l at 140*P for three years, without any radiation exposuro.

l That valvo had boon cyclod 2000 times at room tempora- ,

turo. All three valves then underwent pressurization testing, vibration aging, rosonance search, notamic  !

t tasting, design basis ovont radiation exposure, and a l simulated composito LOCA and MSLB oxposure, f

20. The composito LOCA/MSLl! oxposuro includod stoam, chemical spray, and high humidity conditions. Two transients woro simulated, oach with a targoted peak temporaturn of 420*F and prussuto of 68 psig.

Thormoenuplo data from the tost chambor, howevor, indicated that cottain arons in the chambor oxportanced l temperaturos highor than tho intendod tost conditions. l i

i

The temperature of the naturally aged model Np8316 valvo '

(which lags the test chamber temperature, as described in paragraphs 28 through 33) increased to 410*F. significantly l 1

above the 350*F to 360*F temperatures reached by the other l valves in the test chamber.

21. The ASCO model 206-381-6F valvo performed satisfactority through all of the tests. Both of the '

model Np8316 valves, however, failed to operato proporly during the composite LOCA/MSLB sicalation. The modul  ;

Np8316 valve that had boon artificially aged could not be

' cycled properly between the first and second transiants i

because the air supply could not be maintained at suffi-clont pressure and volume, prior to the start of the second transient, Franklin was able to supply sufficient air prosauro and volumo to cyclo the valvo, and it con-l tinued to function until four days olapsed timo in tho  ;

LOCA/MSLD simulation. f

22. The naturally agod modol Np8316 valvo stopped .

cycling betwoon the first and socond LOCA/MSLB transients, l

at 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into tho tost, but began to function again at i

15.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> into tho tout and continued to oporato until l l

25.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. At that point no furthur cycling could bo l l

accomplinhod. I

23. In Novombot 1983, Franklin Rosoarch Contor issued  !

l a toport conentning its test results, untitled " Tost l

i i

f

Program and Failure Analysis of Class 1E solenoid r Values." NUREG/CR-3424. After reviewing those results, the NRC staff in December 1983 revoked those portions of f t

the Safety Evaluation Report that it had previously issued ,

to Westinghouse that related to the environmental qualifi-cation of the ASCO modo! NP8316 valvo. In April 1984, the NRC staff issued IE Information Notice No. 84-23, which -

reported its initial assessment of the Franklin Research Center test results.

24. In IE Information Notice No. 84-23, the NRC

' staff discounted the failures of the artificially aged valvos in the Franklin Research Conter tests, concluding that those tost results were inconclusivo duo to-thu savoro proconditioning to which those valvos woro exposed. With respect to the naturally aged model Np8316 i

valvo, the NRC staff decided that its falluto in tho l Franklin Rusuarch contor tosts called into question tho  ;

prior test results obtained during the joint Westing-  ;

house /ASCO tasting program. That model ASCO solonoid i

valvo, the NRC staff concluded, was acceptablo for uso l only in applications whoro tho environmental conditions to which it might bo exposod woro onvolorod by the conditions ,

to which that model valvo had boon tisstod eartior by l

!somodix, tue. on bohalf of ASCO as describod in !somodix -

t Tust Roport No. AQS21678/TR-Hovision A, dated July 1979.

I b

f l

i

2 1

. In thee tontle.g program employed by Isomodix, the test J

valves, including a valvo representative of the model

\

NP8316 valvo, woco exposed to a peak ten',wrature of 346*F for throo hou'ts. '

25. The NPC sta f reiterstod its conq1usions con-corning the model NP8316 valvo in IE.!nformation Notico tio. 85-08 issued on January 30, 1985. After stating that the NRC staff considered all ASCO NP series nolonoid f' valves with othleno propyleno elastomorJ nthor than the model;PI'8316 to bo qualified to tho lovola_,roported in the 5' joint 'lostingho'tJJo/ASCO testing program,. t ra.' notico stated: "ASCO valve '.odol NP 8316 with.Eri..eno Propylone '

olastomors la cor.sidorod qualified to the IAvils repo'rted in tsomodix Tost Roport No. AOS(AQS] 216 7 8 /'i d , 'liev. A, datedMarch19N,'revisedJuly1979."

, s l r IV. The Ritsults of the Franklin liewarch Contor Testing Program Do Not call,1,nto Quostiori the

, Fnvitonmontal Qualification ot'the AJC0 Modol flph il6_ SJdqfinid Valvo for t)f 6 at,MPa

26. Westinghouso and ASCO havo i.4ct % 1.' ud ;od t ho

,i ,

results obtainod by Franklin Rosoarr:t. Cont'or, hath Wostinghouso and ASCO concludod thtt. bocauso M anomalion in tho tost procuduro umod by Franklin Hotoarch Contor and thu moto sovuto,ot/>ironmental condition 2 co which it I

I j \ r 4

) iI '

l tested the valves, the test results obtained by Franklin do not call into question the validity of the test results found in the joint Westinghouse /ASCO qualification testing program. Based upon the NRC staff's evaluation of the Franklin Research Center test results, however, Westing-f house has modified the generic compcsite LOCA/MSLB temperature and pressure profile to which it considers the model NP8316 valve to be qualified by reducing the peak temperature during each transient to 400*F. A thermal lag analysis performed by Westinghouse for the model Np8316 valvo, whic's analysis determines the temperature reached by the valve itself, has shown that upon exposure to the conditions shown in the durated Westinghouse LOCA/MSLB profilo, the temperature of the valve would not exceed the temperaturo reached by that model valve in the prior qualification testing performed by Isomedix, Inc. on behalf of ASCO. As the NRC staff concludod in IE Infor- .

1 mation Notico Nos. 84-23 and 85-08, the results of tho l oarlier tsomodix testing program havo not buon called into question by the valvo failures experienced in the Franklin Research Center qualification testing undor significantly more novoro environmental conditions.

A. Thn tsomedix, Inc. Tonting.

27. In its testing program, Isomodix, Inc. exposed the tost valvos to 268'F for twolvo days of thormal aging i

)1 to simulate a design life of four years. During that thermal aging, the valves were continuously energized (O

, except for five minutes once every six hours when they

, were cycled by being de-energized. The valves were then

! radiation aged by exposure to a total integrated dose of 50 megarads and wear aged by being cycled 40,000 times.

Next, the valves underwent seismic simulation, vibration endurance testing, and exposure to an additional 150 megarads to simulate the radiation that would be exper-1 l

ienced under accident conditions. Finally, Isomedix

. exposed the valves to simulated LOCA conditions. Those l

1' conditions, which are profiled in Figure 10.5-4, included a peak temperature of 346*F and peak pressure of 110 psig s

that lasted for three hours.

B. The Thermal Lag Analysis Performed by Westinghouse.

28. Because of the long period, three hours, to which the model NP8316 valve was exposed to the peak temperature of 346*F in the testing performed by Isomedix, the actual temperature reached by the valve under those conditions l- would have equaled that peak temperature. The shorter duration of the exposure to peak temperatures that would occur in a composite LOCA/MSLB simulation, approximately three minutes for the derated Westinghouse generic LOCA/MSLB profile, would mean that the temperature of li- . . , . . . . . . . - . . .

those ASCO model NP8316 valves located inside containment would not reach that peak environmental temperature to which they were exposed. Instead, a thermal lag analysis performed by Westinghouse for the model NP8316 valve, which accounts for the amount of time it takes for the valve temperature to equalize with the surrounding environment, demonstrates that the temperature that would be reached by the model NP8316 valve during and subsequent to a design basis event would peak at a much lower value since the valves would be exposed to the peak environ-mental temperature for only three minutes. That thermal lag analysis is documented in WCAP-8687 Supp. 2 -HO2A/HO5A Addendum i Revision O.

29. During a typical composite LOCA/MSLB simulation involving high temperature and pressure, the actual thermal response of a particular test specimen is governed chiefly by the nature of the heat transfer mechanisms taking place at a given point in time. For this reason, the thermal profile of the steam environment during the LOCA/MSLB varies greatly from the actual thermal response of the test specimen. As explained in the report prepared i by Westinghouse describing the thermal lag analysis, upon

-exposure to a temperature and pressure transient for a s composite LOCA/MSLB simulation, a model NP8316 ASCO solenoid valve would respond in the following manner.

r_ _ _ - - - _ _ _ - - - . . .

1.

30. During the initial rapid environmental tempera-ture rise from ambient to peak superheated steam tempera-tures, the valve temperature would rise rapidly, although l

lagging the environmental temperature, until it reached the saturation temperature corresponding to the vessel pressure. Initially all the steam impinging on the valve would condense, giving up its heat to the cooler valve.

The valve temperature would rise at a rate dependent primarily on the steam temperature itself, the surface area of the valve, and the mass flow rate of the steam. '

t

! During this phase of heatup, the valve temperature would rise in a relatively linear manner.

31. Once the valve reached the saturation temperature corresponding to the vessel pressure, the valve temp' era-ture would temporarily stabilize. The heat transfer mechanism would change significantly as steam condensation ended and the moisture condensed on the valve began to evaporate. The amount of time at this plateau and the relatively slow temperature rise during this plateau would depend primarily upon the mass and surface area of the 4

valve, the temperature of the steam, and the mass flow rate of steam impinging on the valve. The time spent by the valve on this plateau would be relatively short and would last only until the moisture on the surface area of the valve had evaporated and the entire valve had been heated to the saturation temperature.

32. At this point in time heat transfer from the superheated steam would again raise the valve tempera-ture. The rate of temperature rise of the valve would depend primarily upon the mass and surface area of the valve and the steam temperature.

33. The thermal lag analysis performed by Westing-house for the model NP8316 ASCO solenoid valve demon-strated that if the temperature peak in the Westinghouse generic LOCA/MSLB profile is reduced to 400*F, the maximum temperature that would be reached by that valve under LOCA/MSLB conditions would be 345'F. That temperature is below the maximum temperature of 346'F that was reached by the model NP8316 valve under the Isomedix testing program, which has been accepted by the NRC staff.

C. Westinghouse's Modified Generic LOCA/MSLB Profile Envelopes the Conditions That Might Be Experienced at VEGP.

34. Betchel Power Corporation has advised Westing-house that the temperature conditions to which ASCO sole-noid valves located inside containment at VEGP must be environmentally qualified are those conditions profiled in Figure 10.5-5. As shown by that figure, the peak tempera-ture of 400*F would have a duration of three minutes. As stated in paragraph 22 of the affidavit of Victor L.

Gonzales, that peak temperature of 400*F includes a margin of more than 20*F. The temperature conditions reflected in Figure 10.5-5 are enveloped by the conditions profiled in Westinghouse's modified generic LOCA/MSLB profile

described above. Therefore, the peak temperature that would be reached by a model NP8316 solenoid valve inside containment at VEGP in the event of a design basis event would not exceed the temperature reached by that valve in the Isomedix test.

V. Other Problems Recently' Encountered With ASCO Solenoid Valves Are Not Applicable to the ASCO Model NP8316 and 206-381-6F Solenoid Valves Used in Safety-Related Functions at VEGP.

35. Subsequent to the issuance of IE Information Notice No. 84-23 in April 1984 concerning the results of the Franklin Research Center testing program, the NRC staff has issued two other IE Information Notices identi-fying potential problems with ASCO, solenoid valves. Those potential problems do not apply to the model NP8316 and 206-381-6F solenoid valves used in safety-related func-tions at VEGP that were supplied by Westinghouse.

36. In IE Information Notice No. 85-08, 'ssued i on

' January 30, 1985, the NRC staff described the following limitation applicable to certain ASCO solenoid valves:

ASCO NP series solenoid valves with resilient seats and Viton elastomers may be considered qualified only for_those applications in which the valves are not required to shift position following exposure to total gamma radiation doses greater than 20 megarads up_to 200 megarads. No qualification ~ data _are available for applications in which the radiation dose exceeds 200 megarads gamma.

None of the model NP8316 and 206-381-6F valves supplied to VEGP by Westinghouse utilize Viton elastomers.

37. On March 1, 1985, the NRC staff released IE Information Notice 85-17, which reported sticking problems encountered with model HTX 8323-20V ASCO solenoid valves at a boiling water reactor. The ASCO HTX series solenoid valves utilize Viton elastomers and have a different material for the solenoid coil from the the model NP8316 and 206-381-6F ASCO solenoid valves supplied by Westinghouse to VEGP. The model HTX 8323-20V valve is not similar to those valves.

VI. Conclusion.

38. Westinghouse has supplieu to VEGP two models of ASCO solenoid valves, model NP8316 and model 206-381-6F, for use in safety-related functions. The model 206-381-6F has-been shown to be qualified for use in the environ-mental conditions to which it might be exposed at VEGP by the joint Westinghouse /ASCO qualification testing program.

In that test program the conditions to which the test valve was exposed exceeded the most severe conditions to which such valves might be subjected at VEGP. The qualification of the model NP8316 valve for use at VEGP has been shown by the same qualification testing program as supplemented by the thermal lag analysis performed by Westinghouse. That analysis *showed that under the most extreme conditions that could be experienced at VEGP, the temperature reached by the model NP8316 valves would not e

exceed the 346*F limit established by the NRC staff based upon the' older Isomedix test program.

39. For these reasons, I am confident tnat the model NP8316 and 206-381-6F ASCO solenoid valves are environmentally qualified for use in safety-related functions at VEGP.

b *% 0 f/

Richard B. Miller Sworn to and subscribed before me this 46 *

' day of h _ , 1985.

1. 6 cWO7h.

Notary Public Ma '

LORRAINE u. pgggggh NOIARY P'sillC MCWfYl!!C 8020. Att(cHINY COUNTY UY COMM!Ul0S f%P!RE: C!C 14 1337 Member. Penas,hania Assceta' son et Not,nes 9

m Flow Diagrams NORMALLY CLOSED DE-ENERG12ED ENF.RG12ED Seierod Soiered Eshaust Cylinder Exhaust Cylinder

• E* A* "A*

n.nor. -r U 1 n.nor. d

-r EIGURE 10.5-1 Flow Diagrams for ASC3 Model NP8316 Valve

l Flow Diagrams NORMALLY CLOSED DE ENERGlZED ENERGl2ED

{, PRESS.

SOL I f PRESS.

(2) (2)

CYL P EXH. CYL J EXH.

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EXHIBIT A

. Summary of Qualifications Richard B. Miller Principal Engineer Nuclear Technology Division Westinghouse Electric Corporation I was graduated from the University of Delaware in 1967 with a Bachelor of Electrical Engineering degree and joined Westinghouse that year in the Field Service Department. After participating in several plant startups, I transferred to the Engineering Department in 1970. Whii: there, I had lead responsibility for the design and procurement of instrumentation systems and sensors, as well as being the interface between Nuclear Safety and Engineering for licensing issues. I am the co-author of WCAP-8587, " Methodology for Qualifying Westinghouse WRD Supplied NSSS Safety Related Electrical Equipment," and several IEEE papers on the qualification of electrical equipment. I am the Secretary of the IEEE sub-committee on electrical equipment qualification (NPEC/SC-2) and am a registered Professional Engineer in the State of Pennsylvania. I have also been very active in establishing instrumentation setpoints consistent with safety analysis limits and plant and instrument characteristics and have co-authorred a report detailing the methodology that is used for determining plant specific setpoints. I am presently the lead engineer in the Nuclear Safety Department responsible for electrical equipment qualification and am the primary interface on this subject with the NRC and Westinghouse customers.

0338G/JCC/6-85

)

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OCE F ETEf In the Matter of  : USNRL GEORGIA POWER COMPANY, et al. :

DOCKET NOS. 50-424 85 AUG -2 P1 :49

50-425 (Vogtle Electric Generating  : G F n t t - K. t i /.

Plant, Units 1 and 2)  : DOCHElgyt9Vt t CERTIFICATE OF SERVICE I hereby certify that copies of the Affidavit of Richard B. Miller, dated July 26, 1985, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, or where indicated ,

by an asterisk (*) by hand delivery, this 30th day of July, 1985.

(

0 .

h*'

nes E. Joine orney for A p icants Dated: July 30, 1985

r

, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION I

Before the Atomic Safety and Licensing Board In the Matter of )

)

GEORGIA POWER COMPANY, et al.

-- -- ) Docket Nos. 50-424

) 50-425 (Vogtle Electric Generating Plant, )

Units 1 and 2) )

SERVICE LIST Morton B. Margulies, Chairman *0ouglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U. S. Nuclear Regulatory Commission Atlanta, Georgia 30306 Washington, D. C. 20555

• Laurie Fowler Mr. Gustave A. Linenberger Legal Environmental Assistance Atomic Safety and Licensing Board Foundation U. S. Nuclear Regulatory Commission 218 Flora Avenue, N. E.

Washington, D. C. 20555 Atlanta, Georgia 30307 Dr. Oscar H. Paris *Tbn Johnson Atomic Safety and Licensing Board Campaign for a Prosperous Georgia U. S. Nuclear Regulatory Commission 175 Trinity Avenue, S. W.

Washington, D. C. 20555 Atlanta, Georgia 30303 Bernard M. Bordenick, Esquire Docketing and Service Section Office of Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C. 20555 Atomic Safety and Licensing Board Panel' Bradley Jones, Esquire U. S. Nuclear Regulatory Commission Regional Counsel Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Suite 3100 Appeal Board Panel 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555