ML20136F559
| ML20136F559 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Vogtle |
| Issue date: | 12/03/1984 |
| From: | Johnston W Office of Nuclear Reactor Regulation |
| To: | Novak T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML082840446 | List:
|
| References | |
| FOIA-84-663 NUDOCS 8412100064 | |
| Download: ML20136F559 (9) | |
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o UNITED STATES g
NUCLEAR REGULATORY COMMISSION 2
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DEC 0 31984 Docket Nos.
50-424/425 MEMORANDUM FOR:
Thomas M. Novak, Assistant Director for Licensing Division of Licensing FROM:
William V. Johnston,' Assistant Director Materials, Chemical & Environmental Technology Division of Engineering
SUBJECT:
V0GTLE ELECTRIC GENERATING PLANT UNITS 1 AND 2 -
ELIMINATION OF LARGE PRIMARY LOOP PIPE RUPTURES By letter E. P. Rahe, Jr. to Darrell E. Eisenhut dated November 15, 1984, Westinghouse has agreed to permit the NRC staff to release certain information considered by Westinghouse to'be proprietary.
Thus, we are now able to identify specific information utilized by the' Materials -
Engineering Branch to reach the conclusions stated in our previous memorandum to you on this subject dated August 20, 1984.
Attached is a revised version of the STAFF EVALUATION AND CONCLUSIONS (pages 9,10, and 11) of our previous Safety Evaluation.
Please sub-stitute them for the original pages before preparing the exemption document for the Vogtle facility.
W & Y-William V. Johnst n, Assistant Director-Materials, Chemical & Environmental Technology Division of Engineering
Attachment:
As stated cc:
See Pagt 2
Contact:
K. Wichman X-24679 A
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i DEC 0 31984 Thomas M. Novak 2-4 cc:
R. Vollmer D. Eisenhut
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J. P. Knight
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Adensam B. D. Liaw R. Bosnak E. Sullivan S. Pawlicki 1
M. Miller K. Jabbour R. Klecker W. Hazelton C. Y. Cheng K. Wichman I
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STAFF EVALUATION AND CONCLUSIONS-Based on its evaluation of the analysis contained in Westinghouse Report WCAP-10551 (Reference 3), the staff finds that the applicant has presented an acceptable technical justification, addressing the above criteria, for not installing protective devices to deal with the dynamic effects of large pipe ruptures in the main loop primary coolant system piping of Vogtle, Units 1 and 2.
This finding is predicated on the fact that each of the parameters evaluated for
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Vogtle is enveloped by the generic analysis performed by Westinghouse in Reference 5, and accepted by the staff in Enclosure 1 to Reference 4.
Specifically:
(1) The loads associated with the highest stressed location in the main loop primary system piping are 1,962 kips (axial), 28,810 in-kips
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(bending moment) and result in maximum stresses of about 75% of the bounding stress used by Westinghouse in Reference 5.
- Further, these loads are approximately 70% of those established by the staff as limits (e.g., a moment of 42,000 in-kips in Enclosure 1 to Reference 4).
(2) For Westinghouse plants, there is no history of cracking failure in reactor primary c~oolant system loop piping.
The Westinghouse reactor coolant system primary loop has an operating history which demonstrates its inherent stability.
This includes a
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. low susceptibility to cracking failure from the effects of,' corrosion (e.g., intergranular stress corrosion cracking), water hammer, or fatigue (low and high cycle).
This operating history totals over 400 reactor years, including five (5) plants each having 15 yec.rs of operation and 15 other plants with over 10 years of operation.
(3) The leak rate calculations performed for Vogtle, using an initial through-wall crack of 7.5 inches are identical to those of to Reference 4.
The Vogtle plant has an RCS pressure
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boundary leak detection system which is consistent with the guide-lines of Regulatory Guide 1.45, and it can detect leakage of one (1) gpm in one hour. The calculated leak rate through the postulated flaw results in a factor of at least 10 relative to the sensitivity of the Vogtle plant leak detection system.
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(4) The margin in terms of load based on fracture mechanics analyses for the leakage-size crack under normal plus SSE loads is within the bounds calculated by the staff in Section 4.2.3 of Enclosure 1 to Reference 4.
Based on a limit-load analysis, the load margin is about 2.9 and based on the J limit discussed in (6) below, the margin is at least 1.5.
(5) The margin between the leakage-size crack and the critical-size crack was calcuhted by a limit load analysis.
Again, the results demonstrated that a margin of at least 3 on crack size exists and is within the bounds of Section 4.2.3 of Enclosure 1 to Reference 4.
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. (6) As an integral part of its review, the staff's evaluation of the material properties data of Reference 9 is enclosed as A'ppendix I to this Safety Evaluation Report.
In Reference 9, data for ten (10) plants, including the Vogtle Units, are presented, and lower bound or " worst case" materials properties were identified and used in the analysis performed in the Reference 3 report by Westinghouse.
2 The applied J for Vogtle in Reference 3 was less than 3000 in-lb/in and h~ence the staff's upper bound on the applied J (refer to Appendix I, page 6) was not exceeded.
In view-of the analytical results presented in Reference 3 and the staff's i
evaluation findings related above, the staff concludes that the probability or likelihood of large pipe breaks occurring in the primary coolant system loop of Vogtle Units 1 and 2 is sufficiently low such that protective devices associated with postulated pipe breaks at the eight (8) loca-tions per loop in Vogtle Units 1 and 2 primary coolant system (as specified in the applicant's letter of April 2, 1984 which forwarded their safety balance report need not be installed.
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1 ROUTING'AND TRANSEITTA!. SLIP
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TO: (Name, ottice symbol, room number, initials Date building, Agency / Post) 1
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For Clearance Per Conversation As Regt.ested
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For Correction Prepare Reply Circulate l
l Fer Your Information See Me bomment investigate S!gnature lCoordir:ation Justify RF. MARY.S lbYs g
21 1 yg 46//NYMa$kWA AdAUSy 6-Mdf n V DO NOT use this form as a RECORD of approvafs, concurrences, disposals, clearances, and similar actions FROM:(Na)me,br,g mbol. Agency / Post)
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OPTIONAL FORM 41 (Rev. 7-76) l so41-102
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n Status of Emergency Preparedness Licensing Review For Vogtle Electric Genarating' Plant, Waynesboro, Ga.
t Emergency Plan submitted by Georgia Power on 8/31/83 - has not been reviewed.
Provided General Design Plan for Emergency Response Facilities as part of the FSAR.
State and Local Government Emergency Plans for the Vogtle Site have not i
been received.
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10 Mile EPZ Covers:
States -
Georgia South Carolina Counties Burke Aiken Barnwell Allendale Georgia has received a 44 CFR 350 approval from FEMA for Hatch South Carolina has received a 44 CFR 350 approval for Oconee, Robinson and Summer l'
Date for the FEMA Finding has not been established:
i Usually 5 months prior to hearing i
l If no hearing 3 months prior to Commission Decision for i
Full-Power i
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=.:x Emergency Preparedness Appraisal date has not been established.
Usually 3 months prior to the start of Low-Power Operation Emergency Response Facilities Appraisal is not necessary for licensing if,, Interim Facilities are provided.
If Final Facilities will be com-pleted pri3r to Fuel Load (Vogtle say they will be completed) then ERF i
I-Appraisal will take place at that time.
EP Full Scale Exercise'has not be scheduled.
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Must be held within l yr. before Full-Power License is issued and prior to Operation at>5% of Full-Power.
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UNITED STATES 8
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DEC 2 71984 Docket Nos. 50-424 and 50-425 MEMORANDUM FOR: Thomas M. Novak, Assistant Dircctor
. for Licensing Division of Licensing Office of Nuclear Reactor Regulation FROM:
J. Nelson Grace, Director Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement
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SUBJECT:
.QA BRANCH SER INPUT FOR'V0GTLE In accordance with the guidance provided in your memorandum of December 12, 1984, the QA Branch has reviewed the draft SER for Vogtle enclosed with that memorandum. We are providing a neat markup of section 17 of the DSER to the project manager. A copy is enclosed for your information.
Any questions on the enclosure should be addressed to the QA Branch reviewer, Jack Spraul, en ext. 24530.
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J. N(1 son Grace, Director Dividion of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement
Enclosure:
Markup of Section 17 cc w/ enclosure:
G. W. Knighton M. Miller
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17 QUALITY ASSURANCE 17.1 General The description of the quality assurance. ( g g for the operations phase of the Vogtle Electric Generating Plant 1s contained in Section 17.2 of the 3
Final Safety Analysis Report (FSAR). The staff evaluated this QA program through FSAR Amendment 9 on the basis of a review of this information and discussions with the applicant.
The staff assessed the applicant's QA program for the operations phase to determine if it complies with the requirements of 10 CFR Part 50, Appendix B, " Quality Assurance Criteria for Nuclear Power PlantsandFuelReprocessingPlantsktheapplicableQArelatedfegulatory guideslistedinTable17.1;andtheStandardReviewPlan(SRP) Section 17.2, Rev]1," Qual.ityAssuranceDuringtheOperationsPhase."
9 17.2 Organization U
The structure of the organization reponsible for the operation of Vogtle and for the establishment and execution of the operations phase QA program is shown in Figure 17.1.
The Executive Vice President - Power Supply is responsible for establishing the policies, goals, and objectives of the applicant's QA program for Vogtle.
This individual is the final management authority responsible for developing, implementing, changing, and reviewing the operations QA program.
The Senior Vice President - Nuclear Power and the Vice President and General l
Manager - Nuclear Operations are responsible to the Executive Vice President -
l Power Supply for implementing the QA program for plant operations at all nuclear power generating plants in the applicant's system. The General Manager -
Vogtle Nuclear Operations reports to the Vice President and General Manager -
Nuclear Operations through the Manager - Nuclear Operations.
10/12/84 17-1 V0GTLE DSER SEC 17 p,. -.-.
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4 The Vice President and Chief Engineer - Power Supply Engineering and Services is responsible for providing engineering and technical support to the various power supply organizations.
During Vogtle operation, this person is responsible for managing design engineering support, ascertaining that the.puppliers are j
qualified, and reviewing procurement documents for quality requirements.
TheGeneralManagerofQuality'AssuranceandRadiologicalHealthan[fSafety
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(GMQA), located at the general office, is responsible to the Executive Vice President - Power Supply for assuring implementation of the operational QA I
program and for managing activities of the applicant's QA organization.
The GMQA has a staff at the general office and a staff located at the Vogtle site to conduct QA activities. The GMQA keeps the applicant's management personnel informed about the effectiveness and implementation of the operational QA program.
The Vogtle QA Manager reports to the GMQA and is responsible for ensuring that all participants implement the operational QA program for Vogtle.
The Vogtle QA Manager ensures that-Vogtle plant managers establish and maintain satis-factory QA programs and that activities at the site conform to those QA programs.
2 This individual ensures that contractors (e.g., Southern Company Services, Bechtel Power Corporation) and suppliers of safety-related materials, equipment, and services establish and maintain satisfactory QA programs. The Vogtle QA Manager maintains and controls Vogtle's QA Manual.
Southern Company Services (SCS) is the architect / engineer for Vogtle during operation.
In addition,t m asSCS provides QA support; this sup*oort includes per-M surnit o
r eadi as forming audits and reviewing engineering proceduras and,the qua'lifications of j
suppliers.
SCS also administers the Vogtle contract for engineering services provided by Bechtel.
Activities within the SCS work scope are governed by SCS policy and procedures manuals which are reviewed and concurred with by.the SCS QA organization. The GMQA performs or initiates audits of these functions.
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Bechtel.is under contract to SCS to provide architect / engineering services.
l The' work scope includes plant d'esign, development of purchase recommendations for equipment and materials, administration of purchase orders resulting from-10/12/84 17-3 V0GTLE DSER SEC 17
test, and operating status of items; (12) identifying and dispositioning nonconforming items; (13) correcting conditions adverse to quality; (14) preparing and maintaining QA records; and (15) auditing activities that affect quality.
The QA program requires the establishment and continuous imple~ mentation of the QA indoctrination, training, and retraining program to ensure that persons involved in safety related activities are knowledgeable in QA instructions and implementing procedures and demonstrate a high level of competence and skill in the performance of their quality-related activities.
Quality is verified.through surveillance, inspection, testing, checking, and auditing of work activities using procedures, instructions, and/or checklists.
Inspections are performed by inspectors who have been qualified and certified in accordance with codes, standards, or company training programs.
The GMQA is responsible for establishing and implementing the audit program.
Qualified personnel not having direct responsibility in the areas being audited 9
use written procedures and checklists to perform the audits.
The QA program
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establishes a comprehensive audit system to ensure that the QA program require-ments and related supporting procedures are effective and properly implemented during operations. Audits include an objective evaluation of (1) QA practices, procedures, and instructions; (2) work areas, activities, processes, and items; (3) the effectiveness of implementation of the QA program; and E
(4) conformance with policy directives.
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- b'Y Y'C"lb' A The QA program requires that managers who bear resp'onsibility in the area g
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corrective action that is required.
Reaudits determine if nonconformances refe.aled have been effectively corrected and if the corrgivegiogg# gludes,( e, _-ted nonconformances.
The GMQA reviews audit finding 3/which indicate ;=1S.i yea / l/
4aeade-end the effectiveness of the QA programpand reports these findings [to the Executive Vice President - Power Supply on a regular basis.
10/12/84 17-5 V0GTLE DSER SEC 17
(b) Clarification 5 (page 1.9-29) and exception 2 (page 1.9-32) to RG 1.33 both reference paragraph 3.4.2 of ANSI 18.7.
The clarifi-cation refers to the Technical Specifications and the exception refers to FSAR Chapter 13.
In both cases the app 11 dant should identify anything in paragraph 3.4.2 to which it is,not committing itself.
(c) Clarification 16 (page 1.9-30) to'RG 1.33 deletes words from the first sentence in the second paragraph of part 5.2.7 of ANSI 18.7.
The clarification should not delete the words "which conform to applicable codes, standards, specifications, and criteria" that describe t.he written procedures.
(d) Clarification 24 (page 1.9-31) to RG 1.33 substitutes "an equivalent" for "the same" in paragraph 5.2.13.1 of ANSI 18.7.
The applicant should identify who (i.e., by position title) determines equivalency.
(e) Clarification 24 (page 1.9-31) and exception 3 (page 1.9-33) to RG 1.33 are identical.
They delete the guidance in paragraph 5.2.15 L
of ANSI 18.7 to review applicable procedures following an unusual incident unless it is an accident, unexpected transient, significant operator error, or equipment malfunction which results in a report-able event.
The clarification should be eliminated and the exception should be deleted or justified.
(f) Clarification 28 (page 1.9-32) to RG 1.33 refers to clarification 18 (page 1.9-31).
Reference should have been made to clarification 19.
Also, the applicant should identify anything in part 5.2.19(3) of ANSI 18.7 to which it has not comitted.
(g) Clarification 2 (page 1.9-37) to RG 1.3B states that " equipment used to measure secondary conditions, such as warehouse temperature, humidity, etc., will...not be maintained under the calibration and control program."
Doeshumidity,etc.pertainonlygtggwa s
or to other parts of the plant? The applicant should justify t s position.
10/26/84 17-7 VOTGl.E DSER SEC 17 g,
41 ANSI N45.2.3 is not included as part of RG 1.39; therefore, this position should be deleted or justified.
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position states, " Refer to Chapter 17 for further dficussion," and this statement should be deleted or made more specif.jc so that its acceptability can be ascertained.
e (o) Clarification 1 (page 1.9-51) of~RG 1.58 refers to "other FSAR requirements." This reference should be deleted or made more specific so that its acceptability can be ascertained.
(p) Clarification 3 (page 1.9-51) of RG 1.58 exempts inspectors, examiners, and testing personnel (except NCE* personnel) from the 3-level classification portion of ANSI N45.2.6 with no justification or alternative. The applicant should provide one or the other, or..,..
delete the clarification.
(q) Clarification 4 (page 1.9-51) of RG 1.58 addresses qualification of G
inspectors.
The applicant should commit to verify that the training V
and experience of inspection, examination, and testing personnel will ensure their ability to perform the assigned work.
(r) The applicant's position (page 1.9-57) on RG 1.64 states that the
" operations QAP conforms with the intent" of the guide.
The words "the intent" should be deleted or clarified.
(s) The applicant's position (pages 1.9-71 and 1.9-74) on RGs 1.88 and 1.94, respectively, should be clarified to show the applicant's commitment to comply with the guides during the operations phase.
The commitments are not clear.
(t) Clarification 3 (page 1.9-92)of RG 1.123 refers to "an equivalent level" of review and approval of changes to procurement documents.
- nondestructive examination 10/12/84 17-9 V0GTLE DSER SEC 17
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affected presumes the supplier has knowledge of end-use information which he may not have.
The definitions at the bottom of page 1.9-96 require inspection and/or test regarding end use, but it is not clear that the supplier will have the required information.
The applicant should clarify how it ensures the supplier has sucti information.
(z) Clarification 17 (page 1.9-96) of RG 1.123 is not clear when it commits to conformance to paragra'ph 10.2 of ANSI N45.2.13 "to the extent that the certificate of compliance is traceable to the purchase order." Paragraph 10.2 addresses certificates of confor-mance which are not addressed elsewhere in the standard, and the second sentence in the clarification is also not clear. The applicant should explain the clarification.
(aa) The applicant's position relative to RG 1.144 (page 1.9-110).in.dicates conformance to draft 11, revision 0, of ANSI N45.2.9-1973.
This conflicts with the commitment to Revision 2 of RG 1.88 (page 1.9-71) as noted in item S above.
The applicant's position should show a comitment to ANSI N45.2.9-1974.
(bb) Table 17.2 shows where the applicant has committed in FSAR Section 1.9 to do something else rather than follow the specific NRC guidance (RG)/ ANSI standard.
In each case the applicant should
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identify anything in the specific NRC guidance / ANSI standard not being committed to that is not included in the commitment to something else.
(2) The response to NRC Questions 260.61 and 260.62 regarding the items controlled by the applicant's QA program was, provided in FSAR Amendments 8 and 9, respectively. The staff review of the response has resulted in the following items which require a commitment from the applicant that the pertinent provisions of its operational QA program will be applied during the operations phase.
O 10/12/84 17-11 V0GTLE DSER SEC 17
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Table 17.2 Applicant's alternate commitments No commit-FSAR ment to RG/ ANSI Std.
pg/ item paragraph Commitment,instead to 1.30/N45.2.4 1.9-26/1 2.2 Appropriate FSAR section 1.33/N18.7 1.9-29/6 4.1 Technical Specifications 1.33/N18.7 1.9-29/7 4.3.1 Technical Specifications 1.33/N18.7 1.9-29/8 4.3.4 Technical Specifications 1.33/N18.7 1.9-29/9 4.4 Technical Specifications 1.33/N18.7 1.9-29/10 4.5 Technical Spec'ifications, FSAR Section 17.2, and RG 1.144 1.33/N18.7
' 1.9-29/12 5.2.2 Technical Specifications 1.33/N18.7 1.9-29/13 5.2.6 FSAR Section 17.2 1.33/N18.7 1.9-31/19 5.2.8 Technical Specifications
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1.33/N18.7 1.9-32/27 5.2.18 FSAR Section 17.2 and RGs 1.37, 1.39, and 1.54 1.33/N18.7 1.9-32/29 5.2.19.1 FSAR Sections 17.2 and 14.2 and
-mg RGs 1.30, 1.58, 1.94, and 1.116
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1.33/N18.7 1.9-32/30 5.38 Technical Specifications 1.33/N18.7 1.9-32/32 5.2.10 FSAR Section 17.2 1.37/N45.2.1 1.9-35/1
- 2. 5 FSAR Section 17.2 1.37/N45.2.1 1.9-35/3 9
RG 1.88 1.38/N45.2.2 1.9-37/1 2.3 FSAR Section 17.2 1.116/N45.2.8
- 1. 9-86/1 4.4 FSAR Section 17.2 1.123/N45.2.13 1.9-S2/6 3.4 FSAR Section 17.2 1.123/N45.2.13 1.9-95/12 6.4 The Operations QAP 1.123/N45.2.13 1.9-95/13 7.4 FSAR Section 17.2 1.123/N45.2.13 1.9-95/14
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10/26/84 17-15 V0TGLE DSER SEC 17 8
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