ML20137J463
| ML20137J463 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/26/1985 |
| From: | Bordenick B NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20137J349 | List: |
| References | |
| CON-#385-366 OL, NUDOCS 8508300379 | |
| Download: ML20137J463 (6) | |
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8/26/85 UNITED STATES OF AMERICA 00LKQED NUCLEAR REGULATORY COMMISSION U%%
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'65 AUS 29 P12:00
^
In the Matter of
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$CkO SEVlk ERANCH GEORGIA POWER CO.
Docket Nos. 50-424
--et al.
50-425 (0L)
(Vogtle Electric Generating Plant, Units 1 and 2)
NRC STAFF RESPONSE TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 10.5 (SOLEN 0ID VALVES)
I.
INTRODUCTION.
On July 31, 1985, Applicants filed a Motion for Summary Disposition of Joint Intervenors' Contention 10.5 (" Motion") which alleges that Applicants' environmental qualification testing of solenoid valves is inadequate based upon certain identified test results.
For the reasons presented below and in the attached Affidavit of Armando Masciantonio, the Staff submits that the Motion should be granted.
II.
LEGAL STANDARDS GOVERNING
SUMMARY
DISPOSITION The Staff previously set forth the applicable legal standards governing motions for summary disposition in its July 26, 1985 " Response to Applicants' Motion for Summary Disposition of Contention 10.3 (Cables in Multiconductor Configurations)" (at pp. 1-3).
In order to avoid 8508300379 850826 DR ADOCK O 4
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unnecessary repetition, that discussion is incorporated by reference herein.
III. APPLICANTS' MOTION In its order of September 5,1984, the Board admitted Joint Intervenors' Subcontention 10.5 which " challenges the qualification of solenoid valves at Vogtle... based upon test results performed by ASCO and Franklin Research Center and upon an NRC Board Notification issuance." LBP-84-35,20NRC887,905(1984).1/ For the reasons presented below, this issue does not constitute a problem for the safe operation of the Vogtle facility and, accordingly, the Staff supports Applicants' Motion for Summary Disposition of Contention 10.5.
A.
ASCO Solenoid Valve Qualification Pursuant to 10 CFR 6 50.49, each OL applicant must establish a program for qualifying electric equipment which perform safety functions.
This section contains the specific requirements to satisfy the general requirements for environmental qualification in General Design Criteria (GDC) I and 4 of 10 CFR Part 50, Appendix A, and Sections III, XI and XVII of 10 CFR Part 50, Appendix B.
In Regulatory Guide 1.89, the Staff
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Contention 10.5 was derived from the Applicant's identification of subissues raised in Contention 10. Contention 10, as originally proffered by Jointed Intervenors, alleged that:
l Applicant has not shown that safety-related electrical and mechanical equipment and components will be environmentally
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qualified at the onset of operations and throughout the life of the plant as required by General Design Criteria 1, 2 and 4 of 10 CFR 50, Appendix A and other applicable NRC rules.
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has endorsed IEEE Standard 323-1974, the industry standard, as an acceptable means to demonstrate environmental qualification of equipment. Masciantonio Affidavit at 1 3.
The Vogtle plant uses four models of Automatic Switch Company (ASCO) solenoid valves to perform functions within the scope of 10 CFR 9 50.49.
These solenoid valves are used as control valves for air operated valves.
M. at 11 5, 8.
As indicated in the attached affidavit, the Staff agrees with the Statement of Material Facts appended to Applicants' Motion and concludes that the environmental qualification of each ASCO solenoid valve in use at the plant has been properly established for the respec-tive requirements based on existing documentation. M. at 11 2, 7, 8, 9, 11, and 12.
Specifically,thequestionastotheabflityofASCOsolenoidvalves to perform their safety functions arose as a result of Franklin Research Center (FRC) tests performed under contract to the NRC for the purpose of qualification methodology research. The FRC tests resulted in a number of failures which did not occur in previous qualification tests done by ASCO. The Staff issued Board Notifications (BN 83-128 and BN 85-128A) in1983tokeeptheCommissionersandlicensingboardsapprise(ofthe Staff's investigation of the failures. M. at 14.
Applicants have averred that only ASCO solenoid valve models NP 8316, NP 8320, NP 8321 and 206-381-6F are within the scope of 10 CFR 50.49.
See Applicants' Statement of Material Fact No. 2.
The Staff has concluded that the qualification levels in a 1982 ASCO Test Report (No. AQR-67368/
Rev. 1) exceed the service and accident requirements at the Vogtle plant for each of the above valve models except for NP 8316.
In addition, i
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since the Applicants have averred as a basis for licensing that none of the ASCO valves which use Viton elastomers are used in applications which would require a shift in valve position after exposure to a total gama radiation. greater than 2 -megarads, the Staff concludes that the valves can be considered qualified. Masciantonio Affidavit at 117, 8.
The qualification status of valve model NP 8316 has also been established.
In April 1984, based on the results of the FRC test, the Staff concluded that the failure of two naturally aged valves justified reconsideration of the previous Staff acceptance of the qualification status of ASCO valve model f;P 8316. M.at114,6. Subsequently, the Staff concluded that valve model NP 8316 was nnly qualified to the levels reported in 1979 Isomedix Test Report (No. AQS21678/TR-Rev. A) and was not qualified for the more severe environmental conditions and 30-day operating time claimed by the 1982 ASCO Report and Westinghouse Report.
,Id. at 1 8.
As a result of its review of the FRC test report, the Staff further concluded that tlere are circumstances in which valve model NP 8316 may be considered acceptable for use in environtrental conditions as severe as those listed in the 1982 ASCO test report. The valve may be considered qualified (1) in situations where it is only required ;o operate early into an accident and subsequent failure neither degrades other safety functions nor misleads the operator or (2) in situations where long term valve operation is required and it can be shown through acceptable analysis that the valve temperature does not exceed 340'F.
In each instance, prudent engineering ju:'gment dictates the level of qualifica-tion.
Id. at 1 9.
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A recent Westinghouse topical report (WCAP-8687 Supplement 2-H02A/H05A, Addendum 1, Revision 0, dated January 1985) has provided a means of establishing the environmental qualification of ASCO valve model NP 831G. The report documents an analysis to demonstrate qualification to a derated Westinghouse generic loss-of-coolant accident and main steam line break (LOCA/MSLB) which has a maximum peak temperature of 400"F for approximately three minutes. The predicted maximum temperature of the ASCO NP 8316 solenoid valves installed in plants whose accident environ-ments are enveloped by the derated Westinghouse LOCA/MSLB is less than 345 F.
_Id. at 1 10.
The Staff has reviewed the Westinghousc report and concludes that the approach used to generate the derated Westinghouse generic LOCA/MSLB temperature profile is reasonable and consistent with prudent engineer-ing judgment, and is acceptable as a means of establishing the environ-mental qualification of ASCO valve model NP 8316. The derated Westing-house generic temperature profile envelops the Staff accepted accident profile for the Vogtle plant with considerable margin. Thus, the report is an acceptable means for establishing the er.vironmental qualification of ASCO valve model NP 8316'.
I_d. at 1 11.
In sum, the Staff concludes that the Applicants have demonstrated, through testing, that each of the ASCO solenoid valves at the Vogtle power plant is environmentally qualified in accordance with GDC 1 and 4 of 10 CFR Part 50, Appendix A, Sections III, XI, and XVII of 10 CFR Part 50, Appendix B, and 10 CFR 50.49.,I_d. at 1 12.
III. CONCLUSION For th~e reasons stated above, the Staff submits that Applicants' Motion for Sumary Disposition of Contention 10.5 should be granted.
Respectfully submitted, M
FM ernard M. Bordenick Counsel for NRC Staff i
Dated at Bethesda, Maryland this 26th day of August, 1985 e
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