ML20137J508
| ML20137J508 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/26/1985 |
| From: | Masciantonio A Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20137J349 | List: |
| References | |
| OL, NUDOCS 8508300389 | |
| Download: ML20137J508 (10) | |
Text
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UNITED STATES OF AMERICA DE'KETED NUCLEAR REGULATORY COMMISSION umc BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'85 IG 29 P12:00 In the Matter of
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NkTb'N
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Sus:a GEORGIA POWER CO.
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Docket Nos. 50-424
--et al.
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50-425
)
(0L)
(Vogtle Electric Generating Plant, )
Units 1 and 2)
)
AFFIDAVIT OF ARMAND0 S. MASCIANTONIO IN SUPPORT OF NRC STAFF RESPONSE TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF JOINT INTERVENORS' CONTENTION 10.5 (ASCO SOLEN 0ID VALVES) s I, Armando S. Masciantonio, being duly sworn, state the following:
1.
I am employed by the U.S. Nuclear Regulatory Commission as an Equipment Qualification Engineer in the Equipment Qualification Branch, Division of Engineering, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission.
I am responsible for the technical reviews, analyses and evaluations of the adequacy of the environmental qualification of electric equipment important to safety and safety-related mechanical equipment whose failure under postulated environ-mental conditions could adversely affect the performance of safety systems in nuclear power plants.
Before joining the NRC I was employed as an engineer by Vitro Laboratories Division of Automation Industries, Inc.
I was responsible for the environmental and seismic qualification of the safety-related electronic control equipment supplied by Vitro Laboratories Division.
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Specifically, my duties were to develop and write the environmental and seismic quS11fication test plans, procedures and reports and oversee the test and procurement activities in support of qualification.
Prior _ to that, I was. employed at the U.S. Naval Surface Weapons
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Center as a mechanical engineer. My duties involved support of the development, test and evaluation of advanced naval weapons.
I have a B.S. degree in Mechanical Engineering (1972) from Drexel University, Philadelphia, Pennsylvania and a Masters degree in Mechanical Engineering (1976) from the Catholic University of America, Washington, D.C.
I also hold a Masters degree in Administrative Science (1980) from the Johns Hopkins University, Baltimore, Maryland.
I have knowledge of the matters set forth herein and believe them to be true and correct.
2.
The purpose of this affidavit is to respond to Applicants' Motion for Summary Disposition of Joint Intervenors' Contention 10.5 (ASCO Solenoid Valves), dated July 31, 1985 [ Applicants' Motion], and Applicants' Statement of Material Facts regarding Contention 10.5, dated July 31, 1985, which is appended to Applicants' Motion.
I have reviewed the Applicants' Motion and pplicants' Statement of Material Facts and have no disagreements with the Applicants' statements.
3.
The general requirements for environmental qualification are stated in General Design Criteria (GDC) 1 and 4 of Appendix A and Sections III, XI, and XVII of Appendix B to 10 CFR 50. Specific requirements for environmental qualification of electric equipment important to safety are stated in 10 CFR 50.49, " Environmental Quali-fication of Electric Equipment Important to Safety for Nuclear Power
Plants."
Regul'a' tory Guide 1.89, Rev. 1, provides a method acceptable to the f!RC staff for complying with 10 CFR 50.49. This Regulatory Guide endorses IEEE Standard 323-1974, "IEEE Standard for Qualifying Class 1E Equipment for Nuclear Power Generating Stations," the industry standard used to demonstrate environmental qualification of equipment. Additional guidance is found in NUREG-0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment."
4.
Contention 10.5 challenges the qualification of Automatic Switch Company (ASCO) solenoid valves used at Vogtle based upon failures of the valves during tests performed by the Franklin Research Center (FRC) and the subsequent issuance of NRC Board notifications (BN 83-128, August 31, 1983, and BN 83,-128A, October 6, 1983).
The Board notifications were issued to inform the Commissioners and licensing i
boards about the Staff's investigation of the reported test failures encountered in FRC testing completed in 1983. The FRC tests resulted in a number of failures which had not been experienced in previous quali-fication tests performed by the manufacturer. Based on the results of the FRC test, the NRC Staff concluded in April 1984 that the failure of two naturally aged valves justified the reconsideration of the previous Staft acceptance of the qualification status of ASCO valve model NP 8316.
IE Information Notice 84-23, "Results of NRC-Sponsored Qualification Methodology Research Test on ASCO Solenoid Valves" (attached).
5.
ASCO solenoid valves are generally used in safety related applications as control valves for air operated valves.
By controlling the flow of air to air operators, ASCO solenoid valves will cause t
process valves to either open or close. These valves are generally foundbroughouttheplant,bothinsideandoutsidecontainment.
6.
The NRC Staff has reviewed the qualification reports pertaining to ASCO so.lenoid valves,'specifically:
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(a)
Isomedix Test Report No. AQS21678/TR-Rev A " Qualification Tests of Solenoid Valves" March,1978, Revision A. July 1979.
(b) ASCO Test Report No. AQR-67368/ Revision 1, " Report on Qualification of ASCO Catalog NP-1 Solenoid Valves for Safety-Related Applications in Nuclear Power Generating Stations," March 2, 1982.
(c)- Westinghouse. Topical Report WCAP-8587, Revision 6 (NP)
" Methodology for Qualifying Westinghouse WRD Supplied NSSS Safety Related Electrical Equipment," WCAP-8587 EQDP-HE2/HE5, and WCAP.-8687 EQTR-H02A/H05A, all_ dated March, 1983.
(d) NUREG/CR-3424, " Equipment. Qualification Research Test Program and Failure Analysis of Class IE Solenoid Valves" prepared by Franklin Research Center, November 1983.
Qualification tests (a) were conducted by Isomedix, Inc., for ASCO and established the qualification of ASCO valves to the current 1978 IEEE standards. Tests (b) and (c) above were conducted by ASC0/ Westinghouse to qualify ASCO valves to a higher level and tests (d) were performed by FRC under contract to the NRC for the purpose of qualification methodology research.
7.
Based on a review of the above reports listed in paragraph 6, the NRC Staff reached the following conclusions, which were stated in IE Information Notice 85-08, " Industry Experience on Certain Materials
Used in Safety-Related Equipment," January 30, 1985, regarding the
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environinen'tal qualification of ASCO solenoid valves:
(a) 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 megrads. No qualification data are available for applications in which the radiation dose exceeds 200 megarads gamma.
(b) Except for model NP 8316 with Ethylene Propylene elastomers (Suffix "E"), ASCO NP series solenoid valves are considered qualified to the extent and levels reported in Table 5.1, pages 59 and 60 of ASCO Test Report No. %QR-67368/Pev.1,
" Report on Qualification of Automatic Switch Co. (ASCO) Catalog NP-1 Solenoid Valves for Safety-Related Applications in Nuclear Power Generating Stations " dated March 2, 1982.
8.
The Applicants have stated that the only ASCO solenoid valves used in the Vogtle plant which fall within the scope of 10 CFR 50.49 are model numbers NP 8316, NP 8320, NP 8321, and 206-381-6F. Applicants' Statement of Material Fact No. 2.
They have also stated that of those ASCO valves which use Viton elastomers, none are used in applications which would require a shift in valve position after exposure to a total gamma radiation dose greater than 20 megarads. Affidavit of Victor L.
l Gonzales at 1 31.
The qualification levels demonstrated in ASCO Test Report i
No. AQR-67368/Rev. 1 exceed the service and accident requirements at
the Vogtle plant for ASCO valve models NP 8320, NP 8321 and 206-381-6F.
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Thus, the' Staff can conclude that these models have been environmentally qualified.
The Staff also indicated in IE Information Notice No. 84-23 that ASCO valve model NP 8316 with Ethylene Propylene elastomers is not considered qualified for the environmental conditions and the 30-day operating time claimed by ASCO report AQR-67368/Rev. I and Westinghouse Report WCAP 8587 EQDP-HE2/HES. This valve is considered qualified to the less severe levels reported in Isomedix Test Report No. AQS 21678/TR, Revision A.
9.
Based on a review of NUREG/CR-3424, the staff has recently concluded that there are circumstances in which valve model NP 8316 might
, be considered acceptable for use in environmental conditions as severe as those listed in ASCO report AQR-67368/Rev. 1.
These include situations in which the valve is only required to operate early into an accident, as in the case of isolation valve applications, and subsequent failure does not degrade other safety functions nor mislead the operator. Under these circumstances, report AQR 67368/Rev. I will be an acceptable qualifica-tion document for valve model NP 8316. Similarly, for applications in which the valve is required for long term operation, if it can be shown by analysis in accordance with NUREG-0588 that the temperature of the valve does not exceed 340*F, the valve can be considered qualified by Isomedix AQS 21678/TR-Rev. A, even though it is exposed to a more severe temperature. Prudent engineering judgment will dictate the level to which ASCO solenoid valve model NP 8316 can be considered qualified.
- 10. Westinghouse has provided a method of addressing the environ-
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mental qualification of ASCO valve model NP 8316 in topical report WCAP-8687," Supplement 2 - H02A/H05A, Addendum 1, Revision 0, dated January'1985. This report documents the analyses which demonstrate qualificat, ion to a derated Westinghouse generic loss-of-coolant acci-dent / main steam line break (LOCA/MSLB) temperature profile which has a maximum peak temperature of 400'F for approximately three minutes.
The derated Westinghouse generic profile is based on a heat transfer model developed by using the actual thermocouple data and test environmental parameters from the FRC test. The model predicts the temperature response of an ASCO solenoid valve exposed to a LOCA/MSLB.
Westinghouse concludes that the maximum temperature of ASCO NP 8316 solenoid valves installed in plants whose accident environments are enveloped by the derated Westinghouse LOCA/M3LB profile will be less than 345'F and the model NP 8316 is therefore qualified by Isomedix Report No. AQS 21678/Tr-Revision A.
- 11. The staff has reviewed the information provided in WCAP-8687, Supplement 2 - H02A/H05A, Addendum 2, Revision 0 and finds that the approach used to generate the derated Westinghouse generic LOCA/MSLB profile is reasonable and consistent with prudent engineering judgment, and is acceptable as a means of establishing the environmental qualifi-cation of ASCO valve model NP 8316. The derated Westinghouse generic LOCA/MSLB temperature profile envelops the Staff accepted accident profile for the Vogtle power plant with considerable margin. The Staff is confident that, with the available margin, the temperature of this valve will not exceed 340"F.
- 12. To summarize, as detailed in paragraphs 7, 8, 9 and 11 above,
the Staff concludes that the Applicants have adequately demonstrated, through testing, that each of the ASCO solenoid valves at the Vogtle i
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.
ls S * & b Armando 5. Masciantonio Subscribed and sworn to before me this R4'n day of August,1985.
$fd A >Ykhek Notary Public My commission expires:
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s UNITED STATES OF AMERICA c
NUCLEAR REGULATORY COMMISSION i.[ig
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
'85 AljG 29 PI2:00
@ g,
L y g(p g j
In the Matter of GEORGIA POWER COMPANY,
)
Docket Nos. 50-424
.et al.
)
50-425
)
(0L)
(Vogtle Electric Generating Plant, )
Units 1 and 2)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF RESPONSE TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF CONTENTION 10.5 (SOLEN 0ID VALVES)" and Supporting Documents in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 26th day of August, 1985.
Morton B. Margulies, Esq., Chairman
- Mr. Gustave A. Linenberger, Jr.*
Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Oscar H. Paris
- Bradley Jones, Esq.
l Administrative Judge Region 1 Counsel Atomic Safety and Licensing-Board U.S. Nuclear Regulatory Commission i
Panel Suite 3I00 U.S. Nuclear Regulatory Commission 101 Marietta Street l
Washington, D.C.
20555 Atlanta, GA 30303 Bruce W. Churchill, Esq.
Douglas C. Teper David R. Lewis, Esq.
1253 Lenox Circle Shaw, Pittman, Potts & Trowbridge Atlanta, GA 30306 i
1800 M Street, N.W.
Washington, D.C.
20036 l
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Atomic Saf.e.ty and Licensing Laurie Fowler, Esq.
Board Panel
- 218 Flora Ave. NE U.S. Nuclear Regulatory Commission Atlanta, GA 30307 Washington, D.C.
20555 Office of the Secretary ~
Atomic Safety and Licensing Docketing and Service Soction*
Appeal Board Panel
- U.S. Nuclear Regulartory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 James E. Joiner, Esq.
Ruble A. Thomas Troutman, Sanders, Lockerman, Southern Company Services, Inc.
& Ashmore P.O. Box 2625 127 Peachtree Street, N.E.
Birmingham, AL 35202 Candler Building, Suite 1400 Atlanta, GA 30043 Tim Johnson Executive Director Campaign for a Prosperous Georgia 175 Trinity Avenue, S.W.
Atlanta, GA 30303 l'A
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Bernard M. Bordehick Counsel for NRC Staff i
i s