ML20141N100

Documents History of Use of Test Vs Analysis for Qualification of Equipment Under Site Qualification Review Team & Pvort Programs.Results of 860128-29 Pvort Audit Will Be Discussed in Forthcoming Meeting Summary

ML20141N100
Person / Time
Site:	Clinton
Issue date:	02/25/1986
From:	Siegel B Office of Nuclear Reactor Regulation
To:	Butler W Office of Nuclear Reactor Regulation
References
NUDOCS 8603030571
Download: ML20141N100 (4)

Text

. . - - - - . . .

,u, , . . . .

. .~ ~ .. . -

UNITED STATES

- g NUCLEAR _ REGULATORY COMMISSION

.'3 :j WASHINGTON, D. C. 20566

\*****/ FIB 251986

, MEMORANDUM FOR: W. R. Butler, Director BWR Project Directorate No. 4 Division of BWR Licensing.

i FROM: Byron Siegel, Project Manager

! Project Directorate No. 4  !

! Division of BWR Licensing i

SUBJECT:

USE OF TEST VS ANALYSIS FOR THE QUALIFICATION OF EQUIPMENT j UNDER THE SQRT AND PVORT PROGRAMS FOR CLINTON POWER STATION i

l The purpose of this memorandum is to document the history of these prograins

! with regard to the subject concern since the initial SQRT and.PVORT. audits  ;

i were performed between August 27-30, 1985. Although several meetings and i audits have occurred since this concern was initially identified the. applicant has not been able to resolve the issue to the staff's-satisfaction. The problem -

I believe has been primarily the result of the lack of a clear understanding 'i

between the staff and the applicant regarding the requirements to satisfy the test versus analysis concern to demonstrate operability identified by the staff.

j During the SQRT and PVORT audits the staff (J. Lombardo and A. Lee) and .its i' consultants from BNL (B. Miller and K. Bandyopadyay) identified a concern related to the generic qualification for active valves._Specifically the staff l and BNL were primarily concerned over the lack of test data and the applicant's

! (Illinois Power Company) apparent dependence primarily on analysis for valve

qualification. During the SQRT audit the staff clearly identified to the-

applicant that qualification of active valves was an open issue and would only be resolved by providing more pertinent test data. The IP s_taff and the ,

IP engineering manager acknowledged the mistake and agreed that every effort including performing more tests would be taken to meet the. staff's licensing criteria. In addition during the audit B. Miller of BNL held a seminar to inform the applicant how the staff's requirements for operability qualification j relating to test vs analysis could be satisfied. The staff and BNL were ,

under the impression, based on comments received from the applicant's staff,  !

that an approach similar to that presented by BNL during the seminar would be~

j util.ized by IP to address the staff's concern. Apparently, the statements or commitments made by the applicant's staff had not been approved by its management.-

i .

l The concern related to test vs analysis was discussed again_during a meeting l held an Bethesda on October 21, 1985 to discuss IP's PVORT recovery program.

A second PVORT audit was required because the result of'the first audit were unacceptable. During that meeting the staff agreed in principle on the l,

b A

approach that IP was using to qualify active valves. However the staff reiterated that while it agreed in principle with the approach, the application of the program to specific valves would have to be reviewed to determine its acceptability. During and after the meeting the staff wu assured that supporting data for all active valves would be forth coming to substantiate the general approach presented at the meeting for a specific type of valve.

The week of November 18, 1985 a second PV0RT audit was held and at the exit interview the test vs analysis issue was identified as one of several open items.

In early December 1985 the BNL consultants for SQRT and PVORT again raised questions related to test vs analysis for qualifying active valves at Clinton.

At this time the project manager requested the NRC reviewers to provide a staff position with regard to the issue that would satisfy both SQRT and PVORT concerns (Enclosure 1). This was telecopied to the applicant on December 19, 1985.

Following transmittal of this position subsequent telephone conversations were held between the staff, BNL and IP where the applicant explained how the staff position was satisfied. It was mutually agreed that IP should informally submit a valve qualification package to BNL for review to demonstrate how this position was met. This package was received in early January and reviewed by the BNL consultants. Based on their review it was determined that the valve qualification package submitted did not satisfy out concerns related to operability for the SQRT or PVORT programs. Therefore, the issue of test vs analysis for valve qualification still remained a concern.

A letter from Kamal Bandyopadhyay of BNL to Arnold Lee (NRC) dated January 16, 1986 (Enclosure 2) reiterates BNL's findings relative to test vr analysis for qualification and sumarizes the current status of this concern with regard to Clinton.

Based on this letter and the applicant's need to resolve this issue prior to fuel load, several conference calls were held between the parties involved on January 21, 1986. W. Butler, Director, BWD-4 and B. D. Liaw, Chief, Engineering 1

Branch were involved in these conference calls. The end result was that a meeting was scheduled at the S&L offices in Chicago, Illinois on January 28 and 29, 1986 between the staff, BNL, S&L and IP for the staff to perform a final audit and evaluation of the test data used by S&L for verification of the analysis.

During these conference calls IP and S&L identified additional test data not previously reviewed by the staff that warranted the additional audit to determine if the analytical method used to qualify the valves for Clinton is acceptable.

Summary Since the initial audit in August it has been the staff's impression that the applicant understood our concerns and they would be adequately addressed in subsequent submittals. Unfortunately this has not materialized. It has been the applicant's contention that its approach, which is primarily analytical,

1 provides an acceptable alternative. .IP believes that it has enough test data to justify its approach. The purpose of the January 28 and 29, 1986 audit by the staff and its consultants was to determine if the staff concurs. The results of this audit and followup actions will be discussed in the staff's meeting summary which is forthcoming.

N yron Si gel, Project Manager BWR Project Directorate No. 4 Division of BWR Licensing cc: R. Bernero R. Houston G. Lainas B. Liaw i

i 1

l-

r-provides an acceptable alternative. IP believes that it has enough test'. data to justify its approach. The purpose of the January 28 and 29, 1986 audit by the staff and-its consultants was to determine if the staff concurs. The results.

of this audit and followup actions will be discussed in the staff's meeting summary which is forthcoming.

Byron Siegel, Project Manager BWR Project Directorate No. 4 Division of BWR Licensing cc: R. Bernero R. Houston G. Lainas B. Liaw DISTRIBUTION

.DocketJ11e' NRC PDR.

Local PDR EHylton BSiegel i

i PD /F BSiepj 02/%/8

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ = _ _ _ _ _ _ _ . _ _ _ _ _ _