ML20205K610

Testimony of a Mascianatonio on Joint Intervenors Contention 10.5 Re Automatic Switch Co Solenoid Valves. Related Correspondence

ML20205K610
Person / Time
Site:	Vogtle
Issue date:	02/24/1986
From:	Masciantonio A Office of Nuclear Reactor Regulation
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, f s EDCORRESP06. & t

) 00tMETED USNHC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION g gg g34 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE Gr R ' 4'

, . 00Cnti m ^ ; M t! r BRANH i

In the Matter of )

)

, GEORGIA POh'ER COMPANY ) Docket Nos. 50-424 et al. ) 50-425 e ~~

) (OL)

(Vogtle Electric Generating Plant, ) ,

Units 1 and 2) )

NRC STAFF TESTIMONY OF ARMANDO MASCIANTONIO ON JOINT INTERVENORS' CONTENTION 10.5 (ASCO_ SOLENOID VALVES)

Q.1 Please state your name and position with the NRC and summarize your professional qualifications.

A.1 My name is Armando f!asciantonio. I am presently employed by the U.S. Nucicar Regulatory Commission (NRC) as a mechanical engineer in the Engineering Branch of PWR-A, Division of Licensing, Office of Nuclear Reactor Regulation (NRR), Before November, 1985, I was employed as an equipment qualification engineer in the Equipment Qualification B ranch, Division of Engineering, Office of Nuclear Reactor Regulation. I was responsible for the technical reviews, analyses and evaluations of the adequacy of the environmental quclification of electric equipment important to safety and safety-related mechanical equipment, whose failure under postulated environmental conditions could adversely affect the performance of safety systems in nuclear power plants, k

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[

. Before joining the NRC I was employed as an engineer by Vitro Laboratories Division of Automation Industries, Inc. from February, 1981 until Slay,1982. I was responsible for the environmental and seismic qualification of the safety-related electronic control equipment supplied by Vitro Laboratories Division. Specifically, my duties were to develop and write the environmental and seismic qualification test plans, procedures and reports and to oversee the test and procurement activities in support of qualification.

Prior to that. I was employed at the U.S. Naval Surface Weapont Center an a mechanical engineer from August, 1972 until January, 1981. Sly duties involved support of the development, test and evcluation of advanced naval weapons.

I have a B.S. degree in Pfechanical Engineering (1972) from Drexel l'niversity , Philadelphia, Pennsylvania, a h1 asters degree in hicchanical Engineering (1976) from the Catholle University of America, Washington, D.C., and a afasters degree in Administrative Science (1980) from the Johns !!opkins University, Baltimore, hfaryland.

Q.2 What is the purpose of this testimony 7 A.2 The purpose of this testimony is to address Joint Intervenors' Contention 10.5 and to respond to the Atonic Safety and Licensing Board's "Stemorandum and Order (Ruling on hiotion for Summary

. Disposition of Contention 10.5 re: ASCO Solenoid Valves)" dated

.Tanuary 7,1986.

Cor tention 10.5 challenges the environmental qualification of the Automatic Switch Company ( ASCO) solenoid valves used at Vogtle.

The contention is based on the results of tests performed by the Automatic Switch Company and Franklin Research Center (FRC) and

. the subcequent issuence of NRC notifications.

Q.3 Please describe the results of the FRC research to:,ts.

A .3 The Nuclear Regulatorv Commission , Office of Nuclear Regulatory Rencarch (RES) sponsored a qualification methodology research test on seven ASCO solenoid valves. This research test program indiented a number of failures which had not been experienced in previous qualification tests performed by the manufacturer. The FRC tent specimens consisted of seven different valve models, of which five valve models were artificially aged, and two valve models were naturally aged. The naturn! nging, which was done by the manufacturer, consisted of exposing the two test valve models in an air oven at 140*F (600C) for three years. The valves were pressurized with nitrogen and valve solenoids were continuously energized. Of the seven valve models that were tested, one passed and six failed during the LOCA/MSLD test. Of the six valve models that failed, four models were artificially aged and two valve models were naturally aged. Failure was defined as the innbility of

. i the valve to perform its function. The anomalous behavior noted

during the tests have been evaluated and resolved to the i

j satisfaction of the staff.

i

f. The nature of the FRC test was a qualification methodology research test, not an equipment qualification test, and allowed the j valves to cycle at high temperature during thermal aging. Because

) of the unrealistic, severe preconditioning which the artificially aged

,! - valves received, the NPC staff concluded that the failures of the i FRC artificially-aged valves were inconclusive .  !!owever , the i failure of the two naturally aged valves (models N P-8316 and

• l j NP-8344) during the FRC test cannot be discounted since they were i not subjected to the sono severe preconditioning as the artificially I aged valves, l

i 1 Based on the results of that test, the NPC staff concluded that the l

j failure of two naturally aged valves (NP 8316 and NP 8344) justified i

{ downgrading the level of the previous staff accepted status of (

i

! ASCO valve model MP 8316. Details of the staff position on this

matter are found in IE Information Notice 84-23 "Results of l

j HRC-Sponsored Qualification Methodology Research Test on ASCO

]

j Solenoid Valves" a copy of which is included in this testimony as j Attachment 1.

I i

) Q.4 What are the NR C's regulatory requirements for environmental l

j qualification of equipment important to safety? j i

l 1

)

I.-_.-______. .,. .- - _ _. _ - -,_ __ _ _ . _ _ _. _ __ _

. A.4 The regulatory requirements for environmental qualification are stated in General Design Criterion 1 and 4 of Appendix A and Sections III, XI, and XVII of Appendix B to 10 C.F.R. , Part 50.

Specific requirements for environmental qualification of electric equipment important to safety are stated in 10 C.F.R. I 50.49,

" Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants."

Regulatory Guide 1.89, Rev.1, provides a method acceptable to the NRC staff for complying with 10 C.F.R. I 50.49. This Pegulatory Guide endorses IEEE Standard 323-1974, "!EFE 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."

Q.5 What is the purpose of environmental qualification?

A.5 The purpose of environmental qualification is to demonstrate that equipment used to perform a necessary safety function is capab!c of maintaining functional operability under all service conditions postulated to occur during the installed life for the time the equipment is required to operate. Regarding the Board's question at p.13 of its January 7,1985 Order, of how long any of the valve models will be required to operate in VEGP following an accident,

. post-accident operability time is a function of the specific system requirements and varies for each application. The qualification process must demonstrate that the equipment is indeed capable of the specified length of operating time following an accident.

Q.6 flow does the staff assure that the period of required post-accident operability is adequately specified?

A.6 The applicant must establish the perled of time cach specific piece of equiptrent is required to operate in order to perform its safety-related function. The Staff's environmental qualification review for the Vogtle plant, which will be performed prior to licensing, will verify that the period of post-accident operability has been properly specified and the demonstrated post-accident operability time envelops the specified requirements.

Q.7 Ilow does the qualification process assure that c piece of equipment is capable of performing its required Lifety functiois during and after a design basta occident for the period of its installed life (qualified life)?

A.7 Environmental quellfication can best be achieved by subjecting a representative piece of equipment to a test program which simulates the expected environmental nnd service conditions the equipment will see during its installed life , followed by exposure to the

. expected design basis accident during which the equipment is required to operate.

The program typically consists of the following sequence of tests:

Boreline functional testo Accelerated aging to place the equipment in a physically aged state equivalent to the condition in which it would be at its end of life. Accelerated aging includes thermal aging, radiation exposure, operational cycling and other ctresses such as vibration, pressure, etc. which the equipment would likely encounter during its installed service life.

Design Ilasts Accident test to demonstrate that the piece of equipment, at the end of its installed life, is capabic of performing its required function for the period of time required during and after the most severe design basis event it will see.

Other methods such as operating experience and analysis in combination with partial testing can also be used to demonstrate qualification. These other methods are reviewed on a case by case basis.

This qualification process provides reasonable assurance that equipment of a specific type can perform as needed during Ita installed life. This process is endorsed by both industry and the NItC .

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o _g-Q.8 What is the purpose of " margin" in a qualification program?

A8 Margin is the difference between the environmental and operational levels applied during qualification testing and the most severe service conditions under which the equipment is required to operate. Margins are applied to account for unquantified uncertainties ich as the effects of production variations and other inaccuracies. Adequate margin can' be assured by increasing the level of test, number of test cyclen, and test duration.

Q.9 Ilow is the specific test unit to be used in the qualification test program selected?

s A.9 The test unit used for the qualification program should essentially be selected randonly from the prodt.ction run. No special consideration should be given to selecting any specific unit for the purpose of influensing the results of the test. In order for the qualification process to be considered valid, the test specimen must show the same performance characteristics as the production model.

s Q.10 Does the qualification process recognize the possibility of anomalies during the test program? 1 A .10 Yes . A proper cualification pdogram should establish failure /accepta'nce criteria before the start of the test. Any anomaly observed during the test must be evaluated and resolved to J

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e

assure that it is not a safety-related concern. Anomalies judged to be equipment failures must be evaluated to determine if the failure is. random or caused by the combined influences of age and harsh operating conditions (common mode failure).

The qualification process does not eliminate random failures. It is intended to assure that the equipment does not experience common mode failure. If common mode failure results, the equipment cannot be considered qualified to the levels of the test program.

In addition, any operational limitations identified during the qualification test, such as, sealing , installation and interface requirements, must be implemented in the plant installation of the equipment. For example, this would include sealing of the NP8316 valve housing where required for particular VFCP applications.

Since qualification tests showed that unsealed solenoid housing could result in water intrusion into the solenoid housing which could cause improper operation , ASCO recommends that ASCO valves be installed in a manner that prevents water inleakage. The staff evaluation of the anomalies is addressed in succeeding questions and answers. See O and A 16,17,18 and 19.

O.11 How are ASCO solenoid valves typically used in nuclear power plants?

. A.11 ASCO solenoid valves are generally used in safety-related applications such as controllers for air operated valves. By controlling the flow of air to air operators, ASCO solenoid valves will cause process valves to either open or close. In response to the specific question posed on the Board Order at p.13 regarding whether any type of failure of any of the valve models considered

- will result in achieving an unsafe configuration, the staff has no information as to the Vogtle - specific configurations. In general, these solenoid valves are designed to operate in a fall safe mode; 4 that is, loss of power to the solenoid will result in its achieving a safe condition. These valves are generally found throughout the plant, both inside and outside containment. Further, if a valve is determined to be qualified it is recognized that it will not experience common mode failure as explained in Answer 10.

O.12 Which ASCO solenoid valves are used in the Vogtle plant?

A.12 The Applicants have stated that the only ASCO solenoid valves used in the Vogtle plant which fall within the scope of 10 C.F.R. 5 50.49 are model numbers NP 8316, MP 8320, NP 8321, and 206-3SI-6F.

Q.13 What is the extent of the NRC staff review of the qualification status of ASCO solenoid valves?

A.13 The NRC staff has reviewed the following qualification reports pertaining to ASCO solenoid valves:

. (a) Isomedix Test' ' Report No. AQS 21678/TR-Rev A.

" Qualification Tests of Sole noid Valves" Pf arch , 1978, Revision A, July 1970.

(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," P! arch 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-IIE2/flES, WCAP-8687 EQTR-HO2A/HOSA, and WCAP-8687 Supp. 3-IIO2A/HO5A Addendum 1 Revision O.

(d) N UR EG / C P.-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 current 1978 standards.

l l Tests (b) and (c) above were conducted by ASCO/hestinghouse to qualify ASCO valves to a higher level.

Tests (d) were performed by Franklin Research Center under contract to the NRC for the purpose of qualification methodology research.

. l ll

, A comparison of pertinent test parameters is shown on Attachment 2.

Q.14 Ilave the ASCO qualification tests been properly conducted?

A.14 As evidenced in the test reports reviewed by the staff, the qualification programs were properly conducted in accordance with accepted standards. Test results show that all anomalies vrere appropriately addressed and valve performance was demonstrated in agreement with the staff pos ion.

Q.15 Where is the staff position on the qualification status of ASCO solenoid valves explained?

A.15 The staff position on the qualification status of ASCO solenoid valves has been made known in IE Information Notice 84-23, "Results of URC-Sponsored Qualification Methodology Research Test on ASCO Solenoid Valves" and Information Notice 85-08, " Industry Experience on Certain Materials Used in Safety-Related Equipment."

Q.16 What is the specific staff accepted qualification level for ASCO valve model NP 8316 and what is the basis for the staff position?

A.16 As stated above, ASCO valve model NP 8316 is considered qualified to the levels reported in Isomedix Test Report Number

. AOS 21678/TR, Revision A. This valve model was capable of performing its required safety function during and following a design basis event (DBE) simulation with a peak temperature of 346oF. The valve had been preaged to the equivalent of 4 years at 140oF and had received a radiation exposure of 200 megarads. All anomalies were resolved in accordance with the process stated in answer 10 of this testimony.

The higher level of qualification claimed in ASCO Report No.

AQR-67368 is not accepted by the staff because of the failure of a naturally aged NP 8316 valve during the NRC-sponsored tests at Franklin Research Center. The test conditions during the FRC test of this valve were similar to the conditions during the ASCO tests reported in Report AQR-67368.

Based on the review of the FRC test results during which a naturally aged NP 8316 valve failed after 2.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br />, the staff has also 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 in which subsequent failure does not degrade other safety functions nor mislead the operator. Under these circumstances, report AQR-67368/Rev. I will be an acceptable qualification document for valve model NP 8316. Similarly, if the

valve is required for long term operation, an analysis in accordance with NUREG-0588 can be used to .show that even though the ambient temperature may be greater than 346oF for a short period of time, the temperature of the velve will not exceed 3460F. This temperature corresponds to the valve qualification level determined by the Isomedix tests. If this can be shown, the valve can be considered qualified by Isomedix AOS 21678/TR-Rev. A for long term operation.

Q.17 Ilow has Westinghouse shown that ASCO model NP 8316 is qualified for the appropriate levels in light of the above?

A.17 Westinghouse has provided a method of addressing the long term environmental qualification of ASCO valve model NP 8316 in topical report WCAP-8687, Supplement 2 - IIO2A /HO5 A , Addendum 1, Revision O, dated January 1985. This report documents the anelyses which demonstrate qualification to a dera.ted Westinghouse generic LOCA/It!SLB temperature profile which has a maximum peak temperature of 400oF for epproximately three minutes.

The derated Westinghouse generic profile is based on a heat transfer model develope (* by using the actual thermocouple data and test environmental parameters from the Franklin Research Center 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 83.16 solenoid valves installed in plants whose accident environments are enveloped by the derated Westinghouse LOCA/MSLB profile will be less than 345eF and therefore qualified by Isomedix Report No. AOS 21678/TR-Revision A.

The staff has reviewed the information provided in WCAP-8687, Supplement 2 - HO2A/HOSA, Addendum 2, Revision O, dated January 1985 and finds that the approach used to generate the derated Westinghouse generic LOCA/MSLB profile is reasonable and cceeptable as a means of establishing an environmental qualification level for ASCO valve model NP 8316.

The derated Westinghouse generic LOCA/MSLB temperature profile

, envelops the staff's accepted accident profile for the Vogtle power plant .

Q.18 What is the specific staff accepted qualification level for ASCO valve model NP 8321 and what is the basis for the staff position?

A.18 ASCO valve model NP 8321 is considered qualified to the levels reported in Isomedix Test Report Mumber AQS 21678/TR-Rev. A.

This test included preaging equivalent to 4 years at 140cF, peak accident temperature of 3460F and radiation exposure of 200 megarads. The reported anomalies were adequately resolved in accordance with the process described in answer 10 of this

. testimony. Based on these test results this valve model is considered qualified to the levels reported in Isomedix AQS 21678/TR-Rev. A.

Based on information submitted by the applicant , the staff understands that these qualification levels exceed the stated service and accident requirements for this valve model at the Vogtle plant.

Q.19 What is the specific staff accepted qualification level for ASCO valve models NP 8320 and 206-381-GF and what is the basis for the staff position?

A.10 These two valve models are considered qualified to the levels reported in ASCO Report No. AQR-67368. This test included preaging to the equivalent of 8 years at 1400F, a peak accident temperature of 420 F and radiation exposure of 200 megarads. All test anomalies were adequately resolved in accordance with the process stated in answer 10 of this testimony. Based on the test results, these valve models are considered qualified to the levels reported in AQR-67368.

The staff accepted qualification levels exceed the stated requirements for the Vogtle power plant.

Q.20 What is the staff position on the results of the FRC tests?

. - 17 .

A.20 Eecause of the unrealistic and severe cycling of the valves during the high thermal aging temperatures, the test results of the valves which were artificially preconditioned cannot be considered conclusive and the previously demonstrated qualification levels are still considered valid.

.l The two naturally aged valves (Models NP 8316 and NP 8344) were not subjected to the severe preconditioning received by the other valves . Therefore , the failure of these two valves must be considered as valid failures. Since the FRC tests were patterned after the same standards and environmental conditions as in the ASCO AQR-673G8 tests, tbc staff' has negated the previous acceptance of valve model NP 8316 to the qualification levels claimed in the AQR-67368 report and relies on the Isomedix tests for the qualification levels of valve model NP 8316.

Q.?! Ilas the qualification status of each ASCO valve used at Vogtle been established?

A.21 As detailed above, the staff concludes that adequate documentation is available to establish the environmental qualification of each of the ASCO solenoid valves used at the Vogtle power plant. The qualification levels established envelop the specific Vogtle requirements for each valve model. A site audit will be conducted prior to licensin g to verify that a record of qualification in accordance with 10 C . F . R . 9 50.49(j) exists and is maintained for the Vogtle plant.

ATTACHMENT 1 SSINS No.: 6835 IN 84-23 UNITED STATES NUCLEAR REGULATORY COMMISSION ~

OFFICE OF INSPECTION AND ENFORCEMENT ..

WASHINGTON, D.C. 20555 April 5, 1984 .,

IE IN ORMATION NOTICE NO. 84-23: RESULTS OF THE NRC-SPONSORED QUALIFICATION METHODOLOGY RESEARCH TEST ON ASCO SOLEN 0ID VALVES

[

Addressees:

All nuclear power reactor facilities holding an operating license (OL) or construction permit (CP).

Purpose:

) This information notice is provided as an early notification of a potentially

? significant event concerning the failure of two naturally aged Automatic g Switch Company (ASCO) solenoid valves. These valves are ASCO models NP-83.16

= and NP-8344. The failure of these two naturally aged valves occurred during the LOCA/MSLB (Loss-of-coolant accident / main steam line break) simulation phase of a qualification methodology research test conducted by the Franklin Research Center (FRC). It should be noted that this information notice is not addressing the-earlier concerns dealing with the Viton/EPDM material used in ASCO solenoid valves as described in previously published information notices. It is expected that recipients will review the information for applicability to their facilities and take appropriate action. A response is not required.

Description of Circumstances:

Recently the Nuclear Regulatory Commission (NRC), Office of Nuclear Regulatory Research (RES) sponsored a qualification methodology research test on seven ASCO solenoid valves. The test program was developed by FRC for the NRC. This research test program resulted in a number of failures which had not been experienced in previous qualification tests performed by the manufacturer.

The FRC test specimens consisted of seven different valve models, of which five valve models were artificially aged, and two valve models were naturally aged. The natural aging which was done by the manufacturer, consisted of exposing the two test valve models in an air oven at 140 F (60*C) for three years. The valves were pressurized with nitrogen and valve solenoids were 8l continuously energized.

The test program was patterned after the requirements of IEEE,323-1974, 344-1975, 382-1980, and NUREG-0588, Rev. 1, with the exception that the two naturally aged valve models (model NP-8316-66E, and model NP-8344-A71E) were not exposed to radiation preaging. All seven valves were subject to DBA radiation followed by LOCA/MSLB simulation. The specified temperature /

8403140263

IN 84-23 April 5, 1984 Page 2 of 3 pressure profile for the simulated LOCA/MSLB exposure, and details of the FRC Solenoid valves test program and failure analysis can be found in NUREG/CR-3'474'(published in November 1983.)

Of the seven valve models that were tested, one passed and six failed during the LOCA/MSLB test. The valve model which passed was artificially aged and had a metallic seat. Among the six valve models that failed, four models were arti-ficially aged and two valve models were naturally aged. Naturally aged valve model NP-8344 failed af ter 14 minutes into the test, and naturally aged valve l model NP-8316 failed after 2.75 hours8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> into the test. Failure was defined as the inability of the valve to perform its function. J Failure of naturally aged valve NP-8344 was attributed to the elastomer sticking to valve metallic parts. For naturally aged valve NP-8316, the failure was attributed to the cumulative degradation of the elastomer -

diaphragm.

Discussion:

The NRC staff has reviewed the FRC test results and has made the following observations: (1) the nature of the FRC test is a qualification methodology research test, which has allowed the valves to cycle at higher temperature during thermal aging, and (2) that the actual temperature profiles during both LOCA/MSLB transients were higher and longer in duration than recommended by industry standards. The NRC staff concluded that the failures of the FRC artifically-aged valves were inconclusive. However, the failure of the two naturally aged valves (models NP-8316 and NP-8344) during the recent FRC test cannot be discounted since they were not subjected to the same severe precondi-tioning as the artificially aged valves.

~

Similar valve models as those naturally aged valves that failed the FRC test were also tested by ASCO and Westinghouse (W) in 1982. The results of this--

test were documented in ASCO Report AQR-67368, Rev. O, March 1982 and WCAP In the ASCO/W test, 8587 EQDP-HE2/HE5 Rev. 4, WCAP 8687 EQTR-H02A/H05 Rev. 2. ,_

model NP-8344 failed and model NP-8316 passed. Both the 1983 NRC/FRC test and the 1982 ASC0/W test were patterned after the same standards ano since model NP-8316 failed the recent NRC/FRC test, the NRC staff considers that model NP-8316 may not be suitable for the environmental conditions and operat-ing time requirements as reported in the aforementioned ASC0/W test reports.

Westinghouse has been informed of these findings in a NRC letter dated December 23, 1983 from R. Vollmer (NRC) to E. P. Rahe (Westinghouse).

Similar models of these same two valves were also tested in 1978 and reported in Isomedix. AQS report number 21678/TR-Rev. A. Applications in which y environmental conditions are enveloped by test conditions described in this Isomedix AQS 21678/TR-Rev. A report, are considered acceptable. ,

IN 84-23

- April 5, 1984 Page 3 of 3 If you have any questions regarding this matter, please contact the Regional Administrator of the appropriate NRC Regional Office, or this Office.

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/'i ...

ward L. Jordan, Director l Division of Emergency Preparedness and Engineering Response 9 Office of Inspection and Enforcement Technical Contacts: N. B. Le, IE

. (301) 492-9673 A. Masciantonio, NRR (301) 492-8205

Attachment:

List of Recently Issued IE Information Notices ,

e l' .

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n . - -... - - - - . , ~ , . . - - . , - - - . . - . - - .

O Attachment IN 84-23 April 5, 1984 LIST OF RECENTLY ISSUED IE INFORMATION NOTICES Information - Date of Notice No.- Subject Issue Issued to 84-22 Deficiency in COMSIP, Inc. 03/29/84 All power reactor Standard Bed Catalyst facilities holding an OL or CP 84-21 Inadequate Shutdown Margin 03/28/84 All power reactor facilities holding an OL or CP 84-05 Exercise Frequency 03/28/84 All power reactor facilities holding an OL ,

84-20 Service Life in Safety- 03/21/84 All power reactor

~~

Related Systems facilities holding an OL or CP 84-19 Two Events Involving Unau- 03/21/84 All power reactor facilities holding thorized Entries into PWR Reactor Cavities an OL or CP 84-09 Lessons Learned from NRC 03/7/84 All power reactor Inspections of Fire Protec- facilities holding Rev 1 tion Safe Shutdown Systems an OL or CP (10 CFR 50, Appendix R) 84-18 Stress Corrosion Cracking in 3/7/84 All power reactor facilities holsfing Pressurized Water Reactor Sysetms an OL or CP 84-17 Problems with Liquid Nitrogen 3/5/84 All power reactor Cooling Components Below the facilities holding Nil Ductility Temperature an OL or CP 84-16 Failure of Automatic 3/2/84 All power reactor Sprinkler System Valves to facilities holding Operate an OL or CP 84-15 Reporting of Radiological 3/2/84 All power reactor Releases facilities holding ',

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an OL or CP

! OL = Operating License l

CP = Construction Permit 1

L.

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^

Attachment 2 i ASCO SOLENGIDS TFST PROGRAM COMPARISON Age Conditioning DBE Simulation IEEF Qual. Life Test Stds.* Sequence

! Thermal Cyclic Radiation Radiation MSLR/LOCA Claim IJsed of Tests FRC i,

NUREG/ 15.3 days 2,000 cycles 9 50 Mrads 150 Mrads 420*F peak 4 yrs P 140*F 323-1974 Baseline CR-3424 P 131*C thermal aging P 0.5 Mrad /hr 9 0.5/0.9 30 days (Arrhenius) 344-1975 Radiation

' temp. 382-1980 -Thermal Aging Mrad /hr I

(8 cycles per Pressure Aging

! minute for 21 Vear/ cycling i j minutes per day Vibration for 12 days) Seismic DPF Radiation i LOCA/MSLB i

i ASCO/W 18 days 2,000 cycles P 23 Mrads 182 Mrads 420*F peak 8 yrs 9 140'F 323-1974 Baseline 1982 0 121*C thermal aging P 0.7 Mrad /hr P 0.9 30 days (Arrhenius) 344-1975 Thermal Aging RUR!E7368 temp. (1.3 cycles Mrad /hr 382-1972 Wear /cycline

per minute first 3R2-1980 Pressure Aging 24 hrs; 180 cycles Radiation Aging over balance of Vibration aging period), Seismic

! 18,000 cycles e DBE Radiation

! room temp. LOCA/MSLB ASCO 12 days 48 cycles 9 50 Mrads 150 Mrads 346'F peak 4.4 yrs 9 140'F 323-1974 Baseline I 1978 P 131*C therwel aging 9 0.5 Mrad /hr P 0.8 30 days (10*C rule) 344-1975 Therwal Aging

• Isomedix temp. (1 cycle Mrad /hr 382-1972 Radiation Aging AQS 21678/TR every 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />), Wear / Cycling 40,000 cycles P Vibration room temp. Seismic DBE Radiation 4 LOCA/MSLB L

i

$