ML20214D169
| ML20214D169 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/18/1986 |
| From: | Mark Miller Office of Nuclear Reactor Regulation |
| To: | Conway R GEORGIA POWER CO. |
| References | |
| NUDOCS 8611210385 | |
| Download: ML20214D169 (5) | |
Text
r Docket Nos.: 50-424 and 50-425 Mr. Richard Conway, Vice President 1 8 NOV 1986 and Project General Manager Georgia Power Company Route 2, Box 299A Waynesboro, Georgia 30830
Dear Mr. Conway:
Subject:
Vogtle Environmental Qualification Audit of the Equipment Qualification Files and Request for Additional Information During the period of September 9 through September 11, 1986, the NRC staff audited the environmental equipment qualification files of Vogtle Unit 1.
The staff audited a total of 14 files for equipment located in a potentially harsh environment. The enclosure contains observations and comments made by the staff at an exit interview held at the Vogtle site on Septeober 11, 1986.
You should respond to the corcicents and requests for additional infonration in the enclosure within one week of the date of this letter. Our evaluation of GPC's EQ program including the results of the audit, will be provided as input to a future SER supplement.
Sincerely, Melanie A. Miller, Project Manager PWR Project Directorate #4 Division of PUR Licensing-A cc:
See next page
Enclosure:
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I t.r. R. E. Conway Georgia Power Company Vcptle Electric Generating Plant CC:
Mr. L. T. Gucwa Resident Inspector Chief Nuclear Engineer Nuclear Regulatory Commissier Georgia Power Ccreary P. O. Box 572 P.O. Box 4545 haynesboro, Georgia 30830 Atlanta, Georgia 30302 l
Mr. Ruble A. Thomas Deppish Kirkland, III, Counsel Vice Presicent - Licensing Office of the Consurers' Utility Yogtle Project Courcil Georgia Power Company /
Suite 225 Southern Company Services, Inc.
32 Peachtree Street, fl.W.
P.O. Box 2625 Atlanta, Georgia 30303 Birmingham, Alabama 35202 James E. Joiner Mr. Donald O. Foster Troutman, Sanders Lockerman, Vice President & Project General Manager
& Ashmore Georgia Power Company Candler Building Post Office Box 299A, Route 2 127 Peachtree Street, N.E.
Waynesboro, Georgia 30830 Atlanta, Georgia 30303 Danny Feig Mr. J. A. Bailey 1130 Alta Avenue Project Licensing Manager Atlanta, Georgia 30307 Southern Company Services, Inc.
P.O. Box 2625 Carol Stangler Birmingham, Alabama 35202 Georgians Against Nuclear Energy 425 Euclid Terrace Ernest L. Blake, Jr.
Atlanta, Georgia 30307 Bruce W. Churchill, Esq.
Shaw, Pittman, Potts and Trowbridge 2300 N Street, N.W.
Washington, D. C.
20037 Mr. G. Bockhold, Jr.
Vogtle Plant Manager Georgia Power Company Route 2, Box 299-A Waynesboro, Georgia 30830 Regional Administrator. Pegion II L'.S. huclear Regulatory Commission 101 lbrietta Street, N.W., Suite 2000 Atlanta, Georgia 30323 l
4 2
Et! CLOSURE Comrrents on Staff Audit of Environmental Equipment Oualification and Request for Accitional Information Audit Coments 1.
During the audit it was discovered that the containment profile (s) used to qualify some equipment is different from the profile (s) provided to the staff in the Vogtle Equioment Oualification (EO) submittal. Georgia Power Company (GPC) has agreed to provide the new profile (s) to the staff for review and approval.
2.
10 CFR 50.49(f) states that:
"Each item of electrical equipment important to safety must be qualified by cne of the following methods:
(1) Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to shev that the equipment to be qualified is acceptable.
(2) Testing a similar item of equipment with a supporting analysis to show that the equipment to be qualified is acceptable.
(3) Experien~ce with identical or similar equipment under similar con-ditions with a supporting analysis to show that the equiement to be qualified is acceptable.
(4) Analysis in combination with partial type test data that suppcrts the analytical assurptions and conclusions."
After reviewing several files, it was discovered that there are instances when GPC did not meet the above requirement, e.g., in File No. E0DP-X3AB03 Conax 15KV Electrical Penetrations; the maxirem environmental parameters for which these penetrations are required to operate are: temperatuge, 400*F; pressure, 50 psig; 1007 relative humidity; radiation, 2 x 10 Rads TID; and chemical spray containing 2000 pprr boron and 30-35 Weight % NaOH with a pH of 8.5-10.5.
The required pcst accident operability time is one year.
However, qualification of these penetrations is claimed basec on tests of a SkV penetration supplemented by tests er en 8KY penetration.
The SKV penetratign was thercally eged at 250 F for 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> and received 1.19 x 10 Rads TID.
It was then excesed to a simulated accident environ-ment of 396"F peak temperature without chenical spray and a post-accioent simulation equivalent of 152.7 days. The justification for similarity was not given for all tests conducted.
In addition, not all tests required by IEEE 317, "IEEE Standard fcr Electric Penetration Assemblies in Containment Structures for Nuclear Power Generating Stations," were perfomed on the SKV penetratier por were they conducted in the specifiec sequence and they did not always envelope the specific voltage requirements. Justification for scre parameters were given by referencing tests conducted on the CRV penetration.
. v, As indicated above, qualification in this maritier dces not meet the require-ments of 10 CFR 50.49(f); therefore, you should review the entire Environ-mental Qualification Program to identify al! files that do not meet the requirements of 10 CFP 50.49 and relocate, requalify, or otherwise demon-strate qualification in accordance with the requirements of 10 CFR 50.49, 3.
The following comments are specific tc individual EQ files as indicated.
However, you must update all files te f rcorporate these concents where applicable.
Conax Electrical Penetration, ISKV Medium Voltace - File No. EODP-X3AB03 The test report establishing qualification has unacceptable deviations from IEEE 317. GPC suggested the use of a test report for a different penc-tration. This approach is acceptable to the staff, however you must verify that the test conditions envelope the Vogtle specifications and previde an acceptable similarity analysis.
Eaton 600V Instrument Cable, File No. E0BP-X3AJ04 The technique used to establish qualification is unacceptable. GPC agreed to provide heat transfer (thermal lag) analysis to establish qualification.
Additional calculations, provided to the staff during the audit, to estab-lish qualified life and post-accident operability were found acceptable.
Limitorque Actuator File No. E0DP-HE-4 This file has unacceptable deviations from the guidelines in Revision 1 of NUREG-0588, " Interim Staff Position on Envircomertal Oualification of Safety-Related Electrical Eauipment." GPC agreed to update the file with acceptable qualifica. tion information that was provided during the audit.
Limitorque Actuator, File No. E0DP-X5AC01 Information to establish a forty-year life for the specified conditions was not included in the file. The file should be updated with the information provided to the staff during the audit.
Pyco RTD File fio. EODP-X5AE06 Post-accident operability calculations should be added to the file and referenced on the SCEW sheet.
In addition, the required and demonstrated accuracies are open items.
Chen Pump, File No. EQDP-AE-3 Ecuirrrent location does not agree with SCEW sheet data.
4.
In addition to the items noted above, the followine were alsc audited:
Fisher /Asco Scienoid valve, File No. E0DP-X5AC03 Fisher /Namco Position Switch, File No. EQDP-X5AC03 Westinghouse Hydrogen Recombiner, File No. EQDF-SP-1 Raychem Heat Shrink Termination Kit, File No. E0DP-X3AJ11 Carton Pressure Sensor, File No. EODP-ESE-21 Barton Pressure Trensnitter, File No. EQDP-ESE-3A Conax/Litton Electrical Seal Assembly, File f o. ECCP-HE-8 Limitorque Valve Actuator, File No. EODP-HE-1
Request for Additieral Information To facilitate our review of your equicment qualification submittal dated Octeter 31, 1986, the following must be proviced:
1.
In accordance with the guidelines of Regulatory Pnsition C4 of Regulatory Guide 1.89, provide a failure modes and affects analysis for all equip-ment, inside and outside containment, that will be eypesed to an environ-ment more severe than the environment to which equipnent has been qualified.
The analysis should include equipment inside containment thet is required for a LOCA but may not be required to mitigate the consequences of an IGLB, and should also include equipn,ent in the t1SIV area that is not rec,uf red to function for an MSLB but will experience the environment of superheated stean.
2.
Notify the staff that all deficiencies identified during the audit have
~
been corrected.
3.
There are two figures identified as FSAR Figure 3.11.8.1-1 (sheet 9 of 12).
Please indicate which is tc be used in the staff review of Vogtle.
4.
Provide a copy of the analysis identified as calculation number X6CJH.49.
.