ML20214P433
| ML20214P433 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/26/1986 |
| From: | Deutsch H GEORGIANS AGAINST NUCLEAR ENERGY |
| To: | |
| References | |
| CON-#486-1706 84-499-01-OL, 84-499-1-OL, OL, NUDOCS 8612040200 | |
| Download: ML20214P433 (9) | |
Text
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00bb gELATED CORttESPONDEMS DOCKETED UNITED STATES OF AMERICA USNFC NUCLEAR REGULATORY COMMISION
[
ATOMIC SAFTY AND LICENSING BOARD
~86 DEC -1 All :34 Before Adminastrative Judges:
OFFICE :e :...
M*
00CnLIIM 4 S! RilCI.
Morton B. Margulies, Chairman M"
Gustave A.
Linenberger, Jr.
Dr. Oscar H.
Paris l
)
Docket Nos. 50-424-OL In the Matter of
)
50-425-OL
)
GEORGIA POWER COMPANY, et a1
)
(ASLBP No.84-499-01-OL)
)
(Vogtle Electric Generating
)
November 24, 1986 Plant, Units 1 & 2
)
)
' STATE OF GEORGIA COUNTY OF FULTON AFFIDAVIT OF HOWARD M. DEUTSCH Howard M. Deutsch, being duly sworn according to law, depose and say as follows:
My name is Howard M. Deutsch. I am a member of and have been authorized to speak in behalf of Georgians Against Nuclear Energy (GANE). The purpose of this affidavit is to respond to the Atomic Safety and Licensing Board's letter of November 6, 1986 in which the record in this matter was reopened.
In BN No. 86-18 the NRC staff voiced it concerns about the methodology used for testing ASCO solenoid valve exposed to superheated steam following a MSLB accident.
The exact nature of this concarn was not completely explained, but obviously any 1
factor which would tend to make the analysis of this testing 1
e6120402OO e611 g PDR ADOCK 0500 p
approach more conservative, would raise more concern with the NRC staff.
Applicants informed the staff that only four ASCO valves (type NP8321, all in the control building) were relevant to BN No. 86-19. Applicants had earlier supplied to Intervenor a list of all qualified ASCO valves at Vogtle (letter dated March 13, 1985 to Mc. Laurie Fowler).
This list, labeled attachment C, does not show any ASCO NPS321 valves in the control building.
Instead, six NP8321 (models ASE and A185E) are shown in the MSIV area.
This discrepancy, which seems to indicate a lack of knowledge by both applicants and NRC staff, casts a serious cloud over the whole issue. Applicants have now informed Intervenor that this error was merely a typographical error and should have been obvious.
One wonders what other typo's have not been corrected.
The staffs request questioned the thermal lag methodology used to establish the qualifications of ASCO valves when expoced to superheated steam.
Based on applicants reanalysis of the problem, the staff has changed its opinion and now feel the valves are qualified (letter to ASLB dated September 15, 1986 from J. W. Thompson).
The thermal lag methodology previously used divided the temperature response into three phases:
- 1) Temperature rise to saturation temperature.
- 2) Temperature remaining at saturation point until condensate is vaporized (this was the main point of staffs concern).
- 3) Temperature rise based on forced convection heat transfer.
In the new analysis, the first two phases are assumed to 2
occur instantaneously.
This was accepted by staff, since this is a more conservative approach.
However, if the staff was primarily worried about phase two, why would this new more conservative approach satisfy them?
The only effect of eliminating all thermal lag would be to possibly raise the actual final temperature! What was not explicitly mentioned was the fact that applicants were now relying on Vogtle specific temperature profiles, which were calculated to be less than the Westinghouse generic profiles. They use the calculated internal temperature of the valve to estimate the surface temperature.
Applicants new analysis then shows that the maximum temperature differential across the valve would be no more than 0.80 F, and therefore the surface temperature would be 326 F.
Since the " qualification 0
temperature" is 346 F,
applicant and staff concluded that the NP8321 valve was qualified for the " worst case" environmental conditions following a MSLB outside containment. This qualification temperature was presumably based on Isomedix test data, in which valves were artificially pre-aged, and then subjected to simulated accident conditions.
During the pre-aging both of the NP8321 valves tested developed excessive seat leakage.
In addition one of the valve allowed spray solution to enter its electrical coil. The accident test conditions included 0
a peak temperature of 346 F (test condition temperature, not valve temperature), pressure of 110 psig, and chemical spray.
These conditions were imposed for approximately three hours (see testimony of G. H. Baenteli et al, Feb. 24, 1986, on contention 3
10.5, p 33-36).
Based on these test results I would not conclude with great certainty that the valves were fully qualified to 346 F.
Intervenor would also like to remind the Board of several IE information notices that have shown a continuing history of problems with ASCO solenoid valves. Although these notices are not specifically related to " environmental qualifications" they do indicate operating experience and would therefore be even more important than laboratory and theoretical modeling experiments.
These would include: 86-57, July 11, 1986, " Operating Problems with Solenoid Valves at Nuclear Plants"; 85-95, December 23, 1985, " Leak of Reactor Water to Reactor Building Caused by Scram Solenoid Valve Problem"; 85-17, March 1, 1985, "Possible Sticking of ASCO solenoid Valves"; 85-08, January 30, 1985, " Industry Experience on Certain Materials Used In Safety-Related Equipment".
In all of these cases, ASCO solenoid valves were involved.
The latest notice, 86-57, which should be considered i
new evidence since it was issued after the March 1986 licensing hearing, details a series of valve failures that have occurred recently at several operating nuclear plants.
The following general problems were pointed out:
- 1. High ambient temperature not being monitored.
- 2. Hydrocarbon contamination from poor quality pressurized air.
- 3. Chloride contamination from handling, packaging, and storage.
4.
Poor maintenance programs in which short lived parts, such as elastomers were not replaced, and poor quality of mechanical overhaul work led to valve failures.
All of these problems go beyond the " simple" qualification of 4
valves in terms of temperature, pressure, radiation, etc.
These valves fail repeatedly in the field, and are obviously difficult if not impossible to maintain.
Intervenor specifically asked applicants about this maintenance problem (transcript of proceeding, March 13, 1986, p.528 at 2-7, and during discovery) but in no case was an adequate answer given.
Applicants response was simple - we have a maintenance program and it will work.
But that is clearly not good enough, in light of the problems with these valves! Intervenor asks the Board to find that these valve are not suitable under either normal or accident conditions, and to not allow licensing of the plant until this serious problem is corrected.
Intervenor would also like to point out a serious flaw in both applicants and staffs approach to the environmental qualification program. They both refer in numerous documents (as has Intervenor) to the need to qualify equipment which is used in
" safety-related applications".
However the applicable standard is equipment "important to safety", which includes all " safety-reinted" and some "nonsafety-related" equipment. Nonsafety-related equipment whose failure could prevent the satisfactory accomplishment of required safety functions by safety-related equipment must also be included in this program. The Equipment Qualification Branch (EQB) of the NRC is charged with the responsibility for " reviewing information that confirms the operability of equipment important to safety over its entire range of service conditions (i.e.,
all normal and accident 5
loads), throughout the equipment's installed life".
Intervenor feels that it is the responsibility of the ASLB and the Staff to see that the applicable standard of "important to safety" is carried out by the applicant and that these parties must review all of their records to see if this has been properly implemented.
Intervenor has only recently become aware of a document that is extremely important to the safety of Plant Vogtle as well as all Nuclear Plants.
Although this study " Impacts of Budget Cuts on NRC's Ability to Assure Safety", Victor Stello, Jr., Executive Director Operations, NRC, is dated April 30, 1986 we feel that it should be considered new information. This is because it was not served on us, and to the best of our knowledge has not been served at any proceeding. Because of the potential impact of this study, we would also like to ask the why the staff has not served this report to the ASLB, the Appeals Board and to the parties of this hearing. The staff is responsible to bring before the Board 1
all information which would cast a new of different light or issues before the board, or that would raise new issues.
Specifically, in this report (refereed to as " Budget Cuts")
on page 19 the effects on the equipment qualifications program are summarized. To quote in part "The rules and qualifications efforts of industry are based in many instances on engineering l
judgment. Failure to complete the research leaves the future performance of equipment in a TMI-2 type of event significantly more uncertain and increases the risk to the public. The research on equipment qualification would have provided the basis for 6
resolving many uncertainties in the methods and added assurance that equipment would be available and function during and following accidents." What this points out is that the basis for qualification testing is not well understood, additional research is necessary, and that in the meantime a very conservative
't approach must be taken. If there is any reason to doubt the testing that equipment has undergone, then one must assume that equipment is probably not well qualified.
In reference to applicant response of October 30, 1986
( Affidavit of S.J.
Cereghino and W.V.
Cesarski) intervenor question the applicability of the Bechtel FLUD code in calculating the Vogtle specific MSLB/LOCA conditions. In the above report (" Budget Cuts"), on page 26 is given a summary of the effects on the Severe Accident Risk Analysis program, which will be eliminated in FY 1987. To quote in part "The development of plans to implement the severe accident policy requires the use of a combination of complex computer codes capable of modeling accident phenomena and estimating the details of accident progression from inception to final impact on the public. Current computer codes used for these purposes are not integrated, are expensive to run, and do not adequately incorporate the latest research results on, for example, common cause failure or external events--nor do they provide an explicit estimate of the uncertainties involved." Because of these questions the Board should be very reluctant to accept applicants position that the ASCO solenoid valves are fully qualified, especially in light of the 7
poor response (see affidavit of Cereghino and Cesarski) to the Boards questions in this area (letter of October 24, 1986). For example the Board asked about the precision or uncertainty of all temperatures. Applicants typical response (on pp. 4,6 and 8), "The 0
346 F qualification temperature.... should be accurate to one degree. The temperature profiles and temperture computed by thermal lag analysis have not been assigned uncertainty valves,.." Intervenor maintains that an answer such as should be accurate to one degree (no units specified) is not adequate for a formal hearing into the safety of a nuclear plant. Applicants response further reinforces NRC's position that the computer codes used to generate temperature profiles are inadequate and do not give an estimate of the uncertainties involved. Intervenor asks that the Board consider these uncertainties when deciding on the safety and qualifications of ASCO valves and not issue an operating license until they are fully resolved.
Howard M. Deutsch l
Sworn to and subscribed before me this $f[
day of November, 1986.
At2.
Ald)K.)
n Notar ~Public Not:ry 6 ub4Ccor:b,03:3 Cl LCfC3 W% % Mar.8,1989 8
g co_RRSSW CERTIFICATE OF SERVICE AND SERVICE LIST I hereby certify that I have served copies of the foregoing.gg Affidavit on behalf of Intervenor Georgians Against Nuclear %c Energy on the following by placing in the U.S. Mail, first-class postage attached, this the GL6 day of November, - 1986,86 DEC -1 A11 :34 Morton B. Marulies, Chair Atomic Safety & Licensing Atomic Safety & Licensing Board Appeal Board {gn,el U.S. Nuclear Regulatory Commission U.S. Nuclear Reg 41 story. Commhssion Washington, D.C.
20555 Washington, D.C.
20555M Dr. Oscar H.
Paris Docketing & Service Section Atomic Safety & Licensing Board Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Gustave A. Linenberger Bernard M. Bordenick, esq.
Atomic Safety & Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Commission Director Washington, D.C.
20555 Ur.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety & Licensing Board Panel Ruble A. Thomas U.S.
Nuclear Regulatory Commission Southern Company Services, Inc.
Washington, D.C.
20555 PO Box 2625 Birmingham, Alabama 35202 George F. Trowbridge Ernest L.
Blake, Jr.
James E.
Joiner David R.
Lewis Sumner C. Rosenberg Shaw, Pittman, Potts & Trowbridge Hugh Davenport 1800 M Street, N.W.
Troutman, Sanders, Lockerman Washington, D.C.
20036 The Candler Bldg., Ste.1400 127 Peachtree Street, N.E.
Tim Johnson Atlanta, Georgia 30303 Campaign for a Prosperous Georgia 1083 Austin Avenue Brad Jones, esq.
Atlanta, Georgia 30307 Regional Counsel U.S.
Nuclear Regulatory Commission Ste. 3100, 101 Marietta St.
Atlanta, Georgia 30303 Howard M. Deutsch l