ML20214W664

Forwards Proprietary & Nonproprietary Info Re SER Open Item 1 Issue Concerning Equipment Qualification,Per 861113 Telcon.Info Includes Explanation of Plant Conformance to Reg Guide 1.89,Rev 1.Proprietary Info Withheld (Ref 10CFR2.790)

ML20214W664
Person / Time
Site:	Vogtle
Issue date:	11/26/1986
From:	Bailey J GEORGIA POWER CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
Shared Package
ML20214W666	List: ML20214W664 ML20214W703
References
RTR-REGGD-01.089, RTR-REGGD-1.089 GN-1194, NUDOCS 8612100362
Download: ML20214W664 (11)

Text

-- y Georgia Pbwer Company o -g - pbst Offics Box 282 -

• Waynesboro, Georgia 30830 Telephone 404 554-9961 404 724-8114 Southem Company Services,Inc.

Pbst Office Box 2625 Birmingham, Alabama 35202 Telephone 205 870-6011 g

November 26, 1986 Director of Nuclear Reactor Regulation File: X3ELO1 Attention: Mr. B. J. Youngblood Log: GN-1194 PWR Project Directorate #4 Division of PWR Licensing A U. S. Nuclear Regulatory Commission Washington, D.C. 20555 ,

NRC DOCKET NUMBERS 50-424 AND 50-425 CONSTRUCTION PERMIT NUMBERS CPPR-108 AND CPPR-109 V0GTLE ELECTRIC GENERATING PIANT - UNITS 1 AND 2 SER OPEN ITEM 1: EQUIPMENT QUALIFICATION

Dear Mr. Denton:

As requested during a conference call with your staff on November 13, 1986, we are providing additional information concerning environmental qualification t

issues. The information is provided in the following attachments:

Attachment 1: VEGP Conformance to Regulatory Guide 1.89, Rev. 1, Regulatory Position C.4 (3).

- Attachment 2: Response to Audit Findings Identified in NRC i letter dated November 18, 1986

' A thermal lag calculation for Limitorque actuators is not enclosed. The l

calculation is currently being performed based on the FSAR Section 6.2, i containment analysis (352*F profile). The calculation will be provided by.

' December 5,1986.

A proprietary thermal lag analysis for Eaton cable is enclosed in Attachment

2. It is respectfully requested that the information which is proprietary to Bechtel Power Corporation be withheld from public disclosure in accordance with 10 CFR 2.790 of the Commission's regulations. An application for j withholding along with an affidavit is enclosed in Attachment 2 in response to i

NRC Concern 4.

f b

4 f$5"f88!! ggggg;, _ e,4 ys ,

3

e . . .

Director of Nuclear Reactor Regulation November 26, 1986 Page 2 Should you have any questions, please advise.

Since rely, ,

J. A. Bailey Project Licensing Manager JAB /caa Attachment xc: R. E. Conway NRC Regional Administrator R. A. Thomas NRC Resident Inspector J. E. Joiner, Esquire D. Feig B. W. Churchill, Esquire R. W. McManus M. A. Miller (2) L. T. Gucwa B. Jones, Esquire L. Magleby G. Bockhold, Jr. Vogtle Project File 0894V l

f ATTACHMENT 1 VEGP CONFORMANCE TO REGULATORY GUIDE 1.89, REV. 1 REGULATORY POSITION C.4(3)

The VEGP Equipment Qualification Program conforms to the require-ments of Regulatory Position C4 of Regulatory Guide 1.89 Rev. I which states in part that:

... Justification must include, for each piece of equipment,...the potential need for the equipment later in an event or during recovery operations, a determination that failure of the equipment after performance of its safety function will not be detrimental to plant safety or mislead the operators..."

Implementation of the Equipment Qualification Program for VEGP included the review of the location of safety related (both mild and harsh) equipment to determine the worst case environment that the equipment could be subjected to. This review consisted of a detailed evaluation of the credible events that could be postulated at the equipment locations including high energy line breaks, moderate energy line breaks resulting in flooding, recirculating post-LOCA fluids, and radiation streaming through containment penetrations. Once the worst case environment was established for a location, the qualification documentation for the safety related equipment located there was reviewed to ensure qualification.

For equipment that was identified as not being qualified for the most severe environment, a qualitative assessment was made regarding operability requirements during the harsh environment or to determine the impact of the potential failure of the equipment as a result of being exposed to an environment more severe than its qualification level. For equipment that was not qualified an evaluation was made to address the impact of; o spurious actuation o failure of the equipment to function on demand o loss of the equipment during post-DBE recovery o maintaining required post accident monitoring In cases where this evaluation identified an unacceptable impact, the equipment was relocated, requalified or replaced.

For those cases where it was concluded that equipment would not be required and did not result in unacceptable impacts, qualification to the harsh environment is not required and the SCEW sheets are so annotated.

Regarding the specific components required for LOCA only (containment hydrogen recombiners and the post-LOCA cavity purge fans) our assessment has considered various credible failure modes, including the potential impact of inadvertent actuation, failure of the units to start on demand and failure of the units to de-energize if operating. This assessment concluded that these potential failures would not result in unacceptable impacts to the plant.

The methodology section of the Environmental Qualification (EQ) Report will be revised to include a discussion of the assessments conducted to review the impact of potential failure of equipment not requiring qualification to the most harsh environment at the component locations (i.e.,

...LOCA only). This revised methodology section will be submitted in the updated EQ Report by December 5, 1986.

The design of the plant incorporates the requirements of Regulatory Guide 1.97 regarding post-accident monitoring so that the operators are not reacting to incorrect or misleading information. During the accident mitigation and recovery stages, operator actions are assisted by the use of type A Categcry I PAMS devices which are appropriately qualified for the environment in which they must operate and are uniquely marked on the main control board.

I 1

l l

l l

l l

l l

i

ATTACIIMENT 2 RESPONSE TO AUDIT FINDINGS IDENTIFIED IN NRC LETTER DATED NOVEMBER 18, 1986

NRC Concern 1:

During the audit it was discovered that the containment profiles used to qualify some equipment are different from the profiles provided to the staff in the Vogtle Equipment Qualification (EQ) submittal. The applicant has agreed to provide the new profiles to the staff for review and approval.

GPC Response Based on subsequent discussions with the staff, it has been determined that the temperature profiles for the containment functional analysis presented in FSAR Section 6.2 are an acceptable profile for Equipment Qualification.

The SCEW sheets for equipment that is required to function during the DBA and Post-DBA environments inside containment ,

have been reviewed to insure that existing qualification l documents demonstrate qualification to this temperature i profile with a peak temperature of 3520F. Thermal lag analyses are being performed for all required equipment whose qualification profile did not envelope the require-ments presented in FSAR Section 6.2. The results of these analyses indicate that all required equipment is qualified for the environment in which it must operate inside contain-ment. The thermal lag calculations will be submitted by December 5, 1986.

NRC Concern 2:

10CFR50.49(f) states that:

"Each item of electric equipment inportant to safety must be qualified by one of the following methods:

(1) Testing an identical item of equipment under identical conditions or under similar conditions with a supporting analysis to show 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) Experience with identical or similar equipment under similar conditions with a supporting analysis to show that the equipment to be qualified is acceptable.

(4) Analysis in combination with partial type test '

data that supports the analytical assumptions and conclusions."

The applicant should review the entire Environmental Qualification Program to identify all files that do not meet the requirements of 10CFR50.49 and relocate, requalify or otherwise demonstrate qualification in accordance with the requirements of 10CFR50.49.

GPC Response:

A review of the environmental qualification file was conducted as part of the Document Turnover Program to GPC. This review was conducted to ensure that the documentation referenced in the EQDP for qualification demonstrated that the safety-related equipment used at VEGP has been qualified in accordance with the require-ments of 10CFR50.49 and is properly presented on the SCEW sheets. Discrepancies identified during this review have been corrected by performing additional analyses or by additional qualification documentation from the vendors as appropriate. Resolution of the specific concerns identified during the Environmental Qualification Audit are discussed in response to individual concerns, included in this attachment.

o' e

• During the Environmental Qualification audit the Conax SKV penetration report, which was used to qualify the 15KV penetration, was found to have unacceptable deviations from IEEE 317. Another Conax test report for.8 KV pene-trations was produced and found acceptable provided the test results envelop Vogtle requirements and a similarity analysis be performed. The results of the review and evaluation are provided in a response to NRC Concern 3.

The Conax qualification file (EQDP X3AB03) with the 8KV report and similarity evaluation now meets the requirements of 10CFR50. 49 (f) .

NRC Concern 3:

Conax Electrical Penetration, ISKV Medium Voltage - File No. EQDP-X3AB03 The test report establishing qualification has unacceptable deviations from IEEE Standard 317. The applicant suggested the use of a test report for a dif ferent penetration. This approach is acceptable to the staff, however the applicant must verify that the test conditions envelop the Vogtle specifications and provide an acceptable similarity analysis.

CPC Response:

The qualification of electrical penetration assemblies supplied by Conax is documented in Conax report IPS-473 which is specific for Vogtle. This report compares subcomponents of the Vogtle 15KV penetration to the tested 8KV unit and demonstrates similarity.

Tables 3.1 and 4.4a of IPS-473 show that the design and construction of the penetration used at Vogtle contains the identical leakage paths, leak mechanisms, feedthrough concepts, seals, insulation systems and materials as the tested penetration assembly and that no differences exist between the 8KV penetration and the Vogtle 15KV design which would affect qualification.

The IPS-473 report also demonstrates that the Vogtle penetration assemblies are qualified for the required 41 year life under the conditions specified for Vogtle. The report shows that neither the penetration nor the penetration materials manifest susceptibility to any significant degradation due to thermal aging and radiation and that the penetration is qualified to the specified service levels and conditions of the Vogtle plant.

The qualification for the 15KV penetration assemblies is based on similarity to the 8KV penetration assemblies which were subjected to extreme testing meeting the requirements of Section 6.4 of IEEE standard 317-1976, and thus the requirements for qualification of IEEE standard 323-1974. The 8KV Conax report IPS 585.5 documents the type testing of the 8KV penetration assembly which was subjected to sequential testing in accordance with the requirements of IEEE 317-1976 section 6.4. The tests performed, and the sequence of tests, were more severe than required by IEEE 317-1976 and demonstrated the design integrity of the unit. A review of environmental specification requirements and test data for the 8KV penetration assembly and comparison to the 8KV penetration shows that in regard to every requirement the tested performance meets or exceeds the specified requirements for the 15KV penetrations of the Vogtle plant.

In addition, the materials test information in section 6 and protection test information in Section 7 of IPS 473 shows that the penetration assemblies provided for Vogtle meet all requirements of IEEE 317-1976 and the project specific requirements of specification X3AB03.

0895V

NRC Concern 4:

Eaton 600V Instrument Cable, File No. EQDP-X3AJO4 The technique used to establish qualification is unacceptable.

The applicant agreed to provide heat transfer (Thermal Lag) analysis to establish qualification. Additional calculations, provided to the staff.during the audit, to establish qualified life and post-accident operability were found acceptable.

GPC Response A thermal lag' analysis on Eaton 600V instrument cable was performed in accordance with NUREG 0588 which demonstrated that this cable is qualified for its intended use throughout the plant including the MSIV area considering the effects of superheated steam. This analysis is documented in calculation X6CJH.37 ( Proprie ta ry ) .' The proprietary calculation is attached for your review.

A copy of the information provided to the staff during the audit regarding qualified life and post-accident operability is also attached for your information.

I I

l l

. , , . -.- - . - . . - - - . - - . .