ML18018B763
| ML18018B763 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/31/1984 |
| From: | Masciantonio A Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18018B764 | List: |
| References | |
| OL, NUDOCS 8409130326 | |
| Download: ML18018B763 (25) | |
Text
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(
8/31/84 UNITED STATES OF AMERICA NUCLEAR REGULATORY COllt11 SSION BEFORE THE ATONIC SAFETY AND LICENSING BOARD In the Yiatter of
)
)
CAROLINA POMER AND LIGHT COIIPANY AND NORTH CAROLINA EASTERN MUNICIPAL POh'ER AGENCY (Shearor Harris Nuclear Power Plant,
)
Units 1 and 2)
)
Docket Nos.
50-400 OL 50-401 OL NRC STAFF TESTINONY OF ARIQNDO MASCIANTONIO ON EDDLEYiAN CONTENTION 9 Ql.
Please state your.
name and position with the NRC.
Al.
Yy name is Armando Nasciantonio.
I am employed by the U.S. Nuclear Regulatory Commission as an Equipment Qualification Engineer in the Equipment Qualification Branch, Division of Engineering, Office of Nuclear Peactor Regulation.
I am responsible for the technical reviews, analyses and evaluations of the adequacy of the environ-mental qualification of electric equipment important to safety and safety-related mechanical equipment whose failure under postulated environmental conditions could adversely affect the performance of P,
safety systems in nuclear power plants.
A statement of my professional qualifications is included as Attachment I to this testimony.
Vhat is the purpose of this testimony' A2.
The purpose of this testimony is to address Eadleman Contention 9, which states:
The program for environmental qualification of electrical eouipment at Shearon Harris is inadequate for the following reasons:
The proposed resolution and vendor's modification for ITT-Barton transmitters has not been shown,to be.adequate.
(Ref. IE Information Notices 81-29, 82-52 and 83-72).
B.
C.
D.
E.
F.
G.
There is riot sufficient assurarice that the concerns with Limitorque valve operators identified in IE Information Notice 83-72 (except for Items C2, C5 and C7) have been.
adequately resolved.
It has not been demonstrated that the RTDs have been qualified in that the Ar rhenius thermal aging methodology employed is not adequate to reflect the actual effects of exposures to temperatures of normal operation and accidents over the times the RTDs could be exposed to those temperatures.
(Ref.
NUREG/CR-1466, SAND-79-1561, Predicting Life Expectancy of Complex. Equipment Using Accelerated Aoing Techniques.)
The qualification'f instrument cables did not include adequate consideration and analysis of leakage currents resulting from the radiation environment.
These leakage currents could cause degradation of signal quality and/or spur'ious signals in Harris instrument cables.
There is not sufficient assurance that the physical orientation of equipment in testing is the same as the physical orientation of equipment installed.
The effects of radiation on lubricants and seals has not been adequately addressed in the environmental ovalifica-tion program.
There is inadequate assurance that failure to report all results of environmental qualification tests, including
- failures, has been brought to light in connection with electrical equipment installed in Harris.
This includes past test failures of equipment which subsequently passes an Eg test and test failures of equipment which is said to be qualified by similarity.
(Ref. Item 2, Page 5, L. D.
Bustard et al., Annual Report:
Equipment gualification Inspection 7iogram, Sandia National Laboratories, FY 83.)
g3.
Please describe what is meant by the terms "environmental qualifica-tion" and "environmental qualification program".
A3.
Environmental qualification is the generation and maintenance of evidence to assure that equipment important to safety will operate on demand to meet the necessary performance requirements under all postulated environmental conditions resulting from design basis events.
An Environmental gualificaticn Program is the systematic and formal process employed by a licensee or applicant to demonstrate that equ',pment important to safety is environmentally qualified.
g4.
Mould you describe the standards and the process which the Staff employs in reviewing the adequacy of an applicant's environmental qualification program'?
A4.
The Staff review of the environmental qualification program for license applicants is based or the requirements listed in Section 3.13 of HUREG-0800 (Standard Review Plan);
NUREG-0588, "Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment";
and the final rule, 10 CFR 50.49.
In the review of submittals from Operating License applicants, the Staff must ascertain the following:
Proper definition of postulated environmental conditions
4 Completeness of the environmental qualification program Oemonstrated qualification of equipment items based on supporting documentation.
Ti e information is supplied by the applicant in the FSAR and/or in a separate, comprehensive Equipment ljualification Report.
The postulated environmental conditions are based on the most severe accident for which the equipment is required to operate.
For equip-ment located inside containment, the design basis accident is the Hain Steam. Line Break and Loss of Coolant Accident.
These conditions are reviewed and verified by the Staff.
Outside containment, the environmental conditions in areas which could experience a High Energy Line Break must be calculated and submitted for Staff review.
The guidelines in NUREG-0588 and tlUREG-0737 must be satisfied in the calculation of radiation doses.
In addition to temperature, pressure ard radiation, other environ-mental conditions include humidity, chemical spray and submergence.
~ 0~ ~
lhe environmental qualification program must be complete.
In the review, the Staff verifies that the following equipment items are included in the qualification program:
a) equipment needed to perform the safety functions of emergency reactor
- shutdown, containment isolation, reactor core cooling, containment and reactor heat
- removal, and prevention of significant release of radioactive materials to the environment.
b) nonsafety-related electrical equipment whose failure unoer postulated environmental conditions could prevent the satisfactory accomplishmert of the required safety functions.
c) certain post accident monitoring equipment specified in Regulatory Guide 1.97, Revision 2, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident".
The Applicant must demonstrate environmental qualificatior, of the equipment items included in the qualification program.
In demon-strating qualification, the equipment must be shown to be operable under all postulated environmental conditions.
Vargin must be applied in the qualification program to account for unquantified uncertainties such as the effect of production varia-tions, inaccuracies in test instruments, and errors associated with defining satisfactory performance.
This information is submitted to the staff in the form of summary sheets included in the equipment qualification report.
Upon a determination that the submittal is complete and in conformance with applicable regulations, an audit of the applicant's qualification files is conducted by the Staff.
The purpose of this a~dit is to verify that adequate documentation exists to support a
claim that the equipment is qualified.
Approximately 10$ of the equipment items are selectively chosen for audit.
The actual test procedures and reports are examined to verify that qualification has been established in accordance with accepted standards.
As part of the site audit the actual plant installed equipment is examined to verify that the equipment, as installed, does not invalidate the basis for qualification (i.e., mounting orientation, interfaces, etc.
are representative of the test conditions).
The final aspect of the Staff review is the identification of any corrective actions required as a result of the audit.
A Safety Evaluation Report is prepared by the Staff which lists the findings of the review and audit.
This SER then forms the basis for acceptance of the qualification program.
05.
Are the concerns identified in this contention normally within the scope of the Staff review for Environmental gualification?
A5.
Yes.
All of the concerns identified are normally part of standard NRC review of FSAR Section 3.11 and the Applicant's Environmental gualification Program.
The review will assure that the concerns identified in this contention have been resolved.
The concerns expressed in Eddleman Contention 9 are well known to the hRC Staff.
They are based on the results of NRC sponsored
- research, inspections, or reporting requirements.
The contention does not identify any issue which the Staff is not aware of.
As stated above all of these issues are considered in the Staff's review of each Applicant's environmental qualification program.
The corcerns identified must be resolved to the satisfaction of the NRC Staff before a license is issued.
06.
Have the Applicants indicated how these concerns will be resolved in the Harris environmental qualification program'?
A6.
Information ir response to Eddleman Contention 9 was provided in a letter dated July 25, 1984.
Additional information was requested by the Staff and was provided in letters dated August 24, 19S4.
g7.
Vhat review has the Staff done on the information provided?
A7.
The Staff has reviewed the information provided in the above letters to determine the adequacy of the Harris environmental qualification program in addressing the issues raised by this contention.
In addition, the Staff made a site visit to the Harris plant on August 9 and 10, 1984 to verify the accuracy of the information.
QB.
What are the results of the review and site visit?
A8.
The results of the Staff review and site visit are detailed below for each portion of Eddleman Contention 9:
9A - The proposed resolution and vendor's modification for ITT-Barton transmitters has not been shown to be adequate.
(Ref.
IE Information Notices 81-29, 82-52 and 83-72).
Information Notices 81-29 and 82-52 describe erroneous and noisy output of Barton transmitters (Westinghouse Lot 4, Group A) during High Energy Line Break tests.
The reported problems were apparently due to inadequate contact in the connector assembly.
The proposed corrective action consists of rework of the connector assembly (i.e., resoldering).
The Staff has concluded that this corrective action is adequate.
The results of the Staff review are documented in a Safety Evaluation Report of Westinghouse Equipment Qualification Gocumentation WCAP 8587, WCAP 8587 Supplement 1,
WCAP 8687 Supplement 2, and WCAP 9714, dated August 8, 1983.
Information Notice 83-72 describes two defects which have been identified for the Barton model 763 and 764 transmitters.
The first defect was in the form of thermal non-repeatability resulting in output performance, outside Barton specifications.
The cause of this defect was attributed to a leakage current path through the shafts of the zero and span potentiometers and the mounting brackets.
The proposed corrective action consists of minor mechanical modifications (installation of a fiberglass insulator between the potentiometer shafts and the mounting brackets).
Barton notified the BRC that the reported defect can be eliminated as demonstrated by test on the modified units; however, further I
testing will continue to evaluate long term stability tc ensure that no other undesirable effects have been introduced as a
result of the modification.
The second defect was for the suppressed zero model 763 and exhibited itself in the form of a negative shift in the transmitter output during the initial exposure to operating pressure.
The cause of the defect was identified as due to the combined creep in:
- 1) the link wire between the pressure bourdon tube and strain sensing
- beam, and 2) the materials used to attach the link wire.
Barton is investigating possible corrective actions to eliminate this problem.
A 'Westinghouse analysis irdicates that adequate margir, exists for the Shearon Harris Plant and the observed negative drift is not a safety concern.
This analysis will be reviewed by the Staff for acceptability.
CPKL has stated that all safety related Barton transmitters model 763 ard 764'have been returned to the factory and will remain there until all corrective modifications are implemented.
The Staff review of the Harris environmental qualification program will verify that the reported defects have been corrected and qualification has been established as claimed.
All documents, test results and analyses will be examined.
Before an operating license is issued, the Applicants must provide all necessary information to demonstrate that the reported defects have bee>> corrected.
9B - There is riot sufficient assurance that the concerns with Limitorque valve operators identified in IE Information Notice 83-72 (except for Items C2, C5 and C7) have been adequately resolved.
Limitorque valve operators are oevices typically composed of an electric motor and associated electrical comiponents such as terminal blocks, limit switches, brakes, etc.,
and a gear trair. assembly and are used to open and close valves.
IE Informiation Notice 83-72 identified the following concerns, among others, regarding components used in Limitorque valve operators installed at the Nidland Plants:
1.
The use of terminal blocks which were underrated, unidentifiable, or without proper environmental qualification 2.
Other qualification concerns motor insu)ation ambient temperature ratings orientation of the equipment installation ot drain plugs installed components not in agreement with purchase orders and qualification t>les qualification status of 0-rings lhe pertinent portions of this information notice are attached to this testimory as Attachment 2.
CPKL has proposed an inspection/verification program to assure tha ~ the concerns identified tor the Limitorque valve operators in IE Information Notice 83-72 do not apply to the Harris plant.
The Staff informed CPLL that the proposed sample basis inspec-tion described in the July 25, 1984 fetter was not adequate.
As a result CPEL has agreed to perform a 100'nspection oi'll Limitorque operators included in the environmental qualification program.
Based on a 100'>>'nspection/verification, the Staff finds the proposed resolution of the concerns identified for the Limitorque operators to be acceptable.
9C - It has not been demonstrated that the RTDs have been qualified in that the Arrherius thermal aging methodology employed is not adequate to ref'lect the actual effects of exposures to temperatures of normal operation and accidents over the times the RTDs could be exposed to those temperatures.
(Ref.
NUREG/
CR-1466, SAND-79-1561, Predicting Life Expectancy ot Complex Equipment Using Accelerated Aging Techniques.)
e The statement of considerations accompanying 10 CFR 50.49, states that the requirements listed under Category II of NUREG 0588 apply to nuclear power plants for which the construction permit safety evaluation report was issued prior to July I, 1974.
Shearon Harris must meet these requirements.
The qualification program aging requirements for the Shearon Harris Nuclear Power Plant are detailed in Category II, of NUREG 0588.
This requires that, with some exceptions, the qualification program address aging only to the extent that equipment composed of materials susceptible to aging effects should be identified and a schedule for periodically replacing the equipment and/or materials should be established.
Pre-aging prior to type testing is not required for Category II plants except for equipment containing electronic components in wlich seal failure could make them susceptible to the effects of steam and pressure, and qualification programs committed to the requirements of IEEE Std. 382-1972 (for valve operators) and IEEE Std.
334-1&71 (for motors).
'egulatory Guide 1.33, Rev. 2, "guality Assurance Program Requirements (Operation),"
and the industry standard which it
- endorses, ANSI N18.7-1976/ANS-37 "Administrative Controls arid l}uality Assurance for the Operational Phase of Nuclear Power Plants," contain recommendations for surveillance and main-tenance procedures acceptable to the Staff.
The Applicants have committed to follow the guidance in Regulatory Guide 1.33, Rev. 2, in developing the surveillance and maintenance proce-dures for the Shearon Harris Nuclear Power Plant.
Before an operatinig license is issued the Staff will verify that an appropriate surveillance and maintenance program is implemented.
For the RTDs in question, CPKL has chosen to meet the aging requirements of NUREG 0588, Category 1.
Since pre-aging has been included in the RTD qualification program, the basis for the aging calculations was reviewea during the site visit of August 9 aria 10, 1984.
Based on the results of the review and responses to questions asked by the Staff, the following information was established:
Accelerated aging was based on the Arrhenius methodology.
A number of inaoequacies are inherent in this methodology as pointed out in the existing literature (Ref:
EPRI Report NP-1558, "A Review of Equipment Aging Theory arid Technology;"
NOREG/CR-1466, SAND 79-1561, "Predicting Life Expectancy of Complex Equipment Osing Accelerated Aging Techniques" ).
The Staff is aware of these inadequacies;
- however, as also pointed out in existin9 literature, the Arrhenius methodology is recognized as being the best approach presently available to address accelerated thermal aging and has been used in the qualification program of every nuclear power plant licensed by the NRC.
NUREG/CR-1466, SAND 79-1561 concludes, "Accelerated aging techniques offer the best opportunity for predicting lifetimes or simulating aoe of complex equipment."
In addition, the introduction to EPRI Report NP-1558 states, "Although equipment aging or.
a rigorous scientific basis is beyond the current state of technology, it is nonetheless possible to satisfy the purpose of aging in equipment qualification.
This is true only so long as the intent of aging is to assess qualitatively the vulnerability of equipment with respect to aging effects ard not to achieve aging in the strict sense."
Mithin the context of NRC requirements for environmental qualification, accelerated aging exclusively is not used to address the requirements for establishing a qualified life.
As already stated the Applicants must implement a
surveillance/maintenance program to account'for unantici-pated degradation which is not reflected in the results of the accelerated aging procedures.
Combined with a good surveillance/maintenance program, the Arrhenius methodology is considered an acceptable method of addressing accelerated aging by the Staff for use in establishing a qualified life.
A life of 2C-23 years is calculated for the RTD based on a maximum ambient temperature of 50'C and a 50'C temperature rise due to process fluid, for a total of 100'C (212'F).
Radiation is not the limiting factor in determining lifetime for the Shearon Harris plant.
The 50'C temperature rise for the RTD is based on a
Westinghouse heat transfer analysis which assumes a 620'F coolant temperature and 140'F ambient temperature.
The activation energy was conservatively chosen and a
basis was provided.
A test conducted for the NRC in 1983 by Sandia National Laboratories to determine the steady state temperatures of an RTD housing located inside containment during FVR operations resulted in RTD housing temperatures estimated in the range of 150'F to 200'F for PWR primary coolant temperature of 600'F and containment ambient temperature of 108'F.
The test results are detailed in Sandia National Laboratories "guick Look Report," Tests to Determine Typical Service Temperatures Inside RTD Connector
- Heads, by F. V. Thome, March 25, 1983.
These numbers are consistent with those used in the Shearon Harris calculations.
Based on the information summarized above, the Staff finds that the method used by CPGL to address aging of the RTDs is acceptable.
&D - The qualification of instrument cables did not include adequate consideration and analysis of leakage currents resulting from the radiation environment.
These leakage currents could cause degradation of signal quality and/or spurious signals in Harris instrument cables.
During the site visit of August 9 and 10, 1984 the Staff reviewed three qualification files for instrument cables.
In all cases it was determined that the effects of radiation on the insulatior resistance (IR) of the cable had been included in the qualification program.
Yieasuremer t.of IR gives a
direct indication of leakage current.
.The reports stated that the IR of the cables was measured after radiation exposure as well as other times during the qualification test program.
The results showed little loss of insulation resistance due to the radiation exposure.
As part of the qualification requirements, CPSL must factor any inaccuracies due to environmental effects into instrument accuracy requirements.
Demonstrated envelopment of accuracy requirements will be part of the environmental qualification review.
The Staff recognizes that some materials deteriorate to a
greater degree under long-term doses of radiation than when exposed to the same total dose over a shorter period of time as is usually done in qualification tests.
1n order to account for any unanticipated degradation due to dose rate effects, the Staff requires applicants for an operating license to develop and implement surveillance and maintenance procedures which will detect age related degradation and take corrective action before a safety prob'lem develops.
The Applicants have committed to the guidance in Regu'lation Guide 1.33, Rev. 2, as previously stated, for guidance in developing acceptable surveillance and maintenance procedures.
Based on the above information, the Staff finds the resolution of this concern to be acceptable.
9E - There is not sufficient assurance that the physical orienta-tion of equipment in testing is the same as the physical orientation of equipment installed.
Proper environmental qualification requires that the actual installed configuration of equipment does not violate the tested configuration.
As part of the environmental qualificatior review audit, the installed equipment is examined during a plant walkdown.
The purpose of this walkdown is to verify actual nameplate information, physical orientation of equipment, installation requirements such as requirements for drain holes and sealing plugs, and interface requirements.
The information provided by CPSL concerning their installation review process demonstrates that the physical orientation of equipment is adequately addressed in the qualification program.
This, was verified during the site visit on August 9 and 10 and in the review of a Limitorque qualification file.
- However, further review of this file and two other files showed that interface requirements had not been properly aodressed.
From the documents provided it could not be determined if the test configuration afforded the equipment protection which was not provided at plant installation.
It appeared that during the qualification test the equipment intern'als were sealed and not exposed to the harsh environment and this same degree of sealing was not reflected in the installationi.
CPKL was made aware of -this concern and stated that the situation would be reviewed aria corrected as necessary.
The Staff will select additional pieces of equipment for review during the environmental qualification audit to assure that interface requirements have been adequately addressed.
9F - The effects of radiation on lubricants and seals has not been adequately addressed in the environmental qualification program.
The final rule on environmental qualification, 10 CFR 50.49(c)(4), requires that the electric equipment qualifica-tion program must include and be based, in part, on the radiation environment including total dose during normal operation over the installed life of the equipment, radiation from the most severe design basis accident, ano must include dose rate effects.
Curing the site visit v August g,and 10, CPSL demonstrated in a number of qualification files that radiation had been included in the, qualification program, not only for lubricants and seals, but other orcanic materials.
In the majority of cases radiation is accounted for by actually exposing the equipment, including lubricants and seals, to the total expected dose during the installed life.
In situations where lubricants or seals other than the one tested are to be used, the qualification documents must provide proper analysis or additional data to demonstrate that the lubricant and seals to be used are qualified for the intended application.
The results of the qualification tests ano analyses coupled with a good surveillance/maintenance program will provide assurance that unanticipated degradation is not taking place.
The Shearon Harris environmental qualification program will be further reviewed and additional files will be audited to assure that the effects of radiation on lubricants and seals have been properly addressed.
9G - There is inadequate assurance that failure to report all results of environmental qualification tests, including
- failures, has been brought to light in connection with electrical equipment installed in Harris.
This includes past test failures of equipment which subsequently passes an Eg test and test failures of equipment. which is said to be qualified by similarity.
(Ref. Item 2, Page 5, L. D. Bustard et al., Annual Report:
Equipment {jualification Inspection
- Program, Sandia National Laboratories, FY 83.)
Under i,he requirements of 10 CFR Part 2k, environmental qualification test facilities are obligated to report directly to the NRC all test failures and test results which coulo affect safety.
In addition, quality assurance requirements applicable to vendors and test facilities, detailed in 10 CFR Part 50, Appendix B, require that all results of environmental qualification tests be documented and reported.
Industry standards are also explicit in the requirement to report all qualification test results.
In August 1982, the NRC instituted the Vendor Inspection Program to assess the environmental qualification test facilities'stablishment and implementation of a quality assurance program based on the requirements of 1G CFR Part 50, Appendix B.
As a result of the inspections conducted under this program, numerous nonconformances and violations have been identified which have subsequently been correcteo as verified in follow-up inspections.
The specific case cited (Ref. Item 2, Page 5 of Sandia National Laboratories FY 1983 Annual Report on Equipment (jualification Inspection Programj is based on the results cf one such inspec-tion ax the Rockbestos Company.
As a result of the inspection it was and is still concluded that environmental qualification of Rockbestos cables has not been established based on the documentation provided.
The Staff set forth its findings concerning the Rockbestos company in Information Notice 84-44, which is attached to this testimony as Attachment 3.
As part of that information notice the Staff suggested several possible courses of action which could be taken by users of Rockbestos cables to eualify these cables.
Applicants must demonstrate that this eouipment is suitably qualified before a license is issued.
The Rockbestos Company is currently in the process of implementing corrective actions to their quali-fication programs to eliminate the deficiencies cited.
The results of the Rockbestos requalification activities will be evaluated when they become available.
The Staff is keenly aware of all the concerns raised by Sandia National Laboratories in the FY 1983 Annual Report on the Equipment gualification Inspection Program.
The subject matter and Staff action regarding these concerns have been addressed in the Commission's "Statement of Policy on Environ-mental (jualification" 49 Fed.
Reg.
8422 (March 7, 1984),
and Staff memorandum to the Cormission, SECY-83-457C, dated January 18, 1984.
The Staff review of the Shearon Harris Environmental (jualifica-tion program will include full consideration of the concerns identified an'd responded to in the above documents.
(j9.
Car you summarize the presert Staff position on the Shearon Harris environmental qualification program as related to the concerns idertified in Eddleman Contention 9!
A9.
Based or a review of the information provided by CPKL in letters datec July 25 and August 24, 1984 and the results of the site visit on August 9 and 10, 1964, the Staff finds that the Harris environ-mental qualification program addresses the concerns identified in Eddleman Contention 9 in that the Applicants have demonstrated an awareress of these concerns and have established procedures to correct the inadequacies that may exist at the present time.
The Shearon Harris environmental qualification program will be reviewed to determine conformance with all applicable NRC regula-tions.
Emphasis will be placed on the review of those items identified in this testimony which presently have rot fully been resolved (e.g.
Contention 1tems 9A and 9G).
Proper attention to equipment interface requirements will be a
matter for verification during the audit.
The review of the Shearon Harris environmental qualification program is presently in the beginning stages.
The Applicants must demonstrate full conformance with the reouirements of 10 CFR 50.49.
The ongoing Staff review of environmental qualification of electrical equipment will verify that the Applicant's position is properly implemented and the results of the Staff review will be detailed in a Safety Evaluation Report.
Surveillance and maintenance activities by the Applicants anc future inspections by the NRC should be adequate to detect problems which may arise in the areas of Vr. Eddleman's concerns once the equipment has been qualified.
ATTACHMENT I Professional gualifications of Armando S. Hasciantonio I am an Equipment gualification Engineer in the Environmental gualification Section of the Equipment gualification Branch, Division of Engineering, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission.
I am responsible for the technical reviews, analyses and evaluations of the adequacy of the environmental qualification 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.
Before joining the NRC I was employed as an engineer by Vitro Laboratories Division of'Automation Industries, Inc.
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 quali-fication test plans, procedures and reports and oversee the test and procurement activities in support of qualification.
Prior to that, I was employed at the U.
S.
Naval Surface Weapons Center as a mechanical engineer.
Hy duties involved support of the development, test and evaluation of advanced naval weapons.
I have a B.S.
degree in Mechanical Engineering (1972) from Drexel University, Philadelphia, Pennsylvania and a Masters degree in Mechanical Engineering (1976) from the Catholic University of America, Washington, D.C.
I also hold a Masters degree in Administrative Science (1980) from the Johns Hopkins University, Baltimore, Maryland.