ML20032B204
| ML20032B204 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 10/30/1981 |
| From: | Kennedy J, Knight J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20032B200 | List: |
| References | |
| NUDOCS 8111050286 | |
| Download: ML20032B204 (10) | |
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10/30/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
HOUSTON LIGHTING AND POWER COMPANY Docket No. 50-466
)
(Allens Creek Nuclear Generating
)
Station, Unit 1)
)
NRC STAFF TESTIMONY OF JAMES E. KNIGHT AND JAMES E. KENNEDY REGARDING BOARD QUESTIONS ON SCRAM DISCHARGE LEVEL MONITORING SYSTEM Q.
Please state your names and respective positions with the NRC.
A.
My name is James E. Knight.
I am employed by the U.S. Nuclear Regulatory Commission as a Principal Reactor Engineer in the Division of Systems Integration. A copy of my professional qualifications statement is attached.
My name is James E. Kennedy.
I am employed by the Commission as a Scnior Equipment Qualification Engineer in the Equipment Qualification Branch. A copy of my professional qualifications statement is also attached.
Q.
Gentlemen, what is the purpose of your testimony?
l A.
The purpose of this testimony is to respond to questions asked by the Board at the top of page 20 of its September 1,1981 "Second Order Ruling Upon Motions For Summary Disposition." These questions concern i
tne testing that has been or will be done with respect to the differential Ofj1050286811030 ADOCK 05000466 T
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. pressure level transmitter system to be used in the scram discharge instru-ment volume in the Allens Creek design. The specific questions are as follows:
(1) What environmental qualification testing has been or will be conducted on the proposed solid state differential pressure level transmitter system, with what results, and on what schedule?
(2) - Will reliability and operational test information
. i be required before final acceptance of this design departure from earlier systems? What will be the nature and scheduling of the testimony?
Mr. Kennedy will address the first question, and Mr. Knight will reply to the second.
Q.
Mr. Kennedy, would you please respond to the Board's first inquiry?
A.
The transmitters used fo'r measuing the scram discharge volume level at the Allens Creek facility must conform to the Category I environ-mental qualification requirements of NUREG-0588, "Interin Staff Position on Environmental Qualification of Safety-Related Electrical Equipment."
Category I requirements apply to plants now under review for a construction permit and present the WRC Staff's interpretation of IEEE Standard 323-1974, "IEEE Standard for Qualifying Class IE Equipment for Nuclear Power Generating Stations."
The above documents require that equipment be demonstrated to be operable during and after exposure to the environment caused by a design basis accident at the end of its qualified life (usually 40 years).
While the specific parameters of the qualification environment that will be experienced by the differential pressure transmitters have not yet been developed at this stage of the design, it is to be expected that tnat environment will not differ significantly from those already reviewed
. by the Staff for BWR/6's with Mark III containments. Parameters of temperature, radiation doses, pressure, etc. for all plants of a particular design in a particular area of the facility are similar for a given accident.
In lieu of developing the design-specific qualification parameters for Allens Creek, the Applicant could choose to qualify equipment to the generic BWR profile set forth in NUREG-0588.
Q.
Would you briefly summarize the testing required by IEEE-323-1974?
A.
Yes. The stringent testing prescribed by that standard consists of subjecting the same piece of equipment to the following test sequence:
(1) Operate under normal conditions to obtain a data base for comparison with later performance (2) Operate to extremes of all performance and electrical character-istics (3) Age equipment to put it into a condition which simulates the expected end of qualified life condition (usually 40 years, the life of the plant). Thermal, mechanical and radiation aging are included, as applicable i
(4) Subject equipment to in-service mechanical vibration and pre-t dicted seismic vibration (5) Operate while exposed to simulated design basis accident conditions of elevated temperature, pressure, humidity, water spray or j
flooding, as appliceble.
(6) Disassemble and inspect.
I I
J I should point out that the level transmitters used in the scram discharge volume in plants previously reviewed by the Staff have been qualified, but using test procedures set forth in NUREG-0588, Category 2, which does not require that the same piece of equipment be subjected to all of the steps shown above. However, numerous qualification tests in accordance with NUREG-0588 Category I requirements are presently being conducted by the industry to achieve full qualification of all safety-related equipment by June 30, 1982, the Commission imposed deadline, or in the case of Allens Creek, at the operating license stage of review.
In fact, the Clinton facility (a BWR/6 Mark III) operating license review will begin shortly and will incorporate the requirement that the pressure transmitters used in the scram discharge volume meet Category I criteria.
Thus, prior to the operating license stage of review of Allens Creek, there will have been transmitters reviewed and approved by the Staff which are fully qualified to Category I.
Q.
Mr. Knight, would you please respond to the Board's second question?
A.
Yes. The use of the differential pressure measurement method proposed by the Allens Creek applicant to monitor the level i n the scram discharge volume is not new. The method has long been extensively used in both BWRs and PWRs to measure level to provide input for safety functions for reactor vessel and pressurizer level as well as various flow measurements.
Therefore, no special reliability and operational test information beyond that which is normally requirea to qualify any safety related Class IE equipment has been requested. As described by Mr. Kennedy, it is required l
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Q.
How do the pressure transmitters to be used in the scram discharge instrument volume at Allels Creek differ in terms of susceptibility to malfunction compared with the float switches formerly used.
A.
Full range output of the AP level' sensor requires about 0.004 inches movement of a diaphram caused by differential pressure changes, as opposed to the mechanical movement required of float switches; therefore the differential pressure sensors are not subject to the failures which have characterized float switch design. The differential sensors are mounted external of the scram discharge volume and are connected to the scram discharge volume by pipework. This provides the capability for testing the sensors during operation.
Reliability and operability for this system will be assured by frequent testing (monthly) which is in accordance with the Standard Technical Specifications. This contrasts with the past practice of testing of the float switches only during shutdown periods. Technical Specification reporting requirements will identify any frequently occurring failures in the level sensing system whether found during functional testing or ob-served during daily channel checks. Additionally, operational experience will be gained during the preoper.'.'onal test phase for Allens Creek and from other plants (LaSalle, Limeric', Hope Creek 2 and Nine Mile 2) which will operate prior to Allens Creek.
We, therefore, conclude chat sufficient measures are being taken to assure continued reliable scram discharge level monitoring.
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JAMES E. KNIGHT DIVISION OF SYSTEMS INTEGRATION O. S.-NUCLEAR REGULATORY COMMISSION PROFESSIONAL QUALIFICATIONS I am a Principal Reactor Engineer'in the Instrumentation and Control Systems Branch, Division of Systems -Integration, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission.
I serve as a principal reviewer in the area of nuclear power plant instrumentation and control systems in performing and coordinating reviews and evaluations of those portions of the applications for Construction Permits and'0perating Licenses and submittals regarding proposed modifications in licensed nuclear power plants for which the branch has responsibility to assure public health and safety and pmtection of the environment; in this area of review.
I serve as project leader and coordinator of other reviewers for the resolution of highly complex technical issues and licensing problems and provide technical assistance and authoritative advice in the areas relating to the safety aspects of reactor plant instrumentation and control systems and components.
2 I received a Bachelor of Science degree with honors in Electrical Engineering from Lawrence Institute of Technology in 1967. Additional graduate studies were subsequently performed at Wayne State University. Other educational background includes:
1.
Air Force electronics school,12 months; 2.
Air Force instructor training school 3 months; 3.
The Rational Manager (Kepner-Tregoe Course) one week 1973; 4.
Nuclear engineering course covering Boiling and Pressurized Water Reactors -
sponsored by Detroit Edison (6 months) 1974; 5.
Fire Protection for Nuclear Power Plants - NRC sponsored (2 weeks) 1978; Boiling Water R,E' actor Simulator school - NRC sponsored (2 weeks) 1978; 6.
7.
Pressurized Water Reactor Simulator school - NRC sponsored (2 weeks) 1979; 8.
Government Management Seminar II (Kepner-Tregoe Problem Analys:s - Division Analysis Potential Problem Analyses) (1 week) 1980.
I am a registered professional engineer of the State of Michigan, qualified by written examination.
I have been certified since October 1,1970.
_ _ _ _ _ _.. _. ~ ~,... _.. _.
f y.s E. Knight 1: u f m ional qua n f it.aiu.s
~ From 1960 to 1967 I was employed by" Atomic Power Development Associates Incorpor-ated as an instrumentation and controls technician at the Fermi-1 Plant and later as a test facility supervisor responsible for design, installation, maintenance and calibration of instrumentation, centrol and electrical equipment for special process loops and test rigs related to the Fermi i fast breeder reactor and the Government's fast breeder program.
From 1967 to 1973 I was employed as a senior electrical engineer for Atomic Power Development Associates Incorporated (APDA) responsit'e for electrical, instrumentation,
.and control designs and modifications to the Enrico Fermi 1 power plant, the development of electrical testing procedures, analysis of test results Jar the Fermi 1 emergency power systems, and the development of instrumentation for liquid metal cooled reactors.
I acted as an (APDA) consultant to the Cetroit Edison Company for electrical systems on the Fermi 2 BWR.
I was a principal instrumentation and control contributor to a joint APDA, Detroit Edison and Central Research Institute of Electric Power Industry of Japan " Conceptual Design Study of a 350 MWE Demonstration Fast Breeder Reactor." I was a principal investigator in acoustic leak detection studies for nuclear steam supply systems.
From 1973 to 1975 I was employed by the Detroit Edison Company as a senior electrical engineer, acting as system engineer in the project management office of the Enrico Fermi 2 Boiling Water Reactor. As a system engineer I was responsible for management of the design of instrumentation and control systems for safety systems and balance-of-plant systems from concept to final design. Responsibilities included design review and approval, resolu. tion of safety and technical problems, and the development of the safety analysis report on instrumentation and control.
From 1975 to present I have been employed by the Nuclear Regulatory Commission as a Reactor Engineer (Instrumentation) from January 1975 to January 1976 in the Electrical and Instrumentation and Control Systems Branch, Division of Technical Review; from f
January 1976 to September 2,1979 as an Engineering Systems Analyst and Senior Engineering Systems Analyst in the Division of Operating Reactors, from September 2,1979 to March 9,1980 as Senior Electrical Engineer in the Systematic Evaluation Program Branch, from March 9,1980 to May 1981 as Principal Electrical Engineer in the Operating Experience Evaluation Branch, Division of Safety Technology, and from May 1981 to the present as Principal Reactor Engineer in the Instrumentation and Control Systems Branch, t
Division of Systems Integration.
In these capacities, I have been responsible for i
nurerous safety reviews on boiling and pressurized water reactors including activities t
- Jarnes E. L
- '.i gn t 3-Professional Qualifications as a lead reviewer in the fire protection revie.es of fifteen operating reactors subsequent to the Browns Ferry fire.
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s STATEME14T OF PROFESSIONAL QUALIFICATIONS OF JAMES E. KENNEDY Present Employment:
I joined the Nuclear Regulatory Commission in March of 1980.
I am a member of the Equipment Qualification Branch with the title of Senior.
Equipment Qualification Engineer. My duties ar.d responsibilities include the review of licensee and applicant environmental qualification programs for safety-related electrical equipment. This review encompasses identi-fication of equipment, determination of environmental parameters, adequacy of the test programs used for demonstrating qualification, audits of qualification documentation, and inspection of installed equipment at the plant sites.
Previous Employment:
- Saxter Laboratories (various divisions)
(1972 - 1980) dy responsibilities included the following:
Manager of Quality Assurance Departsint for division which produced electrical components.
Supervisicn of a test laboratory which performed environmental tests and life tests on electrical components.
Preparation of test procedures, reports, and design of test equipment.
- Fansteel Inc.
1 (1970 - 1972)
Performed studies of candidate materials for use in the Space Shuttle.
- Fairchild Industries (1968 - 1977)
Various materials engineering tasks related to NASA programs.
Education:
B.S. in Materials Science, Cornell University,1968.
2-Honors Dean's List, Phi Eta Sigma Honorary Fraternity, Cornell University.
Patents:
One U.S. patent, granted in 1978.
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