ML20079R242

Affidavit of DG Bridenbaugh Re Info in Record on Suffolk County Contention 11 Re Passive Mechanical Valve Failure. Discusses Deficiencies in Inservice Testing Program. Certificate of Svc

ML20079R242
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	06/17/1983
From:	Bridenbaugh D SUFFOLK COUNTY, NY
To:
Shared Package
ML20079R236	List: ML20079R232 ML20079R242
References
ISSUANCES-OL, NUDOCS 8306220141
Download: ML20079R242 (9)

Text

t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

)

Docket Nos 50-322 0.L.

)

(Shoreham Nuclear Power Station)

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AFFIDAVIT OF DALE G. BRIDENBAUGH STATE OF CALIFORNIA

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)

ss.

COUNTY OF SANTA CLARA

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DALE G.

BRIDENBAUGH deposes and says under oath as follows:

My name is Dale G.

Bridenbaugh.

A statement of my qualifications and experience has previously been provided to this Atomic Safety and Licensing Board (Board) as part of my testimony on several Suffolk County Contentions (see Statements

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8306220141 830620 DR ADOCK 05000 2

of Qualifications of Suffolk County Witnesses submitted on April 12, 1982).

This Affidavit relates to Suffolk County (County)

Contention 11 (Passive Mechanical' Valve Failure) informatiou

~that has been entered into the record in the form of testimony, cross-examination, findings of fact, and supplemental evidence and findings of fact.

On May 26, 1983, the Licensing Board issued a " Memorandum and Order Directing Clarification of Certain Matters Related to Contention SC 11" which requested that the NRC Staff and the Applicant address certain issues related to this contention.

Both Staff and Applicant submitted documents dated June 10, 1983, (NRC Staff Response to Board j

Question on Passive Mechanical Valve Failures and Response to the Board's Memorandum and Order Directing Clarification of 4

[

Certain matters Related to Contention SC 11).

I have reviewed I

i these documents and have the following comments to which I attest:

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1.

The June 10, 1983 Aff.idavit of John A. Rigert states that 579 of the 1,268 safety related valves in the Shoreham IST

. program are check valves.

Of these 579 check valves, 168 are in piping systems and 411 are in the hydraulic control units.

I have examined the IST program and agree that the correct numbers of valves have been specified in the program.

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further agree with the statement of Mr. Rigert that a test or L

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tests for each of the check valves is specified in the IST

' program.

By this agreement, it should not be construed that I find the IST program fully satisfactory.

I still find deficiencies in the IST program as follows:

o Mr. Rigert states that each and every check valve in the IST program is to be tested for operability in one of three ways:

forward flow testing, reverse flow testing, or both forward and reverse flow testing (Rigert Affidavit, p. 3, para. 5).

The criteria stated by Mr. Rigert for judging which of the three stated test conditions is to apply is that the selection is based upon the required valve response to system flow conditions during system operation (p. 3, para. 5).

In my judgement, the test selection criteria stated above is overly simplistic and may be inadequate to assure that all significant failures will be detected.

This was precisely one of the points made by IE Bulletin 83-03 with regard to the Dresden and Quad Cities check' valve failures.

As stated in the Bulletin, it is doubtful that a normal forward flow test would have discovered the latent failures.

It is my opinion that a more sophisticated failure analysis should be performed for each of the,

valves.

Such an analysis could determine unusual i

failure modes that might occur, could quantify more accurately the test acceptance criteria, and could i

identify the need for augmented action, such as periodic. disassembly, additional position indicators,

-etc. for valves determined to be "high risk".

Evidence of.such a comprehensive analysis is not found in the Affidavit, the IST program documentation, nor in the record materials.

Mr. Rigert's Affidavit implies that the majority of o

the 579 check valves are tested on a quarterly basis as generally required by ASME Section XI.

I reach this conclusion from the statement contained on page 4, last sentence of 1 6 of his Affidavit which states that "unless a specific relief request has been filed pursuant to the ASME Code, the testing frequency for l

these valves is once every three months."

I have reviewed the.IST program and relief requests and find l

that a total of 446 of the 579 check valves (77 I

percent) have had relief requests filed for relief from the quarterly testing.

This means that only 23%

of the valves are actually being tested in accordance with the ASME Code specified frequency.

The valve in e '

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compliance with Code test frequency is therefore the exception rather than the rule.

The Shoreham IST relief requests apply to 383 of the 411 HCU check valves, to 58 of the 162 regular check valves and to 5 of the 6 stop check valves.

As previously stated by the Applicant, virtually none of the systems check valves have position indicators, so the primary defense against undetected failure is the test program.

The Shoreham test program statistics do not give a large degree of confidence that timely detection will be the rule.

2.

The discussion in Mr. Rigert's Affidavit on page 5 concerning the investigation by LILCO regarding the use of a computerized program to ensure responsive testing and maintenance is,certainly a desirable action to be taken, but i

this system is not yet in use at Shoreham and the Affidavit and the accompanying response by LILCO.are not a commitment that I

such a system will in fact be installed and utilized.

Even if it is implemented, it is important to emphasize that a reactive system such as this, or a program such as the Applicant's

.previously cited ISEG program, cannot obviate the need for a systematic and disciplined failure analysis. _

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3.

The NRC Staff information contained in the June 10, 1983 Affidavit of Ralph Caruso,. is relevant to this issue but it too does not provide the systematic analysis I believe is needed.

The reports discussed in paragraphs 6, 7, and 8 on page 3 of the Affidavit which discuss compilations of valve experience data taken from commercial nuclear power plant reports in recent years are also reactive types of studies.

Some of the data cited are generic and thus may not directly apply to the valves installed at Shoreham.

The other data are specific, but there is no indication that the resulting experience has been directly utilized in specifying test requirements, frequencies, or other unique actions at Shoreham.

I recommend that this information be utilized in the development of acceptance criteria for the valve test time extensions requested by LILCO for evaluating the relief requests pertaining to the 446 check valves described above.

4.

My concern has been and continues to be that no formal studies appear to have been conducted to substantiate the adequacy of the valve test effectiveness and frequency that will be effectuated by the Shoreham IST program.

Similarly, little analytical work exists to substantiate that the level of position indication provided for the Shoreham valves is

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adequate to provide timely indication of passive r:achanical valve failures.

m DALE G.

BRIDENBAUGH Subscribed nd sworn to before a[_7th day of 1983.

M m

E f

OTARY PUBLIC NOTARY PU3LIC CALIFORNIA i l

COUNTY OF SANTA CLARA f

My commiss on expires:

July 28, 1986

{

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

)

)

Docket No. 50-322 (0.L.)

(Shoreham Nuclear Power Station,

)

Unit 1)

)

)

CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY REPLY TO LILCO AND NRC STAFF SUBMISSIONS ON SC CONTENTION 11, dated June 20, 1983, have been served to the following by U.S. Mail, postage prepaid, this 20th day of June, 1983, except as other-wise indicated.

• Lawrence J. Brenner, Esq.

Ralph Shapiro, Esq.

Administrative Judge Cammer and Shapiro Atomic Safety and Licensing Board 9 East 40th Street U.S. Nuclear Regulatory Commission New York, New York 10016 Washington, D.C.

20555 i

Howard L.

Blau, Esq.

Dr. James L. Carpenter 217 Newbridge Road Administrative Judss Hicksville, New York 11801 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission

• *W. Taylor Reveley III, Esq.

Washington, D.C.

-20555 Hunton & Williams P.O. Box 1535 707 East Main St.

• Dr. Peter A. Morris Richmond, Virginia 23212 Administrative Judge Atomic Safety and Licensing Board

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U.S. Nuclear Regulatory Commission Mr. Jay Dunkleberger Washington, D.C.

20555 New York State Energy Office Agency Building 2 Edward M. Barrett, Esq.

Empire State Plaza General Counsel Albany, New York 12223 Long Island Lighting Company 250 Old Country Road Mineola, New York 11501 Stephen B.

Latham, Esq.

Twomey, Latham & Shea Mr. Brian McCaffrey P.O.

Box 398 Long Island Lighting Company 33 West Second Street 175 East Old Country Road Riverhead, New York 11901 Hicksville, New York 11801 r.

Marc W. G31dcmith Mr. Joff Smith

. Enorgy Roccarch Group, Inc.

Shorehrm Nuclear Powar Station 400-1 Totten Pond Road P.O.

Box 618 Waltham, Massachusetts 02154 North Country Road Wading River, New York 11792 Joel Blau, Esq.

MHB Technical Associates New York Public Service Commission 1723 Hamilton Avenue The Governor Nelson A.

Rockefeller Suite K Building San Jose, California 95125 Empire State Plaza Albany, New York 12223 Hon. Peter Cohalan Suffolk County Executive David J. Gilmartin, Esq.

H. Lee Dennison Suffolk County Attorney Building H.

Lee Dennison Building Vetsrans Memorial Highway Veterans Memorial Highway Hauppauge, New York 11788 Hauppauge, New York 11788 Ezra I. Bialik, Esq.

Atomic Safety and Licensing Assistant Attorney General Board Panel Environmental Protection Bureau U.S. Nuclear Regulatory Commission New York State Department of

' Washington, D.C.

20555 Law 2 World Trade Center Docketing and Service Section New York, New York 10047 Office of the Secretary U.S. Nuclear. Regulatory Commission Atomic Safety and Licensing Washington, D.C.

20555 Appeal Board U.S. Nuclear Regulatory

• Bernard M.

Bordenick, Esq.

Commission David A.

Repka, Esq.

Washington, D.C.

.20555 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Matthew J. Kelly, Esq.

Staff Counsel, New York Stuart Diamond State Public Servi ~ce Comm.

Environment / Energy Writer 3 Rockefeller Plaza NEWSDAY Albany, New York 12223 Long Island, New York 11747 Stewart M. Glass, Esq.

• Daniel F.

Brown, Esq.

Regional Counsel Atomic Safety and Federal Emergency Management Licensing Board Panel Agency U.S. Nuclear Regulatory Commission 26 Federal Plaza Washington, D.C.

20055 New York, Nov York 10278 James B. Dougherty, Esq.

3045 Porter Street, N.W.

Washington, D.C.

20008 Gwte*w I

Lawrence Coe Lanpher KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS DATE: June 20, 1983 1900 M Street, N.W.,

8th Floor Washington, D.C.

20036 By hand

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By Federal Express

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