Rebuttal Testimony of W Levis on Behalf of NRC Staff Concerning Limitorque Operators.* Related CorrespondenceML20090J543 |
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Farley ![Southern Nuclear icon.png](/w/images/1/14/Southern_Nuclear_icon.png) |
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Issue date: |
03/13/1992 |
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From: |
Levis W CENTERIOR ENERGY |
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To: |
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Shared Package |
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ML20090J191 |
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References |
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91-626-02-CIVP, 91-626-2-CIVP, CIVP, NUDOCS 9203170296 |
Download: ML20090J543 (6) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20196J3291999-06-28028 June 1999 Comment Supporting Proposed Rule 10CFR50 Re Industry Codes & Standards ML20206M7291999-04-30030 April 1999 Comment Supporting Draft RG DG-1083, Content of UFSAR IAW 10CFR50.71(e). Licensee of Listed Plants in Total Agreement with Comments Provided to NRC by NEI HL-5717, Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC1998-12-18018 December 1998 Comment Supporting Proposed Rule 10CFR50,52 & 72 Re Changes, Tests & Experiments.Util in Total Agreement with NEI Comments to Be Provided to NRC HL-5715, Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments1998-12-14014 December 1998 Comments on Proposed Rule 10CFR50 Re Monitoring Effectiveness of Maint at Nuclear Power Plants.Util Is in Total Agreement with NEI Comments HL-5702, Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols1998-10-23023 October 1998 Comment Supporting NEI Comments Totally on Proposed Draft RG DG-4005, Preparation of Supplemental Environmental Repts for Applications to Renew Nuclear Power Plant Ols HL-5695, Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers1998-10-13013 October 1998 Comment Supporting Nuclear Energy Institute (NEI) Comments on 10CFR50.55(a) Pr, Streamlined Hearing Process for NRC Approval of License Transfers HL-5690, Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC1998-10-0505 October 1998 Comment on Integrated Review of Assessment Process for Commercial Nuclear Plants. Util in Total Agreement with NEI Comments Provided to NRC HL-5983, Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed1998-09-21021 September 1998 Comment on Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors. Snoc in Total Agreement with NEI Comments,To Be Provided to Nrc.Requests That NRC Provide Guidance to Application of NUREG-1022,rev 1 as Listed HL-5682, Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute1998-09-15015 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents, & Endorsing Comments Submitted by Nuclear Energy Institute ML20153B2391998-09-15015 September 1998 Comment on Draft NUREG-1633, Assessment of Use of Ki as Protective Action During Severe Reactor Accidents. Endorses NEI Comments HL-5602, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds1998-04-0303 April 1998 Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds HL-5586, Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps1998-03-0404 March 1998 Comment on Proposed Generic Ltr, Year 2000 Readiness of Computer Sys at Npps HL-5582, Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events1998-02-27027 February 1998 Comment on Draft Reg Guide DG-5008, Reporting of Safeguards Events ML20203B9761998-02-23023 February 1998 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately).Requires That Mcgriff Be Prohibited from Any Involvement in NRC-licensed Activities for Period of 3 Yrs from Date of Dismissal from SNC on 970305 HL-5564, Comment on Draft NUREG 1555, Updated Environ Standard Review Plan1998-01-30030 January 1998 Comment on Draft NUREG 1555, Updated Environ Standard Review Plan HL-5554, Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public1998-01-15015 January 1998 Comment Supporting NEI Comments on PRM 50-63A by P Crane Recommending Emergency Planning Standard for Protective Actions Be Changed to Require Explicit Consideration of Prophylactic Use of Potassium Iodide for General Public HL-5546, Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements1997-12-31031 December 1997 Comment Supporting Proposed Rule & Direct Final Rule on 10CFR50.68 & 10CFR70.24, Criticality Accident Requirements HL-5529, Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard1997-12-0101 December 1997 Comment Opposing Rule 10CFR50 Re Codes & Standards,Ieee National Consensus Standard ML20199J0031997-11-24024 November 1997 Comment Supporting Proposed Rule Re Financial Requirements for Decommissioning Nuclear Power Reactors & Draft RG 1060 HL-5424, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions1997-07-0707 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Tests or Experiments). Encourages NRC Not to Abandon 30 Yrs of Effective Implementation of 10CFR.50.59 for New Positions ML20148N0741997-06-19019 June 1997 Comment on Proposed Suppl to Bulletin 96-001 Re Control Rod Insertion Problems.Util in Complete Agreement That Incomplete Rcca Insertion Not Acceptable HL-5407, Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ1997-05-27027 May 1997 Comment Opposing NRC Proposed Strategies to Address Licensees Need to Establish & Maintain safety-conscious Work Environ ML20132A9171996-11-27027 November 1996 Comment Supporting Draft RG DG-1047, Stds Format & Content for Applications to Renew NPP Ols ML20128M3411996-09-30030 September 1996 Comment on Proposed Generic Communication, Primary Water Stress Corrosion Cracking of Control Rod Drive Mechanism & Other Vessel Head Penetrations ML20116D6491996-07-31031 July 1996 Exemption from Requirements of 10CFR70.24 Re Criticality Monitoring Requirements ML20116G9271996-07-29029 July 1996 Comment Supporting Proposed Rule 10CFR26 Re Mods to Fitness-For-Duty Program Requirements ML20115D1911996-07-0505 July 1996 Comment on Final Rule 10CFR51 Re Environ Review for Renewal of Nuclear Power Plant Operating License.Supports NEI Comments ML20115H1951996-07-0303 July 1996 Comment Supporting Proposed Rule 10CFR50, Reporting Reliability & Availability Info for Risk-Significant Sys & Equipment ML20113C6691996-06-24024 June 1996 Comments on Proposed Rule 10CFR50 Re Financial Assurance Requirements for Decommissioning Nuclear Power Reactors ML20100D1871996-01-29029 January 1996 Comment Opposing Petition for Rulemaking PRM-50-63, Recommending That Planning Std for Protective Actions for General Public Include Stockpile or Predistribution of Ki for Prophylactic Use ML20095D9801995-12-0808 December 1995 Comments on Proposed Generic Communication, Boraflex Degradation in SFP Storage Racks ML20094M9691995-11-13013 November 1995 Comment on Proposed Rules 10CFR60,72,73 & 75, Safeguards for Spent Nuclear Fuel or High-Level Radioactive Waste ML20091Q2711995-08-28028 August 1995 Comment Opposing Review of Revised NRC SALP ML20086N6141995-07-10010 July 1995 Comment on Proposed Generic communication;10CFR50.54(p), Process for Changes to Security Plans W/O Prior NRC Approval. Endorses NEI Comments ML20086M8011995-06-28028 June 1995 Comment on Proposed Review of NRC Insp Rept Content,Format & Style. Util Applauds NRC for Undertaking Endeavor to Make Insp Rept More Effective Tool for Communicating W/Licensees & Public ML20083N4921995-05-0404 May 1995 Comment on Proposed Rule 10CFR50, Primary Reactor Containment Leakage Testing for Water-Cooled Power. Util in Total Agreement W/Nei Comments ML20082K0461995-04-10010 April 1995 Comment on Draft Policy Statement, Freedom of Employees to Raise Safety Concerns W/O Fear of Retaliation. Endorses NEI Comments ML20078J8101995-02-0303 February 1995 Comment Supporting NUMARC Comments on Proposed Rule 10CFR50 Re Shutdown & low-power Operations for Nuclear Power Reactors ML20080G8471995-02-0101 February 1995 Comment on Proposed Rule 10CFR21 Re Procurement of Commercial Grade Items by NPP Licensees.Recommends That New Definitions Be Applicable & Consistent to Licensees Who Hold Other Licenses as Well as Part 50 License ML20085E5381995-01-0505 January 1995 Comment on Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control. Supports NEI Comments ML20077F6561994-12-0101 December 1994 Comment on Proposed Generic Ltr Re Reconsideration of NPP Security Requirements for Internal Threat.Util in Total Agreement W/Nei Comments ML20077E9171994-12-0101 December 1994 Comments on Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal,Proposed Revs.Informs That Util in Total Agreement W/Nei Comments to Be Provided to NRC ML20072T6651994-09-0202 September 1994 Comment on Supplemental Proposed Rule 10CFR51 Re Environ Review for Renewal of Operating Licenses.Util in Agreement W/Nei Comments to Be Provided to NRC ML20072K3331994-08-17017 August 1994 Comment Supporting Petition for Rulemaking PRM-9-2 Re Ohio Citizens for Responsible Energy,Inc Petition ML20072B3711994-08-0909 August 1994 Comments on Proposed Rule 10CFR26 Re Consideration of Changes to FFD Requirements.Licensee in Total Agreement W/Nei Comments ML20071H1321994-06-27027 June 1994 Comment Supporting Proposed Rulemaking 50-60 Re Virginia Power;Filing of Petition for Rulemaking ML20069J5901994-06-0909 June 1994 Comment Supporting Proposed Rule 10CFR170 & 171 Re Rev of Fee schedules;100% Fee recovery,FY94 ML20065P4631994-04-25025 April 1994 Comment Supporting Proposed Rule 10CFR50 Re Codes & Stds for Npps;Subsections IWE & Iwl ML20065P4541994-04-0505 April 1994 Comments on Draft NUREG-1022,Rev 1, Event Reporting Sys (10CFR50.72 & 50.73) Clarification of NRC Sys & Guidelines for Reporting. Util in Total Agreement W/Nei Comments ML20064L8671994-03-11011 March 1994 Comment Supporting Proposed Amends to 10CFR20 Re Radiological Criteria for Decommissioning of NRC Licensed Facilities 1999-06-28
[Table view] Category:TRANSCRIPTS
MONTHYEARML20090J5491992-03-13013 March 1992 Rebuttal Testimony of W Levis on Behalf of NRC Staff Concerning Gems Level Transmitters.* Related Correspondence ML20090J5431992-03-13013 March 1992 Rebuttal Testimony of W Levis on Behalf of NRC Staff Concerning Limitorque Operators.* Related Correspondence ML20091P0381992-01-16016 January 1992 Direct Testimony of Alabama Power Co,Vol Ii.* Testimony of Je Love,Je Sundergill & Dh Jones Re Environ Qualification Issues at Facility.Related Correspondence ML20091P0151992-01-16016 January 1992 Direct Testimony of Alabama Power Co,Vol I.* Testimony of Dh Jones,Bd Mckinney,R Berryhill & Wb Shipman Re Environ Qualification Issues at Facility.Related Correspondence ML20246D9941989-05-10010 May 1989 Transcript of 890510 Meeting W/Util,Westinghouse & Listed Persons Re Hydrogen Gas Intrusion Event at Facility.Pp 1-80 ML20154D6631988-05-0606 May 1988 Transcript of 880506 Public Meeting in Rockville,Md Re Affirmation/Discussion & Vote.Pp 1-7 1992-03-13
[Table view] Category:DEPOSITIONS
MONTHYEARML20090J5491992-03-13013 March 1992 Rebuttal Testimony of W Levis on Behalf of NRC Staff Concerning Gems Level Transmitters.* Related Correspondence ML20090J5431992-03-13013 March 1992 Rebuttal Testimony of W Levis on Behalf of NRC Staff Concerning Limitorque Operators.* Related Correspondence ML20091P0381992-01-16016 January 1992 Direct Testimony of Alabama Power Co,Vol Ii.* Testimony of Je Love,Je Sundergill & Dh Jones Re Environ Qualification Issues at Facility.Related Correspondence ML20091P0151992-01-16016 January 1992 Direct Testimony of Alabama Power Co,Vol I.* Testimony of Dh Jones,Bd Mckinney,R Berryhill & Wb Shipman Re Environ Qualification Issues at Facility.Related Correspondence ML20246D9941989-05-10010 May 1989 Transcript of 890510 Meeting W/Util,Westinghouse & Listed Persons Re Hydrogen Gas Intrusion Event at Facility.Pp 1-80 ML20154D6631988-05-0606 May 1988 Transcript of 880506 Public Meeting in Rockville,Md Re Affirmation/Discussion & Vote.Pp 1-7 1992-03-13
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20090J5491992-03-13013 March 1992 Rebuttal Testimony of W Levis on Behalf of NRC Staff Concerning Gems Level Transmitters.* Related Correspondence ML20090J5431992-03-13013 March 1992 Rebuttal Testimony of W Levis on Behalf of NRC Staff Concerning Limitorque Operators.* Related Correspondence ML20091P0381992-01-16016 January 1992 Direct Testimony of Alabama Power Co,Vol Ii.* Testimony of Je Love,Je Sundergill & Dh Jones Re Environ Qualification Issues at Facility.Related Correspondence ML20091P0151992-01-16016 January 1992 Direct Testimony of Alabama Power Co,Vol I.* Testimony of Dh Jones,Bd Mckinney,R Berryhill & Wb Shipman Re Environ Qualification Issues at Facility.Related Correspondence ML20246D9941989-05-10010 May 1989 Transcript of 890510 Meeting W/Util,Westinghouse & Listed Persons Re Hydrogen Gas Intrusion Event at Facility.Pp 1-80 ML20154D6631988-05-0606 May 1988 Transcript of 880506 Public Meeting in Rockville,Md Re Affirmation/Discussion & Vote.Pp 1-7 1992-03-13
[Table view] |
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4 i 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION :
BEFORE Tile ATOMIC SAFETY ANL) LICENSING BOARJ2 In the Matter of - .)
) Docket Nos. 50-348-CivP l
ALABAMA POWER COMPANY ) 50 364-CivP i )
(Joseph M. Farley Nuclear Plant, )
Units 1 and 2) )
) (ASLBP NO. 91-626-02-CivP)
! REBUTTAL TESTIMONY OF WILLIAM LEVIS ON BElfALF OF THE NRC STAFF CONCERNING LIMITOROUE OPERATORS f Ql. State your full name and current position with the NRC.
A. William Levis, Senior Resident inspector, Davis Besse Nuclear Power Station.
Q2. Have you prepared a copy of your Professional Qualifications?
i A. A copy of my Professional- QualiGeations has been admitted previously into i
evidence as Staff Exh.- 1.
i Q3. What is the purpose of your testimony?
]
f A. The purpose of my testimony is to rebut portions of the Alabama Power Company l (APCo) Testimony regarding violations of the environmental quali6 cation (EQ)-
requirements for the Limitorque Motor Operated Valves (MOVs) at the Farley nuclear plant which led to the civil penalty that is the subject of this hearing. The APCo testimony which is the subject of this rebuttal testimony is contained in 9203170296 920313 PDR ADOCK 05000348 T PDR
2 Direct Testimony of Jesse E. Love, James E. Sundergill and David H. Jones on Behalf of Alabama Power Company (ff. Tr. 9%) (hereafter L/S/J) and Direct Testimony of Philip A. DiBenedetto on Behalf of Alabama Power Company (ff.
Tr,1227) (hereafter DiBenedetto). -
Q4 Are you aware of any 30 day tests of Limitorque motor valve operators in which a motor operator without a T-Drain installed failed the test? (L/S/J._Q&A 162 pp.183 85; DiBenedetto Q&A 160, pp.125-26)
A. No, I am not aware of any test to either support use of Limitorque motor valve operators without T-drains in a long term post LOCA environment or that shows failures of Limitorques without T-drains in that environment. The point is that there have not been opportunities in industry in which a MOV had to operate for 30 days in post LOCA environment. Absent testing to simulate those harsh
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conditions for that period of time, we just do not know how the motors will respond Mr. DiBenedetto's testimony answering APCo Q160 is misleading in .
that he states that he is unaware of any failures without stating basis for his conclusion.
Q5. Would not the information in NUGEQ- Report " Clarification of Information Related to the Environmental Qualification of Limitorque Motorized Valve l>
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4 i
3 Operator," April 1966, and the absence of information regarding the installation of T-drains in test reports 600456 or B0058 lead a reasonable engineer to conclude though Arrhenius techniques and reasonable engineering judgment that T-drains were not required for the environmental qualification of Limitorque -
motor valve operators? (US/J/ Q&A 162 & 163, pp.183 85; Q&A167 & 168, pp.187 90)
A. To begin with, in his answer to question APCo Q162 at pp.184 85, Mr. Sundergill states that "[i]nstallation of T-drains is not revealed anywhere in Test report 600456 or Test Report B0058," I do not agree with that statement, Paragraph 6.0 on page 30 of Test Report B0058 (Staff Exh. 54) describes the design and construction of Limitorque MOVs for use inside containment and states that T drains were one of the features added to permit the actuator to withstand the more severe containment chamber DBE conditions. The paragraph specifically uses the term " chamber," which any reasonable engineer would take l-to mean the test chamber used in qualifying the MOVs,-
Mr, Sundergill's argument that all Limitorque motor valve operators at- -
Farley are covered by test report 600198, the test without T-drains installed, in l
answer to Ql68 is flawed, During the inspection the inspectors acknowledged the existence of the NUGEQ document which discussed the Limitorque issues. Some-equipment items perform their safety function prior to 7 days and are not required
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4 after that time. For that very reason the inspectors stated that the use of the 600198 test report (Staff Exh. 52) could be used for those Limitorque MOVs with short operating times, less that 7 days. However for those valves which have a greater than 7 day operating requirement, the report was not acceptable because the long term effects of moisture were not evaluated. I can not understand how Mr. Sundergill can assume that NUGEQ is endorsing the principle of extending the test. In fact, Mr. Sundergill acknowledges in his testimony that the test can be used if conditions in the test report envelope the plant specific conditions, in the case of valves with a greater than 7 day operating requirement, the test simply does not envelope plant required conditions. As Mr. Sundergill stated in answer to APCo Q167, the -Arrhenius technique shows that the conditions of high temperature for short durations can be equated to a condition oflower temperature for a longer period of time. This demonstrates the ability to withstand these temperatures for a given period, not necessarily the effects of moisture; Q6. Was the issue- of T-drains in _ Limitorque motor valve operators an issue in industry prior to November 30, .19857 (L/S/J/ Q&A 160, p.181; DiBenedetto Q&A 161, pp.126-27)
A. Yes it was. In his answer to APCo Q160, Mr. 'Sundergill states that the T-drain issue " clearly evolved after the EQ deadline" of November 30,1985. I can state
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that I know of several sites where this configuration attribute was checked prior to the deadline For example, on page 13 of the inspection report for a h1 arch 1985 inspection of Crystal River, (Staff Exh. 65) the NRC Staff notes f. tat the licensee planned to verify the presence of T-drains and other details of their Limitorque h10Vs during a h1 arch 1985 outage. Prior to my employmei t with the NRC, the company for whom I worked prior to November 30,1985, had developed a series of checklists for EQ equipment that detailed qualification requirements. The checklist for h10Vs indicated that T-drains were required for those h10Vs in harsh (high energy line break) environments. ,
On page 127 of h1r. Dillenedetto's Direct Testimony, he states that the fact that the T-drain issue was cited at 21 different utilities demonstrates that issue was not a concern of many reasonable and prudent engineers. I do not draw the same conclusion from those facts. I see the NRC consistently applying the same criteria to all licensees inspected. The fact that more facilities were not cited shows that niany reasonable and prudent licensee personnel knew that T-drains were required and properly installed them.
Q7. Is hir. Sundergill correct when he says that he suspects that the Limitorque recommendation regarding the installation of T-drains was offered to you more as a maintenance matter than a qualification matter? (USS Q&A 161, pp.182-83)
6-A. No. In his answer to APCo Q161 at p.183, Mr. Sundergill is misusing the wording I used to describe my conversation with Limitorque. The fact of the matter is that Limitorque would not state to me that it was acceptable not to use T-drains for those MOV's which experience LOCA environmental conditions; In fac* T-drains are shipped with the actuators with accompanying instructions stating to install the T-drains for EQ purposes.
Q9. ' Does this complete your testimony regarding this matter? l A. Yes.
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