ML20091C498

Affidavit of PM Yandow,Em Steudel & Hw Bowles Re Eddleman Contention 11.Certificate of Svc Encl

ML20091C498
Person / Time
Site:	Harris
Issue date:	05/25/1984
From:	Bowles H, Steudel E, Yandow P CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20091C448	List: ML20091C445 ML20091C467 ML20091C476 ML20091C498
References
NUDOCS 8405300584
Download: ML20091C498 (17)

Text

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DOCKETED USNRC UNITED STATES OF AMERICA 4 NUCLEAR REGULATORY COMMISSION T4 NAY 30 A!0:49 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '

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In the Matter of )

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CAROLINA POWER & LIGHT COMPANY )

and NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL

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(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

AFFIDAVIT OF PETER M. YANDOW, EDWARD M. STEUDEL AND HAROLD W. BOWLES l County of Wake )

I sst State of North Carolina ) .

Peter M. Yandow, Edward M. Steudel and Harold W. Bowles, being duly sworn, cepose and say as followst

1. I, Peter M. Yandow, am a Senior Engineer in'the Elec-q trical Unit, Harris Plant Engineering Section, Nuclear Plant

, Engineering Department, Carolina Power & Light Company. My

! business address is Route 1, Box 101, New Hill, North Carolina 27562. A summary of my professional qualifications and experi-ence is attached hereto as Exhibit A. I have personal knowl-edge of the matters set forth herein and believe them to be i

true and correct.

2. I, Edward M. Steudel, am Manager-Technical Support, Shearon Harris Nuclear Power Plant, Carolina Power & Light

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l Company. My business address is Route 1, Box 101, New Hill, North Carolina 27562. A summary of my professional qualifica-tions and experience is attached hereto as Exhibit B. I have personal knowledge of the matters set forth herein and believe them to be true and correct.

3. I, Harold W. Bowles, am Director of On-site Nuclear Safety, Shearon Harris Nuclear Power Plant, Carolina Power &

Light Company. My business address is Route 1, Box 101, New Hill, North Carolina 27562. A summary of my professional qual-ifications is attached hereto as Exhibit C. I have personal knowledge of the matters set forth herein and believe them'to be true and correct.

OPERATING EXPERIENCE AT BRUNSWICK AND ROBINSON

4. Carolina Powe.r & Light Company ("CP&L") currently op-erates two commercial n'uclear power plants, the Brunswick Steam Electric Plant (" Brunswick"), Units 1 and 2, and the H. B. Rob-inson Steam Electric Plant (" Robinson"). These operating plants are important sources of information for CP&L concerning the performance of equipment and materials, including electri-cal cable insulation, in commercial nuclear power plant appli-cations. CP&L has reviewed the operation and maintenance his-tory of electrical cable insulation used at Brunswick and Robinson in order to determine whether polyethylene or other cable insulation has experienced significant degradation from radiation dose-rate effects.

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5. Brunswick is a Boiling Water Reactor. Unit I has been operating since 1975. Unit 2 has been operating since 1977. Robinson is a Pressurized Water Reactor, as is the Shearon Harris Nuclear Power Plant ("SHNPP"), which has been operating since 1971. The combined operating reactor history of these plants is 29 years.

6. Neither Robinson nor Brunswick uses simple polyethylene cable insulation for safety-related electrical ca-bles. 3runswick uses a variety of cable insulation materials, including cross-linked polyethylene and ethylene propylene rub-ber. Ethylene propylene rubber is the bulk of cable insulation used at SHNPP.1/ Robinson also uses several different kinds of cable insulation. One type of cable used at Robinson has a cross-linked polyethylene jacket.

7. The majority [of safety-related electrical cables at Brunswick and Robinson are located in radiation environments where the dose rate is well below the threshold dose rate of 13 to 25 rads /hr. suggested by the Sandia Studies, i.e., the dose rate below which significant dose-rate effects have not been shown to occur. For example, the cables with cross-linked polyethylene jackets at Robinson are exposed to radiation dose rates of ranging from .007 to 3.14 rads /hr. However, cross-linked polyethylene-insulated electrical cables in the drywell at Brunswick Unit 1 have been exposed to dose rates as high as 1/ See index of cable types attached to Letter from M. A.

McDuffie to Harold R. Denton (April 26, 1983).

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171 rads /hr., for a total 9 year integrated dose of 1.35 x 10E7 rads. This is an order of magnitude higher than the total in-tegrated dose which the radiation zone with the highest dose rate at SHNPP will experience in 40 years of normal full power operation.

8. The results of the review showed no evidence that cable insulation (or other electrical insulation) used in these commercial nuclear power plants exhibits any degradation at-tributable to dose-rate effects. There have been some in-i stances in which cable insulation degradation was detected dur-ing routine maintenance or surveillance tests (e.g.,

embrittlement of a section of cable insulation). This degrada-

! tion was determined in every instance to be the result of im-proper installation (e.g., the cable was allowed to come into contact with hot metal / surfaces). In all cases, cables have been replaced and installation modified. Upon modification, these failures have not reoccurred.

I SURVEILLANCE AND MAINTENANCE

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9. CP&L will have a surveillance and maintenance program l for SHNPP in place prior to fuel loading of Unit 1. CP&L has committed to follow the guidance of Regulatory Guide 1.33, Re-

! vision 2 in designing the surveillance and maintenance program.

The program will include the following program elements: pre-4 ventive maintenance, corrective maintenance and performance

! testing. One function of the program will be to detect signif-icant equipment degradation; this will include meggar testing i

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(testing to measure insulation breakdown) of selected cables as part of preventive maintenance. In addition, CP&L has an oper-ational experience feedback system which will provide informa-tion for maintenance activities.

30. Corrective maintenance will be performed, when re-quired, to assure satisfactory equipment operability. Correc-tive maintenance, when performed in recurring situations on like or similar equipment, will identify component or component part performance trends.

11. Preventive maintenance ccheduled and performed on equipment will identify regular activities to extend component life and assure performance of the component's function. Pre-ventive maintenance procedures will take into account equipment manufacturers' recommendations and operating experience. -

12. Preventive or corrective maintenance that may affect the performance of safety-related equipment will be conducted in accordance with approved procedures, instructions and/or drawings. In addition, good maintenance practice provides that, during performance of maintenance, a visual check of the equipment's condition be conducted, including the condition of cable terminations, in order to detect component degradation.

which may be due to wear and/or inservice aging.

13. Periodic performance testing will be scheduled and performed on a routine basis. These tests are performed to monitor safety system operation. All failures will be analyzed to determine their cause and whether any trend is indicated.

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14. . In addition to the surveillance and maintenance pro-gram, CP&L has an operational experience feedback system which will provide information for maintenance activities. One part of this system is the Nuclear Plant Reliability Data System

("NPRDS"). This program collects failure data, including any failure data relating to electrical cables, from Brunswick, Robinson and other participating nuclear utilities. NPRDS issues periodic reports on the data collected.

15. A second part of the operational experience feedback system is CP&L's Corporate Nuclear Safety Section's system for assuring that nuclear industry operating experience feedback is supplied to the appropriate organizations at SHNPP, Brunswick and Robinson. This responsibility is shared between the Nucle-ar Safety Review Unit in CP&L's corporate office and the Nucle-ar Safety Unit at each plant. The Nuclear Safety Unit at SHNPP performs a detailed evaluation of all INPO Significant Event Reports and Significant Operating Experience Reports, applica-ble Licensee Event Reports from Brunswick and Robinson, and - ,

other industry reports and bulletins. Data supplied to the Plant Operations Department by the Nuclear Safety Unit is fur-ther evaluated and incorporated into maintenance procedures, as appropriate.

16. Similar to the system for monitoring industry experi-ence, the SHNPP Regulatory Compliance Unit reviews NRC bulle-tins, circulars and notices'for applicability to SHNPP, and distributes and tracks such documents to the appropriate SHNPP

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organizations. Data is incorporated into maintenance proce-dures as appropriate.

17. The SENPP surveillance and maintenance program thus will include features that will enable identification of equip-ment degradation. In addition, any cable failures at SHNPP will be rcutinely evaluated by various levels of technical per-sonnel, including nanagement. Final.ly, a comprehensive system is already in place for collect!.ng ar.1 evaluating other indus-try operating experience, including any 3xperience with radia-tion dose-rate effects in cable or other e69ctrical insulation.

Since dose-rato effects on electrical cable or other insula-tion, if they occur, are a long-term phenomenon, there will be ample means for identifying significant degradation before un-safe conditions can ocour.

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i' l EXHIBIT A i Peter Maurice Yandow Senior Engineer Education / Training: Bellows' Free Academy, Fairfax, Vermont - 1969 B.S.E.E., Northeastern University, Boston, Massachusetts - 1974 Experience:

June 1974 to December 1974 Stone and Webster Engineering Corporation, Boston, Massachusetts Enployed as a Career Development Engineer January 1975 to April 1978 Combustion Engineering, Incorporated, Boston, Massachusetts Employed as'a Cognizant. Engineer' for Protection- System for five operating nuclear' power plants. Duties included maintenance of operating systems, detection and solution of design-problems and the procurement of spare and replacement-items.

April 1978 to May 1983 Yankee Atomic Electric'Companyi Framingham, Massachusetts Employed as a Senior. Engineer.

Duties includedfollow-up work- on all major instrumentation systems:

at three operating ~ nuclear plants and one presently being built.

May 9, 1983- Carolina Power and' Light Company. '

Employed as a Senior Engineer in

.the Electrical Unit, Harris Plant

! Engineering Section,1 Nuclear-~ Plant.

l Engineering Department, located at i

New Hill, North, Carolina.

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1 Edward M. Steudel i Manager - Technical Support l Education / Training: E. S. Degree in Electrical Engineering, University of South Carolina, 1964 M. B . A. Degree, Golden Gate University, 1977.

U. S. Naval Nuclear Power Training, 1965 Professional Societies: National Society of Professional Engineers Registered Professional Engineer, Maryland, Ohio, Florida Institute of Electrical and Electronic Engineers American Nuclear Society Association of Energy Engineers Member IEEE Subcommittee SC-6, Related Systems,and Chairman of. Working Grouc 6.5, Safe Shutdown System Civic Organizations: Member of National Association of Regional Council's Steering Committee on Natural Resources and Environment r Toastmasters Club Commander, U.S. Naval Reserve Experience:

September 1981-Present Manager - Technical Support.in the Harris Plant Operations Sec:-ion, Harris Nuclear Project.

September 1980- Principal Engineer.- Special Projects in the September 3981- Environmental & Radiation Control Section of the Nuclear Operations Department.

Located at the Harris ' Energy & Environ-mental Center, New Hill, N.C.

~May 1970-August 1980 Engineering Supervisor - Bechtel' Power Corp.

Gaithersburg, Maryland June _1964-May 1970 U. S. Navy - Submarine Officer-l' l

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EXHIBIT C Harold Bowles Director - On-Site Nuclear Safety Education / Training: South Charleston, WVa High School - 1965 Washington & Lee University, Lexington, Va., BS Physics-Engineering, 1969 U.S. Navy Nuclear Power School, Vallejo CA/ Idaho Falls, ID, 1971 North Carolina State University, Raleigh, N.C., Master of Economics, 1980 Honors: Phi Beta Kapoa, Washington & Lee University, 1969 Navy Achievement Medal, USS Henry L.

Stimson (SSBN 655), 1973 Professional Societies: Member - ANS Registration: Registered Professional Engineer - North Carolina, 1978 Experience:

Carolina Power & Light Company November 19 82 - Present Director - On-Site Nuclear Safety,. Harris Plant. Manage on-site unit responsible for performing Independant Safety Engineering Group and Operational Experience Feedback functions.

October 1981 -

November 1982 Project Engineer - Corporate Nuclear Safety Section. Conducted independent safety review of procedures and equipment associated with Robinson, Brunswick, and Harris nuclear plants. Company interface with EPRI in probabilistic risk assess-ment effort (GO Code).

February 1975 -

October 1981 Nuclear. Engineer III, Senior Engineer, Pro--

ject Engineer - Nuclear Fuel Section.

Supervised subunit responsible for.

nuclear fuel cost projections, fuel' fabrication procurement,'and long-term nuclear fuel cycle economic projections.

Coordinated negotiations on several nuclear fuel-contracts. CP&L Project Manager for-GE/ Brunswick nuclear fuel contract.

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Harold W. Bowles Page 2 ,

January 1974 -

February 1975 Nuclear Engineer, Nuclear Plant Engineering Section. Worked on various projects associated with three-unit B&W Plant, including Fuel Handling Building design and FSAR drafting effort.

U.S. Navy - USS Henry L. Stimpson (SSBN 655) - Electrical Officer, Auxiliary Division Office, Damage Control Assistant; Qualified Engineering Officer of the Watch. Duty tour included shipyard refueling / overhaul (18 months) and two FBM patrols at sea.

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1 00LKETEP U%PC May25,Lg4 !!AY 30 A10:49 LFFICE OF SECEtM r UNITED STATES OF AMERICA COCdEitr4G A SEm: !

BRANCH NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos . 50-400 OL and NORTH CAROLINA EASTEPN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of all the documents listed on the attached Document List were served this 25th day of May, 1984, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.

% st hat./ h.dO/ %

Michael A. Swiger I

Dated: May 25, 1984 l

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3 DOCUMENT LIST

l. Applicants' Motion for Summary Disposition of Eddleman Contentio'n 11.

2. Applicants' Statement of Material Facts As to Which There Is No Genuine Issue To Be Heard on Eddleman Contention ll.

3. Affidavit of Richard M. Bucci.

4. Affidavit of Peter M. Yandow, Edward M. Steudel and Howard W. Bowles.

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[ ,e fi UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00,3 ET,Er v3 %

BEFORE THE ATOMIC SAFETY AND LICENSIS$ SQ M A10 :49 In the Matter of )

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[0C N O' 'N N 'I

) BRANCH CAROLINA POWER & LIGHT COMPANY ) Docket Nos.- 50-400 OL and NORTH' CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

SERVICE LIST Jees L. Kelley, Esquire John D. Rtmkle, Esquire Atmic Safety and Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulat:ory Cmmission 307 Granville Road

! Washington, D.C. 20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atmic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Cm mission P.O. Box 12607

Washington, D.C. -20555 Raleigh, North Carolina 27605 Dr. J ees H. Carpenter Dr. Richard D. Wilson Atcmic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Ommission Apex, North Carolina 27502 Washington, D.C. 20555 Mr. Wells Eddleman Charles A. Barth, Esquire 718-A Iredell Street Janice E. Moore, 5' amire Durh m , North Carolina 27705

. Office of Executive Imgal Director .

! U.S. Nuclear Regulatory Camission Richard E. Jones, Esquire Washington, D.C. 20555 Vice President and Senior Counsel Carolina Power & Light Capany Docketing and Service Section P.O. Box 1551 Offim of the Secretary Raleigh, North Carolina 27602 U.S. Nuclear Regulatory Owiasion Washington, D.C. 20555 Dr. Linda W. Little i

Governor's Waste Managment Board l Mr. Daniel F. Read, Praaidant 513 Alha==rle Building l

OfANGE/EEP 325 North Salisbury Street

! 5707 Waycross Street Raleigh, North Carolina 27611 l Raleigh, North Carolina 27606

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I Bradley W. Jones,-Esquire l U.S. Nuclear Regulatory Ctmission Region II l 101 Marrietta Street

! Atlanta, Georgia 30303 l

l Steven F. Crockett, Esquire At mic Safety and Licensing Board Panel U.S. Nuclear Regulatory Ccunission Washington, D.C. 20555 i Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 l

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