ML20096B803

Testimony of RW Prunty & PM Yandow in Response to Eddleman Contention 9 Re Environ Qualification of Electrical Equipment.Related Correspondence

ML20096B803
Person / Time
Site:	Harris
Issue date:	08/31/1984
From:	Prunty R, Yandow P CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20096B797	List: ML20096B794 ML20096B803 ML20096B809 ML20096B820 ML20096B828 ML20096B832 ML20096B841 ML20096B854 ML20096B860
References
OL, NUDOCS 8409040357
Download: ML20096B803 (12)

Text

O RELATED Cor ;29CMDMCC l

August 31, 1984-- -l

-00CKETED USNRC

. UNITED-STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION- *84 SEP -4. A11 :15

( $25.Cf' ',SECi'f ~

Before the Atomic Safety and Licensing Board ' -

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.In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket No. 50-400 OL and NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY )

)

l. (Shearon. Harris Nuclear Power )

Plant) ) .

APPLICANTS' TESTIMONY OF ROBERT W. PRUNTY AND PETER M. YANDOW IN RESPONSE TO EDDLEMAN CONTENTION 9 (ENVIRONMENTAL QUALIFICATION OF ELECTRICAL EQUIPMENT) l 8409040357 840831 ~

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'Q.1- Please state your names.

A.1 . Robert W. Prunty and Peter M. .Yandow.

Q.2 Mr. Prunty, please-state your address, present occu-pation and. employer.

A.2 (RWP). I-am employed by Carolina Power & Light Com-panyl("CP&L") as a Principal Engineer in the Electrical and In-strumentation and Control ("I&C") areas. My business address is the Shearon Harris Nuclear Power Plant ("SHNPP"), P.O. Box 101, New Hill, North Carolina 27562.

Q.3 State'your educational background and professional work experience.

A.3 (RWP) I graduated from.the University.of South Carolina in 1971 with a Bachelor of Science degree in Electri-cal Engineering. I have worked in the nuclear field for 13 years.

Upon graduation, I entered the U.S. Navy as a commis-sioned officer through the Naval ROTC program. I attended the Naval Nuclear Power School at Bainbridge, Maryland, and quali-fled as Engineering Officer of the Watch ("EOOW") at the opera-tional Nuclear Power Training Unit reactor in Windsor, Con-necticut. Upon completion of this one-year training program, I attended the Navy's basic submarine school and was assigned to the USS Flasher, an attack submarine in Pearl Harbor, Hawaii.

In 22 months on board I qualified as EOOW and Officer of the Deck ("OOD"), earning my submarine " Dolphins".

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.ILthen attended the advanced submarine school for six months.and was assigned ~to the U.S.S. Daniel Boone, a. ballistic missile. nuclear submarine, spending 16 months of my two-year.

tour -in -the Portsmouth, New Hampshire, : Naval Shipyard during a major overhaul. While on the U.S.S. Daniel Boone, I requalified as EOOW and OOD,.and also successfully completed a comprehensive oral and written examination administered by Naval Reactors-in Washington, D.C. to become certified as Chief Engineer of a nuclear vessel. My work and watchstanding expe-rience on both ships covered the entire array of electrical, I&C, and mechanical systems operation and interaction.

For'the next two years I was assigned as an officer

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instructor at the Naval Nuclear Power. School,- now located in Orlando, Florida, teaching integrated plant operations, tying together the theoretical knowledge of reactor physics, accident analysis, and classical engineering with the overall operation of a nuclear power plant'. I becane division director during the second half of my tour. ll l

In mid-1979 I came to work for CP&L as a Senior Engi-neer in the electrical discipline at the corporate offices in Raleigh, North Carolina. In late 1979 I was made lead electri-

cal engineer of the newly formed Harris Plant Engineering Sec-tion ("HPES") which was established at the SHNPP site. I hav,e subsequently been promoted to Project Engineer and Principal Engineer. I a:m responsible for technical interface with Ebasco in the areas of design and design change control; for field t'

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interface-in the area of design problem and constructability resolution;.for commercial interface with Ebasco, Westinghouse, and numerous SHNPP equipment vendors; for operational interface and operability problem resolution with plant start-up and operations personnel; for quality assurance ,and' regulatory interface with both internal and external groups interacting with CP&L; and for.the Environmental Qualification Program at the SHNPP.

I am a registered professional engineer in the State l-of-Florida and am a member of the Institute of Electrical and Electronics Engineers ("IEEE") and Tau Beta Pi professional en-gineering society.

Q.4 Please elaborate on your professional experience that is directly relevant to the testimony which you are presenting regarding environmental qualification of electrical equipment at the SHNPP.

A.4 (RWP) I have been directly involved in environmental qualification since my assignment as lead electrical engineer

! of the newly formed HPES in December 1979. I was responsible l for the establishment of the SHNPP Environmental Qualification Program and am integrally involved with formulating the SHNPP compliance with 10 C.F.R. 6 50.49, NUREG-0588, and other NRC regulatory directives. Additionally, I am the technical super-visor of the Instrumentation and Control Group and until re-cently was also technical supervisor of the Electrical Group.

These two groups specify and procure a majority of the 4

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-equipment' covered by the Environmental Qualification regula-tions.

Q.5 Mr. Yandow, please state your address, present occu-

[ pation.and employer.

A.5 (PMY)'I am-employed by Carolina Power'& Light Company.

L as an Electrical-Engineer. ~My business address is Shearon Harris Nuclear Power Plant, P.O. Box 101, New Hill, North Carolina 27562.

Q.6 . State your educational background and professional.

work experience.

.A.6 (PMY):I have a Bachelor of Science in Electrical En-

.gineering from Northeastern University in Boston, Mas-sachusetts.

I have worked in the nuclear power field for 10 years. This does not include co-operative engineering work during my years as a student. After graduation from Northeast-ern in~1974, I worked for Stone & Webster Engineering Corpora-tion in Boston, Massachusetts in the Controls Group. I was a trainee in their career development program which included three-month assignments in various parts of the company on var-ious projects. After Stone & Webster engineering, I worked for Combustion Engineering in the Instrument and Controls Design Group.' Combustion Engineering is a nuclear steam supply system manufacturer located in Windsor, Connecticut. During this time I was responsible for backfits on five operating nuclear unit reactor protection systems. This included setpoint calculations of instrument loops.

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In 1978.I was employed by the Yankee Atomic Electric Company-in Framingham, Massachusetts. Yankee ~ Atomic Electric

Company is a design engineering consultant for a group of northeastern utilities. In this assignment I worked in the Instrument and Control Engineering Group as,a e'ngineer. In 1979, I was involved in the first backfits following the issu-ance of-NRC Bulletins 79-01,79-01A, 79-01B (on environmental qualification concerns) and NUREG-0737 (TMI Action Plan). Be-fore leaving.I was Senior Engineer in charge of Instrument and Control Design at Yankee for the Maine Yankee Atomic Power Plant in Wiscasset,-Maine. This included on-site work during two refuelings ar.d support for several others.

In 1983, I joined CP&L as a Senior Engineer in the Instrument & Control Engineering Group at SENPP. I am cur-rently responsible for the Environmental Qualification Program at the SHNPP.

Q.7 Please elaborate on your professional experience that is directly relevant to the testimony which you are presenting regarding environmental qualification of electrical equipment at the SHNPP.

A.7 (PMY) During my ten years of work experience I have worked in the Instrument and Control Area as an electrical en-gineer.. Because the first items of concern in the Equipment Qualification Area were on electrical equipment, I was assigned responsibility to address these concerns. This included training on equipment qualification terminology and techniques O

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in the equipment qualification field. I have contributed to

. utility responses to NRC environmental qualification concerns

=(Bulletins 79-01,79-01A, 79-01B, and NUREG-0588). This in-cludes equipment selection, specification writing, purchasing and installation in operating plants. Durin,g the last year I-have:been assigned to coordinate the environmental qualifica-

-tion effort at the SHNPP. This involves ~ coordination of the efforts of our architect engineer, Ebasco, and NSSS supplier, Westinghouse Electric Corporation, with-respect to the CP&L i

F program at the SHNPP. I also coordinate and work on NRC Infor-mation Notices and Bulletin Responses for the Instrument and

( Control Group of the Harris Plant Engineering-Section.

Q.8 klhrt is.the purpose of this testimony?

A.8 (RWP, PMY) The purpose of this testimony is to de-f-

scribe briefly the program for environmental qualification of electrical equipment at the SHNPP, so that we may place in con-text our testimony and the testimony of Applicants' other wit-nesses which will address specific allegations found in Eddleman Contention 9. Contention 9 states, in its entirety:

The program for environmental qualification L of electrical equipment at Shearon Harris is inadequate for the following reasons:

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l A. The proposed resolution and vendor's l modification for ITT-Barton transmit-

-ters has not been shown to be ade-l quate. (Ref. IE Information Notices 81-29, 82-52 and 83-72).

L i B. There is not sufficient assurance that '

L the concerns with Limitorque valve op-erators identified in IE Information Notice 83-72 (except for Items C2,.C5 and C7) have been adequately resolved.

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C. .It has not been demonstrated that the RTDs have been qualified in that the Arrhenius 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 tempera-- '

' tures. .(Ref. NUREG/CR-1466, ,

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SAND-79-1561, Predicting Life Expec-tancy of Complex Equipment Using Ac-celerated Aging Techniques.)

D. The qualification of instrument cables did not include adequate consideration and analysis of leakage currents re-sulting from the radiation environ-ment. These leakage currents could cause degradation of signal quality and/or spurious signals in Harris instrument cables.

E. There is not sufficient assurance that the physical orientation of equipment -

in testing is the same as the physical orientation of equipment installed.

F. The effects of radiation on lubricants and seals have not been. adequately addressed in the environmental quali-fication program.

G. There is inadequate assurance that failure to report all results of envi-ronmental qualification tests, including failures, has been brought to light in connection with electrical equipment installed in Harris. This includes past test failures of equip-ment which subsequently passes an EQ test and test failures of equipment which is said to be qualified by simi- ,

larity. (Ref. Item 2, Page 5, L. D. i Bustard et al., Annual Report: Equip-ment Qualification Inspection Program, Sandia National Laboratories, FY83).

Q.9 What is the purpose of the program for environmental qualification of electrical equipment at the SENPP?

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A.9 (RWP, PMY) Equipment that is relied on to perform a necessary safety function must be demonstrated to be capable of maintaining functional operability under all service conditions postulate. to occur during its installed life for the time it is required to operate. The purpose of the. environmental qual-ification program for electrical equipment at the SHNPP is to ensure all safety-related electrical equipment and other elec-trical equipment important to safety is qualified to be capable of performing its safety functions in the environment postu-lated for design basis events. Environmental conditions in-clude temperature, pressure, humidity, radiation, chemicals, and submergence.

Q.10 What regulatory requirements apply to Applicants' en-vironmental qualification program?

A.10 (RWP, PMY) The Commission's regulations at 10 C.F.R.

$ 50.49 establish requirements for environmental qualification of electrical equipment important to safety. Equipment "impor-tant to safety" includes safety-related electrical equipment and nonsafety-related electrical equipment whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions by safety-related equipment.

At the SHNPP, all equipment "important to safety" is safety-related. In general, environmental qualification is required to meet General Design Criteria 1, 2, 4 and 23 of Appendix A, and Sections III and XI of Appendix B, to 10 C.F.R. Part 50.

Staff guidance for meeting the regulatory requirements in 10

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C.F.R. $ 50.49 is provided in NUREG-0588 (Revision 1), " Interim Staff Position on Environmental Qualification of Safety Related Electrical Equipment."

Q.11 Where is Applicants' environmental qualification pro-gram' described? ,

A.11 (RWP, PMY) Applicants' environmental qualification program is described in some detail in the Shearon Harris Nu-clear Power Plant Final Safety Analysis Report ("FSAR") at Sec-tion 3.11. FSAR Appendix 3.11A compares Applicants' procedures for environmental qualification of electrical equipment with NUREG-0588. FSAR Section 3.11 and Appendix 3.11A are Appli-cants' Exhibit .

Q.12 In general, how do Applicants ensure electrical equipment is qualified to withstand postulated harsh environ-ments?

A.12 (RWP, PMY) Applicants' program for environmental qualification of electrical equipment is designed in accordance with 10 C.F.R. $ 50.49 and NUREG-0588 (which is endorsed by 10 C.F.R. $ 50.49(k)). The principal elements of Applicants' pro-gram to meet Section 50.49 include:

(1) Identify on the Master List all electrical i equipment required to be environmentally qualifed.

(2) Identify environmental parameters at equipment locations, e.g., radiation, temperature, humidity.

(3) Specify equipment for the appropriate environ-mental parameters in accordance with applicable NRC regulations and guidance and industry standards.

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-(4)- Evaluate vendor l proposals for meeting the speci-fications and evaluate vendor test plans prior to testing.

('5)- Review vendor. environmental qualification re--

zports.

'(6) Assemble Environmental Qualif,1 cation Packages containing'all required documentation.

- ( '7 ) Prepare documentation for NRC Staff audit, including:

(a)-' Environmental Qualification Program Report; (b) Master List;

-(c) Component Evaluation-Sheets; (d) Environmental Qualification Packages.

(8) Respond to any Staff audit findings and requests for additional information.

(9) Qualify all equipment prior to fuel load.

l (10) Monitor NRC and other studies, reports and l Information Notices,.IE Bulletins, vendor information and other i

industry experience for applicability to the SENPP.

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Q.13 How have Applicants organized their direct case in response to Eddleman Contention 9?

A.13 (RWP, PMY) Applicants are presenting a separate piece of testimony on each of the seven specific allegations in 1

Eddleman Contention 9, as follows:

1. " Applicants' Testimony of Robert W.

Prunty, Peter M. Yandow and Richard B.

Miller in in response to Eddle: nan Con-tention 9A (ITT-Barton Transmitters)."

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2. " Applicants' Testimony of~ Robert W.

-Prunty and Peter M. Yandow in Response to Eddleman Contention 9B (Limitorque Valve Operators)."

3. ." Applicants' -Testimony of Richard B.

Miller-and Thomas W. Dakin in Response =

to Eddleman Contention 9C (Thermal

• Aging of RTDs)." ,

4. " Applicants' Testimony of Richard M.

Bucci and Edwin J. Pagan in-Response to Eddleman Contention 9D (Instrument Cables)."

5. " Applicants' Testimony of Richard M.

Bucci, Edwin J. Pagan and Edward M.

McLean in Response to Eddleman Conten-

-tion ~9E (Physical Orientation of Equipment)."

6. " Applicants' Testimony of Richard M.

Bucci, Edwin J. Pagan and Peter M.

Yandow in Response to Eddleman Conten- .

tion 9F (Lubricants and Seals)."

7. " Applicants' Testimony of Robert W.

Prunty, Richard M. Bucci, Edwin J.

Pagan and Kumar V. Hate in Response-to Eddleman Contention 9G (Type Test Re-porting)."'

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