ML20112C908

Proposed Findings of Fact on Contentions 41,116 & 9 Re Pipe Hangers Qa/Qc,Fire Protection & Environ Qualification of Electrical Equipment,Respectively

ML20112C908
Person / Time
Site:	Harris
Issue date:	01/08/1985
From:	Eddleman W EDDLEMAN, W.
To:
References
CON-#185-026, CON-#185-26 82-468-01-OL, 82-468-1-OL, OL, NUDOCS 8501110475
Download: ML20112C908 (20)

Text

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. C$lls. u e"3 DXKUE3 uwC UNITED STATES OF AMERICA qa 8, 19845 NUCLEAR BEGULATOBY COMMISS' SON JM 11 F(e'gyary xtension of the annroved by Staff,

,r,7 er rg,,. Applicants and Board 7 f.F ~. 6 / Jan 2,1985)

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of

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CAROLINA POWER AND LIGHT CO. et al. )

(Shearon Harris Nuclear Power Plant, Unit 1) ASLBP Ho. 82-h68-01

) OL Wells E ddleman's Proposed Findings on Contentions 41

(?ipe Hangers QA/QC),116 (Fire Protection) and 9 (Environmental Qualification of Electrical Equipment)

(With Conclusions and Orders Included)

Under the Board's order of November 15, 1984 (Tr. 7367-7369)

Walls Eddleman hereby files pronosed findings of fact as follow:

CONTENTION 41:

1. The quality assurance reouirenents of 10 CF4 50 Annendix B are mandatory and admit of no exceptions. 10 CFR 50 App B at I:

The applicant shall be resnonsible for the establishment and execution of the quality assurance program. The applicant may delegate to others, such as contractors, agents, or consultants, the work of establishing and executing the quality assurance program, or any nart thereof, but shall retain responsibility therefor. (emphasis added)

The mandatory language "shall" is used throughout Apnendix B.

("CA" )

i The pipe hanger quality assurancejprogram at the Shearon Harris Muclear Pcwer Plant was established and carried out by Carolina Power & Light Comoany (prefiled testinony of Apolicants, passim, following Tr. 6663).

2. In spite of these clear requirements, CP&L's pine hanger CA nrogram at the Harris, plant went through several longstanding programmatic failures; one of the possible " root causes" of these failures (see740 4 was still beine revised at the time of the hearing below) kbo o oo rgra o D93

~2 in Novenber, 1984, or shortly before then (see Tr. 7334, also 7335-6),

i.e. unclear weld inspection criteria. This was so in soite of the fect that pipe hanger inspection had been going on at the Harris clant since early 1979 (Tr. 6673), over 5 years, and in suite of the clear raquirenent of 10 CPR 50 Appendix B. XVI to assure that "the cause of the condition is determined and corrective action taken to preclude rapetition." ,

3 Significant longstanding progranmatic OA failures by CP&L include: (1) From the beginning of the hanger orogram in 1979 (Tr. 6673 )

through at least September 1980 (see, e.g. Maxwell testimony at 72hl-h2 and 7243 in the transcriot), unclear welding synbols, missing synbols and improper welding (vs. both design requirements and quality cceeptance criteria) occurred. See Aeolicants' crefiled at o.15 following Tr. 6663 These failures continued at least until insnector Gsonge Maxwell of tho N90 found them on 3 Rentember 1980 and a subsequent CP&L investigation revealed their widesoread scope.

617 of 1786 hanger drawings included unclear symbols (tr. 7243) and of approxinately 1085 hangers installed by the time of reinsnect?.on, 598 were rejected upon reinspection (a failu-e rate of over 55f;).

Sao Tr.7243 Concerning the t$ning of this inspection and the ransons for Maxwell looking into this hanger area, see below.

(2) extensive

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failures by contaractors to properly l inspect vendor-supplied shon welds. This was complicated by lack of training of personnel, and incorrect training of CP&L inspectors, at the Harris plant site, concerning such welds, e.g. ,

skawed-tee fillet welds. These persisted well into 1982, n n b I

af ter inspections began to show the eroblem[82AM10

. ASee Tr.  ; see also Q&A #s 27, 28 and 29 (op 17-19) of Apolicants ' prefiled testinony as revised November 5, 198h. There was also " inaccurate and Anplicahts' inconelete QC documentation" on these welds (Fuller, A. 28, ibid, prefiled)

(3) improper fabrication of welds (see NRC inspection renort 80-15-01, Staff prefiled testimony at 9 following Tr. 7217) (1980)

(h) failure to follow urocedures for visual examination of welds, failure to follow nrocedures/ instructions for reporting of discrepancies, and failure of inspector to identify and inspect all welds. (Staff inspection recort 82-01-03, ibid.) (1982)

(5) Also in 1982, two NFC insuection renorts (82-03-01 and -02, ,

Staff prefiled testimony at 10, ibid.) document the use of uncertified welding insoectors. bcc, h DN (6) noncompliance with anplicable requirenents continued well into 1983 (NBC inspection renort #83-25 -02, see Eddlenan Exhibit 49 also) and the Staff testified (crefiled at C/A #11 op 10-11, ff$. T". 7217) that CP&L "never adequately addressed" the root cause of these

, problems over the years. By June of 1983, the nroblems had been going on for more than four years since pipe hanger inspection began in 1979 (see finding 1, supra, and Tr. 6673). Thus, at least until June of 1983, CD&L was not conolying with 10 CFR $0 Anoendix B with respect to pine hangers at the Shaaron Harris nuclear plant. Fven Auplicants' witness Hat 6 acknowledged there were times the reouirements were not conn 11ed with (Tr. 6672). Noncono11ance with the requirenent i

of Appendix B XVI to address the root cause continued for four years at least, and there are further probl. ems concerning whether the root cause has been addressed (see Finding h, below) 4 When asked what the root cause of the problem was, the four Staff withesses gave at least three different answers (see Tr. 7321-7327). Witness Ha11strom, who has only looked at a "very ,

small samole" of the Harris nipe hangers (Tr. 7357) believes the root cause was differences in inspection criteria (Tr. 7321-22; see Finding 5 bolow); Witness Maxwell believed it was having the accentance criteria in nore than one document (Tr. 7323-2h); Maxwell was the resident

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' NRC construction inspector from mid-1980 through late 198P (see his qualifications, filed in the nanagement nhase trans crint).

' Paul Bemis of NnC Staff said the root cause was that the insnection 4- " criteria was too broadly internreted " Tr. 7326, But he conceded that clear criteria are recuired by 1C CP9 50 Annendix B, and that Appendix B has always annlied to the Shearon Harris nuclear plant.

Tr. 7327.

Thus, even though the Staff now claims CP&L has addressed the root cause of its nervasive hanger inspection uroblems, they do not egree on what that root cause is. (See also Staff nrefiled Answer 22 following Tr. 721}y. CP&L was s till clearing up (or trying to clear up) wold insnection criteria at the time of the hearing or thar*abouts, November 1984 (see Finding 2 above; Tr. 7334, also 7335-36).

5. Despite the above claims as to root causes of the problems i CP&L persistently had and failed to correct (see FindinE 3, above),

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" virtually all weld accentance OC criteria are things you can measure".

Subnoenaed witness GG "Pete" Tingen, weld insnector at Thearon Harris, (c,wphas;5 ada7J)

Insnectors have standard tools and measuring devices to Tr.716p4 do this at Harris. Tr. 7159-7167, C=&L insnectors ' testimony.

Measurable criteria are about as objective as can be found.

Logically, this testimony of the inspectors themselves shows that these objective criteria, and tools t'o measure them with, were always available for Harris hanger inspections. Thus, the " root causes" claimed by witnesses Ha11strom and Maxwell (differences in inspection 9

criteria, and having insnection criteria in more than one document) l may be valid, but the "cause" claimed by witness Bemis is not credible.

Given the requirement of 10 CFR 50 Appendix B criterion V for well-documented criteria, having two inconsistent sets for years l

is a serious nrogrammatic failure. It also shows CP&L was ineffective I

__-_., _ ___ __.-.~.___, _ _ . _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _

-5 at best in dealing with the requirement of Anoendix B II to" regularly raview the status and adequacy"of the QA nrogram since this inadecuacy norsisted in some form even up to the hearing (unclear accentance criteria, see Hallstron Tr. 733h-7336 and vinding h, n.h, above).

6.Nor was unclear or inconsistent criteria the only major nrogrannatic failure in CD&L's 9hearon Harris pipe hanger OA nrogram. In spite of the identification in 1982 of'inproner insnections and the use of -

uncertified inspectors (see Findt.ng 3 items (4) and (5), p. 3 above),

CP&L did not begin supervisory checks on the work of pine hanger inspectors until the niddle of 1982 (Anplicants' witness Hate, Tr. 7056) 7.CP&L's inspection philosophy seems to be to wait until a nroblem is made obvious and then begin to look for it. This is certainly raflected in their not identifying the unclear weld synbols, miss*rg wald symbols, and inoroner work on hangers before the NRC insuector i

found hanger problems in September 1980 (see Finding 3 item (1)p.2 above).

It is equally evident concerning defective vendor-suunlied walds in 1982 (defective vendor supolied welds had been identified by the Staff as a noncono11ance with N90 regulations in 1980 -- see Finding 3 iten (4) p.3 above). Witness Hate testified (Applicants' prefiled, Answer 21, p.13, ffg. Tr. 6663) that sanoling of vendor l walds (skewed-tee fillet, etc. ) began in May 1982 after nroblems w3re first identified early in 1982. 'That is a gan of a month or pcrhaps several nonths in even beginning sampling. Then, due to I "high reject rate" the CP&L sampling went to 100% insnection in June of 1982f k hN2s same " sample until you see a problem" strategy continues 7kkh-h5 sven now for the " enhanced" CP&L inspection. program (see Tr. 7039 and )

l dasoite its failure in the past. Even with the enhanced nrogram, defects still get by QC insoection (Weld Monitor KA Douglas, Tr. 7192). While The sanpling currently indicates 98.78% of CC-insoected attributes that are reinspected are OK (Tr. 6671,7042) this would have been a minimal inspection quality (if that) to begin with, much less af ter 5 years.

8. CP&L's QA exnert described CP&L's actions on Harris pine hanger CA as " planned and systematic" (Tr. 6673). vat the CP&L panel of witnesses didn't know if Shearon Harris navsonnel we=e trained in the matters covered in Eddleman Exhibit 37 (which, see) before 1 Septenber 1980 (Tr. 6955. On 3 Sentember 1980, N90 insnector Maxwell discovered the pipe hanger nroblems related to these matters for the first time. (See Tr. 72hl.-h2, 7252, Fddleman Exhibit C8).

CP&L failed to have an adeouate " trending nrogram" to "not just stumble over one nroblem and fix it; and stubble over another one I

and fix that ..." (Staff, Tr. 7328; see also Answer 11 in Staff nrefiled at nn 10-11 following Tr. 7217, and Finding 3 item (6) and concluding discussion on p.3 above). Instead, the N90 continued to find uroblems (tr. 7328). The program wasn't working and "we knew it every time wo wrote a violaticn" (Bemis, Staff, Tr. 73?9)

9. Applicants' prefiled testimony states (A.15, p.7, ffg. Tr. 6663):

Early in the hanger erection effort, CP&L studied the hanger erection problems being reported in the industry

, and visited several other sites to gain a better understanding l of current hanger erection and insnection problems.

It was concluded that many of the nroblems ... at other sites ...

could be avoided if insnecti on started as early as nossible * *

• Based on these considerations, the initial hanger insnection program was set up ... (emnhasis added)

It is clear than hanger inspections at Harris began in early 1979 (Applicants ' witness, Tr. 6673; and Finding 2, above ). But it was ravealed on further cross-examination that the visits to other sites ware made, and this study was done, in the 'suring of 1982 -- three years later! (Tr. 7328, Hate for Apolicants). It is equally clear that the decision to set un the initial inspection program was made in early 1979 (see Tr. 6673). The above testimony is definitely contradictory, if not actively misleading.

Taken on its face, it aopears it took the Applicants three years to recognize that there were pipe hanger eroblems in the industry and that they could learn from them (and needed to!). This is the same

slow reaction to problems that has plagued the CP&L Harris pipe hanger QA program (see Findings 3, 6, 7 and 8 above).

Such problems were common knowledge to NRC inspectors even in 1980. (Maxwell,Tr. 7P60). Indeed, soon af ter he arrived at the Harris site (Tr. 7259), Maxwell testified, he " felt compelled" to inspect pipe hangers at Harris "having noticed the industry experiencing sone (see Tr. 7258-60 ) .

problems with welding on pine supports". As noted above, Maxwell was the first to identify nine hanger problems at the Harris niant.

At' mininum, this finding suggests slow reaction by CD&L to a persistent nroblem of their hanger program failing to meet NBC qualify assurance requirenents of 10 CF4 50.Annendix B. It is noted that some of the CP&L panel of witnesses, all of whom were involved heavily in running the Harris pipe hanger progran (or training insnectors) visited plants when CP&L finally did look at other plants for pipe hanger nroblens (Tr. 7023 ft).

10. Quality assurance is an unconditional connitnent by anplicants for NRC licenses (10 CFR 50 Appendix B, e.g. at I). It depends on the commitment the utility itself nade (Maxwell, Tr. 7350) and it is basic that the licensee keen those comnitnents (ibid) Nevertheless, CP&L lot a progrannatic breakdown continue for at least four years in pipe hanger QA, and af ter 5d years was still having trouble clarifying wald inspection criteria (a nossible root c'ause of CP&L's nroblem).

(See Finding 3, above, and Findings ? and 5 above, resnectively)

This is true even though objective criteria were used (see Finding 5).

Nevertheless, the sunervisors heavily involved in the failures documented in this record are still in their jobs at CP&L and we=e ovan presented as principal witnesses on the contention (see qualifica-tions and work experience of the CP&L panel, attached to their testi-many following Tr. 6663). CP&L has not been keeping its commitments to Quality Assurance at Shearon Harris and thus lacks the requisite

character to establish fitness to receive an operating license for the Harris plant.

Contention 116

11. Staff witness Kubicki testified (December 17, 198h confev9nce call (see Tr. 7h16 & following) that for the fire doors listed on I pp 1 of 5 (enclosure 1) and up 2,3,4, and 5 of 5 in that sane enclosure -

(Tr. 7h18) to Apolicants' 10-10-8h fire door and other info submission to the NP.C on fire protection (and highlichted in the "ovember 8, ICSE subnission to the Staff, Tr. 7h19) (this subnission is "ddlenan Exh 61-Tr. 7h20, 7hP1), which have not been tested (Staff hearing testimony),

the following aculy to his analysis:

(A) a yield noint of 1100 degrees F for the Steel of the doors, Tr. 7423 (3) the Sthff uses the ASTM E-119 criteria (tine tennerature j curve) to c.ualify certain fire rated assemblies, such as fire rated l doors (Tr. 7424-25, see at 7425) i i

(C) no check was nade on the heat cauacities or coefficient of thernal expansion for the steel of those doors (Tr. 7h?5)

(D) the fire brigade, by standard assunction, is assuned to extinguish the fire within 30 minutes (Tr. 7hP6-27), and is never assuned to be delayed beyond 30 minutes (Tr. 7h27). However, no snacific analysis of fire brigade response tine for these doors was l nade by the Staff (Tr. 7427) (Feither did Applicants. Tr. h306, nor l

others on the Staff, Tr.h685, 4687-88 (Tberly)).

12. The ASTM E-119 tine tenocrature curve as given in Applicants '

( Ssrbanescu crefiled of 8-09-8h at p.10 (follows 10/10/8h supplemental Sorbanescu testinony following Tr. h256), not challenged by any earty, chows 1000 degrees F in 5 minutes,1300 degrees in 10 ninutes, and 1550 degrees F in 30 minutes.

s 13 The Board takes official notice of the relatively high j (see b Vif 2 7/

thormal conductivity of steel and its modest heat capacity.p These fact' ors, found in standard references, indicate that steel doors can heat un ranidly when exoosed to ASTM E-119 temnera tu-e condit*ons.

The Harris special fire doors are not protected by other fireproofing. Tr. 7423 14 The Staff's " analysis" of fire detection near these doors was basically standard and does not contradict the above (Tr. 7h27-28),

l Although it is witness Kubicki's opinion that the fire would not rsach an intensity able to significantly innact one of these untested l

fire doors, before the fire brigade arrived (Tr. ThP8), his lack of analysis of fire brigade response tines (Finding 11 (D) above) and the fact that the assuned yield point of the door and frame steel, 1100 degrees F (Tr. 7423) is less than would be achieved within 10 minutes in an ASTM E-119 fire (Finding 12, above), and not nuch above

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the 5-minute tenperature in such a fire, indicate there is no l

raliable assurance one of these doors will not fail if a fire occurs.

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15. The frequency of fires significant enough to be reported to the NRC is 32 in 250 reactor years (Staff Exhibit 6, NUSEO-0800, Standard Review Plan section 9.5.1, Fire "rotection, ass p. 9.5.1-9, itan B), or about 1 every 8 years. This suggests k or 5 fires in a 30 or 40 year Harris plant operating life, fires daat could be oignificant. One of these fires could reasonably be in an area ncar one of the approximately 15 fire doors in question here, tho untested steel ones. Because yielding steel can collapse i

(as well as warp -- see Tr. 7h30-31 re warnage), these doors are insufficiently orepared against fire and need to be tested.

This testing can be done with aporopriate physical arrangements (see Tr. 4725) in the aonroximately 10 by 18 foot opening j in a standard test furnace.

Such testing is hereby ordered for each door in question.

16. Anulicants ' chief fire nvotecthn err *neer, ?fargareta Sorbanescu of Ebasco Services, knew before August 9,198h that diesel fuel' oil has a heat content of about 1h0,000 BTU ner gallon. (Tr. hP58, sce also 4266). Nevertheless, the FSAR indicated 95,000 BTU ner Fallon ett and orior to that time (Applicants ' Exhibit 6 and PSAR 9.5.12: 9.5A ) ;

17. Uitness Serbanescu also knew that NFDA (National Five Protection Association) code #37,' issued in 1979 (TR. 4381) was apolicable to Harris, before orefiling testinony on 8-09-8h, annlied to the Harris diesel day tanks. (Tr. h381-82); tha FSAR did not list it even though it says it lists all annlicable codes (Tr. h38P). The Staff believes y NFPA 37,binilar to NFPA 30 (see Tr. h386-h393, h900 etc)) wasn't listed

18. Witness Sberly of NRC Staff said he did not question h; the 95,000 BTU per gallon figure in the FSAM for diesel fuel, though ha knew it was really about 1h0,000 BTU ner gallon for diesel fuel.

Tr. h699-h700,

19. Anplicants updated theiv V'TT pr foot o e. cable insulation l

l for the Harris plant in October,1984 (Sunnlemental testinony, ffg.

Tr. 4256) even though there was cable installed at Farvis well before the testinony nrefiling dated (Tr. hP65) and it could have been neasured b3 fore August 9,1984, the prefiling date (Tr. h272-73; see also 4279).

20. The fact that there are exceptions to the enclosure of all l fire areas within 3-hour rated fire barriers on all sides, was only October 1984 ,

cdded into the psunplemental testimony l it was not stated in the nrefiled of August 9, though it was known. (See, e.g. Waters, Tr. h248-h9)

, 21. While fact 20 above may be in the nature of a correction, the other omissions are more important and logically raise the question

! cf what else may have been lef t out of the Harris FSA9 on fire protection, cnd thus not analyzed or checked against. This is an open question.

For examnle, the Staff testified its analysis was comnlete excent for fire doors (Tr. h714) but did not snecify hg gev hagg n w he t c tentofcableinsulatiN f.q' Fach above).

nsidered

? _?thy? g? ?p ? p?_ ?  ??  !- - -- -

22. Applicants ' witness Waters learned fire u*otection on-the-job (Tr. h305); he doesn't do fire brigade training himself (k312) and there is.odly one independent fire drill critique for the Harris plant planned or required every three years. (Tr. 4310). The tynical nuclear plant fire is an interior, structural fire, but the fire brigade has not yent been trained in a facility that has 'the tynes of things that are tvpical. of a power niant there." Tr. h330-31. Thus, fire .

brigade training is now inadequate; it must be assured on facilities typical of power plants before the Harris plant is allowed to operate.

23. The seals between fire areas are not yet installed at the Harris plant (Tr. h31h-15) and witness Waters, heading the Harris fire (cf.Ans.6, Vaters orefiled, Tr.

protect 4.on nrogran, doesn't know when they will be (Tr. h315). These scals must have the same rating (by test) as the fire barrier (s) they pcnetrate (Tr. 4314). Unless they are verified in place by N#C walkdown tith Ereat care in insnection, the Harris plant cannot ba allowed to operate because it has inadequate measures against the spread of fires. (Contnention 116 critioues the FSA9" analysis" of spread of fires as being just a rationalization. A missing or dpfective or inoroperly installed seal is a way for a fire to spread

, b3 tween fire areas, thus inneriling redundant safety equipment trains rsquired to shut down the plant and avoid a nuclear accident. Cf.

10 CFR 50.k8) -

24 The flame tennerature of burning diesel fuel is about (Tr.?h736,k700) 2000 degrees F. The diesel generator day tanks contain about 3000 gallons of this fuel each (Tr. h69?, h69h-95). This is a deviati.on .

from NFPA 37 requirements forbidding tanks above 1100 gallons inside buildings (Tr. h697-98, also h692, h694-95). The Staff approved the d;viation (Tr. h71h-17) but the Staff doesn't know where the manual ralease for the diesel day tank areas snrinklers is (Tr. k762).

Legically, if the automatic sprinklers fail (or snatter fuel to create on exnlosive mixture which could blow out a door), or a door to the

' day tank area were lef t oven, a very lar6e fire could result, given 3000 gallons and 140,000 ETU cer gallon.

25. Therefore, unusually careful analysis of this tank area is necessary. It is also necessary because the diesel generators to are-the main backup source of powen keep the nuclear plant under control when its other sources of power are lost. It is not clear from'the evidence that sufficient careful analysis has been done, '

especially.in light of the variance on the tank size. Applicants and Staff are instructed to submit additional analysis of these tanks and fire suncression, detection, and explosion nrevention in thei" areas.

Tha doors to the day tank areas should have alarms to indicate if they era ooen. This indication should annear in security stations and in the control room.

26. The Staff denends on Aunlic. .cs Quality Assurance for:

4 radundant fire p"otection seals and construction, Tr. k7h4; installation of suppression and detection systens (Tr. h753). As found above in Fact 10, Applicants' OA orogram is suspect. Therefore the Staff should conduct snecial audits and additional inspections in these areas.

27 The Staff does not know if suppression and detection systems for the Harris plant awe designed in confornance with (the reouired) guidance (Tr. k?52-53). This should also be the subject of additional inr.nections and audits by the Staff. *

28. There is considerable additional information (imnortant to fire protection) that is not in the Safe Shutdown Analysis and

, FSAR 9 5.1 and FSAR 9.5A- (what the Staff reviews, see e.g. Tr. h683):

i Technical Specifications, Fire Protection QA Progran, nrocedures for fighting' fires in the niant, pre-fire plans, etc. (Tr. h706-7). These itsms should be produced as soon as oracticable and then insnected, chscked and audited by the Staff carefully. No license should issue 1to_ such an incomplete program, and certainly not without review.

NSO

29. Contention 116 isgliterally true in a considerablo nunber of respects. Anong the more significant are:

(A) FSAR 9.5A (and 9.5.1.1.1) usually (gives) no analysis of location of (fire) detection instruments. (All extracts from the contention are from Staff testimon7 up 5-6 following Tr. 4653, where the contention is rencoduced). This is literally true not just for these sect!cns, but also for the SSA (Safe Shutdown Analysis), PSAR 9.5.1 and 9.5A (Tr. 4683). Locations are not checked yet by F90 and can't be until the clant is comoleted. Tr. h683-84. This is logical also because construction often results in relocating objects from their designed places, and this may well apply to five detection instruments o= devices.

(B) PSAR 9.5A (snd 9.5.1.1.1) no* assumes ihm . . . the fire brigade will resnond ranidly ... the tits it takes to get peoule ... to the fire (is) not well analyzed ( ) ). The Staff has done no analysis of fire brigade response time. Tr. h685, see also 4687-88. Applicants' faith in rapid response is the personal opinion (Tr. h306) of a verson who l

1 earned fire protection through being assigned to work on it (Tr. 4305).

There just is not the kind of analysis necessary to show daat the brigade can get to fires within the time s costulated.

(C) #9AD 9.5A (and 9.5.1.1.1) *** estimates BTU of conbustible material (in an area ) *** and assumes ' . . . tihe fire brigade will ...

put out the fire, or the automatic eouitment will work.

Serbanescu, 8/09-/84 prefiled at 17-18, states that "by using calorific values for classes of naterials", they "sinnlify" the cniculation. $1 (Follows Tr. h256 and 10-10-8r sunnlemental testimony).

Anolicants' witness Waters does not agree with the word " estimated" (Tr. 4523) but the use of general values for soecific substances clearly can lead to errors. Consider the 95,000 BTU / gallon for combustible L liquids, applied to' diesel fuel with a value of 140n000 (Finding _16. above).____

-1k-Further, the Staff has nerformed no Shearon-Harris-specific analysis of the tenpe=ature curve for conbustibles in the Sheavon Har[is plant. (Tr. h686-87).

(D) The effect of a fire in a f?.re zone or area with a conbustible londing of over 240,000 BTU per souare foot doesn't get dealt with in realistic terms.

Not only has the staff not analyzed the tine-temosrature curve for such conbustibles,(Tr. 4686-87), there is no soecific analysis (other than generalities) about the effects of a fire in the diesel day tank area in the record.

(R) In establishing fire resistance ratings of five barrie=s with respect to fires in cable trays, Applicants have not established that qualification tests represent actual nlant conditions or connarable monditions.

The Staff testified (Tr. h656 ff) that in 1977, they had studies made of tests done vis-a-vis condit'.ons, and accented the AST?' F-119 time temperature curve as renresentative of such a fire (tr. h657 lines 7-11) but they didn't nake any snecific determination for Harris (ibid, lines 16-17). This is more significant in light of the Staff's not having reviewed the cable insulation heat values for Harris yet (Sce Tr. 4731-32, 4749 and Finding 21 above). The NFC Staff also ralies on CP&L's QA program for product (in' stalled)-test (sanele) baing the same (Tr. 4662, lines624 ). Anplicants have not selected and informed N90 of other fire barrier material (Tr. 4663-6h) and the Star.* has no control over this process (T". ?h663). The NRC doesn't chock soecifics (Tr. h66k) and has done no formal study to see if -

higher temperatures (than the ASTM E-119 curve) can be generated (h667) though they did "some studies" (k666).

(F) Another vague statement is that fire barriers are used "whore practical" without defining practical or stating the criteria to . decide where a fire barrier is or is not oractical (and what tyne of fire barrier is to be used).

Such criteria are not laid out in USA 9 9.5.1 - "nowhere" (Tr.

h670, lines 3-17). Sracticality of fire barriers in Sefe Shutdown Analysis is not directly describe'd (Tr. h672, lines 10-12). The only example (not an examole of criteria for practicality) cited was there bsing no barrier in the niddle of the control roon; rather, another chutdown panel is in another location (Tr. 4673, lines 20-24),

(G) The Harris FSAR assunes fire detection devices and automatic cuppression systens will work. Applicants practically concur: Tr. 4521, "our analysis does assume detectors and suooression systens will have power suoplied to them" (Waters). 3at there is no basis for this assunction. All systens fail, so failures in fire protection should bo analysed.

(H) PSA9 9.5.A

• 4

• estinates snoke generation and removal rate.

Most of this analysis was removed (See ADplicants' Fxhibit 6 and l Tr. 4687), but Apolicants are required to analyze the need for snoke l

ramoval per Branch Technical Position CMEB 9.5.1 (Eberly, Tr. h677).

The Harris fire damners are designed to totally shut off flow

( in ducts (Tr. kh60; see also hh65, h678). There is automa tic shut off of HVAC fans if snoke is detected in ducts at the olant (Tr. h679-80),

end smoke renoval capability is now reduced (Tr. h681), but there is not an analysis of why this is done and why it is OK in all cases, or ovan of whether it is better overall, except in the nost general possible tarms. Plant specific analysis is required, and is ordered, on this issue.

Contention 9 30 The Harris niant progran for environmental cualification of electrical equipment is inadequately documented. The Board takes official notice of Staff questions 270.1 through 270.9 (cony attached) concerning this nrogram, transmitted on 5 Decenber 198h, af ter the close of the hearing. The fact that these basic questions were asked is beyond dispute. That they are basic information is equally beyond dispute and undernines all assertions that the Harris PO urogram is adequate.

31. Finding 30 is true even though Aunlicants testified (Prunty and Yandow, Contention 9, prefiled of 8 09-84 following Tr. k971)

(answer 12, pp 10-11) about detailed documentation they had to orepare for N70 Staff review. See item 7, p.11, etc.

32. There have been significant problens with covering un failed tests, and " qualification by similarity" for Rockbestos cable.

(See, e.g. 9andia National Laboratories FY 1983 Annual Renort, as cited in Contentien 90). The Staff has not reviewed Rockbestos cable documents (Masciantonio, Tr. 5624, and has to verify later, Tr. 5627). Because several tynes of cable which had failed tests were "oualified" by similar-ity to FSS-6-104 (which passed one test, but may have failed others),

CP&L cannot rely on gu4lification by simila'rity for its Rockbestos cable unless they track down all EQ tests of (1) the " Qualified" cable to be sure it has not failed in any FQ tests; and (2) the "similar" cables of each type, to be sure none of them have failed. Otherwise, CP8L cannot assure that its Rockbestos cables are really environmentally qualified. The Staff considered 90 (fraudulent testing) not fully rasolved (Answer 9, p.22 at bottom, Masciantonio prefiled following Tr. 5567; see also Tr. 5691). The Board concurs and orders that the above-reguired action be taken by: Applicants and reviewed by theStaff. ]

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M %y WE P Additional Information Required for SHNPP Environmental Qualification Program hgC -

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Note: In all cases in the followin environmental qualification uestions and comments, the

} program referred to is the fY) '

' harsh environment environmental' program in response to l'0 CFR 50.49. r- i .e 270.1' Please describe in detail the methodology used to select (SRP3.11) equipment to be included in the SHNPP EQ program developed in response to 10 CFR 50.49. Your response should address the internal review process used to assure the accuracy and ,

, . completeness of the list of equipment and the criteria used for excluding any equipment item from the program.

, 270.2 Page 3.11.1-1 of the FSAR states that plant safety related (SRP 3.11) systems are identified in Table 3.2.1-1. Please correlate the systems listed on Table 3.2.1-1 with the systems included in the EQ program. For any system listed in Table 3.2.1-1 which is not included in the EQ program, provide the justification for exclusion of the system (e.g., all system components located in a mild environment, etc.). Indicate l

the safety functions of the systems included in the EQ program.

I 270.3 Provide information which demonstrates how the SHNPP EQ (SRP3.11) program complies with the scope of 10 CFR 50.49. Specifi-cally you must address how the EQ program is in compliance with 10 CFR 50.49 (b)(2) and (b)(3) and the requirement that all design basis events have been considered in the development of the list of equipment in the EQ program.

270.4 -Provide a description of the surveillance / maintenance (SRP 3.11) program which will be used to assure that the qualification status of equipment is maintained. Describe also the specific surveillance / maintenance activities to be performed l cn the following types of equipment: cables located inside l primary containment, ASCO solenoid valves, Limitorque motor operators, Barton pressure transmitters.

270.5 Provide detailed descriptions of the methods and assumptions

(SRP3.11) used to take credit for radiation dose, reduction at specific equipnent locations and methods used to calculate the surface temperature of equipment for which credit is taken for thermal i lag. . _

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Pf 90ppse) 270.6 Provide a description of the program used in the environ I - M(ggf (SRP3.11) mental qualification of safety related mechanical equipment fu h in response to the guidance provided in the SHNPP SER. As f p wg,g yg a minimum, the following information should elso be sub-

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--()l) A list of all safety,related mechanical equipment items which includes'the -component description, manufacturer, model number and locotiofr-in the SHNPP.

(b) The qualification status of'each item as established by ~~

the review of qualifjcation documents. .

(c) If the qualification status has not been determined, briefly describe the t' asks that still must be performed.

Please note that the information requested in (a) and (b) above can be effectively' submitted in the form of individual Sumary Component Evaluation sheets.

270.7 Indicate compliance with a one hour time margin for equipment (SRP 3.11) items with operability times less than ten hours, or provide justification for reduced margin.

270.8 Please provide details of the assumptions made and an example (SRP 3.11) of the calculations used to determine the environmental con-ditions due to a high energy line break in areas outside containment. In your response you should address the range of breaks considered in the analysis and assumptions made regarding isolation of pipe breaks.

270.9 Identify, by categories listed in NUREG-0737, the components (SRP 3.11) included in the qualification program in response to TMI Action Plan Requirements.

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35. Other soecific findings re contention 9:

(A) Cable deterioration detection deoends on Auplicants ' RA (Tr. 5686-87).

QA is already found suspect and unreliable above. Periodic recalibra-tion of Resistance Tennerature Detectors (FTDs) also denends on CP&L's

QA (Tr. 4963) and maintenance snecifications are un to CP&L (Tr. h963).

(3) While Dr. Dakin testified that no significant inteFrity damage from enoxy-water interaction (chemical reaction) would occun until after a few years (Tr. h96k), Staff witness Masciantonio nointed out that

(

hunidity cannot be simulated or considered in the ure-aging, and the Arrhenius methodology cannot take into account effects of creen or

machanical stress; therefore accelerated aging information is only qualitative (Tr. 5647-48). Since the tenperatures measured by the RTDs are imnortant measures of primary coolant tencerature (Anps testinony and XE), it is vital that these RTDs be accurately tested and maintained.

(C) Apnlicants are still working on the Limitorque qualification (Apolicants ' witnesses Prunty and Yandow, Tr. k905-96). These valves must be fully qualified if a license were to issue for the Harris plant.

l (D) Contention 90 is broader than just Rockbestos cable orobh ms (Tr. 5660); although witness Masciantonioe t'stified "The staff is kncnly aware of all the concerns raised by Sandia National Laboratories" in their Fiscal Year 1983 findings (prefiled p.21 following Tr. 5567),

when he was asked about the docunent, he didn't know whether items 3, 4 or 5 of those findings applied to the Shearon Harris niant (Tr. 5661, 5662, see also 5664), though he believed he could get the identification of comoanies with those EQ uroblems (Tr. 5659; see also 5663-5664). The Staff has not done any tests of narris electronic squipnent (Tr. 56541)

(E) All orientation and nonwelding insnections of environnentally-qualified equipment positions etc. at Harris are by CI (Construction Inspection) (Tr. 5379-80, witness McLean).3ut as Eddlenan Fxhibit k9 (admission ruling to come, see Tr. 7361; see also Tr. 699h, 7021, 7073-7085, 7207-721h) establishes, NRC insnectors have found CI did not have sufficient indenendence to perform their duties in accordance with an adequate 10 CFR 50 Anpendix 3 QA program.

Further, the Linitorque interface recuironents (also orientation) have not been nronerly addressed (Masciantonio, Tr. 5688). The staff LEends to check orientations later.

(F) Concerning lubricants and seals, the whole device is not qualified (by test) if the drive or connected component is not electrical (Tr. 5h5h-55, witness Yandou). The Mobil study (Annlicants ' nreffled at pp 6-7, following Tr. 5h41) covens lubricants to be used on eouirnent where the lubricant was not qualified with the equienent; see also Tr.

5kh3 Discussion of which euinnent has lubricants and seals, as lished in Apolicants' Exhibit 8 (i.e. identifyingequipment in this list which does nave lubricants and seals) is at pages $459 and following. (Tr. 5h59

& ffg.) The Staff has not reviewed the Mobil study and has no plans to review it (Tr. 5690). The environnental qualification packages concerning lubricants are not done yet (Yandow, prefiled A.17 at p.7 following Tr. $hhl). All of this evaluation needs to ha "ev4.eued by the Staff with care and in denth before any license for Harris operation can issue.

(G) Applicants' witness Bucci testified that the qualification (of eh ctrical equinnent) is demonst~ated when the documentation nacka6e is coneletely assenbled and theecuinnent (test) and the nethod is sent to the NRC as nart of the master lint and they have an onnortunity ho r; view the nackage. (Tr. 5519-20). This must be done before onoration.

CONCLUSION: An onerating license is nrovisionally denied on the basis of Contention 41; other matters re Contentions 116 and 9 must be fully vesolved ner the ahnvn findinea. nvaava ned +b4e n*4== - 4 m