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AUG 2 6 1982 Dodet no. 90 382 PEMDRANDtM FOR:
Thomas H. Novak. Assis tant Director for Licensing Division of Licensing FRON:
William V. Johnston, Assistant Director Materials and Qualifications Engineering Division of Engineering
SUBJECT:
WAlERFORD UNIT 3 - AFFIDAVIT CONCERNING UllPESOLVED GE!ERIC SAFETY ISSUE A-46 Attached is an Affidavit of T.V. Chang conceming unresolved generic safety issue A-46 (seismic qualifications of equipment) for Louisiana Power and Li'1ht Company's Waterford Unit 3.
The Affidavit i s in response to an order of the ASLB for Waterford Unit 3.
The primary mytower for this plant is T.Y. Chang. The Affidavit was prepared with the assistance of Mary Haughey, the alternate reviewer, and Gouta:n Banchi.
Section Leader. Seismic and Dynamic Load Qualification Section.
.o the event that testimony is mquired. we would appreciate being infonned as early as possible regarding the schedule for the heartnq.
This would qn=ativ assist us in our planning.
William V. Johnston Assistant Director Materials and Qualification Engineering 8P09230041 8.'0826 Division of Engineering C6 ADOCK 03000302 CD
Enclosure:
As stated cc:
R.H. Vollmer Z. Rosztoczy F.J. Miraglia po fA.gy -N-2 G. Bagchi R. Wright i
T.V. Chang g/ g M.F. Haughey S. Turk l 1O * %% L I{)[f/
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Ur.ITED STATES OF AuERICA NUCLE AR LEGULATORY C0!t'i!SS10.
BEFORE THE AT_0MIC SAFETY A'iC LICENS!!iG E0*RD in the Matter of
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LOUISIANA POWER AND LIGHT COMPANY
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Docket ho. 50-382
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(Waterford Steam Electric Station, )
Unit 3)
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AFFIDAVIT OF TSUN-YUNG CHANG CONCERNING UNRESOLVED GENERIC SAFETY ISSUE A-46 (SEISMIC 00AllFICATION OF EQUIPMENT)
Q.1.
Please state your name and by whom you are employed.
A.I.
My name is Tsun-Yung Chang.
I am employed by the United States Nuclear Regulatory Comission as Senior Mechanical Engineer.
Seismic and Dynamic Load Qualification Section, Equipment Qualification Branch, Division of Engineering, Office of Nuclear Reactor Regulation.
A copy of my professional qualifications is attached.
Q.2.
Please describe the status of Unresolved Safety Issue (USI) t- - 4 (Seismic Qualification of Equipment in Operating Plants) with nt to the Waterford Unit 3 facility.
A.2.
USI A-46 only applies to operating plants which did not use current design criteria for the seismic qualification of mechanical and electrical equipment; USI A-46 does not apply to Waterford Unit 3, notwithstanding its having been mentioned in Appendix C to the Waterford SER, inasmuch as Waterford Unit 3 is being reviewed against curren't criteria.
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Will the outcome nf U51 A-46 have any impact upon the- '*aff
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t seismic qualification review for Waterford Unit 3?
A.3.
No.
The purpose of A-46 is to decide whether the current criteria as applied to seismic qualification of safety related equipment should be backfitted in part or in whole with regard to operating plants.
I The resolution of A-46 is not expected to have any impact on the seismic s
i qualification of equipment in Waterford Unit 3 inasmuch as Waterford t
i Unit 3 is being reviewed against current seismic criteria, which are not expected to be revised following the resolution of USI A-46.
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F 4 Please describe the status of the Staff's seismic qualification
.i; cent review for Waterford Unit 3 against current criteria?"
A.4.
The Staff's review, which is unrelated to USI A-46, is continuing at this time.
In order to assure that the Applicant has provided an adequate program for qualifying safety-related electrical and mechanical equipment for seismic and dynamic loading, the Seismic Qualification Review Team (SQRT) of the Equipment Qualification Branch performs a two-step review.
The first step involves a determination as to the acceptability of the procedures used, the standards followed and the completeness of the program in general; this is accomplished by review of the applicable i
sections of the Final Safety Analysis Report (FSAR) against the following
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current licensing criteria:
IEEE 344-1971, and additional requirements i
I as specified in Standard Review Plan (NUREC-75/087) Section 3.10, and 9
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Regulatory Guides 1.92 and 1.100. The second step consists of an on-site audit of selected equipment to develop a basis for determining
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4 whether the Irvlementation of the seisr:ic er,a d rir i; program is adequate and complete.
The Staff's review of the Applicant's FSAR against ta "*
criteria is ongois.g at this tine. With respect to the SQRT on-s'te audit, an initial site visit was conducted on September 15-18. 1('I.
a second site visit will be conducted during the week of Augu.t 30. '
e The results of this review will be used to determine the adequacv of the Waterford Unit 3 seismic and dynamic qualification program.
The $taft's evaluation of that review will be reported in a future supplement to the SER.
Q.5.
Has the Staff determined whether it would be acceptat le~to permit Waterford Unit 3 to operate despite the incompleteness of the Staff's review against current criteria?
A.S.
The Staff's position is that the Applicant must demonstrate satisfactory seismic qualification of equipment against current criteria
- rior to licensing.
At this time, that demonstration has not yet been made satisfactorily. The Staff will require that a resolution of this item be provided prior to permitting the commencement of operation.
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4 PR0i i ',';I G'.? t QUAL I f I L AT 10*.',
OF TSU?.-Yl!NG CHA%
i am a senior mechan'tal engineer in the Set.mir and D f r it '<.n1 f
Qualificatinn Section of the Equipment Qualification Branth, Livi.io..*
I nqineering, Of f ice of Nuc lear Reac tor Fegulat ion, Uni t e<1 '.t a'e. N:o 1.
Regulatory Commission. My duties and responsibilities involve the re s i..
dnd PValuation of the structural integrity, operability, and f uqClinf.3I capability of safety related mechanical and electricdi equipn-nt und.
all norrel, abnormal, and accident loading conditions, as well as seis.it uerences and other pertinent dynamic loads.
I joined the NRC in January 1980, serving as senior mechontcal engin".r in the Engineering Branch, Division of Operating Reactors, Office of Nuclear Reactor Regulation. My duties were to review and evaluate saf ety is'ues related to mechanical, material and structural engineering aspects of reattor facilities licensed for operation; to evaluate applications for construc tion a
permits or operating licenses for non-power reactors; to evaluate the modification of ERDA and D0D-nwned facilities exempt from licensing.
In April 1980 I joined the Equipment Qualification Branch.
Prior to joining the NRC I served as a senior mechanical engineer with Stone and Webster Engineering Corporation for over seven years, where I was involved in various aspects of pipe stress analysis for a nuc.ber of nuclear power plants.
I have a Bachelor of Science degree in Mechanical Engineerina fror.
Taiwan National Cheng-Kung University, a Moster of Science in Aoronaut ic'.
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-,. f rom California Institute of Technology, a Master in l'echanicel Sc wnce,
f rom Princeton University, and a Ph.D. in. Applied Mechanics f rom Polytech-Institute.of Brooklyn.
I am a registered professional engineer in the states of Massachusetts and California.
I am a member of the American Society of Mechanical Engineers and the Society for Experimental Stress Analysis.
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