ML20151G609
| ML20151G609 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/21/1988 |
| From: | Woodward N PUBLIC SERVICE CO. OF NEW HAMPSHIRE, TENERA, L.P. (FORMERLY TENERA CORP.) |
| To: | |
| Shared Package | |
| ML20151G603 | List: |
| References | |
| OL-1, NUDOCS 8807290037 | |
| Download: ML20151G609 (17) | |
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4 July 21, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
PUBLIC SERVICE COMPANY ) Docket Nos. 50-443-OL-1 OF NEW HAMPSHIRE, gt al. ) 50-444-OL-1
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(Seabrook Station, Units 1 ) (Onsite Emergency and 2) ) Planning and Safety
) Issues)
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AFFIDAVIT OF NEWELL K. WOODWARD NEWELL K. WOODWARD, being on oath, deposes and says as follows:
- 1. I am employed by Tenera Engineering Services as Senior Project Manager. I have previously testified in this proceeding. An updated statement of my qualifications and background are attached hereto and marked "A." I was the Project Engineer responsible for the final content, quality and conclusions of the Environmental Qualification files at Seabrook Station while employed at Impell' Corporation, including EQ File No. 113-19-01, Revision 1, which is also NECNP Exhibit 4 in this proceeding.
8807290037 880721 PDR ADOCK 05000443 0 PDR
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l 2.- A question has been raised as to whether the performance specifications for RG-58 and RG-59 cable appear in the EQ file. as required by 10 CFR 550.49(d) (1) and (2).
The answer to this question is "Yes," as set forth below.
- 3. To' assess adequately the environmental qualification of electrical cable, one must understand the plant specific l performance requirements necessary to ensure proper operation during postulated plant environmental conditions.
- 4. The cable color coding scheme used at Seabrook is generic to all cables purchased for use in the plant. The coding scheme required for each cable is stated in the specification and is directly related to the cable provided by each vendor through the information certified in each purchase order. The Seabrook color coding scheme is described in FSAR Section 8.3.1.3 attached hereto and marked "B".
- 5. The only performance specification that RG-58 and RG-59 cable, with a black with red trace jacket, must meet in the Seabrook-Plant is to remain intact as set forth in the memorandum which is Reference 6 in NECNP Ex. 4. This memorandum, authored by me, applies to all cables in the plant and not just to P.O. 113-18 cables, as evidenced by the fact that it refers to "other cable specifications". Indeed, the entire reason why this memorandum was authored by me and placed in the file was to show that the color of the cable in this file 113-19-01 showed the performance specification, l
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1.g., that in evaluating the environmental qualification of cables with the single solid color red, white, blue or yellow, the evaluating engineer must be aware of the need to ensure that the variation of certain electrical characteristics (e.g. insulation resistance) may affect the required performance of the device to which the cable is attached. Further, for cable that is color coded with any other scheme (e.g. black with red trace), the performance specification is that it remain intact and not fail under postulated environmental conditions in a manner that could prevent the satisfactory accomplishment of plant safety functions. The electrical characteristic that demonstrates that a cable remains intact is its ability to carry current and voltage under postulated environmental conditions and not fail (i.e. not short to ground).
- 6. That the performance specifications set out in Paragraph 5 have been met is clear from Reference 2, the generic test report, and Note 7 of the Environmental Qualification Assessment Report (the first document in NECNP Exhibit 4) at Page 9 thereof, wherein it is stated:
"Although there are no specific performance requirements identified in the test report, the cable was subjected to a high potential withstand test following LOCA (after wrapping around a mandrel of diameter approximately 40 times the diameter of the cable) for five minutes using a potential of 80 VAC rms 60 Hz per mil of insulation. At the end of five minutes, the charging current was measured. The cables were energized with potential and current to simulate service conditions during LOCA test and besides, the insulation resistances were measures
[ sic) throughout the test which indicates a minimum IR of 1.6 x 108 ohms /30' of cable (Reference 2, Table 2, p. 14).
According to Reference 9, the minimum IR value is acceptable. The above test satisfies the requirements of IEEE-383-1974 and assures qualification of the cables."
Note 7 was originated by the engineer performing the evaluation to provide additional clarification with respect to the criteria and information upon which he based his affirmative answer to E.Q. Assessment Report (checklist) Item 21 (NECNP Ex. 4). To complete this Note, the engineer used Appendix A (pg. A1) of NECNP Ex. 4 Reference 1 to identify the color code specified for Seabrook and in conjunction with NECNP Ex. 4 Reference 7 further identified what was actually delivered to the plant. Once the cable color code was known, NECNP Ex. 4 Reference 6 provided the engineer with the tools to define the electrical characteristics of importance necessary to environmentally qualify the cable. It is important to understand that Section 2.2 of the test report (NENCP Ex. 4 Reference 2) specified performance and acceptance criteria provided by the cable vendor (ITT Surprenant) for the successful generic testing of the cable.
However, these requirements by themselves do not necessarily reflect plant specific requirements. Therefore, plant performance requirements also had to be reviewed.
- 7. In Note 7, the performance specification (i.e.
remain intact) of the cable was demonstrated by the l
evaluating engineer's statement that the cable passed the potentially destructive voltage withstand test after all testing was complete and that the cables remained energized with voltage (potential) and current during postulated environmental conditions. Cable failure (i.e. short to ground) would have occurred if the cable had failed to carry voltage and current and the fuse in the test circuit blew.
However, it did not fail during the environmental qualificacion test (NECNP Ex. 4 Reference 2). Further proof that the cable remained intact is that the insulation resistance (measure of an insulation's intactness) was measured to be 1.6 x 108 ohms.
- 8. For cable where the functional operability and performance of attached equipment had to be assessed under postulated environmental conditions (i.e. color codes red, white, blue or yellow), the evaluating engineer provided the insulation resistances (minimum of 1.6 x 108 ohms /30 ft. of test cable) and other electrical test results to an Instrumentation & Controls engineer working for the Applicants who evaluated the results for any imppct on the attached equipment. The documented response of this acceptance is provided in the E.Q. File (NECNP Ex. 4 Reference 9).
- 9. In summation, the performance specifications of concern for the RG-58 and RG-59 cables can be and were defined in the EQ File by identifying the cable color code.
t The electrical characteristics that measure acceptable performance requirements unique to Seabrook Station under environmental conditions are defined and accepted through the engineer's evaluation process in response to E.Q. Assessment Report (Checklist) Item 21, the results of which are discussed in Note 7 (NECNP Ex. 4).
Ilf Y i lj Y LdGi Newell K. Woodward '
COMMONWEALTH OF MASSACHUSETTS Suffolk, ss. July 21, 1988 The above-named Newell K. Woodward appeared before me and made oath that he had read the foregoing affidavit and that the statements set forth therein are true to the best of his knowledge.
Before me,
. 2W. fAW Notary Public My commission expires:
KAREN D. RAMACORTI, Notary Public My C""*9 Expires November. 12,1994 i
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b NEWELL K. WOODWARD Senior Project hianager Education B.S. Charter Oak College hicchanical Engineering hiajor, University of Hartford Nuclear Engineering, U.S. Naval Nuclear Power School Summary of Exoerience hir. Woodward has been associated with the commercial and naval nuclear power industry for over eighteen years. He has extensive experience in nuclear power plant design, licensing, construction, operation, maintenance, refueling and emergency prepa red ness. He has supervised the design, procurement, installation, test, operation, maintenance and repair of nuclear power plant mechanical and electrical eq uipment. He has managed and performed technical work on various multidisciplinary issues including reactor' vessel low temperature overpressure protection, equipment qualification and system interaction. hir. Woodward has prepared testimony and been an expert witness in Atomic Safety and Licensing Board Hearings for PWR and BWR plants. He has also prepared plant operating and maintenance procedures, technical specifications, offsite emergency preparedness plans and procedures and prepared and given training courses and seminars on nuclear plant systems and equipment and regulatory and technical issues.
1986 - Senior Project hianager, TENERA Operating Company, L.P. (formerly Present TERA Corporation). Responsible for the management and technical performance of engineering projects in the areas of Equipment Qualification and Corrective and Preventive hiaintenance, Fire Protection and Mechanical, Electrical, and Nuclear Engineering.
1980 - 1986 Technical hiana ger, Systems Engineering, Impell Corporation.
Responsible for the technical development and management of programs and services with respect to equipment qualification and systems engineering.
Supervising Engineer, Systems Engineering. Impell Corporation.
Responsible for the management and technical performance of electrical and mechanical equipment qualification programs for PWR and BWR plants. Efforts associated with these programs included master equipment list preparation and review; system, equipment, and subcomponent part failure modes and effects analyses; in plant field verification walkdowns; postulated environmental parameter definition; qualification analyses and auditable documentation file preparation; emergency operating procedure review, licensing submittal preparation; preparation of justifications for continued plant operation; NRC audit support and ASLB expert witness testimony; specification and evaluation of preventive maintenance requirements; maintenance and "surveillance program and procedure review and revision; independent program and documentation file reviews; and impact reviews of NRC I&E Notices and Bulletins. Other associated efforts included the completion of a polymer material degradation study with respect to radiation and temperature in support of ASLB hearings for a BWR plant, and the preparation and presentation of equipment qualification training programs to utility management, engineering and technical personnel.
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- NI;WI;LI, K. WOODWAR D Page 2 Lead Senior Engineer, Systems Engineering and Licensing, Impell Corporation. Prepared Pre Construction Safety Analysis Reports for auxiliary and component -cooling water systems based on event and fault tree analyses for a British PWR plant.
Senior Engineer, bianagement Services, Impell Corporation. Prepared offsite emergency plans and procedures for Rockland and Orange Counties surrounding Indian Point. During the course of this assignment, hir. Woodward interfaced with state and county officials as well as utility representatives in the development of offsite emergency plans and procedures.
1976 - 1980 NSSS Design Engineer, Combustion Engineering, Incorporated.
Responsible for the engineering analysis and technical support of special projects relating to the design and licensing of the Nuclear Steam Supply System (NSSS), secondary feedwater and steam supply systems, and auxiliary systems' interfaces. Specific efforts included the analysis, design, installation, operation an'd licensing of system backfits related to the reactor vessel low temperature overpressure protection issue, ATWS analyses, NSSS and auxiliary feedwater system design reviews, and technical specification preparation. Other efforts included participation in EPRI sponsored component failure and root cause analysis programs, the training of nuclear plant operators in the low temperature overpressure protection issue and an assignment to the Technical Advisory Group at Three hiite Island subsequent to the hfarch,1979 cvent.
1974 - 1976 Senior Quality Control Inspector, hforrison Knudsen Company. During the overhaul, modification and refueling of several Naval Prototype PWR plants, hir. Woodward was responsible for monitoring and certifying reactor plant servicing procedures; nuclear and non-nuclear welding and brazing; system and component testing, and pressure vessel and fuel lif ting and handling equipment.
Shift Refueling Engineer, hforrison Knudsen Company. Responsible for the preparation of reactor plant servicing procedures and for supervising the performance of various reactor plant modifications and refueling cycles.
Purchasing Agent, hforrison Knudsen Company, Specified, procured, and expedited nuclear and non nuclear materials, parts, and equipment.
1968 - 1974 hiachinist hiate First Class, US Navy, hir. Woodward was qualified as an Engineering Watch Supervisor and was the hiachinery Division Leading Petty Officer on a nuclear powered submarine.
Professional Affiliations Pi Tau Sigma, hicchanical Engineering Honorary American Nuclear Society American Nuclear Society Standardt Committee ANS 56.3 Technical Presentations A Short Course on Advances in Equipment Qualification for Nuclear Fac . tics, Pa ris, France, h1 arch 1983.
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NEWELL K. WOODWARD Summary of Environmental Oualification Exocrience Pla n t(s) Exoerience Summary Shoreham Nuclear Power Project Engineer for NSSS equipment Station (Long Island Environmental Qualification Program Lighting Company) (NUREG-0588 Cat. I & II).
- E.Q. File preparation for electrical and mechanical equipment.
- Preparation of mechanical equipment Master List.
- Verification of electrical equipment Master List.
- Field Verification Walkdown for NSSS and BOP equipment.
Review of Emergency Operating Procedures.
- Specification of qualified replacement equipment.
Audit of vendor maintained qualification documentation.
- Preparation and review of Justifications for Continued Operation.
- Impact review of I&E Notices and Bulletins.
- NRC audit and regulatory support.
- Atomic Safety and Licensing Board (ASLB) expert witness testimony.
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-s Pla n t(s) Exoerience Summary Seabrook Station Project Engineer for NSSS and (Public Service Company BOP equipment Environmental of New Hampshire / Qualification Program Yankee Atomic Electric (NUREG 0588 Cat. I)
Company)
- E.Q. File pre 2 ration for electrical and mechanical equipment.
- Preparation of mechanical equipment Master List.
- Verification of electrical equipment Master List.
- Field Verification Walkdown of all equipment.
Review of IAE Notices and Bulletins.
- Specification of qualified replacement equipment.
- Preparation of Environmental Qualification Report (Program Description for NRC submittal)
Audit of vendor maintained qualification documentation.
- NRC audit and regulatory support.
- ASLB expert witness testimony.
Three Mile Island Project Engineer / Technical Advisor Unit I and Oyster for NSSS and BOP equipment Creek Nuclear Generating Environmental Qualification Program Station (GPU (NUREG 0588 Cat I and DOR Nuclear Corporation) Guidelines.)
- E.Q. File preparation for electrical equipment.
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e Pla n t(s) Exoerience Summary
- Verification of electrical equipment Master _ist.
- Field Verification Walkdown (OCNGS only.) !
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- Specification of qualified replacement equipment.
1 Audit o f. vendor maintained qualification documentation. 1 Review of I&E Notices and Bulletins.
- NRC audit and regulatory support.
Susquehanna Steam & Project Engineer for E.Q. File Electric Station, Independent Review Program (NUREG-Unit Nos. I and 2 0588 Cat. I & II.)
(Pennsylvania Power
& Light Company)
- Written review of electrical equipment E.Q. Files.
- NRC audit and regulatory support.
Technical reviewer for correction of E.Q. File deficiencies.
Comanche Peak Steam Auditor for Quality Assurance and Electric Station (TU Electric) -
Performed a technical audit of the E. Q.
Program, including master list and environmental parameter design bases, E Q. files, and plant implementation.
Project Engineer for E.Q. File Beaver Valley Power Station, Unit No.1 Independent Review Program (Duquesne Light Company) (DOR Guidelines.)
- Written review of electrical equipment E.Q. Files.
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Pla n t(s) Exocrience Summary Beaver Valley Power Project Engineer for NSSS and BOP Station, Unit No. 2 mechanical equipment (Duquesne Light Company) Environmental Qualification Program.
E.Q. File preparation for mechanical equipment.
Preparation of mechanical equipment Master List.
Perry Nuclear Power Project Engineer for Polymer Plant (Cleveland Degradation Study prepared in Electric illuminating response to ASLB Intervenor Company) questions regarding the degrada-tion of polymer materials in elevated temperature and low level radiation environments.
Work scope included the pre-paration of ASLB testimony.
Project Manager / Technical Advisor for a Class 1 E cable test program. Including preparation of test plan and final report.
Donald C. Cook Nuclear Project Engineer for Thermal '
Plant, Unit Nos.1 & 2 Aging and Surveillance / Maintenance (Indiana & Michigan Evaluation Program (DOR Electric Company / Guidelines)
American Electric Power Service Corporation)
- Thermal aging life determination for NSSS and BOP electrical equipment.
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Plant (s) Excerience Summarv Written review / evaluation of plant programs' and procedures with respect to the implementation of E.Q. related maintenance and an "on-going" qualification program.
- Preparation of Plant Manager Instruction for Environmental Qualification of Safety related Electrical Equipment.
Indian Point Station, Project Engineer for an E.Q.
Unit No. 2 Training Program for management, (Consolidated Edison engineering, and plant technical Company of New York) personnel.
Auditor for Quality Assurance. Performed an audit evaluation for completeness and technical accuracy of E.Q. Files. Effort included reviewing implementation of E.Q. into plant maintenance and procurement procedures.
James A. Fitzpatrick Project Manager / Technical Advisor Nuclear Plant for the preparation of an E.Q.
(New York Power File for the HPCI Turbine Assembly
- Authority) (DOR Guidelines.)
Davis Besse Unit No.1 Project Engineer for NSSS and BOP (Toledo Edison Company) equipment Environmental Quali-fication Program (NUREG 0588 Cat.
I and DOR Guidelines.) (9 month interim period only)
- Addressed technical issues relating to the revision of E.Q. Files to resolve open items.
Revision of E.Q. Files 5
't SB 1 & 2 Amandment 55 i FSAR July 1985 0 8.3.1.3 Physical Identification of Safety"Related Equipment All cables. raceways and safety-related equipment are assigned to a particular channel or train. There are two redundant trains of power and controls, and four redundant channels of instrutentation. Each chanr.el or train is assigned a particular color, as shown below Equipment Raceway Separation Group Nameplate Tag Cable Color A. Channel I and Train A Red Red Red Train A Associated Black Black w/ Red Tracer l B. Channel II and Train B White White White Train 3 Associated Black Black w/ White Tracer l T
C. Channel III Blue Blue Blue D. Channel IV Yellow Yellow Yellow it Each piece of electrical equipment is marked with the node number indicated on the design drawings, in the particular color corresponding to the channel or train to which that equipment is assigned. Similarly, trays and exposed conduits are marked with color-coded markers. The cable jacket color code G serves as its identification. The operator or maintenance craftsman needs only to observe the color of the nameplate of any piece of equipment or the cable jacket color to determine which channel or train it serves. For exceptions to the above cable and raceway identification criteria, see Subsection 8.3.1.4.k.
Si 8.3.1.4 Independence of Redundant Systems
- 4. General The Seabrook Station complies with the requirements of TSAR Appendix 8A, IEEE 384-1974 and Regulatory Guide 1.75, Rev. 2.
These documents describe acceptable methods of complying with IEEE 279-1971 and Criteria 3,17 and 21 of Appendix A to 10 CFR Part 50 with respect to the physical independence of the circuits and electrical equipment comprising or associated with the Class lE power system, the protection system, systems actuated or controlled by the protection system, and auxiliary or supporting systems that must be operable for the protection systea and the systems it actuates to perform their safety-related functions. Preservation of independence of redundant systems within the control boards and all other field mounted racks is discussed in Subsection 7.1.2.2.
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t 00LnEiLO UYliiC CERTIFICATE OF SERVICE I, Thomas G. Dignan, Jr., one of theptRn3fys Aldd39 the Applicants herein, hereby certify that on July 21, 1988, I made service of the within document by depositing copies thereof with Federal Express, prepaid, fod where indicated, by depositing in the Unite"Mel{Wg'es/,%Ej(or d"sEve'ry~ mail, first class postage paid, addressed to) the individuals listed below.
Administrative Judge Sheldon J. Robert Carrigg, Chairman Wolfe, Esq. , Chairman, Atomic Board of Selectmen Safety and Licensing Board Panel Town Office U.S. Nuclear Regulatory Atlantic Avenue Commission North Hampton, NH 03862 East West Towers Building 4350 East West Highway Bethesda, MD 20814 Administrative Judge Emmeth A. Diane Curran, Esquire Luebke Andrea C. Ferster, Esquire 4515 Willard Avenue Harmon & Weiss Chevy Chase, MD 20815 Suite 430 2001 S Street, N.W.
Washington, DC 20009 Dr. Jerry Harbour Stephen E. Merrill Atomic Safety and Licensing Attorney General Board Panel George Dana Bisbee U.S. Nuclear Regulatory essistant Attorney General Commission Office of the Attorney General East West Towers Building 25 Capitol Street 4350 East West Highway Concord, NH 03301-6397 Bethesda, MD 20814 Adjudicatory File Sherwin E. Turk, Esquire Atomic Safety and Licensi; , Office of General Counsel Board Panel Docket (2 copies) U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission One White Flint North, 15th Fl.
East West Towers Bulletng 11555 Rockville Pike 4350 East West Highway Rockville, MD 20852 Bethesda, MD 20814
- Atomic Safety and Licensing Robert A. Backus, Esquire Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03105
t Philip Ahrens, Esquire Mr. J. P. Nadeau Assistant Attorney General Selectmen's Office Department of the Attorney 10 Cen*ral Road General Rye, NH 03870 Augusta, ME 04333 Paul McEachern, Esquire Carol S. Sneider, Esquire Matthew T. Brock, Esquire Assistant Attorney General Shaines & McEachern Department of the Attorney General 25 Maplewood Avenue One Ashburton Place, 19th Floor P.O. Box 360 Boston, MA 02108 Portsmouth, NH 03801 Mrs. Sandra Gavutis Mr. Calvin A. Canney Chairman, Board of Selectmen City Manager RFD 1 - Box 1154 City Hall Route 107 126 Daniel Street Kensington, NH 03827 Portsmouth, NH 03801
- Senator Gordon J. Humphrey R. Scott Hill-Whilton, Esquire U.S. Senate Lagoulis, Clark, Hill-Whilton &
Washington, DC 20510 McQuire (Attn: Tom Burack) 79 State Street Newburyport, MA 01950
- Senator Gordon J. Humphrey Mr. Peter J. Matthews One Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Mr. Thomas F. Powers, III Mr. William S. Lord Town Manager Board of Selectmen Town of Exeter Town Hall - Friend Street 10 Front Street Amesbury, MA 01913 Exeter, NH 03833 H. Joseph Flynn, Esquire Brentwood Board of Selectmen Office of General Counsel RFD Dalton Road Federal Emergency Management Brentwood, NH 03833 Agency 500 C Street, S.W.
Washington, DC 20472 Gary W. Holmes, Esquire Richard A. Hampe, Esquire Holmes & Ells Hampe and McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03841 Concord, NH 03301 l
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Mr. Ed Thomas Judith H. Mizner, Esquire i FEMA, Region I 79 State Street l 442 John W. McCormack Post Second Floor Office and Court House Newburyport, MA 01950 l Post Office Square Boston, MA 02109 Charles P. Graham, Esquire Murphy and Graham 33 Low Street Newburyport, MA 01950
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(*= Ordinary U.S. First Class Mail.)
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