ML20205M812

Testimony of JW Gieseker Re Intervenor Rorem QA Subcontention 8.B Concerning Vulkene Wire.Related Correspondence

ML20205M812
Person / Time
Site:	Braidwood
Issue date:	04/11/1986
From:	Gieseker J COMMONWEALTH EDISON CO.
To:
Shared Package
ML20205M802	List: ML20205M799 ML20205M812 ML20205M816 ML20205M824 ML20205M828 ML20205M836 ML20205M844 ML20205M848 ML20205M853 ML20205M857 ML20205M860 ML20205M873
References
OL, NUDOCS 8604150385
Download: ML20205M812 (12)

Text

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MELATED CORRESPONDENCt April 11, 1986 9

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 000 ED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) 6 A ? 14 P2:14

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COMMONWEALTH EDISON COMPANY ) Dockkhhf6ss!50-456,

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"3,g50-457 (Braidwood Station Units 1 and 2) )

TESTIMONY OF JAMES W. GIESEKER (ON ROREM Q.A. SUBCONTENTION 8.'B)

(Vulkene Wire) 0.1. Please state your full name for the record.

A.l. James W. Gieseker.

Q.2. Who is your employer and what is your occupation?

A.2. I am employed by the Commonwealth Edison Company (CECO).

I have been working at Braidwood Station as an electrical engineer since August 6, 1984. My title is Supervising Engineer in the Project Construction Department (PCD).

Q.3. Please state your education and professional experience.

A.3. I graduated in 1971 from Valparaiso University with a Bachelor of Science Degree in Electrical Engineering.

I have been employed by Commonwealth Edison since July 19, 1971. Prior to my transfer to Braidwood Station, I was assigned to the LaSalle Nuclear Generating Station. While 8604150385 860411 PDR T

ADOCK 05000456 PDR l

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o t at LaSalle, I worked in the Quality Assurance Department, the Station / Production Construction Department and the Station Operating Department. I worked in the Quality Assurance Department from May 1976 to August 1979, where I conducted surveillances and audits to assure that various site contractors, including the electrical contractor, adhered to their QA programs. I also reviewed and approved site work instructions and procedures for these contractors in conjunction with Engineering and the Station Construction Department. In general, I was familiar with the daily operation of the contractors' quality assurance departments.  !

In August of 1979, I transferred into the Station Construction Department where I worked in the electrical group. I was responsible for overseeing the electrical contractor's Quality Department and was the main contact for Nuclear Regulatory Commission (NRC) inspectors in the I i

electrical area. I transferred to the Station Operating Department Technical Staff at about the time the construction of LaSalle was nearing completion. As a member of the Technical Staff, I was first in charge of the Licensing Group and then the Engineering Group. The Engineering Group was responsible for the development and coordination of construction modifications to plant.

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d 0.4. What are your responsibilities with respect to the I Braidwood Project?

A.4. I am presently an Electrical Group Leader. My Group has responsibility for working with L. K. Codstock's Quality Control Department. L. K. Comstock is the site contractor performing the electrical work at Braidwood. I also I assist in the development and review of CECO positions and responses to various questions and matters raised in the electrical area by the NRC as a result of their inspection activities. During the course of my work, I have acquired knowledge of Comstock's use of switchboard wire for internal panel wiring at Braidwood, and I have the i responsibility in PCD for addressing the NRC item of noncompliance that is the subject of subcontention 8.B.

4 Q.5. What is the purpose of your testimony?

1 A.S. My testimony addresses Intervenors' quality assurance subcontention 8.B. concerning the use of General Electric l Vulkene wire at Braidwood. A statement of the subcon-tention is attached to my testimony as Attachment 8.B (Gieseker-1). Specifically, my testimony explains the NRC item of noncompliance issued as a result of inspections i

conducted by the NRC Construction Assessment Team (CAT) upon which subcontention 8.B is based. My testimony also

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l describes the corrective action taken by Commonwealth

! Edison.

j Q.6. Since the vulkene wire issue involves events that occurred j prior to your assignment to Braidwood, please explain how l you became knowledgeable with respect to this matter?

l A.6. I studied the pertinent documents on the issue and discussed the matter with a co-worker. In particular, I reviewed the original design specification requirements, associated purchasing and other documents, and discussed l

i this issue with the person involved in the original l purchases of switchboard wire, incl'uding Vulkene.

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( Q.7. Please describe the NRC item of noncompliance, l

A.7. During the CAT inspections of Braidwood, which were conducted in December 1984 and January 1985, the NRC l

determined that contrary to the requirements of CECO's Quality Assurance Manual and Criterion VIII of 10 CFR Part 50, Appendix B, "some of the approximately 10,500 feet of

( General Electric Vulkene switchboard wire received at the Braidwood site had been installed without appropriate  !

qualification to IEEE-383-1974." The NRC reported this matter as an item of noncompliance in Inspection Report No. 50-456/84-44 and 50-457/84-40, dated April 11, 1985.

Q.8. Is switchboard wire used at Braidwood?

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A.8. Yes, switchboard wire is typically used for internal wiring of equipment, such as control or monitoring panels and valve operators. Switchboard wire is also used by field personnel to wire locally-mounted terminal boxes and to revise the internal wiring of equipment as required by design changes.

Q.9. Was Vulkene wire used at Braidwood?

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A.9. Yes. The material receiving documents were reviewed for i switchboard wire delivered to the Braidwood site.

4 Approximately 12,400 feet of Vulkene wire was received on site between October, 1980 and October, 1981. A search of j 1

plant areas located approximately 1950 feet of unused wire I which suggests that the remaining 10,450 feet had already been installed in the plant. The 1950 feet of wire found unused was placed on " Hold" and was subsequently removed from the site.

l Q.10. What is the concern with respect to the installation of i Vulkene wire at Braidwood?  !

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l A.10. The Braidwood Final Safety Analysis Report (FSAR) provides that switchboard wire installed in safety-related applications in plant areas subject to harsh environments must be environmentally qualified. As explained by Mr.

! Green, the wire must function under the calculated 1

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temperatures, pressures, radiation levels and other environmental conditions assumed to result from certain design basis accidents. The specific environmental qualification requirements for switchboard wire vary depending on the location of the installed wire and the severity of the harsh environmental conditions at that location. The Vulkene wire that is the subject of the NRC l item of noncompliance had not been qualified for use in l

l all harsh environments. The testimony of Mr. Thorsell details the environmental qualification requirements for switchboard wire installed at Braidwood.

Q.11. Could Vulkene wire have been installed at Braidwood in a location for which it was not environmentally qualified?

A.ll. Yes, although I believe the Vulkene wire was used primarily in non-safety-related equipment and in safety-related equipment located in the non-harsh environments of l

the Braidwood Main Control Room and the Auxiliary.Electri-cal Equipment room. However, Vulkene wire could have been installed in an improper environment since it was obtained on the belief that it could be used anywhere in the plant.

l Q.12. Can you explain the circumstances that led to the potential for Vulkene wire being improperly installed at Braidwood?

A.12. Specifications are. developed by CECO's Engineering Department for certain equipment and material needed for the construction of Braidwood. These specifications are used by the Purchasing Department to purchase these items.

The specifications are available to PCD for its use to requisition these items as needed. A specification covering both switchboard wire and cable was used for the initial purchase of switchboard wire at Braidwood.

However, this specification was later amended to delete the switchboard wire requirement and a separate speci-fication for switchboard was not issued by CECO's Engi-neering Department. As a result, PCD had no specification available for acquiring subsequent quantities of switchboard wire for future use.

When it became necessary to requisition additional quantities of switchboard wire, the PCD engineer, finding that no unique specification had been generated by CECO's Engineering Department, used a CECO switchboard wire  !

standard specification of general application, EM-30105.

Although switchboard wire meeting that standard is qualified for some safety-related applications, wire requisitioned under that standard does not meet the l

l environmental qualification requirements for all harsh environments. This subtlety was not apparent; and the requisition was filled with switchboard wire meeting

e l EM-30105 from an existing supply of Vulkene wire maintained in CECO's General Warehouse.

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Q.13. The discussion on pages 3 and 4 of NRC Inspection Report  !

85-47/48 appears inconsistent with the explanation provided in your previous answer -- is there a difference?

And, if so, pleaso explain it. l A.13. Yes, there is a difference. The explanation contained in NRC inspection report 85-47/48 was based on erroneous information. The CECO representative who provided the information to the cognizant NRC inspector was unaware of the root cause discussed above and mistakenly attributed the problem to the process of acquiring general purpose switchboard wire for CECO's General Warehouse. The error was not discovered until after the inspector had issued his inspection report.

Q.14. What action has CECO taken to correct the item of noncompliance?

A.14. CECO issued NCR 707 to resolve the item of noncompliance.

l l CECO determined that any Vulkene wire installed in mild environments could be accepted "as is" because the wire was adequate for this application based on S&L's evaluation of the NCR as discussed in Mr. Thorsell's testimony.

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S&L also advised that, since Vulkene wire may have been installed in harsh environments for which it is not l qualified, an examination of these installations should be conducted. S&L provided a list identifying those l

installations, which included motor operators, junction boxes, and hydraulic operators. S&L recommended the replacement of any Vulkene wire identified during the examination.

In order to prevent recurrence, PCD was directed by CECO's Engineering Department that all fut,ure requisitions of switchboard wire should specify "Firewall SIS" switchboard wire manufactured by the Rockbestos Corporation. This switchboard wire is environmentally qualified for use in any area of the Braidwood plant for all postulated accident conditions. This direction will ensure that PCD will requisition only wire that is qualified for.

i installation at Braidwood on a plant-wide basis.

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, 0.15. Did CECO inspect for the presence of Vulkene wire in electrical installations located in harsh environments at-Braidwood?

2 A.15. Yes, the equipment identified by S&L was examined for the presence of Vulkene wire. The basis for the identifica-tion of the equipment is explained by Mr. Thorsell. f l

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O Q.16. How were the examinations carried out?

A.16. PCD issued procedure PCD-44 to implement the corrective action of NCR-707. This procedure required that the equipment identified by S&L be examined for the presence of Vulkene wire. This examination was accomplished by using documentation from existing corrective action 1

programs or by performing a field survey.

l The motor operators were inspected for the presence of Vulkene wire by Comstock QC inspectors during the recently l completed field walkdown. The junction boxes were reviewed by Comstock Engineering as part of the junction box walkdown. A field survey was performed on the hydraulic operators by electrical designers furnished by S&L.

l l Q.17. How were the inspectors able to identify Vulkene wire?

A.17. SIS wire is identified by the manufacturers' name, wire size and other information which is repeatedly marked on l the insulation approximately every six inches along the length of the wire. Therefore, the wire can be identified by a visual examination of its marking.

Q.18. What do the results of walkdowns and field surveys indicate?

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l A.18. The results ' indicate that a minimal amount of vulkene i

switchboard wire had been installed in harsh environments for which it was not qualified. The total footage that j will be replaced is less than 150 feet. This result  !

supports my earlier expectation, as explained in A.11.,

that the primary use of the 10,450 feet of Vulkene switchboard wire was for the internal wiring modifications of panels located in the Main Control Room and Auxiliary l

Electric Room. Therefore, I conclude that the item of noncompliance identified by the NRC CAT inspectors had i

almost no impact on the quality of construction at

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Braidwood. l 4

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Attachment 8.B (Gieseker - 1)

• CONTENTION ITEM SB

8. Ceskery to Criterion VIII. " Identification and control of Noterials. parts and Components " of 10 C.F.R. Part 50, Appendia S. Cosenonwealth Edison Company has failed to ensure that osasures are established for the identificatiore and control of materials, parts, and components including partially j

i fabricated assemblies in order to prevent the use of incorrect or defective material, parts or components.

3. "10.500 feet of General Electric "VULKENE" switchboard wire was received at Braidwood. Some of this wire has been installed without appropriate qualification to Inst 383-1974. (CAT Inspection Report 84-44/40. Exh. 10.)

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