ML20214A543

Proposed Findings of Fact & Conclusions of Law & Proposed Form of Decision Re New England Coalition on Nuclear Pollution Contention I.B.2 Concerning Duration of Environ Qualification Times

ML20214A543
Person / Time
Site:	Seabrook
Issue date:	11/12/1986
From:	Curran D HARMON & WEISS, NEW ENGLAND COALITION ON NUCLEAR POLLUTION
To:
Shared Package
ML20214A483	List: ML20214A481 ML20214A543 ML20214A565 ML20214A592
References
OL-1, NUDOCS 8611200130
Download: ML20214A543 (25)

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November 12, 1986 UNITED STATES NUCLEAR REGULATORY COMMISSION hhk BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'86 NOV 17 R2:41

) CFfu.

In the Matter of ) 00CMEij.y.1  ;-l,,

) ne c rc 4 Public Service Company of )

New Hampshire, et al. ) Docket Nos. 50-443 OL-l

) 5 0-444 OL-l (Seabrook Station, Units 1 & 2) ) ONSITE EMERGENCY

) PLANNING & TECHNICAL

) ISSUES NEW ENGLAND COALITION ON NUCLEAR POLLUTION'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW AND PROPOSED FORM OF DECISION REGARDING NECNP CONTENTION I.B.2 Introduction The Licensing Board has reopened the 1983 hearing record to take supplemental testimony on New England Coalition on Nuclear Pollution's ( "NECNP's") Contention I.B.2 (Duration of Environmen-tal Qualification Times), NECNP Contention III.1 (Emergency Ac-tion Levels) and Seacoast Anti-Pollution League's Contention 6 (Control Room Design) . At hearings held on September 30 and Oc-tober 1, 1986, NECNP cross-examined Applicants' and NRC Staff's witnesses with respect to NECNP Contention I.B.2. The substan-tive portion of the following proposed findings is limited to NECNP Contention I . B.2.

Procedural Nistory

1) NECNP does not dispute the Applicants' description of the procedural history of this case to any major degree. Para-graph 15 should be corrected to reflect that NECNP filed proposed findings in 1983 on environmental qualification times as well as emergency action levels.

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2) NECNP Contention I.B.2 asserts that:

The Applicant [s] ha[ve] not satisfied the requirements of GDC 4 that all equipment important to safety be en-vironmentally qualified because [they have] not specified the time duration over which the equipment is qualified.

3) During the hearings in 1983, Applicants testified that their environmentaY qualification review was only 80% complete.

I 1-Tr. at 978. The data packages which contained the specific in-formation on duration of qualification and which must be as-

. sembled and kept on file, were not even 80% complete. Id, . At that time, Applicants did not represent that equipment had ac-tually been qualified for a post-accident environment ot a year; but stated only that "As far as our review has gone, we have found no equipment that cannot be qualified for a year." 1-Tr.

at 979 (emphasis added) .

4) Between the close of the 1983 hearings and the current hearings, Applicants made numerous submittals to the NRC Staff l

! which revised and amended their previous representations regard-ing the duration of environmental qualification for safety equip-ment at Seabrook.

l

5) In its opposition to Applicants' Motion for Issuance of Partial Initial Decision Authorizing Low Power Operation, dated July 2, 1986, NECNP requested the opportunity for a hearing on a nunber of issues raised by these submittals, which related to the adequacy of qualification times. ~

l 9

4 3-PROPOSED FINDINGS OF FACT Role of Equipment Qualification Files

6) As required by NRC's environmental qualification regulations at 10 CFR S 50.49, Applicants maintain equipment qualification files which contain documentation suoporting the environmental qualification of electrical equipmen; important to i safety. Tr. at 360.

7) Each Equipment Qualification File is prefaced by a Table of Contents, Equipment List, Summary Evaluation, Qualifica-tion Evaluation Worksheet, and Assessment Checklist." The file also contains numerous documents, including manufacturets' and testers qualification test reports, correspondence regarding the qualification of the components, descriptions of the specifica-tions for the components, and information regarding their instal-lation. See, e.g., NECNP Exhibits 1, 4, 5, 7- 9.

8) The Qualification Evaluation Worksheets, known as " skew sheets," summarize the information that is in the equipment qualification files. Tr. at 358. Examples of skew sheets are found in Applicantsi Exhibit 7. Id,.

Anaconda SkV Power Cable, EQF # 113-01-01

9) In support of their claim that Anaconda SkV power cable is qualified for a post-accident duration of one year, Applicants rely on the manufacturer's qualification test of single conductor cable that is " exactly similar" to the single conductor of the multiple conductor cable used at Seabrook. NECNP Exhibit 1, Equipment Qualification File ("EQF") No. 113-01-01: Re ference 6,

t Letter from Anaconda Company to United Engineers and Construc-tors, dated December 10, 1979, At tachment at 2.

10) The term " exactly similar" does not mean "the same."

Tr. at 368. However, Reference 6 does not identify any of the ways in which the tested equipment differs from the equipment used in the plant.

RG-58 Coaxial Instrument Cable, EQF i 113-19-01

11) Eq uipmen Qualification File No. 113-19-01 purportedly

- contains the documentation necessary to establish the environmen-tal qualification of four types of cable: RG-ll triaxial cable, a nd RG-11, RG-58, and RG-59 coaxial cable. NECNP Exhib(t 4.

12) Only two of those cable types (RG-ll U and RG-59 U coaxial) were qualified by testing. Tr. at 378. The other two (RG-ll triaxial and RG-58 coaxial) were qualified by comparison with the tested components. Tr. at 379.

13), In the " Equipment Summary Evaluation" included in EQF No . 113-19-01, Applicants state that the two tested specimens are

" representative" of all four types of cables supplied to Seabrook l

in this particular purchase order. Equipment Summary Evaluation a t 1, S 4. In support of this statement, Applicants cite l

Reference 4 to that Equipment Qualification File.

14) Equipment Qualification File 113-19-01 also contains a l

l " Qualification Assessment Checklist" which reviews the con-l formance of these components with~ the requirements of NUREG-0588.

f Under a heading entitled " Similarity," Applicants give an affirm-(

ative answer to the question, "Is the documentation traceable to i

l I

t the plant equipment?" Again, the supporting reference given is Reference 4. Assessment Checklist at 4.

15) Reference 4 is a letter from the International Telegraph & Telephone Corporation, ITT Suprenant Division, to Un-ited Engineers & Constructors, dated March 8,1983, which dis-cusses the alleged similarity of the tested cable to the untested cable that was supplied to Seabrook. The letter provides some technical description of the similarities in dimensions, com-ponent composition, and configuration between the tested RG-ll coaxial cable and the untested RG-ll triaxial cable.

16) With respect to the qualification of the untested RG 58 coaxia) cable, the letter states:

We feel similar concerning RG58 LOCA [ loss of coolant accident] approval. Since we have chosen RG59 for our LOCA program and have that approval and RG58 has similar construction details, we are confident that, had it been submitted, it also would have been approved.

17) The only justification offered for IT&T's failure to test the RG-58 cable was "Since LOCA testing is very expensive, testing of all constructions would be economically unfeasible."

Id,

18) According to Applicants' witness Koodward, Applicants performed a review " independently of whatever the manuf acturer stated," which satisfied Applicants that "the constructions were similar enough so that the testing would adequately represent the 1

performance of the cable in the plant." Tr. at 381. However, ,

the witness could not identify any information, other than that contained in Re ference 4, that might have been used to determine i

in what respects the RG-58 coaxial cable was comparable to the tested cable; or whether the similarity was sufficient to justify qualification by comparison.

19) Mr. Woodward stated that if the reviewing engineer

" concluded that the information provided in Reference 4 or maybe  ;

I provided by the vendor outside or Reference is satisfactory, then he agreed with the similarity." Tr. at 382, emphasis added.

However, the witness did not identify any outside information that was used by the reviewer; nor is any referenced in this equipment qualification file.

Equipment Qualification File # 113-20-01

20) On February 2,1986, the Impell Corporation sent a letter to Yankee Atomic Electric Company which transmitted a sum-mary report of the identity of Class lE (safety-related) equip-ment located below the flood level at Seabrook. See NECNP Exhib-it 5, Equipment Qualification File No. 113-20-01: Re ference 12.

21) The letter identificd three items of safety-grade equipment in the mechanical penetration area that were not qualified for submergence, including instrument rack MM-IR-12.

Re f. 12 a t 4. Impell reported that " Rack MM-IR-12, its acces-sories, and the transmitters are not qualified for submergence."

Id. Impell recommended that these components "be relocated above the flood level unless it can be shown that operability for the MELB [ moderate energy line break] 'is not required." Id.

22) Instrument Rack MM-IR-12 is supplied by 300 V Instru-nient Cable, whose environmental qualification is allegedly docu-mented in Equipment Qualification File No. 113-20-01'.

O

23) According to the Qualification Assessment Checklist

("QAW") f or this component, submergence qualification for cable supplying Instrument Rack MM-IR-12 is not required because the instrument tack has been downgraded to Operability Code C. See Note 9 at page 11. The sole documentation offered in support of this downgrade is an " Engineering Change Authorization" or "ECA,",

numbered 03114514A and dated February 19, 1986, which lists the components that have been downgraded f rom Operability Code A No ex-(safety-grade) to Operability Code C (nonsafety grade).

planation or justification for this change is provided in the ECA. Tr. at 391.

24) Applicants' witness was aware of no attempts to determine the feasibility of moving the instrument rack above the flood level. Tr. at 395.

25) The 300 Volt instrument cable whose qualification is allegedly documented in Equipment Qualification File No.113 l l

01 may be subjected to submergence conditions inside and outside of containment during an accident at Seabrook. See NECNP Exhibit 5, Equipment Qualification File No. 113-20-01: Qualification As-sessment Worksheet, No te 9 at 11. Applicants allege that the cable is qualified for 30 days' submergence. Tr . 3 9 5.

26) The analysis for submergence qualification is found in Reference 14 to EQF 113-20-01. The cable was not subjected to Instead, similar cable submergence testing. Id., Tr. at 395.

specimens were aged and irradiated, then subjected to pressurized steam, temperature, and chemical spray environments in the test chamber. Re f . 14 a t 1. Af ter the 100 day LOCA test, the cable-

was submerged in tap water at room temperature for one hour and subjected to a 5 minute high potential test based on 80V/ mil of insulation thickness. Id . a t 2.

27) According to Applicants' witness, the cable was tested in a big test vessel analogous to a pressure cooker, into which I At the end of steam and chemical , spray were injected. Tr. 406.

the test, the vessel was flooded with water in order to submerge the cable. Id.

Equipment Qualification File No. NSS-220-03

28) The February 2 Impell letter also identified limit switches RG-VS-618 and RH-VS-619 as safety grade equipment that should be qualified or relocated above the flood level. See NECNP Exhibit 5, Equipment Qualification File No. 113-20-01:

Reference 12 at 4. These components were later downgraded to Operability Code C, or nonsafety grade. Tr. at 446-47.

29)- The environmental qualification file which purportedly I

contains full and verifiable documentation for the qualification of those components is Equipment Qualification File No. NS S- 2 20-

03. NECNP Exhibit 9. In support of the change in the operability code, the equipment qualification file references the same Engineering Change Authorization (ECA 0 3114514A , dated Fe b-ruary 19,1986) that was used to downgrade the safety classifica-tion of Instrument Rack MM-IR-12, discussed above. That document provides no explanation of the reasons for or justification for l

the change.

30) The Qualification Evaluation Worksheet for this com-ponent inaccurately states that the equipment is above flood level. Tr. a t 4 4 6.

Equipment Qualification File No. 174-15-01

31) During the reopened hearing, NECNP cross-examined Ap-plicants' witnesses regarding the qualification of Transamerica Delaval Level Transmitters, whose qualification is purportedly documented in Equipment Qualification File No. 174-15-01. NECNP Exhibit 7. These level transmitters report the water level in- ,

side containment. Tr. at 429.

32) Applicants assert that this component is qualified for submergence for one year following an accident. Tr. at 4 29. To establish this qualification time, Applicants subjected the com-ponent to a submergence test that lasted thirty minutes._ Id.

However, Applicants determined that the thirty minute qualifica-tion test was inadequate to support the qualification of the equipment. Tr. at 4 80.

33) To compensate, Applicants modified the design of the component. Id. Applicants designed a riser device, filled with Dow silicone oil, that is intended to counteract moisture intru-sion into the level transmitter. Tr. at 4 29. The original design of the ris5r contained a specification that a pressure test must be perfortued on the riser. Tr. at 430.

34) In an Engineering Change Authorization submitted by United Engineers & Constructors, UE&C stated that " vendor sup-I plied splice boxes on LE's [ level elements] will not withstand pressure test. Request to delete-pressure test requirement."

NECNP Exhibit 7, EQF No. 174-05: Re f . 7 a t 2. The requirement for the pressure test was subsequently deleted. Tr. a t 4 31. No explanation is given in this equipment qualification. file as to

why the requirement was deleted, or what other measures would fulfill the purpose of the test.

35) Applicants' witness stated that the reason the test was eliminated was that it could damage the equipment. Tr. at l 1

450. Applicants were not aware of any other attempts to pressure l test the oil ~ riser [Tr. at 432] or to determine what pressure level the oil riser could withstand. Tr. a't 4 51.

36) Applicants stated on cross-examination that the pur-pose of submitting the riser to a pressure test was to examine it for leak tightness. Tr. at 4 50. Applicants stated that it was a

" nicety" to check for leak- tightness. Id. .

37) In view of the importance of the riser in fulfilling the environmental qualification requirements for this component, Applicants' statement that the pressure test was a " nicety" lacks credibility. It is clear that if the oil leaked out of the riser, it would no longer fulfill its function of counteracting moisture intrusion into the level transmitter, and the component would lose its ability to function for the duration of an acci-dent in which it might be submerged.

38) Applicants asserted on cross-examination that a visual examination was performed to verify that the system was leak tight. Tr. a t 4 51. This examination is not documented in the equipment qualification file. Applicants also asserted that leakage could adequately be monitored during pericdic calibra-tions that take place in intervals of a year to 15 months, or during entries into the containment. Tr. at 4 35. However, Equipment Qualification File No. 174-15-01 contains no des'crip-

tion of such measures or evaluation of whether they would con-stitute an acceptable substitute for pressure testing of the riser.

39) The Qualification Assessment Worksheet ("QAW") for Equipment Qualification File No. 174-15-01 describes the "special conditions" under which this equipment has purportedly been i qualified. The QAW states that UE&C Engineering Change Authorization (ECA) No.

50/ll383C (Reference 7) provides details for the pre-vention of moisture intrusion into the level transmit-ters when they are submerged. Filling the units with Dow f 710 silicone oil will result in a pressure head of 4'6" of oil (the height of the tee oil fill point above the postulated flood level of (-)20'-8". Th is pressure head will counteract the less than 0.5 psi pressure head caused by the postulated flood

[(-)20'-8" vs. (-)21'-2 5/8"] and prevent any water from entering the threaded connections and junction box for as long as this equipment is submerged. Compliance with this ECA will ensure acceptable environmental qualification. Upon compliance this special condition will no longer be applicable.

QAW at 1 (emphasis added).

40) The instructions in ECA No. 50/11383C ( Re f . 7 ) , how-ever, are inconsistent with the specifications described in the Qualification Assessment Checklist. At Sheet 3, paragraph 4, the instructions state: " Pour Dow # 710 silicone oil into the riser to a level corresponding to ' flood level' plus 6" (i.e. el.

(-)l7'6") ." . The inconsistency arises in two respects: the flood level described in the ECA ((-)18') i s 2' 8" lower than the flood level described in the QAW ( (-)20'-8"); and the level to which the ECA instructs installers to fill the riser above the flood level (6") is 4' lower than the level specified in the QAW (4'6").

T

41) The discrepancy in the flood levels arises from the f act that af ter the ECA was prepared, the flood level for the plant was recalculated. Tr. at 4 54. The ECA does not represent an as-built drawing for the plant. Tr. at 455.

42) The ECA cor.stitutes the instructions to installers in the field. Tr. at 454. The level transmitter and riser have been installed according to the instructions in the ECA. Tr. at 455.

43) It appears from this inconsistency that the riser may not have been filled to a level that would provide the requisite pressure head of 4'6" above the flood level. Applicants,have not verified whether the oil was filled to the proper level. Tr. at 456.

44) Applicants' witness stated that he was "not particu-larly concerned with the specific numbers that were given in the ECA with respect to elevations," but was only " concerned that you

( had to fill this to the top of the "T" in order to indicate that it was full of oil." Tr. at 4 57.

45) Applicants' stated lack of concern is not credible.

The instructions in the ECA do not call for installers to fill the riser to the top of the "T." (See Sheet 5 of ECA for diagram.) Rather, they instruct installers to fill the oil to "a level corresponding to " flood level' plus 6" (i.e. (-)l7'6"). An installer who knew that the actual flood level was (-)20'8" might easily be confused and decide to ignore the parenthetical reference to (-)l7'6", deciding instead to fill the riser to 6" above the flood level of (-)20'8". -

t

Review of Relevant Literature Concerning Environmental Qualifcation

46) Sandia National Laboratories is under contract with the NRC to do testing and research on environmental qualification.

Tr. at 511. Sandia periodically produces reports on the results of its studies, which are published by the Government Printing Office. An example of one such report is NUREG/CR-4536, SAND 86-0450, "Superheated-Steam Test of Ethylene Propylene Rubber Cables Using a Simultaneous Aging and Accident Environment." This report discussess conservatisms found in environmental qualifica-tion testing of certain cables. Tr. at at 373.

~

47) Impell concluded that NUREG/CR-4536 was not applicable to the cable used in the Seabrook plant because the cable that had the problem in the test was not of similar material to the cable at Seabrook. Tr. at 374.

48) Impell did not review NUREG/CR-4536 until NECNP made Impell aware of the document. Tr. at 375. Impell is not on the mailing list for the Sandia reports. Id.

49) Harold Walker has been the NRC Staff's principal reviewer of the Seabrook program for the environmental qualifica-tion of electrical equipment for approximately the past four years. Staf f Dir. Te s t. at 1, Post Tr. 4 94.

50) Nr. Walker has on occasion read Sandia reports. Tr.

a t 511. He did not review NUREG/CR-4536. Tr. at 510. However, he does not know whether he receives all reports from Sandia Na-tional Laboratories. Tr. at 507.

[

NRC Audit

51) As part of it environmental qualification review, the NRC Staff conducted an audit of twelve equipment qualification files. Tr. at 676. The audit was conducted in conjunction with the Idaho National Engineering Laboratory ("INEL") . Tr. at 677.

i

52) Wi~th respect to six of those files, the NRC found I

deficiencies. Id . '

53) INEL concluded that "In all of the files reviewed dur-ing the on-site audit the applicant incorporated unacceptable ex-trapolations of the Ar rhenius Methodology to establish the demonstrated post-DBA operability times of their compongDts."

NECNP Exhibit 12, Be ahm, et al. , EGG-NTA-7186, " Audit of the En-vironmental Qualification of Safety-Related Electrical Equipment for the Seabrook Station," March 1986, at 6.

54) The NRC Staff's witness could not recall whether the Arrhenius equation was improperly used for all the files reviewed. Tr. at 679. However, he remembered some lengthy dis-cussion about the issue. Tr. at 682.

55) Following the audit, Applicants recalculated the Arrhenius equation for all of its equipment qualification files in which the equation was used. Tr. at 682. As a result of Ap-plicants' subsequent recalculations, it was found for a nunber of components that the post-accident qualification time was not as long as Applicants had previously~ thought, and had to be reduced.

Tr. at 683.

56) The audit revealed ths. qualification documentation was missing f rom two equipment qualification files. File No.

113-03-01 required the addition of testing information. Tr. at 685. File No. 174-15-01 required justification for use of a test sequence different from that specified in IEEE 323-1974. Id.

57) Two of the files needed additional clarifying lan-guage. File No. 113-06-01 required a statement that submergence qualification was not required. Tr. at 686. File No. 236-11-06, required the addition of clarifying test data to the equipment summary evaluation. Id.

58) For File No. 248-37-01, a Limitorque Motor Operator, the audit revealed three internal wires and a terminal block that could not be identified. Tr. at 6 87. Those components jusd to be identified or replaced. Id.

59) The audit also revealed that an ASCO solenoid valve (Equipment Qualification File No. NSS-220-02) had two different equipment identification nmnbers on it. Tr. at 6 87.

60) The NRC conducted no further audits of the Seabrook environmental qualification files.

61) The NRC generally performs an audit af ter it has reviewed a license applicant's equipment qualification program and concluded that it is basically adequate. Tr. at 692. The applicant also agrees that the program is substantially complete b'efore an audit is commenced. Id.

62) In choosing the equipment qualification files to be audited, the NRC staff attempts to achieve a random selection, except where it believes that there could be probelsm, or lack of information, or any indication that there are reasons to believe that a file may not be complete. Tr. at 693. -

63) In choosing the files to be audited for Seabrook, the NPC Staff consulted a table summarizing INEL's evaluation of en-vironmental qualification for safety components at Seabrook.

NECNP Exhibit 13, Beahm and Trojovsky, " Pre-Audit Review of the Seabrook Station Equipment Qualification Program."

64) Table 2 lists over 100 equipment qualification files i

for which Applicants identified deficiencies or for which INEL found there was deficient information. Id.

65) The NRC Staff met with Applicants to discuss each of the deficiencies identified by INEL, and Applicants agreed to correct them. The files to be audited were chosen as a , result of that discussion. Tr. at 696.

CONCLUSIONS OF LAW

66) Applicants' environmental qualification program must comply with General Design Criterion 4 of Appendix A to Part 50 and 10 CFR S 50.49. The environmental qualification requirements l

' of 10 CFR S 50.49 are based on the requirements of NUREG-0588,

" Interim Staff Position on Environmental Qualification of Safety-Related Equipment." Applicants for operating licenses are not

. required to requalify electric equipment important to safety if qualification in accordance with NUREG-0588 was previously re-q u '. r e d . 10 CFR S 50.4 9(k) .

67) The NRC's approval of the equipment qualification pro-gram for Seabrook is based on a finding of compliance with 10 CFR 50.49 and the requirements of NUREG-0588, Category I. Tr. at 501.

17 -

68) In order to provide assurance that safety equipment is qualified to survive an accident for the duration that it will be required to function, Applicants must comply with the require-ments of 10 CFR S 50.49 and NUREG-0588.

69) Under NUREG-0588, testing is the preferred method of qualification. Tr. at 501. Under 10 CFR S 50.4 9( f) (2) , testing a similar item of equipment is permitted if the tester performs a

" supporting analysis to show that the equipment to be qualified is acceptable." In the hearing, NECNP demonstrated that Ap-plicants have failed to meet this standard for two components.

a) Applicants assert that untested Anaconda SkV power cable is qualified by virtue of the fact that it is " exactly similar" to cable that was tested. This vague assertion is not illuminated by any detailed description or analysis or what the differences in the cables are. See TV 9-10 above.

b) Applicants did not test RG-58 instrument cable to r

establish its environmental qualification. Instead, Applicants relied on the manufacturer's unsupported expression of confidence in the similarity of the RG-58 cable to a tested cable. Ap-parently, the manufacturer's decision not to test the cable was based on cost considerations. Applicants made no attempt to test the cable or verify whether it would be excessively costly to test it. Instead, Applicants accepted the manufacturer's unsup-ported and self-serving assertion-that it was qualified. See 11 11-19 above.

70) NUREG-0588, S 2.l(2) establishes specific criteria for accepting analyses in lieu of testing. In general, the staff

will not accept analysis in lieu of test data unless (a) testing of the component is impractical due to size limitations and (b) partial type test data is provided to support the analytical as-sumptions and conclusions reached.

71) NUREG-0588, S 2.2(5), requires that:

Equipment should be located above flood level or pro-tected against submergence by locating the equipment in qualified watertight enclosures. Wher'e equipment is located in watertight enclosures, qualification by test or anslysis should be used to demonstrate the adequacy of suc.' protection. Where equipment could be sub-merged, it should be identified and demonstrated to be qualified by test for the duration required.

It is clear from this provision that although analysis may bean

~

acceptable means of qualifying submerged equipment that is sur-rounded by a watertight enclosure, unprotected equipment must be qualified by testing for the submergence condition.

72) Applicants have not complied with the requirements of NUREG-0588, S S 2. l( 2 ) and 2.2(5) in attempting to environmentally qualify 300 volt instrument cable that may be submerged during an accident. The environmental qualification testing of this com-ponent did not include submergence testing under stressful condi-tions. The fact that at the end of a 100-day test, the test ves-sel was submerged for an hour in room-temperature tap water, in-dicates to the Board that there was no practical impediment to testing this component for submergence. See 11 25-27 above.

73) Applicants have not complied with the requirements of-N UREG- 0 58 8, SS 2.l(2) and 2.2(5) in attempting to environmentally qualify Transamerica Delaval Level Transmitters. To support

~

their assertion that these level transmitters are qualified for

one year's submergence, Applicants performed a 30-minute qualification test. The 30-minute test was inadequate to support the qualification of the level transmitters. Therefore Ap-plicants added a "special condition" in the form of an oil riser that is intended to deter moisture intrusion into the level transmitters. See 11 31-33 above. ,

74) The Board finds that Applicants have violated the let-ter and purpose of NUREG-0588 by failing to demonstrate that these components are qualified for submergence by testing. There is obviously no practical impediment to testing the level trans-mitters for submergence, since such a test was carried qpt for 30 minutes. The addition of the riser device without additional en-vironmental qualification testing to establish the effectiveness of the riser does not meet the NRC's standards for submergence qualification.

75) Moreover, the manner in which the riser was designed and installed raises serious questions about the ability of this equipment to perform its intended function. A pressure test to examine the device for leak-tightness was deleted from the design specifications after it was discovered that the riser would not

! survive the pressure test. No particular inspection and i

m'aintenance . program was prescribed or documented in the equipment qualification file. See 11 3 4-38 above.

76) Finally, the instructions for installation of the riser were inconsistent with the design specifications that pur-portedly assured the environmental qualification of the level transmitters. See 11 39-45 above. -

77) The NRC's environmental qualification requirements are strict and exacting, for the vital reason that safety equipment that may be relied on in an accident must be counted on not to fail. This poorly designed and executed oil riser device cannot substitute for the environmental qualification of the level transmitters.- The. Board finds no reasonable assurance that the I

level transmitters'are environmentally qualified.

78) The NRC's' environmental qualification regulations re-

. quire that applicants and licensees keep a record of qualifica-tion in an auditable form during the entire period in which the safety components are used in the plant. 10 C FR S 50. 4 9J j ) .

79) Nearly each qualification file reviewed in the hearing had some documentation deficiency. The equipment qualification file for Anaconda SkV. power cable lacked a description of the differences between the untested cable used at Seabrook and the tested cable to which it was compared for purposes of environmen-tal qualification. See 11 9-10 above. The equipment qualifica-tion file for RG-58 coaxial cable also lacked documentation of the basis for comparing it to the cable used for purposes of es-tablishing qualification. See it 11-19 above. Changes in safety grade for cable supplying Instrument Rack MM-IR-12 and for limit switches RG-VS-618 and RH-VS-619 contained no de cumentation that justified or explained the downgrade in operability cod.- for these components from safety grade to nonsafety grade. See 11 20-24, 2 8-290 above. Equipment Qualification File No. NSS-220-( ~

contained an erroneous Qualification Evaluation Worksheet, which stated that equipment was above the flood level when. it was ac-l 1

1

.s

• tually submerged. See 11 30 above. Equipment Qualification File No. 174-15-01 asserts that the environmental qualification of certain level transmitters under submerged conditions depends in part on the integrity of an oil riser designed to prevent mois-ture instrusion into the level transmitters. However, the equip-ment qualification file contains no documentation that explains ,

or justifies the deletion of a prescribed leakage test for the riser, and fails to describe any inspection and maintenance pro-grams that might substitute for the detection of leakage through a pressure test. See it 3 3-37 above.

80) The experience of operating plant licensees and the results of testing and research performed by the NRC and its con-tractors are constantly yielding new and important information about the qualification of safety components and the tests by which they are qualified. Both Applicants and the NRC routinely review bulletins and notices from the NRC's Inspection and Enfor-cement branch regarding these issues. However, neither the Ap-plicants or the NRC Staff appears to have a routine and reliable mechanism for reviewing the applicability to Seabrook of environ-mental qualification reports issued by NRC contractors such as Sandia National Laboratories. These reports, may contain impor-t' ant information bearing on the reliability of the qualification of safety components used at Seabrook. See, e.g . , the report l

discussed in 11 46-50 above, regarding potential nonconservatisms in the testing of single-conductor cables to support the qualification of multi-conductor cables. Although that particu-lar report did not implicate the qualification of multi-conductor

t cable at Seabrook, it could easily have been applicable had the insulation on the Seabrook cables been slightly different. It was clear in the hearings, however, that neither the Applicants nor the NRC Staff had examined the report for its possible ap-plication to Seabrook.

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81) In the a,bsence of any systematic means for assessing the applicability and significance of current research conducted

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under contract to NRC by Sandia National Laboratories, the Board finds no reasonable assurance that Applicants' qualification pro-gram provides adequate protection to the public health and l 1 safety. _

82) The NRC does not have the resources to inspect each qualification file for completeness and accuracy. Petition for Emergency and Remedial Action, CLI-78-6, 7 NRC 4 00, 418-19 (1978). Therefore, the audit performed by the NRC Staf f on a li-cense applicant's environmental qualification files is a criti-cally important tool for assessing the quality of the applicant's overall qualification program.

83) The NRC's audit of Applicants' environmental qualification does not support a finding of reasonable assurance that the requirements of 10 CFR S 50.49 are met and that the pub-lic health and safety can be protected in the event of an acci-dent. Half of the files audited contained some deficiency, in-cluding failure to identify equipment properly or to provide test information showing qualification. For all of the files audited, the Applicants misapplied the Arrhenius equation.

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84) Moreover, the NRC did not wait until the equipment qualification program was substantially complete before embarking on the audit. The audit followed closely on an INEL study that showed extensive deficiencies in Applicants' qualification pro-gram. (See 11 63-64 above. ) The only apparent steps that were taken toward resolution of those issues before the audit con- 9 sisted of a meeting between the NRC Staff and Applicants. 165.

Given the large number of deficiencies identified by INEL, it was premature to begin an audit until the extensive revisions called for by the study had been completed. The audit's purpose -- of confirming the completeness of an applicant's environmental qualification program -- cannot adequately served when the pro-gram is still in a substantial state of incompleteness. The ex-tensive deficiencies in the program were only confirmed by the results of the audit.

85) It would be difficult and impractical for the NRC Staff or this Board to investigate every single equipment qualification file that purports to establish the environmental qualification of safety components at Seabrook. The NRC's general review and audit, although not comprehensive, are thus important diagnostic tools for assessing the health of Applicants' qualification pro-gram and the adequacy of the documentation that allegedly sup-

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ports the qualification of each safety component.

86) Based on the NRC's review and the testimony we have heard in these hearings, we cannot conclude that there is a rea-sonable assurance that Applicants comply with the Commission's environmental qualification program. In the files reviewed thus

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far, we have found serious inaccuracies, inconsistencies, and the lack of documentation supporting qualification. We believe that the extensive and repetitious deficiencies identified in this de-cision are not just isolated problems, but rather are indicators of systemic deficiencies in Applicants' environmental qualifica-tion program. ,

87) In light of the above-described deficiencies, we cannot conclude that there is a reasonable assurance that important-entire to-safety equipment can survive an accident at Seabrook for the time in which its survival may be required.

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PROPOSED FORM OF DECISION Upon consideration of the record of this hearing, the Board finds that Applicants have not met their burden of demonstrating satisf action of the Commission's environmental qualification re-quirements found in General Design Criterion 4,10 CFR S 50.49, and NUREG-0588. Moreover, the Board finds that there is no rea-i sonable assurance, in light of this noncompliance, that the Seabrook nuclear power plant can be operated without undue risk to the public health and safety. Therefore the Board denies Applicants' application for an operating license for the Seabrook nuclear power plant.

Respectfully submitted, C -

ane Curran HARMON & WEISS 2 001 "S" Street N.W. Suite 430 Washington, D.C. 20009 (202) 328-3500 November 12, 1986 a

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