ML20214R247

Supplemental Testimony of H Walker Re NRC Review of Util Program for Environ Qualification of Electrical Equipment. Related Correspondence

ML20214R247
Person / Time
Site:	Seabrook
Issue date:	09/19/1986
From:	Walker H Office of Nuclear Reactor Regulation
To:
Shared Package
ML20214R231	List: ML20214R228 ML20214R247 ML20214R265 ML20214R282
References
OL-1, NUDOCS 8609290119
Download: ML20214R247 (9)

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, DOCKETED USHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION SEP 23 P3:10 i

CFFU o-BEFORE Tile ATOMIC SAFETY AND LICENSING If0ARD; ,'

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In the Matter of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443 OL-1 j NEW HAMPSilIRE, et al. ) 50-444 OL-1

) On-site Emergency Planning (Seabrook Station, Units 1 and 2) ) and Safety Issues NRC STAFF SUPPLEMENTAL TESTIMONY OF i  !!AROLD WALKER ON NECNP CONTENTION I.D.2 l

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Q.1. Please state your name and by whom you are employed.

A.I. My name is liarold Walker. I am employed by the U.S. Nuclear Regulatory Commission as a Mechanical Engineer in Section A of Electrical

Instrumentation and Control Systems B ranch , Division of PWR Licensing-A , Office of Nuclear Reactor Regulation. A copy of my professional qualifications is attached hereto.

Q.2. Please state your involvement with the NRC Staff's review of I i

l the Seabrook program for the environmental qualification of electrical

! equipment .

! A.2. I have served as the NRC Staff's principal reviewer of the Seabrook program for the environmental qualification of electrical i

j equipment for approximately the past four years. As part of my i responsibilities, I previously testified in this proceeding concerning ,

' 1 In addition, I was the

) NECNP Contention I.D.2, on August 17, 1983.

l principal author of the Staff's evaluation of the Seabrook environmental

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a l qualification program, as set forth in I 3.11 of Supplement No. 5 to the <

" Safety Evaluation Report Related to the Operation of Seabrook Station, l Units 1 and 2," NUREG-0896 (July 1986) ("SSER 5").

Q.3. What is the purpose of this supplemental testimony?

1 A.3. The purpose of this supplemental testimony is to provide the l

i j NRC Staff's current position on NECNP Contention I.B.2. That t

contention states as follows:

The Applicant has not satisfied the requirements of GDC 4 that all equipment important to safety be l

environmentally qualified because it has not specified

! the time duration over which the equipment is qualified.

I Q.4. What is the basis used by the Staff for evaluating compliance with the requirements of 10 C.F.R. Part 50, Appendix A, General Design

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Criterion (GDC) 4?

j A .4. As set forth in my prior testimony in this proceeding (ff.

l Tr. 990, at 2), 10 C.F.R. I 50.49 specifies the requirements that must be met to demonstrate compliance with GDC 4, relating to the environ-

! mental qualification of electrical equipment important to safety that is located in a potentially harsh environment. In conformance with 10 C.F.R. I 50.49, electrical equipment for Seabrook Unit 1 may be qualified j in accordance with the acceptance criteria specified in Category I of i

NUREG-0588. In addition, guidance as to the means by which 10 C.F.R.

I 50.49 may be satisfied is provided in Reg. Guide 1.89, 1

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Q.5. Has the Staff determined whether the Applicants have included in their environmental qualification program all electrical equipment

e important to safety that is located in a potentially harsh environment, in accordance with GDC 4 and 10 C.F.R. I 50.49?

A.J. Yes. In a submittal to the NRC dated October 31, 1985

(" Environmental Qualification of Electrical Equipment Important to Safety, Revision 2"), the Applicants indicated that the electrical equipment important to safety that is located in a potentially harsh environment and l is required by GDC 4 and 10 C.F.R. I 50.49 to be environmentally qualified , is included in their equipment qualification program ( Id ._ , at 1-3). Based upon that submittal, and additional submittals dated April 10, May 7 and June 20, 1986, as reflected in SSER 5, I 3.11.3.1, the Staff is satisfied that the Applicants have included in their environmental qualification program all electrical equipment important to safety that is located in a potentially harsh environment and required to be environmentally qualified under GDC 4 and 10 C.F.R. I 50.49.

4 Q.6. Have the Applicants specified the pre-accident time duration i

over which the electrical equipment important to safety that is located in n

.; a potentially harsh environment is environmentally qualified?

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A.6. Yes. The Applicants have specified the qualified life for such i

) equipment, which includes pre-accident, accident, and post-accident time

! durations. The Applicants have indicated that all such equipment is i

qualified to be run under pre-accident (that is, normal) operating conditions without losing its ability to withstand a harsh environment after a postulated accident has occurred, (a) for the lifetime of the plant, I or (b) for shorter periods for particular items of equipment, in which 1

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! case such equipment is to be replaced, refurbished or requalified before the period elapses.

! Q.7. IIave the Applicants specified the post-accident time duration over which the electrical equipment important to safety that is located in a potentially harsh environment is environmentally qualified?

i A.7. Yes. The * 'plicants have stated that all such equipment is i environmentally qualified to perform its required safety function for a 1

period of one year following the occurrence of a postulated accident, with i the exception of 12 equipment item types which have been determined to be qualified for periods of less than one year. These 12 equipment item types, and the respective periods of time for which they have been i determined to be environmentally qualified following the occurrence of an accident, are set forth in SSER 5, Table 3.1, at p. 3-34.

Q.8 llave the Applicants satisfied their commitment, referred to in your prior testimony (ff. 990, at 2), as follows:

[ A]Il equipment in their environmental qualification program which is required to function in a harsh environment will be qualified for the postulated post-accident duration of one year. . . . [S]hould it be determined that specific pieces of equipment cannot be qualified for one year, the required operating time for that component will be determined and the component will be qualified for at least that duration plus margin.

1 A.8. Yes. As set forth in SSER 5, 5 3.11.3.4 and Table 3.1, where the Applicants have determined that items of electrical equipment important to safety located in a potentially harsh environment are not i environmentally qualified to perform their safety function for a period of one year following a postulated accident, the Applicants have determined I

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l the required time for which that equipment must perform its safety i function, and have determined that the equipment is environmentally qualified to perform its safety function for that period plus a margin of at least one hour, in accordance with Position C4 of Reg. Guide 1.89, Revision 1.

l Q.9. Ilas the Staff determined whether the Applicants' environmental i

qualification program satisfies GDC 4, as implemented by 10 C.F.R.

I I 50.49, with respect to the time duration over which the electrical equipment important to safety is environmentally qualified?

A.9. Yes. The Staff has determined that the Seabrook environmental qualification program satisfies GDC 4, as implemented by 10 C.F.R.

I 50.49, with respect to the time duration over which the electrical equipment important to safety is environmentally qualified.

Q.10. Please state the basis for this determination.

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A.10. The Staff's determination that the Applicants have satisfied GDC 4, as implemented by 10 C.F.R. I 50.49, with respect to the time durction over which the electrical equipment important to safety is environmentally qualified , is based upon the Staff's review of the Applicants' submittals and the results of the Staff's audit of the Seabrook environmental qualification program.

With respect to post-accident time duration, as set forth in SSER 5, i I 3.11.3.4 (at p. 3-24), Staff guidance typically provides that electrical equipment important to safety that is located in a potentially harsh i

environment be environmentally qualified for a period of 100 days after an I

accident . In some instances, regulatory guidance allows for post-accident qualification periods of substantially less than 100 days; in those instances , an applicant is expected to satisfy the post-accident time margin requirements specified in Position C.4 of Reg. Guide 1.89, Revision 1. The Staff has reviewed the Applicants' determination that the electrical equipment important to safety at Seabrook which is required to be environmentally qualified under GDC 4 and 10 C.F.R. I 50.49, is qualified for a period of one year following a postulated accident or, in the alternative, for the time required to perform its safety function plus a margin, as specified in Position C.4 of Reg. Guide 1.89, Revision 1.

The Staff has found this to be acceptable, based upon its reviews of the Applicants' submittals and the results of the Staff's environmental qualification audit.

First, the Applicants' determination was based upon test results and analyses , summaries of which have been submitted to the NRC Staff.

While the Staff has not independently verified the test results and analyses submitted by the Applicants, the Staff evaluated the Applicants' submittals in light of comparable information submitted by applicants and licensees at other nuclear power plants, and exercised engineering judgment in reaching its conclusion that the Applicants' determination is acceptable.

Second, on February 25-27, 1986, the Staff conducted an audit of the Applicants' environmental qualification documentation and installed electrical equipment , during which time the Staff and its consultants reviewed twelve environmental qualification files which had been selected by the Staff for review during the audit. Included within the information

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l contained in these files was information concerning the time duration for a

which the equipment items had been determined to be environmentally qualified. The Staff's audit did not result in any detrimental findings concerning either the pre-accident time duration for which the Seabrook electrical equipment important to safety is qualified or the time duration for which such electrical equipment is qualified to perform required safety functions following the occurrence of a postulated accident.

With respect to pre-accident time duration, the Staff has reviewed i

i the Applicants' determination that the electrical equipment important to safety that is located in a potentially harsh environment is qualified for the lifetime of the plant, or for shorter specified periods for particular i

items of equipment in which case the equipment is to be replaced , l refurbished or requalified before the specified period elapses. This approach is consistent with 10 C.F.R. I 50.49(e) and is acceptable.

Based upon its review of the Applicants' submittals and the results of the

. i Staff's environmental qualification audit, the Staff is satisfied that the Applicants have satisfactorily specified the pre-accident time duration for i which electrical equipment important to safety at Seabrook is environmentally qualified.

On this basis , the Staff is satisfied that the Applicants have satisfactorily specified the time duration over which electrical equipment important to safety that is located in a potentially harsh environment is i

l environmentally qualified , in conformance with GDC 4 and 10 C.F.R.

i 5 50.49.

PROFESSIONAL QUALIFICATIONS OF HAROLD WALKER I am currently a Mechanical Engineer in Section A of Electrical Instrumentation and Control Systems Branch, Division of PWR Licensing-A, Office of Nuclear Reactor Regula' tion, United States Nuclear Regulatory Comission. From September 1981 to November 1985 I was a Mechanical Engineer in the Environmental Qualification Section of the Equipment Qualification Branch, Division of Engineering, Office of Nuclear Reactor Regulation, United States Nuclear Regulatory Commission. In both positions my duties have included perfonning technical reviews, analyses and evaluations of the adequacy of the environmental qualification of electrical and mechanical equipment whose failure, due to such environmental conditions as temperature, humidity, pressure and radiation, could adversely affect the performance of safety systems. I was previously a Materials Engineer in the Materials Engineering Branch where my duties and responsibilities involved the review and evaluation of Materials performance from the standpoint of operability and functional capability and integrity under normal, abnormal, and accident loading conditions, and analyzing fracture toughness of reactor vessel materials including specific data to assure that the materials will behave in a non brittle manner.

Prior to my position in the Materials Engineering Branch, I was a materials engineer in the Engineering Branch, Division of Operating Reactors. My duties and responsibilities included the review of operating problems to determine if safety requirements were being satisfied and to assure that operating problems were corrected, and met with due regard for safety and environmental protection.

Prior to my position in the Engineering Branch, I was a ACRS Fellow at the Advisory Committee on Reactor Safeguards. My duties included collecting and consolidating information pertaining to non-destructive testing methods.

I have a B.E. Degree in mechanical engineering from the City College of the City University of New York and I have taken graduate courses at the University of Pittsburgh.

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i i Prior to joining-the NRC, I was an engineer at Westinghouse Research Corporation I in Pittsburgh, Pennsylvania where my duties included the application of the state of the art fracture mechanics as well as the study of structural integrity I of materials in various environments and under various loading conditions.

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