ML19282B545

Forwards Applicants' Rebuttal Testimony by Gang & Walker Re ASLB Question 10-4 Concerning QA - Special Processes. Witnesses Will Testify on 790224

ML19282B545
Person / Time
Site:	Black Fox
Issue date:	02/12/1979
From:	Gallo J ISHAM, LINCOLN & BEALE
To:	Purdom P, Shon F, Wolfe S DREXEL UNIV., PHILADELPHIA, PA, Atomic Safety and Licensing Board Panel
References
NUDOCS 7903150328
Download: ML19282B545 (8)

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e ISHAM, LINCOLN & BEALE COUNSELORS AT LAW 10 5 0 17t= ST R E E f. N . W SEVENTH FLOOA was Mc NGTON, O. C. 2 OO 36 TE LE P HO N E 202 833-9730 C H'CbCO 09 9"CE ON E ria s? NafsONAL PLA2 A roserv-SECOND FLOOm February 12, 1979 c c.co,w ~O. .O.Os TELE pwoME 3t2-786-7500 TELEN.2 S288 Sheldon J. Wolfe, Esquire Mr. Frederick J. Shon, Member Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, 9.C. 20555 Washington, D.C. 20555 Mr. Paul W. Purdom, Director Environmental Studies Group Drexel University 32nd and Chestnut Street Philadelphia, Pennsylvania 19104 Re: In the Matter of the Application of )

Public Service Company of Oklahoma, )

Associated Electric Cooperat.'.ve, Inc.,) Docket No. STN 50-556 and ) STN 50-557 Western Farmers Electric Cooperative )

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(Black Fox Station, Units 1 and 2) )

Gentlemen:

I am enclosing copies of Applicants' rebuttal testimony with respect to Board Question 10-4 concerning QA - Special Processes. .

The witnesses are Messrs. Gang and Walker. They will be pre-sented to testify as indicated in the schedule, provided by Mr. Davis, on Saturday, February 24, 1979.

If a slack period in the schedule occurs during the first week of hearings, Applicants will attempt to make Messrs. Gang and Walker available to fill the time.

Sincerely,

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oseph Gallo 7 0 0 315 0 32F one of the Attorneys for the Applicants.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PUBLIC SERVICE COMPANY OF OKLAHOMA, )

ASSOCIATED ELECTRIC COOPERATIVE, INC.,) Docket Nos. STN 50-556 AND WESTERN FARMERS ELECTRIC ) STN 50-557 COOPERATIVE, INC. )

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(Black Fox Station, Units 1 and 2) )

Rebuttal Testimony of MESSRS. WILLIAM G. GANG AND HAROLD C. WALKER On Board Question 10-4 t

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REBUTTAL TESTIMONY OF MESSRS. WILLIAM G. GANG AND HAROLD C. WALKER ON BOARD QUESTION 10-4 In response to questioning from Mr. Shon, Mr. Richard Hubbard, expert witness for the Intervenors on Board Question 10-4, relating to special processes in the Quality Assurance program testified (Tr. 6157) as follows:

Q. (by Mr. Shon) As I see the chief dif-ference between your position and that of Mr. Long, for example, it is that this third criterion of Mr. Long's, that the specified quality cannot be readily determined by an inspection or test, is a criterion that may be rather difficult to imple-ment or define.

He seems to feel that if you can make a given test on something and tell that it's working, then the thing does not satisfy that criterion.

You seem to feel that a simple test that shows that it's sorking does not properly define a more subtle quality, which is the quality of duration in service and, in fact, you feel that there are many cases where duration in service '

simply can't be tested at all on a given piece of production equipment, and that therefore all such things that tend to degrade in service should be controlled by special process. Is that right?

A. (by Mr. Hubbard) I always hesitate to say all, but I think that--in looking at Mr.

Long's definition, I think that that is a weak-ness in that definition.

Q. That it doesn't cover things that might degrade in service, but are inspectable on production; is that right?

A. Yes, sir. (Emphasis added)

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Mr. Hubbard's testimony is incorrect since there are methods by which duration in service can be tested for equipment. These procedures are set forth in IEEE-323, 1974, IfEE Standard for Qualifying Class lE Equipnant for Nuclear Power Generating Stations. This standard provides methods for establishing a period for which satisfactory service can be demonstrated. This period is then con-sidered the qualified life for the equipment. Following this period, corrective action will be taken, which may consist of maintenance, modification, or replacement.

Thus, equipment is qualified to assure that it will per-form on demand to meet the system performance requirements.

The methods of qualification described in IEEE-323,

. 1974, are:

1. Type test.ing, which is the testing of samples of equipment of the same type being used in the plant;

2. Operating experience, which is based on docu-mentation which supports service conditions and equipment performance;

3. Analysis, which requires the construction of a mathematical model of the equipment to be qualified;

4. Combined Qualificatien, which may use type testing, previous operating experience, analysis, or by combination of these methods;

5. On-Going Qualification, which requires the aging and testing of identical equipment or components during the qualified life period of the installed equipment

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In general the standard is applied to complete units of equipment and their interfaces rather than to the individual components of that equipment.

Regulatory Guide 1.89 endorses IEEE-323, 1974, as a means of complying with the NRC's regulations with regard to design verification. PSO is committed to compliance with IEEE-323, 1974. The items listed by Mr. Hubbard on page 10-19 of his prefiled testimony--neutron sensors, seals of electrical penetrations, LPRM seals, circuit boards, pressure transmitters, process instruments, and relays--will be qualified under IEEE-323, 1974, or an ap-propriate implementing standard. Furthermore, these items will be qualified after completion of the respective fabrication processes which Mr. Hubbard suggested should he treated as special processes. Because the items are tested for duration in service after these processes, there is no need to expand the criteria for special processes as Mr. Hubbard suggested. The remaining process and item he mentioned--crimping and terminating of con-trol cables-- would not in any event constitute a special process because the items can be readily tested and in-spected after the process.

Class lE equipment at Black Fox will be qualified

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_4 under IEEE-323, 1974, or under other standards which have been adopted as a means of implementing the type testing set forth in IEEE-323. IEEE-383, 1974, is one of the standards for implementing IEEE-323. In this connection, we note that Mr. Shon asked, at transcript 6798, what kind of aging tests Tef el has been subjected to and what the results were. The aging tests applied to Tefzel cable were heat aging, and Tef e1 was shown to meet the re-quirements of IEEE-383, 1974, for cable to be used in nuclear power plants.

Qualification procedures, such as those under IEEE-323, 1974, are performed as part of the design function and not as a production control. These procedures are intended to measure the adequacy of the design to per-form its intended function throughout its design lifetime.

They are a part of the design verification process, not a means of testing each item as manufactured. The qualification procedures would not be practical or ap-propriate as an acceptance test for items at the produc-tion phase because, among other considerations, they may be destructive.

For these reasons, the qualification procedures are not properly considered as part of the quality assurance function, and Mr. Hubbard's suggestion that the criteria for special processes should be expanded to account for

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duration in service is not well taken. It is a part of the quality control function to determine by inspections or tests whether the specified design requirements have been satisfied. If the specified quality requirements can be readily determined by inspection or test, the third criterion on page two of the testimony of Donald G. Long on Board Question 10-4 has been satisfied and the related process is not "special" within the meaning of 10CFR Part 50, Appendix B, Criterion IX. If the specified quality requirements cannot be readily de-termined by inspection or test and Criterion 1. and Criterion 2. are also satisfied, the related process would be considered "special".

A statement of Mr. Harold C. Walker's qualifications is attached as Attachment I.

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ATTACHMENT I HAROLD C. WALKER Supervisor, Electrical and Instrumentation and Control for Black Fox Station.

EDUCATION:

B.S. Electrical Engineering, 1964 M.S. Mathematics, 1969 ADDITIONAL EDUCATION AND TRAINING:

BWR Plant Design and Fundamentals - G.E. Course, 1977 Codes and Standards Workshop - B&V, 1976 EXPERIENCE:

As Supervisor of E7 actrical and Instrumentation and Control, Mr. Walker reports '- the Manager, BFS Engineering, and is responsible for the surveillance of selected electrical, instrumentation and control design and procurement documents to ascertain they are in accordance with applicable codes, standards, regulations and Public Service Company of Okla-homa's requirements and standard practice. Prior to this, Mr. Walker was Electrical Supervisor at Riverside Station where he reported to the Station Superintendent and was responsible for the electrical, instrumentation and control check-out of two gas fired generating units. After the units were on line, he was responsible for the maintenance of this equipment through administrative control and technical sup-port of plant electrician and technicians. During this time, it was necessary to initiate and implement control design changes to improve operability of certain systems, initiate and administer checkout procedures and implement preventive maintenance procedures. Prior to this assignment and fol-lowing his employment with Public Service Company of Oklahoma in 1969, he worked as an Electrical ?.ngineer with various assignments in the General Office and power stations. These assignments included design, installation and checkout of a water induction prevention system and other projects related to power station operation and maintenance.

Prior to employment with Public Service Company of Oklahoma, Mr. Walker was employed as an electrical engineer working with ground support telemetry at the Chrysler Space Division in New Orleans, Louisiana. In this position, he was re-sponsible for coordinating the design of a demultiplexing system for receiving and processing vibration information.

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