ML20090J549

Rebuttal Testimony of W Levis on Behalf of NRC Staff Concerning Gems Level Transmitters.* Related Correspondence

ML20090J549
Person / Time
Site:	Farley
Issue date:	03/13/1992
From:	Levis W CENTERIOR ENERGY
To:
Shared Package
ML20090J191	List: ML20090J543 ML20090J549
References
91-626-02-CIVP, 91-626-2-CIVP, CIVP, NUDOCS 9203170299
Download: ML20090J549 (6)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOAllD in the Matter of )

) Docket Nos. 50 348-CivP ALABAMA POWER COMPANY ) 50-364-CivP

)

(Joseph M. Farley Nuclear Plant, )

Units 1 and 2) )

) (ASLBP NO. 91-626-02-CivP)

REBUTTAL TESTIMONf Ur hLIAM LEVIS ON BEHALF OF THE NRC STAFF CONCERNING GEMS LEVEL TRANSMITTERS Ql. State your full name and current pasition with the NRC, A. William Levis, Senior Resident Inspector, Davis Besse Nuclear Power Station.

Q2. Have you prepared a copy of your Professional Qualifications?

A. A copy of my Professional Qualifications has been admitted previously into evidence as Staff Exh.1.

Q3. What is the purpose of your testimony?

A. The purpose of mylestimony is to rebut portions of the Alabama Pcwer Company (APCo) Testimony regarding violations of the environmental qualification (EQ)-

requirements for the GEMS level transmitters at the Farley nuclear plant which led to the civil penalty that is the subject of this hearing. The APCo testimony which is i

the subject of this rebuttal testimony is contained in Direct Testimony of Jesse' E.

Dbho!O$$$4g PDR

Love, James E. Sundergill and David H. Jones on Behalf 'of Alabama Power Company (ff. Tr. 978) and Direct Testimony of Philip A. DiBenedetto on Behalf of Alabama Power Company (ff. Tr.1227).

Testimony of Love. Sundergill and Jones Q4. Who first discovered the low or missing silicone oli levels in the GEMS level transmitters? (p.201, Q&A _183)

A. The first GEMS transmitter without any silicone oil was found by NRC inspectors in the company oflicensee representatives. Subsequent to that, APCo found three more GEMS transmitters in an environmentally unqualified condition, because of silicone oil at a level not supported by the qualification documentation. -

Q5. Is APCo correct in its assertion that the low silicone oil level in the GEMS level-transmitters was - an installation / maintenance problem and = not an environmental qualification problem? (p.202, Q&A 185)

A. No. In answer to APCo Q185 Mr. Sundergill states that the lack of oilin the GEMS transmitters does not indicate a weakness in the environmental qualification process.

In his testimony, Mr. Sundergill initially testified that ?the four specific examples of-installation deficiencies in the GEMS containment sump transmitters do not properly o

3 renect on APCo's EQ program." When cross examined on this point, Mr. Sundergill changed his testimony to "the four specific examples of installation or maintenance." ,

(Tr. I170). Mr. Woodard in his testimony, her/ever, testines that Alabama Power Company did not create a separate organization whose job was EQ management.

Mr. Woodard testined that APCo " integrated these requirements into our plant organization." (Tr.1301). The point is that the environmental qualification regulation requires licensees to establish a program for qualifying the electric equipment important to safety as that equipment is installed in their plants. The GEMS transmitters were identined by APCo on their master list as requiring quali6 cation. Four of the transmitters were in a con 0guration for which APCo had not established environmental qualification. If the equipment is not properly installed and maintained, it may not work when required, notwithstanding how many test reports say the piece of equipment is qualified.

Alabama Power Company had no idea or record of the condition of the GEMS level transmitters as of the environmental qualineation compliance deadline of November 30,1985. ' The APCo technical panel of Messrs. Love, Sundergill, and Jones that testified on the GEMS transmitters stated they had no knowledge of the silicone oil level.in the transmitters as of November 30,1985 in response to questioning on this point by. Judge Carpenter. (Tr.1171). The nonconforming silicone oil level condition went unnoticed by APCo until the NRC discovered the l

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l condition on a transmitter during the November 1987 inspection. The NRC inspectors were offered no records that would indicate that the GEhtS transmitters had not been in that condition since before the compliance deadline of November 30, 1985. In his deposition during discovery in this proceeding, hir. Berryhill, who was APCo's hianager of System Performance, an organization which included the quality control group, testified that APCo did not know how or why the nonconforming silicone oil condition occurred.

Q. All right. Would you say that that was a maintenance problem if you're familiar with the particular situation?

A. Well, you know, if I speculated on it I can't say why what we found existed. We couldn't go back and establish -- to my knowledge it was never -- generally when something like that happens we -- and as I recall in this case too you do a very thorough research of your documentation, and you go back and interview a lot of people, and in most cases the interview turns up who did what in the past. 4 1 don't recall that we found an individual, but from my viewpoint I believe tb?.! it was probably some mistake or whatever you want --

you know, that during that maintenance process maybe the fluid was-not put back ir., but again I have no documented evidence either way how it got there.

I do know that for one of those that I believe it was almost all the fluid gone as I recall.

Deposition of Robert Berryhill, June 26,1991, p. 43-44.

This example of four of the eight GEhis transmitters having low silicone oil levels, combined with the lack of discipline APCo displayed in the installation of the V-type terminations leads me to conclude that EQ program requirements were not understood or implemented at the craft level at the Farley plant. This demonstrated -

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5 lack of assurance of EQ requirements and the apparent insensitivity to the importance of EQ equipment and its corresponding special requirements on the part of craftsmen and their management at Parley indicates to me a weakness in the environmental qualification process and not just an installation or maintenance problem as hir Sundergill would have the Board believe.

Testimony of DiBenedltle Q6 Has the NRC Staff suggested that " component disassembly" be included as part of walkdowns? (pp.47-48, Q&A 47)

A, hit. DiBenedetto's response to APCo Q47 leaves you with the impression that complete disassembly was required to perform walkdowns to get the level of detail that the NRC inspector:: were looking for during NRC inspections or that would have been expected of a licensee during licensee verification of proper installation. This is not true. ' The only " disassembly," if you want to call it that, that was required for the NRC inspectors to do their inspections during the NRC walkdowns was the removal of_ switch covers, conduit covers, junction box covers and actuator covers.

This is also the level of detail that other licensees required of me when I was an engineering consultant on EQ matters, prior to my employment with the NRC.

Q7. Does this complete your testimony regarding this matter? -

I A. Yes.

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