ML19331B884
| ML19331B884 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 08/06/1980 |
| From: | Litton F Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19331B836 | List: |
| References | |
| ISSUANCES-CP, NUDOCS 8008130479 | |
| Download: ML19331B884 (15) | |
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UNITED STATES OF AMERICA
. NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In i.he Matter of l
HOUSTON LIGHTING & POWER COMPANY
)
Docket No. 50-466 i
)
l (Allens Creek N; clear Generating
)
Station. Unit 1)
)
AFFIDAVIT OF FELIX B. LITTON CONCERNING DOHERTY CONTENTION 35 i
My name is Felix B. Litton.
I am employed by the Nuclear Regulatory Commis-t sion in the Materials Engineering Branch.
I have been so employed since 1975. A.;tatement of my professional qualifications is attached.
The purpose of my affidavit is to address Doherty Contention 35, which reads as follows:
Applicant will be unable to provide safe welding of piping at ACNGS without costly repairs to such welding or danger to peti-tioners health and economic interests in the event of pipe break as a result of such welding not being rewelded when it should have been. Welding at Comanche Peak Nuclear Steam Station, Units 1 & 2 in Somerville County, Texas, has been done frequently by persons being trained to be, welders prompting large frequency of rewelding and seven meetings between NRC officials and the utility repre-sentatives.
This Intervenor says the same situation is likely te occurhereduetoashortageoftrainedem)loyeesandlessthan union wages from Applicant s constructor, Ebasco.
Intervenor contends Applicant should be required to present a program for training persons before they weld at the ACNGS site and to require a pay scale for employees of all contractors for welding and welvers equal to union wages for welders at similar construction conditions, in order to assure continued employment of such welders.
.8 0 0 81 a o 4t73 a
Griterion IX of Appendix B of 10 C.F.R. Part 50 requires that measures be established to control special processes, including welding, and that they be perfomed by qualified personnel using procedures confoming to the applicable codes, standards, and specifications.
For welding qualification, the applicable standards (per Appendix B) are contained in Section IX of the ASME Boiler and Pressure Vessel c de.
In Section 3.6.3.1.1.5.3.2 of the o
Allens Creek Nuclear Generating Station Unit 1 Preliminary Safety Evaluation Report, Houston Lighting and Power Company states that welders shall be trained to perfom welding procedures to the standards required by the above-mentioned section of the ASME code.
In order to ensure ductile behavior of the welds for the Allens Creek facility Houston Lighting and Power Company requires, in addition to the ASME code requirement, that Charpy-V notch impact tests be perfomed as part of the weld qualification tests.
Section IX of the ASME Boiler and Pressure Vessel Code does not control the basic or fundamental training of the welder or welding operator. The intent of the code is to ensure that the welder or welding operator perfom the welding procedures specified for the facility to make sound welds, which possess the necessary mechanical properties.
Perfomance qualification tests are required by Section IX of the code from each manufacturer or contractor to qualify each welder or welding operator for each welding procedure or process to be used in the production welding.
If, during the perfomance qualification tests, it becomes apparent to the supervisor a
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conducting the tests that th welder or welding operator does not possess the skill to produce sai ;Tm t >ry welds, the tests are teminated and the welder or welding operator disqualified.
)
The type and purpose of the tests and examinations required for the Welding Procedure Qualifications are stated in Article III of Section IX cf the ASME code. The actual test may be selected from a group cf tests required for a particular Welding Procedure Qualification.
The Houston Lighting and Power Company requires that Charpy-V notch 1,mpact tests be perfomed in addition i
to the particular Section IX requirements.
The tests that are required by
)
the code may be Tension Tests, Guided Bend Tests, Notch-Toughness Tests, l
Fillet-Weld Tests, and other tests and examinations, including Radiographic and Macro-scopic Examination. The acceptance criteria are stated with the the test requirements.
l In compliance with Section IX code requirements, Houston Lighting and Power Company has established a Quality Assurance Program at the Allens Creek Nuclear Generating Station Unit I and has developed written procedures and controls for fabrication of components to ensure that production welding is perfomed by qualified personnel. Additional fabrication welding and weld-ing during construction at the site will be governed by procedures developed i
pursuant to Appendix B and ASME Code requirements. These procedures describe the welding to be performed and the documentation required. Confomance to these requiremen,ts is assured by a review of the procedures and controls by authorized inspectors and audits to verify implementation.
1
4-The Applicant and its architect engineer are responsible for testing and documenting the adequacy of production welds. This documentation is then audited by the Commission's Office of Inspection and Enforcement to ensure that the production welds possess the necessary mechanical properties.
The Office of Inspection and Enforcement has conducted inspections since 1974 for the Allens Creek Nuclear Generating Station Unit I for the implementa-tion of the Quality Assurance Program by the Houston L,ighting and Power Company. The inspections consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors. No deviations were identified within the scope of the '
inspection in the most recent report.
With regard to Mr. Doherty's allegation that there is a shortage of trained welders, the short answer is that until the individuals who are to perfom the production welding at Allens Creek pass the qualification tests, no production welding will be perfomed.
l Therefore, the conduct of safe welding operations at Allens Creek will be assured by (1) the requirements of 10 CFR Part 50, Appendix B which mandate appropriate welder qualification, (2) the testing requirements of the ASME code and the Applicant, (3) the examination of production welds by the architect engineer and Applicant to verify that they possess necessary mechanical properties, and (4) the audit of those tests by the Office of Inspection and Enforcement.
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.... The foregoing affidavit was prepared by me and I swear that it is true and 4
correct to the best of my knowledge, information and belief.
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&M 'JG Felix B. Litton Subscribed and sworn to before me this 6th day of August,1980, 1
4L 4:st NotargPublic t
L My Commission expires:
July 1, 1982 e
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I i
PROFESSIONAL QUALIFICATIONS FELIX B. LITTON I am a Senior Materials Engineer in the Materials Engineering Branch of the Office of Nuclear Reactor Regulation Nuclear Regulatory Commission.
I am assigned to the Inservice Inspection and Component Integrity Sections and my duties involve the revies and evaluation of materials and processes used in the construction and oper3 tion of components in the nuclear power industry.
My education consists nf a B. S. (1936) and M. S. (1937) degree in Physical Chemistry from Virginia Polytechnic Institute, Blacksburg, Va.
I have completed additional study in Material Science at the University of New Mexico and have taken special courses in Fracture Mechanics and other job oriented courses at Union College and Georoe Washington University.
Prior to joining the Nuclear Regulatory Commission, my experience consists of metalluraical research related to the preparation, fabrication and alloy formation of new structural materials for nuclear, advanced aircraft and high temperature application.
I have published in technical journals on the environmental behavior, thermodynamic stability and mechanical properties of uranium, plutonium, vanadium, zirconium, tetanium, hafrium and silicon and their alloys. Although my primary experience in ferrous metallurgy has related to the cause of material failure in service. I have managed metallurgical research on welding and welding processes.
=..., _ _ _ __ __ _ __ - _ _ _ _
.I _
DOHERTY CONTENTION 35 1
the reactor.
2 0
A Class 9 accident at another plant 4C
.3 milec away?
4 A.
That would do I think.
5 C.
Is that it?
A class 9 accident er riles r
away v.111 be a!>andoning Allens creek for 3e yerrs?
h 7
A.
A lower accident might also co it.
r C.
Let's c to your last contention on I
E welder training.
That's number 35.
I T
It
!!o w did you surmise that there's a 11
.stortage of trained e"ployees?
12 A.
There eren't any enplcyees.
12 C.
It's yo';r rententien, Fr.
Poherty.
J' 7.
So.
I said there will be.
ell, up in If callas there's a s.'ertage of trained empl oyees,
ir and there's been sono poor welding reported at 17 C.
Le t 's deal with these in incri=ents.
IF A.
These are.to employ your cuestion.
10 C.
The fact that they've had welding 20 problets at Fouth Sexas indicates that there's a 21 sno r tage of welding enployees?
22 A.
It may be well to go in and find out 23 that tha t's not tne case.
That they are well 2t trained, but they are not doing their job.
25 c.
to you have any other factuel basis that i
l INiinNA 2 che L cctni nEPccThac, INC.
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o PotSTON, T L7 A S (713) 552-5"11
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1 there will be a shortage of trained coployees 2
ether than the alleged problems at comanche Peak
,.i and routh 1exas?
~4 4
A.
No.
t'o t h i ng definite.
Cossip.
5 C.
Iow did you surmise that an. FCG will ti cay i
7 A.
You've f o rg o t te n that Ebasco, to my l
T knowicFge, was to be recoved.
O.
Ind that portion ses drorped in the 10, c o.m t e n t i o n ?
11 In the Foard's order and at the 22 licensing hearing it uas rerorted to ne that if I.
11 Chasco is a union business, which our under-le standing is, t !.a t that part is not part of the 25 contention any longer.
i 16 C.
All right.
Fe'11 consider that i'
17 withdrawn.
18 Ita v e you examined UL&P's or Ebasco's 19 selding procedures or CA and Oc procedures 2C relative to welding?
21 A.
No, I don't think so.
22 C.
So you have no basis fo r coementing on 23 the sufficiency of those procedures 2r A.
No t of'those procedures as written, no.
i 25 C.
Le t me. focus now on what exactly is the I.N T L E N A T I C N A L C C Uit i FFFORTERS, INC.
HOUSTON, TEXAS (713) 652-5831 Vrl
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1 oviinitive factual basis for this contention.
1 You allege that there is potential 2
absence of trained enployees due to occurrences 4
at Conanche Feak and at South Texas.
Fhat other 5
facts will contribute to that?
A.
The shortage that you're concerned about?
7 C.
't e s.
The shortage.
tbat else will 5
contribute to inFroper welding?
a A.
Inadecuate training.
J C, C.
Eave you exanined litsP's or Ubasco's Il
- r. r o c e d u r e s for training, welding or training 1
17 welders or qualifying welders or the re-12 c; u a l i f i c a '. i o n s of welders or any other part of CA i
s Id enc CC procecures for monitoring welding?
o 15 A.
No.
j If C.
So is it just speculation on your part
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17 that there will be inproper training?
lb A.
Well, the back up we've already 2
19 nentinned on this contention.
20 0.
I'm sorry.
II A.
Unless I nicunderstood wha t you said.
l 22 C.
How do you know that Ebasco's training 23 of its welders will be inadequate?
24 A.
At this nonent, I do not know that 25 tbasco's pa r t in this will be inadequate.
I.
I A ": & h A T n' A A f
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11 v 1
C.
Lell Ebasco is the constructor, is it 2
not?
I'h a s c o sf31 be doing the wielding, so I 3
don't know who's part other than Ebasco's we're H
/.
talking abcut.
5
- 1..
!! L & F has a part, too.
?
C.
Is it your understandinc that 8' I. & P vill 7
be d o i rig so.e wc3 ding?
F A.
It's oy understanding that II L & P will be l' L & F is in a O
rart of the cc and whatever P L& P 10 position to i n f l u e..c e that osrect of it.
1]
C.
What will be inadequate about !!LEF's 1.-
role in teldin CA or CC?
12 A.
re r ha r s, t.' e y ' l l sinrly not suprort CC 1/
sufficiently which has been r e l. o r t e d et the South 15 Texas Project.
I r.
C.
so 17 A.
They are unw1111ng to do enat.
18 C.
!!a s there been reports that whatever 10 alleged deficiencies occurred in hL&n's 20 canagement have contributed to the problems in 21 welding?
22 A.
As I read the reFort here a couple of 22 weeks ago, yes.
A proprietary report.
2/
C.
Can you give ne references or reges in 25 that report that
.m a k e that connection between c
o 1
1.LEP's CA n a n a r; e..r.r. t end 6.olding?
2 A.
No.
3 didn't tcke down any page nunberc.
3 C.
bas that rerort an ar.sessnent of I!LET's 4
(A program?
5 A.
I den't recall that it van of that.
C.
As I u r.d e r s t a nd the report, it was en 7
investigation only of frown & roct's CA T r o g r a r. ?
P A.
Yes.
Eut 1 LE F was involved in it.
f-(*.
rid the study concern itself with I;Ls P t
l 10 CA or only Erown & Foct C I.7 II A.
Poth.
12 Io you know that for 3 fact?
12 A.
I believe it socid be impossible for the t
i t.
two to be separated ccepletely and rurely.
15 C.
All right.
If you're mistaken as to i
IF that fact, do you have any other basis for your f
17 assertion that H L& P ranagement will contribute to IP welding problens in the future?
19 A.
If H L& P has nothing to do with the 20 3roblems at Couth luxos Project?
21 C.
Fell, your only basis for en assertion 22 that ML&P has sonething to do with the welding 22 g.r o b l e r.s at the South Texas Project is the 24 proprietary report you referenced.
25 Now is there sone disagreenent w-h a t that l
I N 7 E it.N A T 2 G N b L C O L' E i alPOG7Eks, INC.
liC L'S 7C N, 7 E XI.S (713) 652-5011
1 oven discusses?
2 A.
- e l l, there's another basis, too.
I 3
don't think I brought it with
.c.
It's 6 federal M
e Register Fotice v.hich I think you.must know or 5
nust have.
5 c.
Yes.
7 A.
That indicates thOt ht&P it) sone way is e
e responsible for na k i ng cer ta in t!at the 9
constructor follews the CC patterns.
1r.
C.
There's ne doubt about t h.7 t.
11 A.
To ecybe the cuestion is too 12 hypothetical.
12 0
'c.
I believe nere i n :. o r t a n t l y tne
,1 /
question is too speci'ic.
To you have a
- factual, 15 basis for the assertion that rL&P's nanagenent of 16 (A and CC at South Texas has contributed to any 17 alleged welding problems there?
IE A.
If you're asking can 7 prove 19 Q.
Ul t ima tely tha t's wh.t we're gcing to 20 gat to in this proceeding ic ;. roof.
21 A.
hell 22 c.
Then naybe it's as simple as this:
Is 23 it correct that there's evidence to shew trat
' 24 1: LE P has not properly supervised CA-CC, and t r.a t 25 you then conjecture that this i n g. r o p e r l
i n i r n.v. i J L.. A Ct Ln; 34 I i. n i a. h s, I *. C.
l -
P O t'S T C f:, TEXAS (713) <52-5011 l
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1 cupervision can nenife t itcc].
. : _ i r. ;
2 probleus at Al l e n s Creek?
?
A.
Yes.
I think there is by virtte of the 4
fact that the FRC has been efter 1.Lir 'or 5
specifically in thet s ta tenen t in the lederal register.
I think of Pa y 3.
e 7
C.
You're saying that the v!:c f a ci t e d 1: L& P E
sfocifically as to its welding ntnagecent?
e A.
wo.
Its CC.
I
[
I c, C.
All rinht.
rut not s:.ecifically to 11 welding --
12 A.
k;e l l to your knowledge?
12 C.
1<
A.
I'll try to find 15 C.
1.e l l, the document speaks for itself.
16 A.
The d o c u r. e n t is addressed to you.
17 C.
'I don't think my name arreers anywhere 18 in there?
I?
A.
Corry.
To your e r.r.l o y e r here'in this 20 case.
21 0
.y client, perhaps.
- hat's yo u r 22 experience with welding?
23 A.
None.
2<
C.
All r i g i: t.
25 A.
I've never welded anytning.
I N T E R t: A T I C N A L CCUPT 1:FPCF;EFF, INC.
l li C U S T C N, 1 E.*. A S (712) 652-5011
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1 1-C.
- c~c u l d you inou e Lad b e l r~.
if )c. ; i. -
.~. t ?
2 F..
Some.
?
C.
How %ould you recognize it?
A.
It wouldn't be strong e n c e.t h to supt. ort 5
what it was surrosed to do.
You could Lrea!; it C
in your
- t. a n d s or r-o r.e t n i n g like tFct.
7 C.
co if you were tble to rhysically
?
se; arete the held, that would be I
E A.
Cne way, yes.
rethod of testing its ability Of a Ice C.
i I
Il s.e l d ?
l 1.S Yes.
I 8
C.
Is tnet
- 1. o w tr e l d s cre nernally tested?
l It A.
Fo.
They are, at least in nec1cer, 15 citen x-rayed, or s o c.e tires they are ir pa c t 16 tested.
I' 17 C.
Do you knew anything about having IP faniliarity with radiography?
19 A.
I've never done any radiography.
- C C.
You Fave no expertise in weld.ing er 21 radiography?
22 A.
No.
73 C.
Eo you have anything in (A or (C control?
24 A.
It's Creek to
- r. e.
25
.C.
All right. Eine I;.1 L he,412 0.'I L C C'J i T r f. F C F i r l-C, INC.
- C LETC !,
71.i.5 (713) 452-5011 e
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c' t, u t h o r i t y, o :. this t !. e 12 day of 19E0 0
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17 Notary Public in and for 1.
l'a r r i s County, Texas 18 3a.
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