ML20003G969
| ML20003G969 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/27/1981 |
| From: | Peverley R BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.), HOUSTON LIGHTING & POWER CO. |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8105040319 | |
| Download: ML20003G969 (11) | |
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9 UNITED STATES OF AMERICA 60 NUCLEAR REGULATORY COMMISSION
'1 L2 L3 L4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L5 L6 In the Matter of:
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b3 HOUSTON LIGHTING & POWER 5
Docket Nos. 50-4980L I
50-4990L 32 (South Texas Project, 5
13 Units 1 & 2)
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25 16 17 28 TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL.
1 29 30 OF RICHARD W. PEVERLEY p
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UNITED STATES OF AMERICA 5
NUCM REGMORY COMMISSION 6
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 9
10 11 In the Matter of:
5 12 5
13 HOUSTON LIGHTING & POWER 5
Docket Nos. 50-4980L 14 COMPANY, ET AL.
5 50-4990L 15 5
16 (South Texas Project, 5
17 Units 1 & 2) 5 5
lg 19 20 TESTIMONY OF RICHARD W. PEVERIrf 21 ON INTERVENORS' CONTENTION 1(1) 22 23 24 Q. 1 Please state your name and occupation.
25 26 A. 1 I am Richard W. Peverley.
I am Assistant Engineering 27 28 Project Manager-Special Services, for Brown & Root, Inc. (B&R).
29 30 Q. 2 Please describe your professional qualifications and 31 employment backround.
32 A. 2 These batters are set forth in my testimony on 35 Contention 1.7 (a),(b), and (c) in this proceeding.
36 37 Q. 3 What is the purpose of your testimony?
38 39 A. 3 I will address Contention 1(1), which relates to a 40 41 surveying error which occurred in 1978 during the surveying of 42 43 the basemat of the Unit 2 Mechanical-Electrical Auxiliary 44 45 Building (MEAB).
I will describe the error, the engineering i
46 response to the error, and the steps taken to prevent recurrence 47 4
of similiar errors.
I will also show that the error involved 50 no viclations of 10 CFR Part 50, Appendix B.
51.
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5 Q. 4 Please describe the dimensional surveying error that I
occurred in the basemat of the Unit 2 MEAB.
8 A. 4 In September 1978, B&R Field Engineers discovered a 9
10 one foot error in the dimensions of the basemat for the Unit 2 11 12 MEAS while attempting to lay out a sump in the building basemat.
13 14 B&R Houston Engineering and Quality Assurance (QA) were informed 15 16 of the error, a Nonconformance Report (NCR) describing the 17 lg problem was written, and HL&P was notified.
The incident was I
reported to the NRC by HL&P on October 4, 1978.
The matter was 21 then assigned to B&R Houston Engineering to determine the 22 23 corrective action to<be taken and to provide an assessment of 24 25 the safety implications, if any, of the incident.
26 27 Q. 5 What role did you have in the investigation and 28 29 analysis of the surveying error?
30 31 A. 5 It was my responsibility to coordinate and manage 32 the engineering review of the incident and to formulate the 33 34 appropriate corrective action plan.
I also reviewed information 1
36 regarding the causes of the surveying error, and the recurrence 37
- 38 control measures to' prevent similar errors.
39 40 Q. 6 What initial action was taken by Engineering in 41 42 response to the surveying error?
43 44 A.
6 Initially, a series of meetings were held by B&R 45 46 Discipline Project Engineers responsible for equipment in the i
area to discuss engineering redesign options.
Engineering 49 L
50 51 L ;
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disciplines represented in these meetings included structural, 6
Mechanical, Heating Ventilation and Air Conditioning, Instrumen-7 8
tation and Controls, Electrical, Plumbing and Architectural. As 9
10 a result of these meetings, and after conducting further analysis, 11 12 three engineering alternatives were identified -- each of which 13 14 would have provided adequate engineering correction.
These 15 alternatives were to: (1) Demolish and replace the total slab;
- 16 f7 (2) Structurally modify the slab to bring it back to the g
19 originally-designed dimension; or (3) Leave the MEAB slab in 20 21 its present dimensional configuration and redesign and relocate 22 23 the interior equipment to accomodate the dimensional slab l
24 25 change.
- l 26 27 Q. 7 Which of the alternatives, if any, was most prefer-
'8 hg able from a safety standpoint?
30 A. 7 B&R Engineering considered that all three alternatives 31 32 were equally acceptable from a safety design standpoint, and 34 all alternatives would have provided adequate assurance of 35 36 plant structural integrity and would have been in compliance 37 38 with all applicable design and regulatory requirements.
39 40
- g. 8 Which engineering design alternative was selected 41 42 and on what basis?
43 A. 8 B&R submitted the three engineering alternatives to 44 HL&P in early October 1978, and HL&P selected the third alter-47 native.
Since all three alternatives were totally acceptable j
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49 to assure a safe and adequate design, the decision was made to l
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use the engineering redesign that had least impact on the on-going construction activities.
.9 Once the decision was made as to the appropriate eng
- ._ -ing redesign, how was that actually accomplished?
Redesign of the MEAB to compensate for the one foot dimensional error resulted in only interior spatial alterations.
From Column Line A to Column Line H (see Attachment No. 1), the layout within the Building is unchanged from the original design.
From Column Line H to Column Line M.8, the one foot has been compensated by reducing distances between column lines l
and removing excess floor space around the layout of systems l
and equipment.
The general arrangement of equipment within the redesigned area is unchanged by the one foot dimension change.
Approximately three-fourths of the Building (Column Line A to Column Line H) is' unchanged from'the original design and the redesign affected only the West one-fourth of the Building.
In compacting this area of the Building, all safety criteria and bases, stated in the safety analysis report, were determined to have been met for layout of the systems and components.
The following generic drawing categories were reviewed for the MEAB l
l design:
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Instrumentation plan drawings.
2)
Electrical physical drawings.
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Concrete drawings.
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4)
Steel drawings.
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General arrangement drawings.
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Floor and wall sleeve drawings.
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l 10 7) composite piping drawings.
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12 8)
Stress and isometric drawings.
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Fabrication isometric drawings.
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EVAC drawings.
Those drawings which previously had been issued and which 19 required revision due to the interior redesign have been sub-20 21 sequently reissued.
Other drawings affected by the. interior 22 23 redesign which had not been issued will be issued as planned 24 25 during the normal course of engineering and construction acti-26 27 vities.
28 29 Q. 10 Please describe the activities conducted to evalu-30 ate the consequences of the redesign upon safety criteria 31 commitments.
34 A. 10 The redesign has been verified to ensure the follow-35 36 ing safety criteria have been met:
37 38 1)
Mechanical and electrical separation-FSAR Sections 3, 39 40 7, and 8.
41 42 2)
Protection against pipe break and associated jet 43 44 impingement and pipe whip effects-FSAR Section 3.6.
45 3)
Procection against internally generated missiles-FSAR 46 47 Section 3.5.
48 49 4)
Protection against fire hazards-FSAR Section 9.5.
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Protection against sabotage (security considerations)-
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Security Plan.
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In addition, a review of designated engineering design I
documents for both Units was performed to assure that the
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facility design adequately reflected the requirements of k
Regulatory Guide 8.8 and HL&P's policy to provide those design I
features which will result in a reduction of radiation exposure i
i to operators and maintenance personnel.
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Q. 11 _Please describe the likely cause of the surveying
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error.
I A. 11 The surveying error most likely occurred because, instead of using the containment / reactor centerline as the a'
reference as had been intended, ~ the building slab survey calcula-I
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tions and layout in the field used the dimensions relative to I
column line R.1 in the Fuel Handling Building.
Column line R.1 in the Fuel Handling Building is offset one foot to the west'of i
the containment / reactor centerline (see Attachment No. 1) thus resulting in the east edge of the Mechanical-Electrical Auxiliary I
Building being laid out one foot short of the design.
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Q. 12 Were there applicable QA/QC procedures that should
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have detected such errors prior to its detection by the field I
engineers attempting to try out the basemat sump?
i A. 12 No.
This is the type of mistake which could only be detected through appropriate precautionary steps by the I
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5 surveyors themselves or by their supervisors.
There is no I
I applicable'QA/QC procedure to detect these kinds of mistakes.
I Q. 13 Is it common practice in surveying to have QC 9
-10 Inspectors check the surveyors work on a real-time basis.
11 12 A. 13 No.
This is not practical.
The responsibility for
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13 14 any survey rests with the survey crew chief.
He operates the 15 I
16 transit and makes all of the required calculations.
If the 17
.ig calculations are correct and the traverse is properly closed, f3 there is a high degree of assurance that the work was done 21 correctly. The only way that one could inspect a surveyor's
-22 23 work is to redo the survey.
This would be impractical and is 24 25 therefore not done.
26 27 Q. 14 Describe the involvement of QA in the surveying 28 29 operations.
30 31 A. 14 First, QA Engineers are responsible for reviewing 32 33 and approving all construction procedures, including surveying 3
procedures, to ensure th'at the necessary steps are included.
36 Second, it is the responsibility of the QC Inspectors to make 37 38 periodic inspections of the records to ensure that these proce-39 l
40 dures are being implemented. The QA auditing group also performs t
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42 periodic audits on this operation.
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~43 44 Q. 15 Please describe the recurrence control measures 45 46 that have been taken to assure that this error is not repeated.
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A. 15 The Field Engineering department has implemented 5
6 extensive reorganization and procedural changes since the 7
8 survey error occurred.
Personnel must meet increased qualifica-9 10 tion requirements before being hired into the survey group.
11 12 Training meetings must be held every three to six months and 13 must be attended by all personnel. All original control work is 14 15 established by one crew permanently assigned to a particular 16
- 17 building.
All survey operations are checked by the supervisor.
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- 182b i Major layouts are double checked.
Procedures also require that i
21 all building layout points are traversed back to the original
-22 23 point so that closure occurs.
These procedural changes should
.24 25 preclude the problem from recurring.
26 27 Q. 16 Did this error constitute a violation of 10 CFR 50, 28 29 Appendix B (Criterion X and XI), as alleged?
30 A. 16 No.
Criterion X concerns inspections and Criterion 31 32 XI concerns test control.
The act of surveying is not, by 33
' 34 definition, a test.
Testing is done to verify that activities 35 36 satisfy specified requirements. Testing is ordinarily done wuen 37 38 verification cannot be done by normal inspection methods.
39 40 surveying is a basic activity and would not be considered to be 41 42 a test.
As previously stated,' surveying is not amenable to 43 44 inspection techniques either.
Inspection is not required in 45 surveying because self-checking by proper calculation checks 46 and closure methods which are normally employed provide adequate 49 50 51 1 -
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'4 assurance that the survey was conducted properly.
Therefore, 5
6 neither criterion X, XI, nor any other section of Appendix B 8
for that matter, is applicable to the surveying activity in 9
10 question.
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Attachmant No. 1
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Electrical Auxiliary Building Canisinment n /
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188' h8edianical Auxiliary
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Building
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Fuel Handing
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Aree of W Unit 2 h6edianical Electncad Auxiliary
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