ML20049H591

Testimony of Ta Alessi Re Contentions 4(b)(c) &(E).Qa Program Effectively Implanted & Prescribed Insps Instrumental in Finding Deficiencies Subsequently Documented.Prof Qualifications Encl

ML20049H591
Person / Time
Site:	Fermi
Issue date:	03/31/1982
From:	Alessi T DETROIT EDISON CO.
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ML20049H587	List: ML20049H586 ML20049H590 ML20049H591 ML20049H592 ML20049H594
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NUDOCS 8203030335
Download: ML20049H591 (17)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF: )

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) Docket No. 50-341 THE DETROIT EDISON COMPANY )

Enrico Fermi Atomic Plant Unit 2)

TESTIMONY OF TULLIO A. ALESSI on INTERVENOR 'S CONTENTIONS 4(b), (c), and (e) i March, 1982-r i

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• TESTIMONY OF TULLIO A. ALESSI DIRECTOR - ENRICO FERMI 2 PROJECT QUALITY ASSURANCE THE DETROIT EDISON COMPANY ON INTERVENOR'S CONTENTION 4(b), (c) and (e)

TESTIMONY IN RESPONSE TO INTERVENOR'S CONTENTION 4(b) 1 My name is Tullio A. Alessi and I am the Director, 2 Project Quality Assurance for the Enrico Fermi 2 Project 3 of The Detroit Edison Company (Edison). As Director of 4 Project Quality Assurance I have the overall responsibility 5 for the establishment and implementation of the Quality 6 Assurance Program for the Fermi 2 Plant.

7 I have been rquested to respond to Intervenor's 8 Contention 4(b) which alleges:

9 The applicant's Quality Assurance Inspection Program has not been executed in conformance 10 with Criterion X of Appendix B to 10 CFR Part

50. Recent reinspections of various materials 11 and workmanship indicate that quality control was inadequate during construction prior to 12 the 1974 shutdown of construction activities at the site. Specifically, CEE identifies:

13 (1) large and small bore pipe hangers, and (2) welds of safety related components.

14 The Enrico Fermi 2 Project Inspection Program is 15 described in the Detroit Edison Quality Assurance Manual 16 Quality Assurance Procedure No. 11 (QAP 11), entitled 17-

" Inspection". This document codifies the requirements 18 imposed on the Project and on all contractors regarding 19 the inspection of work performed. This document responds 20 to Criterion X of Appendix B to 10 CFR Part 50.

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1 QAP 11 establishes requirements auch as the 2 performance of inspections in accordance with established 3 procedures, and by qualified inspection personnel who are 4 not responsible for the work performed. The Quality 5 Assurance Manual has been reviewed by the Atomic Energy 6 Commission (AEC), and the Nuclear Regulatory Commission 7 (NRC), and subsequent revisions to this document have 8 been sent to the NRC for review. Criterion X of Appendix i 9 B has not been changed since Appendix B became part of ,

10 the AEC regulations in July, 1970. Thus, QAP 11 has not 11 been revised in substance except for revisions reflecting 12 changes in organizational structure and assigned responsi-13 bilities made by the Project.

14 As required by QAP 11, specific Quality Assurance 15 procedures and checklists (plans) are prepared by the re-16 sponsible Project inspection organization to perform and 17 document the inspection of all construction work.

l 18 Inspection procedures and checklists have exis'ted and do 19 exist for all safety-related work at the Plant performed 20 by the civil, mechanical and electrical contractors who 21 have construction responsibilities at Fermi 2.

1 When work is inspected and some deficiency is 22 23 found, a nonconformance report is prepared by the inspector.

24 This report, called a Deviation Disposition Request (DDR),

25 is sent to Project Engineering for analysis. This analysis, 26 which may involve materials testing or component redesign, 27 is referred to as a " disposition". When the disposition 28 has been made, the required repair or rework is performed

1 and thsn reinspected. The reinspection is documented and 2 the inspector signs off en the DDR when the disposition 3 has been satisfactorily implemented. This process can be 4 audited and AEC/NRC inspectors have periodically reviewed 5 the Project's inspection program to examine the inspection 6 activities and records.

7 CEE's contention that quality control during con-8 struction prior to the 1974 shutdown was inadequate may 9 be due to their perception of the significance of rein-10 spection activities performed after the recommencement of 11 construction. That is to say, a relatively high level of 12 component reinspection is not indicative of a failure in 13 quality assurance.

14 For example, during the shutdown of construction 15 in 1974, hangers and hanger materials in storage experi-16 enced some rusting. Upon restart of the Project a 17 refurbishment program was undertaken for hangers and hanger

. 18 materials. This required a reinspection of all refurbished 19 components to establish their continued acceptability.

20 Materials failing the inspection were replaced.

21 Similarly, the reinspection and/or rework of pipe 22 hangers installed before 1974 was not the result 23 of inadequate quality control on the initial installation, 24 but rather the result of their being redesigned or 25 relocated because of changes in the methods used in 26 performing seismic analyses imposed by changes in 27 NRC requirements.

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1 There have been examples where the shop structural 2 welds on some safety related components, such as cable 3 tray hangers and control cabinets, were found not be meet 4 the applicable AWS standard for weld quality. In most 5 cases the defects were identified after the components 6 were received at the Fermi 2 site. In each case DDR's were 7 written for engineering disposition. The approved disposi-8 tion was then implemented and accepted by Quality Contol.

9 The Edison Quality Assurance program has been 10 effectively implemented and the prescribed inspections 11 have been instrumental in finding deficiencies which have 12 subsequently been properly documented and corrected in 13 accordance with procedures approved by the NRC.

. TESTIMONY IN RESPONSE TO INTERVENOR'S CONTENTION '4(c) 1 I have been requested to respond to Intervenor's 2 Contention 4(c) which alleges:

3 The Applicant has not maintained sufficient quality assurance records to furnish 4 evidence of activities affecting quality to comply with Criterion ::VII of Apendix B 5 to 10 CFR Part 50 in that records have been destroyed or lost during the course of 6 construction.

7 Edison has maintained the required QA records for 8 the design, procurement and construction activities of the 9 Project consistent with the objectives set forth in Criterion 10 XVII of Appendix B, 10 CFR 50.

11 Procedures have been established to develop the 12 design and engineering records that must be generated and 13 maintained. Project Engineering has also developed the 14 vendor document lists for equipment purchased for the 15 Fermi 2 plant. These lists identify the engineering 16 documents and records that vendors must furnish, and 17 were used by Quality Assurance personnel to determine 18 whether all required records were received. For the 19 construction phase, project documents, QA program procedures, 20 codes and standards have established what records the 21 contractors have had to generate and turn over to Detroit 22 Edison.

23 In the process of turning over completed systems 24 from the Project Construction organization to the Plant 25 Operations organization, there is an important step that 26 provides additional assurance that the required QA records 27 exist and that work has been satisfactorily completed.

1 This step involves a thorough review of documents to 2 verify that they are complete and adequate. Any deficiencies 3 are punch listed for resolution. The turnover of a system 4 is not finalized until punch list items are satisfactorily 5 resolved.

6 Edison and its contractors have implemented 7 practices that assure that QA records were not only 8 generated and maintained, but also protected against 9 loss. QA records obtained from vendors and contractors 10 have been secured against loss or destruction by safekeeping 11 in fireproof facilities under the control of the QA organi-12 zation. Additional security is provided when records are 13 microfilmed and duplicate master copies are placed in safe 14 storage in separate locations.

15 Therefore, it is Edison's contention that the 16 Project has been and continues to be in compliance with 17 the requirements of Criterion XVII of Appendix B to 18 10 CFR Part 50 relative to the production and maintenance 19 of sufficient QA records as evidence of satisfactory 20 performance of activities affecting quality.

21 Allegations were made to the NRC in 1979 by a 22 member of CEE, that in 1974, when Project work was suspended, 23 QA records were destroyed. Edison is not aware of such 24 an occurrence, and the NRC investigation did not uncover 25 any evidence to support the allegations (USNRC Report No.

26 50-341/79-04; Item 10, p. 10-12).

1 When construction work was suspended in 1974 and 2 site contractor offices were temporarily cleared out, 3 personal file copies of various documents such as letters, 4 drawings, etc., were purposely destroyed by burning.

5 However, original copies of such documents were kept in 6 Edison's Document Control Center along with QA records, 7 which as stated above, were kept in the QA records storage.

8 On December 15, 1978, a faulty gas heater in the 9 piping contractor's office in building 45A, at the Fermi 2 10 site caused a fire which damaged several QA records 11 left on an inspector's desk for which work was in process.

12 Most of the QA records in the office were in a steel cabinet 13 and were not damaged by the fire. The damaged records 14 consisted mainly of welding process sheets and test reports 15 that were left in "in baskets" on top of the inspector's 16 desk over the weekend.

17 The records on top of the desk were burned, but 18 only records on the top of the stack were severly burned.

19 Records near the center were salvageable.

20 Those records which were capable of being salvaged 21 were reconstructed from master files. Two weld process 22 control sheets were damaged beyond reconstruction, and, 23 therefore, DDR's were prepared and the welds involved were 24 re-tested to ssure that they were acceptable.

24 As a result of the fire Edison QA directed all 26 contractors on the site to assure that all QA records, M M

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1 including those in the review process, be stored in steel 2 cabinets instead of being left on desks overnight or over 3 the weekend.

4 The fire and the loss and the subsequent reconstruc-5 tion of the documents was reported to the NRC and the matter 6 was resolved to their satisfaction (USNRC Report Nos. 50-341/

7 79-04, Item 3, p. 12; 50-341/79-22, p. 3).

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TESTIMONY IN RESPONSE TO i

INTERVENOR'S CONTENTION 4(e) 1 I have been requested to respond to Intervenor's 2 contention 4(e) which alleges:

. 3 Specific flaws in construction can be 4

identified, among them

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4 (1) Excessive water in the reactor hole which caused the concrete base slab 1

5 to crack severely, a problem purportedly 6 remedied by patching.

i 7 (2) Hairline cracks in structural steel surrounding the dry well.

8 (1) The Alleged Water Damage in the Reactor Hole:

9 In April, 1972, months after the 4-foot thick 10 concrete base slab for the Reactor Building floor had been 11 poured, radial and circumferential hairline cracks were 12 noted on the surface and it was also observed that small 13 amounts of ground water were seeping onto the reactor 14 basement floor. An engineering evaluation of the problem 15 concluded that the cracking may have been due to a combina-16 tion of shrinkage strains during the curing of the concrete, 17 and the seasonal temperature fluctuations on a restrained slab.

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However, the slab had not been subjected to significant 19 hydraulic forces from the presence of ground water.

20 The cracks were carefully monitored over a period 21 i

22 of time and it was established that the situation had stabilized and no new cracks appeared. Core samples 23 revealed that the cracks extended anywhere from 6 inches 24

! to 3 feet in depth.

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1 A repair program was undartakcn in September, 1973, 2 using a non-shrinking grout applied under high pressure.

3 A final report was submitted to the NRC on November 8, 4 1974 (Edison Report EF2-29,537) .

5 The problem was not remedied by " patching" as 6 Intervenors suggest. The NRC monitored all aspects of 7 the problem analysis and corrective actions and was 8 satisfied with the actions taken by Edison and results 9 obtained (USNBC Report Nos. 50-341/75-01, Items 3, p. 5 10 and Item 5, p. 10; 50-341/79-04, Item 20, p. 27). An 11 engineering analysis concluded that the cracking would 12 not have created safety concerns if the cracks were not ,

13 sealed.

14 15 (2) Cracks in Structural Steel Surrounding the Dry Well:

16 An inspector from the Edison Quality Assurance 17 Organization observed fine cracks on clip angles used in 18 the steel support framing for the slab over the torus 19 (Figure 1). This problem was discussed with the AEC 20 under the requirements of 50 55(e) of 10 CPR Part 50. It 21 was judged by the NRC to be a normal construction problem 22 and not reportable. However, Edison stopped further work

, 23 in the area until the cause of the problem was determined 24 and a solution was found.

25 DDR's prepared by Edison were evaluated by Sargent 26 and Lundy, the designer of the Reactor Building. It was 27 their judgment that the problem was a combination of

1 defects in the clip angle material and/or excessive welding 2 used to attach the clip angles. The recommended solution 3 accepted by Edison was to replace the uninstalled clip 4 angles with the acceptable material and limit the welding 5 to what was required by the drawings. The solution was 6 implemented and the cracking problem did not reoccur.

7 Clip angles previously installed were replaced 8 except in areas where the concrete slab had been poured 9 and thus, the clip angles were not accessible. In those 10 cases the solution was to install beam seats at each clip 11 angle location to t.ssure that the load would be safely 12 carried even if the clip angles failed (Figure 2).

13 The problem analysis, proposed solution, and the 14 ultimate repair work was monitored by the AEC (USAEC 15 Report Nos. 050-341/72-03, Item 6, p. 8; 050-341/72-04, 16 Item 1, p. 8). They were satisfied with the results and 17 so reported in a series of inspection reports which can 18 be found in public document rooms (USAEC Report No. 050-341/

19 73-03, Item 2, p. 4; USNRC Report No. 50-341/79-04, Item 18, 20 p. 25).

21 The problems identified by Intervenors are good 2 examples of how the Edison Quality Assurance inspection 23 program was successful, and how identified problems were 24 carefully analyzed and properly resolved. Complete histories 25 of these problems have been maintained by the project 26 organization and are subject to NRC audit.

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PROFESSIONAL QUALIFICATIONS TULLIO A. ALESSI DIRECTOR ENRICO FERMI 2 PROJECT QUALITY ASSURANCE THE DETROIT EDISON COMPANY 1 My name is Tullio A. Alessi and I am the Director, 2 Project Quality Assurance for the Enrico Fermi 2 Project, 3 as well as Director of the Quality Assurance Department 4 for The Detroit Edison Company. My business address is 5 2000 Second Avenue, Detroit, Michigan 48226.

6 As Director of Project Quality Assurance, I have 7 overall responsibility for the establishment and 8 effective implementation of the Project Quality Assurance 9 Program by Edison and by all the vendors and contractors 10 associated with the Project.

11 I was graduated from the University of Western 12 Ontario, London, Ontario, Canada, in 1945 with a Bachelor 13 of Arts Degree. In 1948, I received a Master of Science 14 Degree in Physics from Wayne State University. During 15 1950 and 1951, I completed graduate courses in physics at 16 the University of Michigar. at the doctoral level. After 17 joining Edison in 1952, I completed 6 semesters of 18 nuclear engineering given by the University of Michigan, 19 a course in power systems engineering presented by Michigan 20 State University and a course entitled " Introduction to 21 Nuclear Power" conducted by NUS, Inc.

22 Between 1946 and 1952, I taught courses in physics,

1 physical chemistry and calculus at the University of 2 Windsor. I joined Edison in 1952. From 1952 through 3 1968, I held the positions of research engineer and 4 supervising engineer in the Engineering Research Depart-5 ment with special assignments on the Fermi 1 Fast Breeder 6 Reactor Project and numerous industry energy conversion 7 and utilization projects. In December, 1968, I was 8 assigned to the Fermi 2 Project as Quality Assurance 9 Coordinator, subsequently, I became the Project Quality 10 Assurance Director and then Director of the Quality 11 Assurance Department.

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s s' s PROFESSIONAL QUALIFICATIONS WALTER M. STREET SUPERVISING ENGINEER - CIVIL THE DETROIT EDISON COMPANY 1 My name is Walter M. Street and I am the Super-2 vising Engineer - Civil, of the Enrico Fermi 2 Project 3 for The Detroit Edison Company. My business address 4 is 2000 Second Avenue, Detroit, Michigan 48226. As 5 Supervising Engineer - Civil, I have the responsibility 6 for the architectural and structural design of the 7 Fermi 2 plant.

8 I was graduated from the University of Detroit 9 with a Bachelor of Civil Engineering Degree and a Master 10 of Engineering Degree. I am a registered Professional 11 Engineer in the State of Michigan (#20120).

12 I have been employed by Edison since my graduation 13 in May, 1969 I was assigned to the Fermi 2 Project 14 from May, 1970, to January, 1975, and from November, 1977, 15 to the present. I have held the position of Supervising 16 Engineer - Civil since November, 1980.

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