ML20078R576

First Set of Responses to General Interrogatories & Interrogatories on Contentions 41 & 65

ML20078R576
Person / Time
Site:	Harris
Issue date:	11/11/1983
From:	Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Eddleman W EDDLEMAN, W.
Shared Package
ML20078R579	List: ML20078R576 ML20078R584
References
ISSUANCES-OL, NUDOCS 8311150209
Download: ML20078R576 (14)

Text

,

o

?

.g I .

igg November 11, 1983 -- - . .

13 NW 14 41:37 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION h[ ;c .3 S' '

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ,,

In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY ) Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN ) 50-401 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' SUPPLEMENTAL RESPONSES TO WELLS EDDLEMAN'S GENERAL INTERROGATORIES AND INTERROGATORIES ON CONTENTIONS 41 AND 65 TO APPLICANTS CAROLINA POWER & LIGHT COMPANY, et al.

(FIRST SET)

Pursuant to the Licensing Board's " Memorandum and Order (Ruling on Discovery Disputes)" of October 6, 1983, and to the rulings issued by the Board during telephone conferences on September 22 and 23, 1983, Applicants herein provide their re-sponses to a portion of those interrogatories for which the Board granted intervenor Eddleman's Motion to Compel Discovery.

As Mr. Eddleman has been advised, responses to the remaining interrogatories (which require the receipt of information from Daniel Construction Company) will be provided at a later date.

hg O pg a

-gD

. RESPONSES TO GENERAL INTERROGATORIES INTERROGATORY NO. Gl(c): Please state the name, present or last known address, and present or last known employer of each person whom Applicants believe or know (1) has first-hand knowledge of the facts alleged in each-such answer; or (2) upon whom Applicants relied (other than their attorneys) in making such answer.

ANSWER: The following list identifies those persons who provided information upon which Applicants relied in answering the interrogatories on Eddleman Contention Nos. 41 and 65 and indicates the particular interrogatory answer (s) for which each such person provided information.

PERSON INTERROGATORY NO(S).

K. V. Hate' 41-1(d); 41-5(c)

G. O. White 41-1(d)

D. Timberlake 41-1(n) and (o); 41-1(q); 41-7 C. French 41-5(i) through (k); 41-6 A.-Fuller 41-3(e) and (f); 41-4(i); 41-5(a) through (f); 41-5(i) through (k)

B. Marlar 65-1(b)

- R. M. Parsons 65-2(a); 65-3(a) and (b)

All of the above individuals are employees of Carolina

' Power & Light Company at the Shearon Harris Nuclear Power Plant, Route 1, Box 101, New Hill, North Carolina 27562.

RESPONSES TO INTERROGATORIES ON CONTENTION 41 INTERROGATORY NO. 41-1(d): Identify the qualifications of those persons.who reviewed welding symbols, blueprints and specifications, i.e., explain what is meant by the term "de-greed engineers" as used in Applicants' initial answer to In-

, terrogatory No. 41-1(d). (As modified by the Board at Tr.

663.)

, - . . _,.-m . , , , - _ . ,y_ _

_,.m,,, .,...,m,, , - ,.___e- w., _ - , . , , - - _ - - , . _ - . . , - .m, .,-, , --

ANSWER: A " degreed engineer" is a person.with a baccalau-reate degree in engineering, or the equivalent degree from a foreign university.

Review of welding procedure specifications has been performed by QA Engineers who have, as a minimum, a bachelor's degree in mechanical or metallurgical / materials engineering.

Of the 34 designers currently with the Harris Plant hanger design organization, 27 are degreed engineers (19 in civil en-gineering and 8 in mechanical engineering). The design organi-zations at Ebasco and Bergen-Patterson have employed many de-signers over the life of the project and detailed records of their qualifications are not available to Applicants. However, the education and experience of these designers would be similar to those employed by Applicants.

INTERROGATORY NO. 41-1(n): State whether Applicants' welder training courses cover the reading of welding blue-prints, including symbols for size, length, position, penetra-tion, groove preparation, heat treatment, undercut allowable, type of electrode required, current setting and type (DC or AC). (As modified, Tr. 666.)

ANSWER: Yes.

l INTERROGATORY NO. 41-1(o): Have Applicants established "

l who made the defective welds identified on pipe hangers at Harris?

ANSWER: No. There are no site or code requirements that

+

require Applicants to maintain records that identify which welder or welders welded on a specific weld joint on a pipe '

hanger. Welder identification is maintained by hanger and not p,-,,, _ . - - , -

by individual weld. A hanger could have any number of weld joints on which several welders have welded, and if one or more ,

of these welds.were rejected it would not be feasible to iden-tify.the specific welder (s) that made the defective weld (s).

INTERROGATORY NO. 41-1(q): If Applicants don't know who made the defective pipe hanger welds, will they admit their QA program is inadequate in that respect?

ANSWER: No.

INTERROGATORY NO. 41-3(e): For each such rejection of -

hanger in b above-[ rejected as a result of reinspection due to

. weld defects), identify and produce a 10% sample of those field change requests, requests for permanent waiver, and field re-werk orders issued with respect to it. (As modified, Tr. 730.)

~ ANSWER: .The requested records regarding pipe hangers will be made available pursuant to Applicants' Supplemental Response to Wells Eddleman's Request for Production of Documents. The 10% sample of applicable Pipe Hanger Problem Reports, Field Change Requests, Permanent Waivers and Reworks was obtained by reviewing the Reinspection Logbook and obtaining the documents associated with the first reject and every tenth reject there-aftch. -

's' _

~,

Applicants' May 12, 1983 Response to Request for Produc-tion of Dgcuments provided the requested documentation concern-l, ing HVACiand conduit hangers.

l INTERROGATORY NO. 41-3(f): Foi e^ach hanger in e above, state what review of the field work orders, field change re-i / quest, or request for permanent waiver was done, and the date

, - - for each such field work order', field change request (FCR) or

- . permanent waiver request (PW) and the date each such was approved. If any such FCR or PW request was denied, or any field work order modified for this hanger, so state, and explain fully, for each hanger covered by this interrogatory.

7'

- f'._ _ _ _ _. -., ___. .- _ .._.- _. _ . __ _

ANSWER: See Applicants' answer dated May 12, 1983. The requested information as to the 10% sample required by th 1-censing Board can be obtained from documents produced in re-sponse to Interrogatory No. 41-3(e), above.

INTERROGATORY NO. 41-4(i): List all persons under g above '

who are no longer at Harris, giving last known address for each.

ANSWER: Not applicable. See Applicants' answer to Inter-rogatory No. 41-4(g) dated May 12, 1983.

INTERROGATORY NO. 41-5(a): State whether welders working at Harris had any instructions, prior to 9/3/80, on what to do if a weld drawing was unclear, unreadable, or in obvious error?

ANSWER: Yes.

INTERROGATORY NO. 41-5(b): If answer to (a) above is af-firmative, state the general instructions given to welders.

(As modified, Tr. 678.)

ANSWER: Prior to September 3, 1980, the various welding foremen were orally instructed by the appropriate Superinten-dents to return drawings with unclear, unreadable or incorrect weld symbols. The individual foremen were then responsible for relaying this information to the welders.

INTERROGATORY NO. 41-5(c): If answer to (a) above is other than affirmative, did QA/QC know of the non-existence of such instructions?

ANSWER: Not applicable.

INTERROGATORY NO. 41-5(d): State whether Applicants can identify every welder who worked on pipe hangers at Harris who identified an unclear or missing detail or instruction on a

, pipe hanger weld olueprint to a superior (foreman, etc.) or QA/QC person at Harris prior to 9/3/80, the date on which s/he

did it, and what action was taken with respect to such blueprint, for each such blueprint. (As modified, Tr. 729.)

ANSWER: 'The requested information cannot be obtained.

The person who initiates a Pipe Hanger Problem report or a Field Change Request in order to correct an unclear or missing weld symbol can be determined from the document itself. The name of the welder who may have originally identified the error is not recorded. Documents produced in response to Interroga-tory No. 41-5(i) below provide information as to the identity of the initiator and subsequent corrective actions.

INTERROGATORY NO. 41-5(e): If no action was taken under (d) above for any report, or if CP&L cannot document the action, so. state; otherwise, provide all documentation of actions taken on such identification of unclear or missing de -

tail or instruction on a pipe hanger weld blueprint prior to 9/3/80, for inspection and copying.

ANSWER: See answer to Interrogatory No. 41-5(d), above.

INTERROGATORY No. 41-5(f): State whether any welders at Harris made defective pipe hanger weids after going through Ap-plicants' welder training program.

ANSWER: Yes.

INTERROGATORY NO. 41-5(i): State exactly how many weld drawings have been returned to the Site Mechanical Unit under the policy of returning such when it is not possible to weld the hanger exactly as drawn due to physical limitations or drawing errors.

INTERROGATORY NO. 41-5(j): For each weld drawing which was returned due to the reasons set forth in (i) above, since 9/3/80, state exactly what was done to resolve the problem and document'all such resolution by identifying all documents which show or contribute to such resolution or approve such resolu-tion.

INTERROGATORY NO. 41-5(k): State whether any permanent waivers have been granted for any weld for which a drawing has I

been returned to the Site Mechanical Unit for the reason (s) set forth in (i) above or any of them, and for each such permanent waiver, state the basis therefor and any engineering rationale underlying it, and state who granted the waiver or approved it.

ANSWER: In accordance with the Board's ruling (Tr.

727-728), Applicants will produce a 5% sample of the applicable Field Change Requests, Pipe Hanger Problem reports and Permanent Waivers pursuant to Applicants' Response to Wells Eddleman's Request for Production of Documents.

All PHPs, FCRs and PWs for pipe hangers were researched to identify those associated with weld symbol errors or inability to make the required weld due to physical limitations. Of this group, every twentieth document has been retrieved for produc-tion to Mr. Eddleman.

For HVAC and conduit hangers, a review of all Architectural-Structural FCRs and PWs was performed to identify those concerned with welding problems. Again, of this group, every twentieth document will be made available for review by Mr. Eddleman.

INTERROGATORY NO. 41-6: Answer all questions and all parts of Interrogatories 41-3, 41-4, 41-5 above, inclusive, with respect to (a) Bergen-Patterson pipe hangers only (b) HVAC hangers only (c) Cable tray and electrical conduit hangers only.

ANSWER: Unless otherwise noted above, the response to subparts (a), (b) and (c) of this interrogatory is the same as the above answers to Interrogatories 41-3, 41-4 and 41-5.

4

t INTERROGATORY NO. 41-7: Identify all percons retrained in welding, blueprint reading . . . re pipe hangers or other supports by CP&L since 9/3/80 and when each such person was retrained, for how long, using what curriculum and materials (produce same for inspection and copying), and state what tests if any were given to each such person during or after such training to determine the effect of such training (or for any other purpose) and what the results of those tests were for that person, for each such person.

ANSWER: Welders were not retrained in welding because their ability to deposit sound welds was established during their performance qualification (per ASME B&PV Section IX re-quirements). Retraining of welders did include the following:

(1) gen 1ral review of welding symbols and (2) procedural re-quirements for structural welding (including pipe hangers).

Information which provides details of the retraining of welders will be produced in accordance with Applicants' Supplemental Response to Wells Eddleman's Request for Production of Documents. Tests were given to welders in the retraining classes to verify their understanding of weld symbols and general procedural requirements, but test results were not maintained as a part of the training records (test results were orally reviewed during training classes).

RESPONSES TO INTERROGATORIES ON CONTENTION 65 INTERROGATORY No. 65-1(b): For each pour in the contain-ment building which exhibited honeycombing or voids and for 5%

of the remaining pour packages, provide the following informa-tion: the date(s) of the pour; the supervisor (s) of the pour; the time (s) in which the pour took place; whether a concrete placement report, or equivalent, exists for such pour; and, whether a sample or samples of such pour was retained, and, if so, identify each such pour. (As modified, Memorandum and Order at 4.)

l

ANSWER: Of.the 106 concrete placements for the contain-4 ment building base mat, exterior walls and dome, only one was identified as having honeycombing or voids. (Note that Appli-cants' answer of:May 12, 1983 to Interrogatory No. 65-1(h) was i

not limited to the containment base mat, walls and ceiling, but included interior concrete pours, and thereby provided informa-tion b;vond the scope of the interrogatory.) The requested in-fo rn.a ulon for this placement is set forth in Exhibit 1 attached hereto.

Exhibit 2 hereto contains the requested information for i

the additional ~ random sample. The random sample was obtained

, by selecting-the first pour package in a file drawer and every tenth package thereafter.

The concrete samples listed in Exhibits 1 and 2 are required by the ASTM Code to be retained for 28 days, at which time compressive strength tests are performed on each sample.

As storage space permits, samples may be retained for a short period thereafter, but are then discarded. ,.

1 INTERROGATORY NO. 65-2(a): To. knowledge of Applicants, including their contractor Daniel International, is it true that (1) the' base mat poured in December 1977 at Wolf Creek has approximately 50 percent of its concrete test containers for -

the base mat pour-failing (or having failed) to meet strength

. of 5000 psi, (2) that 5000 psi is the specified strength for test' containers from this pour, (3) that the concrete used in the pour was purchased from a company that supplied Daniel with a mixLformulated intended for use in ditch linings and box culverts on highways, (4) that such concrete was used in the base mat pour at Wolf Creek, and/or (5) that such concrete is not approved for a highway surface, but only for non-safety-related mud slabs and fill concrete only.

1.

_g.

y.___ _ _ . , - ._ _ , _ , , , ,.

__ ... ,m. . . .._.,.,,u .._,y, . _ , _ . , . , , , , . . , _ , , ,_ ____m ,_, m_. _ _ . . . _ _ . _ . . .

INTERROGATORY NO. 65-3(a): At the Wolf Creek, Callaway and Farley plants, state what major modifications to design and-structures at each were required by (a) NRC (b) Daniel (c) the

. utility after discovery of defects in concrete emplaced in the containment building. (Tr. 686.)

INTERROGATORY NO. 65-3(b): Identify all significant repairs made to concrete in the base mat, and containment walls, at Callaway, Wolf Creek and Farley after discovery of significant defects.

ANSWER: Applicants do not know. Applicants have discussed these interrogatories with their contractor Daniel, which is not a party to this proceeding. Daniel has advised CP&L that any information available to Daniel with respect to these other nuclear projects which would be responsive to the interrogatories is not within the control of CP&L as that term is construed for discovery purposes.

1

In addition, reference is made to the NRC Staff's answers to Eddleman Interrogatories 96 and 97, served on June 24, 1983 (pages'82-84). There the Staff answered questions about

~

concrete placements at the Callaway, Wolf Creek and Farley facilities and identified numerous relevant documents which, it 1

appears, were made available for inspection and copying.

Thomas A. B a x t e r , P'. C .

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Richard E. Jones Samantha Francis Flynn Carolina Power & Light Company P. O. Box 1551 Raleigh, North Carolina 27602 (919) 836-6517-Counsel for Applicants Dated: November 11, 1983

l l

,Ek  %

3.$& W.9$ 0 s ii.p z/

7,.

P P /

97 P 9

. R E St

/ /b'S 5 55 %s%5

/ / s / / 55/>4ac/

/ 6/

_ B /

. /. /. / . .

2h ii 97 h.I k k M '.

A 3 c,

c kW 9 s U F< / P 9 7D ss S 51 M:/ /.56+A w/u 1

t 'S E

L P

E L

N 555/S

/ / /. ./

• S S/ s S 5

/. / / s

/ /Y h, 2 f V 5: 1Ndi M P 'S 4 hN .

iB o s.d 2,. /,

bM i

hxC O A M S A E

S O

Ss65555}5A/

i c

t 77

/ /

7 fA

/ / 1 /

6 1 N I

9 7

D 6

/ &

i x. 'x n

/

EY T N E E /Y R

N C D S

O N E G

H O N C Y I

/ A T

S E

,D R I

O T N

V EN M/

H EY C:

T I AS LT W PSI X S E E S T T ET E N

E RR CO Y NP M OE E CR C

A L

P E M

E I T

M T O

D N

E 0

M 0 8 E C

L L

A L

$3 A P W

R OI TR m

R NO ES 2)

E MIV T E R 'Z X C E A P .

E L U P S B.

T A

B M

E T

N 9 S E 7 A ME -

E T 7 B CA /

AD -

G

. L P S D

L B 2 0

T T 0 N N 6 E E R /

M ME 2 E B N CM L IA A U T L N P

S N 8 O k O llllIIIi1)

Exhibit 2 ONTAINMENT BLDG.- BASE MAT, EXTERIOR WALL 8 DOME: RANDOM SAMPLE OF REMAINING PLACEMENTS PLACEMENT PLACEMENT CONCRETE PLACEMENT CONCRETE SAMPLES PLACEMENT PLACEMENT TIME NUMBER DATE SUPERVISOR REPORT EXISTS: Y/N RETAINED: Y/N SAMPLE NUMBER

/C622/6 ee/ 7-/i-79 XE-4/ett /s;or JM' J's S J/e S /20 7 //e9 /rM

/7/ 3. 'N s', /7/ 7

/z/9, su/ n: 3

/774 /Pi? /NS,

/re 6. /n t sw li'/E. /7/W /?R ,

/Z/Y, //20 //2 7,

/77/./726 T6xw2/9co/ /2 -c 6-7 V J. lnraiw 9;ac M yes bs zec > 7 re sf

/ FAX 4') YNGC/ V'Eh5 .T hTAA/V N */ T A??/ }lG- 9 ,Vg:S d>Sfd'

/dsSXW2T6co/ 8-// fl J d, ///A 77' Tl 3D A7/1 jf t:5 Y&5 77fo l

1 l

l IMwr76so e r,4- Wc, y ts,ps, 7;pcy yeS. yn Spo3 1/ daw 290 et/ 9-23-22 /t.n. ems 4 /o. go Ap>1 J'i=s yo-S 92t,s VfAXW36Vac)/ T'29- W3 sXC AA7 Mr7- 9l 9C AM1 }% f5S /0664 1/PA xa) 3 nee 3 9 - r o %' 3 0,0 % xrr J/:at >4m Fe > 725 t07/9 1/66xa> W6 r>r/ W2 - H 2- ~T C % n t' 9/ch~M177 7e.S J'c > 7502.25s3.fsoa

' #f05 l

WAxa)79/ s/'E </r/5' W2 3 0 A // s e r - #lFo Aw/ Yw XPP ft,(,3, PfdA

,/s -f - K 2- f.t..&spes /7:0s /% wi/ fes yc5  %+si 944&,

lh* AXIO.frcPc/

/eA>w Mice / /2e- 2z .ra Astr s,'n/7/

/

'&s 7c-3 /%dWu ,

/

4 UNITED STA7d5 OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE__THE ATOMIC' SAFETY AND LICEN_S_ING BOARD-In the Matter of )

)

CAROLINA POWER & LIGHT COMPAN'l ) Docket Nos. 50-400 OL and NORTH CAROLINA EASTERN ) 50-401 QL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

AFFIDAVIT OF R_OLAND M. PARSUd County of Wake )

) as:

State of North Carolina )

i Roland M. Parsons, being duly sworn according to law, deposes and says that hc is Project General Manager - Shearon Harris Nuclear Power Plant of Carolina Power a Light Company; that the answers to Interrogatories on Contentions 41 and 65 contained in "Applicantu' Supplemental Responses to Wells Eddleman's General Interrogatories and Interrogatories on l

contentiona 41 and 65 to Applicants Carolina Power & Light

Company, et al., (First Set) are true and correct to the l

best of his information, knowledge and belief; and that l

the sources of his information are officers, employees, agents and contractors of Carolina Power & Light company.

W +~~'

..Rdrand M. Parsons Sworn and subscribed to before me this // r4. day of November,1983.

l' Notary Public f's%_

l My Commission expiren f/J */ f4 __ __

- - . . . . - . . _ - - . , - _ _ . . . . .