ML20092P554

Summary of Testimony & Testimony of Dl Leone on Contention 1 Re Reinsp Program for Work Quality

ML20092P554
Person / Time
Site:	Byron
Issue date:	07/02/1984
From:	Leone D COMMONWEALTH EDISON CO.
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ML20092P552	List: ML20092P551 ML20092P554 ML20092P555
References
OL, NUDOCS 8407090089
Download: ML20092P554 (15)

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COMMONWEALTHrEDIEQN COMPANY Date: July i,*3f983 UNITED STATES OF AMENSbAM -6 p();pg NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In The Matter Of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL

) 50-455-OL (Byron Nuclear Power Station, )

Units 1 & 2) )

SUMMARY

OF THE TESTIMONY OF DONALD L. LEONE ON CONTENTION 1 (REINSPECTION PROGRAM - WORK QUALITY)

I. Donald L. Leone is a partner with Sargent & Lundy.

He is S&L's Project Director for the Byron Station.

II. Mr. Leone's testimony addresses the portion of the engineering evaluation prepared as part of the Rein-spection Program by Sargent & Lundy engineers with respect to various discrepancies identified during the reinspection of objective attributes of work per-formed by Hunter Corporation. .Mr. Leone also dis-cusses engineering evaluations performed with respect to certain weld discrepancies under the ASME Code that-were produced by welders employed by Hunter Corporation.

III. Mr. Leone explains that Hunter was responsible for installation of nearly all the mechanical systems at Byron. Its work fell into the three basic categories for reinspection: hardware installation; related documentation; and welding. The work was also divided into objective and subjective attributes. A total of 71,510 objective Hunter attributes were reinspected.

An additional 3,725 reinspections~of Hunter subjec-tive attributes (welding) were performed.

IV. A total of 689 (approximately 1%) of the objective attributes were reported discrepant. Mr. Leone explains

'that the discrepancies associated with the objective attributes were evaluated by.three methods: by comparing them with current design parameters to determine accept-ability; by use of engineering judgment; or by engineering calculations. Mr. Leone concludes that, based on the detailed evaluation of the Hunter objective discrepancies, 8407090089 840703 gDRADOCK 05000454 ~

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none of the discrepancies had any design signifi-cance.

V. Mr. Leone explains that " design significance" refers to those qualities necessary to meet established. design criteria.

VI. Mr. Leone also discusses the result of the engineering evaluation of the 49 discrepant ASME welds. The engine-ering evaluation for these welds first categorized the welds into four types and then applied a three-method approach similar to that applied to the objective discrepencies. Mr. Leone concludes that none of the 49 discrepant Hunter ASME welds had design significance.

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l In the Matter of )

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL

) 50-455-OL (Byron Station, Units 1 and 2) )

Testimony of Donald L. Leone Q.l. Please state your full name and place of employ-ment for the record.

A.l. My name is Donald L. Leone and I am a Partner and Project Director of Sargent & Lundy which is a consulting engineering firm located ~at 55 East Monroe, Chicago, Illinois 60603.

Q.2. Please describe your job responsibilities.

A.2. As Project Director for the Byron and Braidwood Stations, I work closely.with Commonwealth Edison Company and the Sargent & Lundy (S&L)- Project Team to establish the S&L scope of work and to plan the overall S&L project activit-les on a continuing basis. I am responsible for providing 1

leadership, overall management,. direction, supervision, and 1 progress monitoring of.the S&L Project Team for Byron /

Braidwood.. I.have been Project Director on the Byron / Braid-wood Project since April, 1981.

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Q.3. Please describe your educational background and  ;

work experience.

A.3. I am a 1957 graduate of the University of Notre Dame with a Bachelor of Science Degree in Mechanical Engine-ering. I am a registered professional engineer in Illinois (1967) and eleven other states. I am a member of the American Society of Mechanical Engineers and have served on one ASME (Section XI-Div. 2) and two ANSI technical committees (N45 and N45.2.13).

I started working with Sargent & Lundy in June, 1957 as a Mechanical Engineer. Over the years, I have had increasing job responsibilities on both fossil-fueled and nuclear generating station design projects including assign-ments as a Mechanical Project Engineer (1963), Control &

Instrumentation Engineer (1964), Project Manager (1973) and Project Director (1977) .

I have over twenty-seven years of experience in the design and engineering of numerous major steam-electric generating stations, including directing all S&L engineering efforts on six nuclear and one fossil-fueled generating sta-tion design projects as well as-plant. betterment efforts on several fossil-fueled units. My work has involved me in solving engineering problems covering a wide range of

conditions relative to site selection, size and type of installation, operating requirements, plant and system design, space requirements, water supply, material handling facilities, waste disposal facilities, and plant backfitting for fourteen units with a total capacity in excess of 5800MW.

I have also been involved with the preparation and supervi-sion of many economic and feasibility studies for both ,

fossil-fueled and nuclear plants.

Q.4. Are you familiar with the Byron Reinspection Program?

A.4. Yes. I was involved with the Program since late October,'1983 in terms of overall management of S&L's activities associated with the engineering evaluations of the observed objective and subjective discrepancies. However, I had no direct involvement in the preparation of these engineering evaluations.

l Q.5. What is the purpose of your testimony?

A.S. My testimony addresses a portion of the engineer-ing evaluation prepared as a part ~of the Reinspection Program 1

l by Sargent & Lundy engineers with respect to various dis-crepancies identified during the reinspections of objective l

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5 attributes of work performed by Hunter Corporation. I will also discuss the engineering evaluations performed with respect to certain weld discrepancies under the ASME Code that were produced by welders employed by Hunter Corporation.

Q.6. Since you had no direct involvement in the preparation of the engineering evaluation of the Hunter discrepancies, how is it you are able to testify with respect to this matter?

A.6. I am a qualified mechanical engineer and I am trained in areas of plant and system design including piping.

I have read and participated in the preparation of the Reinspection Report and have been thoroughly briefed by my responsible project team members. I have reviewed the underlying calculations and data for the Hunter evaluations.

I understand and adopt that work. It represents highly competent work. It forms the basis of my testimony.

Q.7. What work was performed by Hunter Corpcration at Byron Station?  :

A.7. Hunter was responsible for the installation of nearly.all.the mechanical systems at Byron. This work included installation.of mechanical equipment and intercon-necting process piping and supports, and the supply of miscellaneous piping and welding materials.

Q.8. How was this work classified for reinspection?

A.8. The Hunter work fell into three basic categories involving' hardware installation, related documentation and welding. Therefore, these areas were established as attributes. The Hunter work was divided into objective and subjective attributes depending on the degree of qualitative judgment inherent in the inspection activity.

Each attribute consists of a number of elements.

For example, the documentation attribute was subdivided into such inspection points as work process sheets, weld material requisition sheets, field inspection reports and discrepancy reports. A complete listing of this attribute and the hardware and welding attributes are shown on Attachment B of Mr. Del George's testimony.

0.9. How many reinspections of these attributes were performed?

A.9. A total of 69,624 reinspections of objective attributes was performed as part of the Program. Another

-1,886' Hunter installations of concrete expansion anchors were. reinspected by-PTL. Thus, the total reinspections of Hunter objective attributes equals 71,510. In addition, 3,725 reinspections of the subjective attribute, visual welding, were performed.

E Q.10. What were the results of the reinspections of the objective attributes?

A.10. A total of 689 (approximately 1%) objective attributes was reported to be discrepant. Five of these discrepancies were associated with concrete expansion anchors reinspected by PTL. The 689 discrepancies involved 441 documentation and 248. hardware discrepancies.

Q.11. How were the discrepancies associated with the objective attributes evaluated?

A.ll. The discrepancies were first compared with the current design parameters and. tolerances or other documentation in determining if'they were acceptable on this basis. The remaining discrepancies were evaluated by either engineering judgment based on comparison of.the discrepancies with design margins or by engineering calculations. Evaluations by: engineering-judgment' consisted of a review of the component design func-tions to determine'whether the function of the component was

-affected by the discrepancy or consisted of a comparison of the discrepancy to the current design to determine'whether the discrepancy had design significance. ..The third. method of-evaluation.was by performing detailed engineering calculations.

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, Q.12. How many of the discrepancies-associated?with- i objective inspections;were evaluated by comparison'to-the design' parameters and tolerances?

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l A.12. A total of 614 (89%) discrepancies were evaluated

-in this manner. This included all 441 documentation dis-crepancies and 173 hardware discrepancies. Discrepancies evaluated typically included cosmetic flaws, minor dimen-sional errors, and documentation errors. The dimensional errors consisted primarily of minor as-built piping and pipe support dimensional errors or incomplete as-built informa-tion. Documentation errors consisted primarily of minor data entry errors and omissions on work reports and process sheets. These discrepancies were evaluated by reviewing corroborating information on the affected documents and other independent documents. The evaluation showed that all hardware discrepancies were within the current design parameters and tolerances. All documentation discrepancies were deemed acceptable based upon reviewing other corroborating documentation.

0.13. How many of the discrepancies associated with objec-tive inspections were evaluated using engineering judgment?

A.13. A total of 54 (8%) discrepancies were evaluated by engineering judgment with all discrepancies hardware related.

Discrepancies _ evaluated included dimensional errors and omis-sions for piping,-pipe supports and pipe whip restraints; hardware substitutions, minor configuration changes; and minor mechanical joint bolting. deviations. None of these dis-

-crepancies impaired component design functions or-had design significance.

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,:.- Q.14. How manyLof the discrepancies' associated with objective inspections were evaluated using detailed-engi-

neering calculations?

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.A.14. A total of 21 (3%)-discrepancies were evaluated in this manner with all discrepancies hardware related. Dis-y crepancies evaluated included 3 as-built pipe support dimen-l l sions, 4 concrete expansion anchors, 3 pipe whip restraints, and ll-small bore pipe bends with excessive ovality. These elements were originally established by engineering calcula-tions and a new calculation was necessary in order to account for the identified discrepancy. ,

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Q.15. What was the nature of the engineering evaluations  !

with respect to pipe ovality?

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A.15. Ovality is a measure of the pipe roundness at the point of: bending. -The 11 pipe bends exhibited average I ovality values of 10.5%, which is in excess of the 8% limit j

, of the American Society of Mechanical Engineers (ASME),

Boiler-and Pressure Vessel Code -- Section III, Nuclear Power Plant Components -- Division I (1974 Ed. Summer, 1975 I

i Addenda). -Accordingly, calculations were performed verifying the acceptablity of the pipe wall thickness and flow area

. reductions allowed-by the ASME Code.- Stress intensification '

effects were evaluated as negligible since all of the pipe bends are five pipe diameters in radius.

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i il4 Q .16 .1 What does the engineering evaluation of the dis-y crepancies.in the objective work attributes performed by l

Hunter demonstrate? l i

i L A.16. -The, detailed evaluation of the Hunter objective i

discrepancies showed me that none of the discrepancies has L .

L any design significance and, hence, no safety significance.

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V Q .17 . - What does the term " design significance" mean?

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A.'17. ' Design significance is a term used to describe L the_ relative importance of discrepancies. Design significance refers.to those qualities necessary to meet established design criteria. -These-qualities vary depending on the aspect of L the design being evaluated. A discrepancy that reduces the 3 strength of a member, componen't or' structure is only design [

significant if-the strength is reduced below that: required to meet design requirements. A discrepancy, such as a missing L component orla material. configuration change, is design lsig -

nificant only if~the operation of the plant is affected. 'As i

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I indicated, r.one of the Hunter discrepancies discussed-above l had design significance..

H O.18. How many welds produced by Hunter Corporation covered by the ASME Code were reinspected?-

A.18.- Of the-3,725; welds;which were reinspected, 2,721 s -

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-(approximately 73%) were covered by the ASME Code. Forty-nine discrepancies were observed in these welds.

Q.19. How were the 49 discrepant ASME welds evaluated?

A.19. The 49 ASME welds were grouped by type into large bore butt welds, socket and fillet welds, NF support welds, and pipe penetrations and reinforcing saddles. The welds then were evaluated to ASME Section III Code design criteria using three methods to determine whether the discrepant welds had design significance.

The initial method involved comparing the weld discrepancy with the current design parameters and tolerances and the ASME Code to determine if it was acceptable on that basis. For examp2e, the visual welding reinspection criteria were too stringent in some cases (surface porosity) which exceeded code acceptance criteria. These reported discrepanc-ies werd determined to meet code design criteria and were, therefore, determined to be acceptable.

If resolution was not possible using the first approach, the next apprcach involved evaluation by engineer-

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1 Ang. judgment based on a comparison of the weld discrepancy

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.1 with. design' margins or the component. design function.

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. 1 determi~ nation was made.whether the function.of the component

-was affected.by the weld discrepancy.

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The final method of resolution of the weld dis-crepancy was an evaluation by detailed engineering calculation.

Q.20. Would you describe the analysis performed for the ASME weld discrepancies requiring engineering calculations?

A.20. All engineering calculations utilized A.SME Code design criteria. Weld assessment calculations were performed with appropriate weld material reductions where a relevant discrepancy was located. Weld discrepancies involving ASME Class 1 piping were evaluated against the fatigue analysis for the piping system. There were only 3 ASME Class 1 discrepancies and all 3 involved undersized seal welds for threaded radiographic plugs, which are non-pressure retaining piping welds. For the socket welds which were reported to be undersized, ASME Code Case N-316 was used to establish the required fillet' weld size on the basis of the socket minimum wall thickness.

Q.21. What were the results of the engineering evalu-ation of large bore piping butt welds which were discrepant?

A. 21. . A total.cf 3 discrepancies were reported. Two i were within current. design. parameters and tolerances, and.

one was compared to design margins and determined to be acceptable by engineering judgment.

l Q.22. -What were the results of the engineering evalua-tion for socket and fillet discrepant welds?

A.22. A total of 30 discrepancies were reported. Three were within current design parameters and tolerances; four were compared to design margins and determined to be accept-able by engineering judgment; and 23 were evaluated by engineering calculation and met ASME Code design criteria.

The majority of the calculations involved a simple arithmetic computation of the Code required fillet weld size.

Q.23. What were the results of the engineering evalua-tion for NF support discrepant welds?

A.23. A total of 14 discrepancies were reported. One was within current design parameters and tolerances, and 13 were reviewed ~by calculation and met ASME Code design criteria. The majority of the calculations involved recal-culating the designed weld with consideration of the-dis-crepancy accounted for and all welds were found to meet ASME Code design criteria.

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Q.24. What were the results of the engineering evalua- l tion for the discrepant welds-for pipe penetration and reinforcing saddles?

A . 24 . -- A total of two' discrepancies were reported. Both

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were reviewed by engineering calculation and met ASME Code design criteria.. Both welds were compared with actual design requirements and neither of the discrepancies were 1

determined to have design significance.

O.25. Did any of the 49 ASME discrepant weld joints fail'to meet ASME Code design criteria?

A.25. No. In all cases, discrepant weld joints met, or exceeded, Code design criteria.

Q.26' . What does the engineering evaluation of the weld discrepancies of work performed by Hunter demonstrate?

kN . A.26. The engineering evaluation of all of the weld discrepancies showed that none of the weld discrepancies had any design significance and, hence, no safety significance.

The quality of the work reinspected is adequate.

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