ML20093L205
| ML20093L205 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 07/30/1984 |
| From: | Johnson L TORREY PINES TECHNOLOGY |
| To: | |
| References | |
| OL, NUDOCS 8407310326 | |
| Download: ML20093L205 (67) | |
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UNITED STATES OF AMERICA i NUCLEAR REGULATORY COMMISSICN pghfp t
BEFORE T113 ATOMIC SAFETY AND LICENSIlpyBO,ARD d'l30 P2:40 In The !!atter 'of ~
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COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454-OL
) 50-455-OL (Byron Nuclear Power S tation, )
Units 1 & 2) )
SUMMARY
OF THE TESTIMOliY OF LOUIS D. JOHNSON ON CONTENTION 1 I. Louis D. Johnson is the Manager of Projects for Torroy Pines Technclogy.
II. Torroy Pinos has performed a third party review of the components uupplied to Dyron by Systems Control Corporation. This review oncompassed Systems Control main control boards, DC fuso panels, local instrument panols, cable trays, and cable tray hangers.
III. Torrey Pines' xeview was performed in accordance with a program plan .rhich encompassed a numh?r of different review tasks.
IV. Mr. Johnson first describes the Torrey Pines review of the Systems Control-supplied main control boards.
Jata portaining to thia component was gathorod and rovioyed by Torrey Pinos personnel, and Torrey Pinos performod a partial inspection of one of the main control boards supplied to Byron. Based on his nvaluation of all the data reviewed by Torrey Pines, Mr. Johnson concludos that tho safety-related main control boards are adequate for design uso. This conclusion is based on the scismic qualifijation and analysis of the boards, the non-significant naturo of the wold discrepancies identified on the main control boards, the oxiatonco of redundant load paths in the structurat, and the design margin which charactorizon the construction of the main control boards.
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- s. <. e 11 V. Mr. Johnson then describes the Systems control-supplied DC fuse panels. Data pertaining to this component was gathered and reviewed by Torrey Pines personnel, and Torrey Pines performed a partial inspection of one of the DC fuso pancia.
Based on his evaluation of all the data reviewed by Torrey Pines, Mr. Johnson concludes that the DC fuse panels are adequate for design use. This conclusion is based on the seismic qualification of the panels, the equivalency of the panels for soismic qualification purposes that can be derived from the nature of the wold discrepancies identified by Torrey Pines, the existence of redundant load paths in the structures, and the design margin which characterizes the construction of the DC fuso panels.
VI. Mr. Johnson's testimony then addresses the local instrument panels supplied by Systems Control. As with the other components, data portaining to this component was gathered and reviewed by Torrey Pinos personnel, and savon panels woro partially inspected by Torrey Pinos. Based on his evaluation of all the data reviewed by Torrey Pines, Mr.
Johnson concludes that the safety-related local instrument panels are adequate for design uso.
This conclusion is based on the seismic qualification of the panels, the equivaloney of the panels for soismic qualification purposes wnich was evident through a review of the wold discrepancies identified by Torrey Pines, the existenco of redundant load paths in the structures, and the design margin which characterizos the construction of the local instrument panels.
VII. Mr. Johnson's testimony then addresses the Systems Control-supplied cable tray hangers. Data portaining to the cablo tray hangers was gathered and reviewed by Torrey Pinos personnel, and Torrey Pines selected 11 hangers for inspection. Based on his ovaluation of all the data portaining to the Systems control hangers, Mr. Johnson concludos that those compononts are adequate for design uso. This conclusion is based on the results of Sargent & Lundy's ovaluation of the connections inspected in the samplo of 80 hangers, the results of Torrey Pines' own inspection of hangers, the results of inspections performed over the years by Industrial contract Services, Peabody Testing Servico, and Pittsburgh Testing Laboratory, the existence of rodundant load paths in the structuros, the design margin which charactorizon the construction of the hangers, and the utilization
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VIII. The final portion of Mr. Johnson's testimony 41scusses the Systems Control-supplied cable 1 trays. Data pertaining to the cable trays was gathered and reviewed by Torrey Pines personnel,
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and Torrey Pines _ inspected six cable trays. Based on his evaluation of all the data pertaining to the'Spstems Control' cable trays, Mr. Johnson
-concludes'that the cable trays are adequate for design use. This conclusion is based on the
-results of Sargent & Lundy's evaluation of cable tray stiffener welds, the results of Torrey Pines'
_own inspection of cable trays, the results of the inspections performed over the years by Industrial Contract Services and Pittsburgh Testing Laboratory, the existence of redundant load paths in the structures, the design margin which characterizes the-construction of the cable trays, and the
, standardized design crit'eria - (representing worst case loading conditions) utilized in the design of cable trays.
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UNITED STATES OF AMERICA 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 Station, Units 1 and 2) )
TESTIMONY OF LOUIS D. JOHNSON Q1. Please state your name.
A1. My name is Louis D. Johnson.
Q2. By whom are you employed?
A2. I am employed by Torrey Pines Technology, a division of GA Technologies located in San Diego, California.
Q3. Please describe Torrey Pines Technology.
A3. Torrey Pines Technology ("TPT") is the Division of GA Technologies Inc. through which GA's extensive engi-neering and scientific resources are offered to indus-try. The scope of these services is individually tailored to meet each customer's special needs which may vary from individual consulting with one of our technical experts to large service contracts for com-plete engineering or R&D programs.
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GA Technologies Inc. has been actively engaged in the nuclear power industry since 1965 and is one of the largest privately owned centers for diversified energy research, development, and engineering ir. the world.
Our activities have centered around the creation of advanced systems of power generation and energy con-version. Our facilities encompass nearly one million square feet of office space and include engineering, sophisticated test facilities, precision manufacturing installations, and advanced technology laboratories.
G. ' Technologies employs approximately 1,725 people of which 859 are degreed professionals, including 435 with advanced degrees. Many of the tecnnical staff are recognized leaders and experts in their field.
They have authored numerous technical books, hundreds of papers and filed more than 400 patents. The staff is highly experienced in the nuclear field and has-extensive background in water cooled nuclear power plant work. Attachment 1 to my testimony lists Torrey-Pines Technology's resources for application to engi-neering services projects. Attachment 2 presents TPT services provided to utilities.
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-Torrey Pines Technology has'successfully performed independent review contracts with Southern California Edison Company for the San Onofre Nuclear Generating Stations Unit 2 and 3, Long Island Lighting Company for the Shoreham Nuclear Power Station, Arizona Public ServiceLCompany for Palo Verde Nuclear Generating Sta-tion Units 1, 2 and 3, Louisiana Power & Light for the Waterford Steam Electric Station Unit 3, and Public Service-Company of Indiana for the Marble Hill Nuclear Generating Stations Unit Nos. 1 and 2. In addition, TPT.has completed an independent management review for Cincinnati Gas and Electric Company on the W. H.
Zimmer Nuclear Power Station. 5n independent design review of Limerick Generating Station Unit 1 is in process for Philadelphia Electric Company.
Q4. What is your position at Torrey Pines?
A4. I am Manager of Projects for Torrey Pines Technology.
QS. Please describe your educational and employment back-ground.
AS. I have a bachelor's degree in mechanical engineering and am a registered professional nuclear engineer in the State of California. I have been working in the nuclear industry for 22-years and have worked on nuc-
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l lear power plants for the past 10 years. (My resume is appended to my testimony as attachment 3.) The last five years have been with Torrey Pines Technology providing engineering services to over 35 nuclear power plants. Among other efforts, we have conducted seven independent reviews of nuclear power plant acti-vities. In 1982 and 1983 I was project manager on the independent construction review of the Shoreham Nuc-lear Power Station. The Shoreham review was structur-ed to provide a basis for judging the adequacy of the safety-related construction of the plant. This was accomplished by reviewing the programs used to control construction for the plant (including the quality assurance program), by reviewing the implementation of those programs in the actual construction, and by in-specting the constructed items in the field'to deter-mine if they complied with the design documents.
Review items were selected to be representative of various levels of complexity, types of hardware, interface relationships, and features important to the safety of the plant. Items selected for review inclu-ded safety-related mechanical and electrical compo-nents, controls, piping, cabling, and structures. The installed hardware was inspected in varying degrees of detail to confirm that the actual hardware met the l
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requirements.specified in the'various construction control documents. Complete auditability was main-tained in the review process, and independence proto-cols were utilized.
As a company, GA Technologies is completely familiar with nuclear plant quality assurance requirements both from its role as a nuclear plant vendor and from TPT's services to nuclear utilities. I have been involved in application of quality assurance disciplines throughout my nuclear industry experience, first in aerospace and then in nuclear plants. The use of sta-tistical analyses as one of the quality assurance tools has been part of this experience, along with the use of engineering judgment in the implementation and evaluation of statistical methods and as a basis for reaching conclusions where statistical methods do not completely apply. This use of engineering judgment was applied in the Shoreham construction review and has been applied in the current Systems Controls Cor-poration hardware review effort.
Q6. What is the scope of your testimony?
A6. My testimony will describe the third party review effort by TPT relating to the adequacy of Systems Con-r:
L trol Corporation safety-related hardware provided to the Byron Station. This review encompassed Systems Control main control boards, DC fuse panels, local instrument panels, cable trays, and cable tray hang-ers. My testimony both describes the work performed by Torrey Pines and sets forth the professional judg-ments I reached as a result of our review.
Q7. How did Torrey Pines become involved with the work performed by Systems Control Corporation at the Byron Station?
A7. TPT was contacted by Mr. Michael Miller of Isham, Lincoln & Beale and representatives of Commonwealth Edison during early May 1984. My understandir.g ic that Edison and its counsel desired that an outside entity with a broad background in nuclear power sta-tion design and construction examine the work perform-ed for Byron by Edison's vendor Systems Control Corporation (" SCC") and provide testimony as an expert witness in this proceeding. A program plan for the third party review effort subsequently was prepared for and approved by Mr. Miller.
Q8. Did Torrey Pines perform any work in connection with the Byron Station prior to its involvement with Sys-tems Control?
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A8. Yes. _As a consultant to Isham, Lincoln &~Beale, I was personally involved, along with Mr. R. Leary, in pro-viding third party review comments on the dEaft report relating to the Byron reinspection program, primarily with respect to presentation of statistical results.
Neither of us were involved in the reinspection effort or the final published report.
Q9. Nhat is the purpose of Torrey Pines' examination'of the work performed by Systems Control at Byron?
A9. The purpose of the TPT examination is to provide a third party opinion on the adequacy of the safety-related SCC hardware at Byron. " Adequacy" in this context refers to the capability of SCC safety-related hardware to accept design loads (stresses) without exceeding code-allowable stresses. A number of dis-crepancies had beer. identified with Systems Control-supplied components during the course of construction at Byron. Consequently, various reinspections wcre performed and both Sargent & Lundy and Westinghouse performed engineering evaluations to determine the adequacy of the Systems Control hardware at the site.
Review by Torrey Pines of the records and analyses pertaining to the SCC components, supplemented by appropriate additional inspections and evaluations, i-
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Q10. What equipment has Systems Control supplied to Byron?
A10. SCC supplied safety-related main control boards, DC fuse panels, local instrument' panels, cable tray hang-ers, and cable trays for the Byron plant.
Qll. What are the design specifications for the Systems Control equipment?
All. Sargent and Lundy design specification F/L 2788 pro-vides requirements for main control boards and DC fuse panels, specification F/L 2809 provides requirements for local instrument panels, and specification F/L 2815 provides requirements for cable tray hangers and cable trays.
Q12. What are the functions of the various components sup-plied to Byron by Systems Control?
A12. SCC main control boards provide a supporting structure for plant equipment in the main control room (instru-ments, gauges, alarms, switches, status indicators, etc.). -The DC fuse panels are cabinet-type structures located in the Auxiliary Building battery rooms which contain fuses and relays which protect the DC system.
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Local' instrument panels provide in-plant supporting structures'for instrumentation transducera and other control-related equipment. Cable tray hangers provide supporting structures for cable trays, which are used to route and protect electrical cables within the plant.
Q13. Please describe the program undertaken at Byron by Torrey Pines to review the work performed by Systems Control.
A13. Torrey Pines prepared a program plan which delineated the scope and nature of the work that TPT was to per-form. The following is an excerpt from the summary paragraph of the TPT program plan:
This program plan has been developed to provide the basis for an objective assessment of the adequacy of all safe-ty-related hardware supplied by Systems Control Corp. (SCC) for the Byron sta-tion. This program will be performed by Torrey Pines Technology, a division of GA Technologies Inc., for Isham, Lincoln & Beale. The program is organ-ized into six tasks, as follows:
Task A Data Collection Task B Records Review Task C Engineering Evaluation Task D Inspection Task E Discrepancy Documentation Task F Evaluation and Report i
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_o' CECO has implemented a program of in-spections, tests and analyses, to' demonstrate that the SCC hardware is acceptable. Torrey Pines Technology will. review that work and.will perform additional inspections and analyses, as deemed necessary, to enable TPT to draw defensible conclusions regarding the adequacy of SCC hardware.
The complete-program plan is appended to my testimony as Attachment 4. A summary of efforts in each task is presented below (each task was performed for each type of component reviewed):
Task A - Data Collection This task was designed to ide aify and assemble all available records such as purchase specifications, l
drawings, procurement documents, material receiving reports, nonconformance reports, inspection records, letters and memos, which provide information on accep-tability of System Control Corporation items. Records-generated by System Control Corporation were not re-viewed.
Task B - Records Review This task was designed to review available records on SCC items and e- sluate the degree to which those records provi/s objective evidence of acceptability of SCC hardware at Byron.
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i Task C - Engineering Evaluation
- This task evaluated the technical basis used to sub-stantiate acceptability of SCC items supplied for Byron Units 1 and 2. Where required, independent ana-lyses were performed to confirm validity of.the engi-neering approaches.
Task-D - Inspection This task identified SCC-supplied hardware items for reinspection to verify' accuracy of inspections.
Samples of hangers, cable trays, main control boards, DC fuse-panels, and local instrument panels were iden-tified for reinspection.
Task E - Discrepancy Documentation When a difference between an observed condition (docu-ment or installed hardware) and a required condition was perceived by an inspection team or document in-vestigator, that difference was recorded on a TPT Dis-crepancy Report (DR) to document the fact that a difference was observed. Each DR was reviewed by a supe: visor for accuracy and clarity of criteria and.
observed condition. In addition, the supervisor coor-dinated his review with a review by the cognizant CECO or S&L engineer to ensure the accuracy of the DR.
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Torrey Pines Technology personnel arrived at the Byron
-site May 22 to start record identification efforts and at the Sargent and Lundy offices in Chicago to start review of engineering analyses on May 29. Peak effort involved 16 men, leading to' completion of site inspec-tion efforts on June 22. A. total of 17 man-months' effort was expended on the project through-June 1984.
Personnel used for the third party review effort were either qualified inspectors or degreed engineers with experience in the fields of structural analysis, nuc-lear system design, quality assurance, statistics, mechanical systems, and project management. Lead per-sonnel on the project had previous experience in inde-pendent review projects for Torrey Pines Technology.
While this effort was a third party review rather than a review meeting NRC criteria for an independent review, the independence of the project personnel was verified in that no one on the TPT team or any of their relatives had previously worked for Commonwealth Edison Company or on the Byron plant, and no one had financial interest in Commonwealth Edison Company.
Q14. Please describe the Systems Control-supplied main con-trol boards at Byron.
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'A14. The'12 main control boards supplied by SCC are located in the Byron main control room. They are closed cabi-net-type structures that are used to mount various types of instrumentation (gauges, status indicators, alarms, switches, etc.) on.the front face with access to the' instruments and electrical terminations from the back of the control board. The cabinet-type structures involve a number of structural steel con-nections to form the structure and utilize two to six welds on each connection.
Q15. Please describe Torrey Pines' review of the Byron main control boards.
A15. Safety-related main control boards for the Byron plant were identified from Material Receiving Reports and the S&L Master Document List. S&L design specifica-tion F/L-2788 and the related purchase order 207534 were obtained. Requirements relating to configura-tion, testing, seismic loading, and welding were de-rived from drawings, procedures, and the specification document. Documentation of main control board inspec-tions by Pittsburgh Testing Laboratory, Westinghouse, and CECO, including related memos and letters, NRC inspection reports, etc., were obtained. Seismic test TT 3:
reports from Wyle Laboratories and seismic analysis reports from Westinghouse were also obtained.
Procurement and receiving records were reviewed for
' adequacy.
Inspection documentation was reviewed to determine the extent and precision of the inspection records. Non-conformance reports and associated documentation also were reviewed.
The seismic qualification test results of Wyle Labora-tories (required by the procurement specifications) also were reviewed. The seismic qualification test is conducted to demonstrate that a component is capable of accepting design seismic inputs. No structural damage was observed after the test at Wyle Labora-tories. Torrey Pines also reviewed the seismic analy-sie of the main control boards performed by Westing-house to verify the boards' structural adequacy (in response to Edison Byron NCR 544 on main control board welds).
Torrey Pines selected one main control board that had been previously inspected for reinspection of 68
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. welds. The inspection showed discrepancies that were comparable to discrepancies identified in previous.
weld inspections on main control boards. Discrepancy report 007 was prepared to document the discrepant welds.
Q16. What is your professional judgment of the adequacy of the main control boards supplied to-Byron by. Systems Control?
A16. Based on evaluation of all data reviewed by TPT, it is my judgment that the safety-related main control boards are adequate for design use.
Q17. What are the bases for your opinion?
A17. First, Torrey Pines reviewed the tests and analyses performed on the main control boards by Wyle Labora-tories and Westinghouse. Four of the 12 boards were tested by Wyle to cover all main control board config-urations. The boards were mounted on a shaker table and subjected to a sine sweep to establish resonant frequencies,.and then subjected to operating basis earthquake (OBE) and safe shutdown earthquake (SSE) seismic inputs as specified. The tests demonstrated that the boards were capable of carrying seismic loads without structural damage.
After weld discrepancies on main control boards were identified, Westinghouse performed a seismic analysis of the as-built conditions of the main control boards, in order to determine the ability of the entire popu-lation of boards installed at Byron to meet seismic load requirements. . Westinghouse utilized its WECAN computer code to determine forces and moments in con-trol board joints undtr the SSE seismic input load-ing. These forces anca moments were then converted to stresses in as-built welds at the joints to confirm adequate design margin in the as-built main control boards.
In reviewing the work performed by Wyle_and Westing-house TPT examined the seismic excitation spectra used in both the seismic qualification testing and the seismic analyses. The bases for validity of the Westinghouse computer model for application to the Byron main control boards was reviewed and determined to be sufficient. Location of peak stresses from the analysis was determined, and the evaluation of design margin in the as-built welds was verified to be proper and conservative.
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After reviewing the tests and analyses of Wyle and Westinghouse Torrey Pines has concluded that the work was properly done. Having concluded that the tests and analyses were performed in appropriate fashion, TPT has concluded that the test and analysis results indicating the capability of the main control boards to carry design seismic loads are valid.
Second, the welds on the main control boards, even though AWS D1.1 discrepancies have been identified,
.are structurally adequate. Inspections performed by Pittsburgh Testing Laboratory in 1980 and 1982, and Westinghouse inspections performed in 1983, found weld surface quality discrepancies which have been demon-strated by Westinghouse's seismic analysis to not have design significance. In addition, Torrey Pines' in-spection of a main control board to AWS Dl.1 criteria (except for length, because the length criteria could not be identified in the pertinent specifications),
confirmed that the weld discrepancies were non-signi-ficant. TPT inspected 68 welds on main control board 2PM01J, and found 20 to have discrepancies. The dis-crepancies included underfill, craters, and boxing.
These discrepancies were similar to those identified in the earlier PTL and Westinghouse inspections of the boards.
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A Third,'our review of the main control boards led us to h
conclude that the structures have redundant load paths available and do not depend on single welds or single weld connections for structural integrity. Typical connections in main: control board construction involve-two to six welds, and loads are shared between multi-ple connections within the structure.
Fourth', a generic factor which exists for each of the components supplied to Byron by Systems Control is the design margin which characterizes the components.
Significant design margin is an expected condition on sheet metal weldments, such at those on the main con-trol boards, since standard material sizes and config-urations are used which result in such a margin. This general condition was confirmed by TPT with regard to the main control boards through our review of the Westinghouse seismic analysis, which shows minimum design margins of approximately 1.25 even after dis-crepant welds are taken into account.
Q18. Please describe the. Systems Control-supplied DC fuse panels at Byron.
A18. The four DC fuse panels supplied by SCC are located in the Auxiliary Building battery rooms, near the control t 3 i
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Q.19 Please describe Torrey Pines' review of the Byron DC fuse panels.
A.19 The DC fuse panels for the Byron plant were identified from material receiving Reports and the S&L Master Document List. S&L design specification F/L - 2788 and the related purchase order 207534 were obtained.
Requirements relating to configuration, testing, seis-mic loading, and welding were derived from drawings, procedures, and the specification document. No weld inspection records were identified. The Wyle Labora-tories seismic qualification test results (required by the procurement specifications) were reviewed. No structural damage was observed after the test at Wyle Laboratories.
TPT selected welds on one DC panel for inspection. A 4
small number of discrepancies were identified (docu-mented on Discrepancy Report 007) that were similar to r-- --
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weld discrepancies identified on other SCC-supplied hardware.
_Q.20- What is your professional judgment of the adequacy of the DC fuse panels supplied to Byron by Systems Cen-trol?
A.20 Based on evaluation of all data reviewed by TPT, it is my judgment that the DC fuse panels are adequate for design use.
Q.21 What are the bases for your opinion?
A.21 First, Torrey Pines reviewed the seismic qualification testing performed by Wyle Laboratories on the DC fuse panels. An as-built panel was subjected to a sine sweep to establish resonant frequencies, and then sub-jected to OBE and SSE seismic inputs as specified.
The testing was properly performed, and no damage to the panel resulted. Therefore, we have concluded that the DC panels have been demonstrated by appropriate testing to be able to carry design seismic loads.
Second, we have concluded that the population of the four DC fuse panels can be deemed to be seismically qualified through the equivalency of the non-tested panels to the tested panel. This conclusion derives m
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from the.results of our inspection of a non-tested DC panel, panel 2DC10J. We inspected 47 welds on the j panel, identifying three discrepancies. These discre-pancies were relatively minor, consisting of two underfill discrepancies and one instance of a crater.
Based on the non-significant nature of these discrep-ancies we have concluded that the non-tested DC panels at the site can be deemed to be equivalent to the tested panel for the purposes of seismic qualification.
Third, we concluded from our review of the DC fuse panels that the structures have redundant load paths available and do not depend on single welds or single weld connections for structural integrity. Typical connections on DC panels involve two to six welds, and loads are shared between multiple connections within the structure.
Fourth, a generic factor in the construction of the DC panels is the design margin which characterizes the construction of the panels. Significant design margin is an expected condition on sheet metal weldments, such as those on the DC fuse panels, since standard material sizes and configurations are used in the con-struction of the panels.
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l Q.22 Does your answer to_ Question 21 encompass the recent evaluationIof DC fuse panels performed by Sargent &
Lundy?
A.22 No, it does not. Sa,rgent & Lundy has recently per-formed a seismic qualification equivalency review of the DC fuse panels by evaluating inspections of welds on each of the panels. Torrey Pines is reviewing the results of the inspections of the panels and Sargent &
Lundy's evaluation. If our analysis of the evaluation of the DC panels leads me to modify my conclusion on the panels, I will appropriately supplement my testimony.
Q23. Please describe the System Control-supplied local instrument panels at Byron.
A23. The 76 local instrument panels supplied by SCC are located throughout the plant. They are open struc-tures of welded steel channel construction, four feet or eight feet in width, that provide a mounting loca-tion to properly support instrumentation (transducers, etc.) used to monitor and control equipment located i
I near the panels. The structures involve a number of connections to form the structural framework and uti-lize two to six welds on each connection. The total number of panels is divided almost equally between the i
i four foot and eight foot panels.
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- Q24. P1 ease describe-the Torrey Pines review of the Byron
- . localD instrument: panels.
. A2 4. - Safety-relatedflocal instrument' panels for the Byron
- plant were identified _by material receiving reports e andithe S&L Master Document ~. List. S&L specification, F/L 2809-and related purchase order 219596 were ob-5 e
tained. - Require tents', inspechions , and. tests were derived-from F/L 2809, the SCC QA manual, andl SCC E
drawings. Documentation of local instrument panel i
' inspections by PTL was obtained. CECO inspection records and associated NCRs were obtained. Seismic i
- test reports by Wyle Laboratories were also obtained.
I' Procurement and receiving records were reviewed for adequacy. Inspection documentation was reviewed to 4
determine the extent and precision of the inspection-i records. Inspection records were available on all 76 i local instrument panels. Nonconformance reports and t.
associated documentation were reviewed. The Wyle ;
seismic qualification test results (required by the J
. procurement specifications) were reviewed. No struc-tural damage was. observed after the testing at Wyle Laboratories.
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.Torrey Pines selected welds on seven local instrument panels for reinspection of the as-built condition.
Four of the panels had weld discrepancies similar to the discrepancies identified on other SCC-supplied hardware. Discrepancy reports 004 and 006 were pre--
pared to document the discrepant welds. Total weld length on'one of the four-foot panels inspected was found to be approximately 353 inches, even though the pertinent design drawing only required approximately 250 inches of weld, and even though the PTL inspector who had inspected the panel documented a weld length much below the amount found by TPT. Discrepancy report 001 was issued to document this weld length discrepancy.
Q25. What is your professional judgment of the adequacy of the local instrument panels supplied to Byron by Sys-tems Control?
A25. Based on evaluation of all data reviewed by TPT, it is my judgment that the safety-related local instrument panels are adequate for design use.
Q26. What are the bases for your opinion?
A26. First, Torrey Pines reviewed the seismic testing per-formed on the local instrument panels by Wyle Labora-
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t tories. A four foot and an eight foot panel were selected for testing. The panels were subjected to a sine sweep to establish resonant frequencies. Both panels exhibited minimum resonant frequencies in ex-cess of the 33 Hz cutoff frequency for significant dynamic amplification. The 8 foot panel was then con-servatively selected for a seismic qualification test using the SSE seismic inputs. Seismic qualification testing of the panel demonstrated that the panel is capable of carrying design seismic loads.
Torrey Pines concluded that the Wyle tests were' prop-erly performed. Therefore, we also have concluded that the local instrument panels have been demonstrat-ed by appropriate testing to be able to carry design seismic loading.
Second, based on our inspection of local instrument panels we have concluded that the Byron population of panels is seismically qualified through the popula-tion's equivalency to the panel tested by Wyle. We inspected portions of seven local instrument panels, including the eight foot panel seismically qualified by Wyle (panel 1PL54J). The panels selected for in-spection represented a cross-section of the panels at
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the site, encompassing the variables of time of fabri-cation, type of panel-(4 foot.or 8 foot); inspection '
-location (site or Systems. Control),(and plant loca-Each of 'these panels, as well as all of the
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other panels supplied to the site, previously had been accepted by'Pittsburgh Testing Laboratory to the re-quirements of AWS D1.1
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The Torrey Pines inspection identified 17 weld discre-pancies in the 205 welds inspected. Eight of the dis-crepancies were located on one of the panels (the Wyle-tested panel), with the rest of the discrepancies distributedonthreepftheothersixpanels. Discre-pancies identified were generally non-significant and included weld surface discrepancies such as porosity, craters, and overlap.
Because of the similarity of the weld discrepancies identified' during our inspection of the local instru-ment panels with the discrepancies identified on other Systems Control components, discrepancies which have been analyzed to be structurally non-significant, we concluded that the discrepancies on the local instru-
, ment panels also are not structurally significant.
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Therefore we.believe that, notwithstanding the weld discrepancies which exist, the population of local instrument panels at Byron is sufficiently equivalent to the panel seismically qualified by Wyle Labora-tories to justify applying the results of the Wyle testing to the overall population. Moreover, the greatest number of discrepancies found during the TPT inspection of the local instrument panels was on the eight foot panel that had been tested by Wyle; this fact further adds to my confidence that the non-tested local instrument panels at Byron can be deemed to be equivalent to the tested panel for the purposes of assessing seismic load capability.
Third, we determined through our overall review of the local instrument panels that the components have re-dundant load paths available and do not depend on single weld connections for structural integrity.
Typical connections involve two to six welds, and the loads are shared between connections within the struc-ture.
Fourth, a generic factor which exists for the local instrument panels supplied to Byron by Systems Con-trol, as well as for the other components supplied by c- .
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SCC, is the~ design margin which characterizes the con-struction of the panels. Significant design margin is an expected condition on' sheet metal.weldments, such as those on the local instrument panels, since stand-ard material sizes and configurations are used in the construction of the panels.
Q27. Does your answer to Question 26 encompass the recent evaluation of performed local instrument panels by.
Sargent & Lundy?
A27. No, it does not. Recent inspections have been per-formed on 17 local instrument panels by Sargent &
Lundy inspectors on loan to Commonwealth Edisen. Four panels were completely wcld mapped, and ten weld con-nections were inspected on each of 13 panels. These inspections are an outgrowth of the Torrey Pines in-spection, and were undertaken in order to confirm the equivalency, for seismic, qualification purposes, of
. the overall' population of local instrument panels with
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the Wyle-tested par,el. Th'e inspections were under-
- taken because the presence of discrepancies-in the i
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( panels inspected by TPT raised the possibility that
'4 the as-built conditions of the non-tested panels might
[ be sufficiently different,from the condition of the
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tested panel that the seismic qualification test re-sults for it cannot be extrapolated to the panel popu-lation as a-whole. Torrey Pines is. reviewing the inspection results.. If our evaluation of this recent review leads us to modify our conclusion on local in-strument panels, I will appropriately supplement my testimony.
Q28. Please describe the Systems Control-supplied cable tray hangers at Byron.
A28. Cable tray hangers are'used in the plant to provide ~
structural support for cable trays. They are welded structures of steel and unistrut elements. Detailed hanger configurations are usually prepared by combin-ing standardized steel and unistrut elements with standardized connection details to form the specific hanger design.
Q29. Please describe the Torrey Pines review of the Byron cable tray hangers.
A29. Material Receiving Records and a Hatfield Electric Company computer-listing were used to identify the roughly 5500 safety-related cable tray hangers sup-plied by SCC. S&L specification F/L 2815 and purchase order 200038 were obtained. SCC weld procedures and 1
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hanger drawings were identified. Inspection _ records prepared by Industrial Contract Services, Peab'ody Testing-Service, Pittsburgh Testing Laboratory, and CECO were obtained for review, along with associated NCRs, NRC inspection reports, applicable memos, let-ters, and engineering analyses of discrepant condi-tions.
Procurement and reviewing records were reviewed for adequacy. Inspection documentation was reviewed to determine the extent and precision of the inspection records. Nonconformance reports and associated docu-mentation were reviewed. This review included NCR's 813, 772, 893, and 407 relating to specific DV connec-tions in hanger assemblies. The S&L analyses of dis-crepant hanger welds identified through inspection of a sample of 80 hangers were reviewed and independent calculations were made to confirm the accuracy of'the results.
Torrey Pines selected welds on eleven hangers for in-spection of as-built weld conditions. A weld discre-pancy was noted on one hanger. Discrepancy report 009 was generated to document the discrepant weld (under-size). Discrepancy report 002 was prepared to docu-
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ment a non-specified weld on cable tray hanger " fin-gers".
Q30. What is your professional judgment of the adequacy of the cable tray hangers supplied to Byron by Systems Control?
A30. Based on evaluation.of all data reviewed by TPT, it is my judgment thatLthe safety-related cable tray hangers supplied by SCC are adequate for design use.
Q31. What are the bases for your. opinion?
A31. First, Torrey Pines-concluded that the results of Sar-gent & Lundy's evaluation of the sample of 80 hangers, encompassing 358 connections, provide valid demonstra-tion of the adequacy of the Systems Control cable tray hangers. S&L randomly selected from the plant's hang-i er population the 80 hangers that were inspected, and all AWS D1.1 weld discrepancies were subjected to engineering evaluation by S&L. The 358 total connec-
-tions inspected included 44 connections that were deemed by S&L to be highly stressed according to plant design. 106 connections were identified to have weld
-discrepancies, and each was evaluated by Sargent &
Lundy and found to be adequate to carry design loads.
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l Torrey Pines concluded that Sargent & Lundy's evalua-tion was performed in proper fashion. The sample of hangers and connections was sufficiently large to sup-
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port the conclusions reached with regard to hanger adequacy, both in terms of engineering judgment and in terms of a statistically-based judgment (the sample of 358 connections establishes with 95% confidence that there is at least 99.4% reliability.that all Systems Control hangers are adequate). Independent calcula-tions of hanger load capacity by Torrey Pines, which focused on the highly stressed connections, confirmed the S&L results. In Torrey Pines judgment, therefore, the hanger evaluation performed by Sargent & Lundy indicates the adequacy of the hangers.
Second, our conclusion of the validity of the Sargent
& Lundy evaluation is further supported by the results of our inspection of Systems Control hangers. TPT inspected 11 hangers selected to encompass variables of (1) hangers in the sample of 80 analyzed by Sargent
& Lundy to be adequate with reduced margins, (2) hang-ers with weld detail DV-162, as addressed in Edison Byron NCR 893, and (3) hangers judged to be sensitive to inadequate or missing weldments based on a qualita-tive failure modes and effects analysis by TPT that
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identified hanger geometries that would be most sensi-tive to weld discrepancies. Six of the 11 hangers had been inspected, found'to have weld discrepancies, and evaluated as part of the sample of 80. We found only one_ discrepancy on the 11 hangers inspected, an in-stance of undersize under the criteria of AWS Dl.1.
This discrepancy was identified on one of the five hangers that had not been'within the sample of 80. We have investigated the differences between our inspec-tion results and those of the S&L inspectors (on loan to Commonwealth Edison) who had identified the discre-pancies, and our conclusion is that the discrepancies themselves are sufficiently minor that the differences in inspection results are attributable to both the subjective nature of visual weld inspection and the apparent conservatism which was exercised by the S&L inspectors. The results of our inspections of hangers confirmed our judgment that the discrepancies that exist on Systems Control cable tray hangers are not structurally significant, and they do not compromise the ability of the hangers to meet design load re-quirements.
Third, this conclusion finds further support in the results of the hanger inspections performed over the J
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l years by Industrial Contract Services, Peabody Testing Service, and PTL. Although these inspection results do not provide a complete inspection history of Byron cable tray hangers, their significance in terms of our conclusions regarding hangers is that the weld discre-pancies identified by each of these agencies generally involved weld surface quality, and such discrepancies were subsequently determined by Sargent & Lundy to not have design significance. Likewise, the types of dis-crepancies identified on' the nonconformance reports which pertained to specific types of connection de-tails (for example, DV-2, DV-162) were determined by S&L to be non-significant.
Fourth, we determined through our overall review of the cable tray hangers that the components have redun-dant load paths available and do not depend on single welds for structural integrity. As with the other Systems Control components supplied to Byron, typical connections in hanger assemblies involve two or more welds, and loads are generally shared between multiple connections within the structure.
Fifth, just as in the case of the other Systems Con-trol components supplied to the site, the design mar-4
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. gin which characterizes the basic construction of the hangers provides further illustration of the adequacy of these components. Significant design margin is an expected condition on' sheet metal weldments, such as those on the cable tray hangers, since standard mater-ial sizes and configurations are used to construct the hanger assembly,.
Sixth, standardized design criteria, in the form of enveloping seismic spectra, are applied in the design of cable tray hangers. These criteria represent worst case loading conditions for-a given elevation within the plant. The existence of such design criteria, which result in significant design margins, has been confirmed by the various evaluations of the Systems Control hangers which have demonstrated adequate de-sign margins even after weld discrepancies are taken into account.
Q32. Please describe the System Control-supplied cable trays at Byron.
A32. Cable teays are used to support and protect electrical cables in the plant. The majority of the cable trays are constructed of sheet metal steel with a channel cross section that is 1-2 feet wide with 4-6 inch high
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- s side panels. V-shaped sheet metal sections (" stiffen-ers") are welded to the bottom of the trays to provide additional stiffness. A small percentage of cable trays are open on the bottom, utilizing pipe sections to form the cable support members (these trays are commonly called " ladder" trays). Straight and angled sections (called " fittings") of solid-bottom cable trays and ladder trays are joined together to form a continuous cable tray system that is supported'by cable tray hangers.
Q33. Please describe Torrey Pines' review of the Byron cable trays.
A33. Safety-related cable trays for the Byron plant were identified from S&L specification F/L 2815 and pur-chase order 200038. SCC weld procedures and drawings for cable trays were obtained for review along with available inspection records from CECO, Hatfield Elec-tric Company, Industrial Contract Services, and PTL.
Associated NCRs, NRC inspection reports, applicable letters and memos, and engineering analyses of discre-pant conditions were obtained for review.
Procurement and receiving records were reviewed for adequacy. Inspection documentation was reviewed to
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. determine the extent and precision of the inspection records. Discrepancy report 003 was prepared toLdocu-ment ths lack of inspection records on most cable trays. Nonconformance reports and associated documen-tation were reviewed. S&L analyses of discrepant-cable tray welds were also reviewed.
Torrey Pines selected welds on six cable trays for inspection of the as-built condition. The weld dis-crepancies that were identified were similar to pre-viously identified, non-significant discrepancies.
Discrepancy report 008 was prepared to document the discrepancies.
Q34. What is your professional judgment of the adequacy of the cable trays supplied to Byron by Systems Control?
A34. Based on evaluation of all data reviewed by TPT, it is my judgment that the safety-related cable trays sup-plied by SCC are adequate for design use.
Q35. What are the bases for your opinion?
'A35. First, Torrey Pines concluded that the results of Sar-gent & Lundy's evaluation of cable tray stiffener welds provide valid demonstration of the adequacy of Systems Control cable trays. In response to Edison
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E Byron NCR 529 an inspection of 123' cable trays, encom-passing 227 stiffeners, for weld length and spacing was performed. 'S&L evaluated the discrepancies iden-
.tified during this inspection, and concluded that each of the stiffeners.had weld in excess of minimum' design requirements. Sargent & Lundy also reviewed these same stiffeners for weld quality, as documented in Edison Byron NCR 707. Although aach stiffener had a weld discrepancy of some kind, S&L found that the dis-crepancies were minor and that each stiffener weld was capable of carrying design loads. Torrey Pines re-viewed the evaluations performed by Sargent & Lundy and concluded that the approach taken by S&L to show structural integrity of the cable tray hangers was conservative and was accurately performed.
Second, our conclusion of the va) dity of the S&L evaluation is further supported y'the'results of our inspection of System Control cable trays. Because of the similarity of cable tray configurations TPT selec-ted only six cable trays for inspection, five of which had been determined to have reduced weld margins in S&L evaluations related to Ecison Byron NCRs 529 and 707, and one of which had no previous inspection record. 50 of the 104 stiffener welds inspected by Torrey Pines had minor discrepancies per AWS D1.'1 cri-
-teria. 45 of these discrepancies related to length of the stiffener welds. 'Two weld cracks-(one longitudi-nal crack and one transverse crack on stiffener end welds) were identified on separate stiffeners. Based on the S&L analyses of the cable trays we determined' that the discrepancies were not significant. The re-sults of our inspection of cable trays thus confirmed our judgment that the discrepancies that exist on Sys-tem Control c able trays are not structurally signifi-cant and they do not compromise the ability of the.
trays to meet design load requirements.
Third, this conclusion finds further support in the results of the cable tray inspections performed over the years by Industrial Contract Services and PTL.
Although these inspection results do not provide a complete inspection history of Byron cable trays, their significance in terms of our conclusions regard-ing hangers is that the weld discrepancies identified by each of these agencies generally involved weld sur-face quality, and such discrepancies subsequently were determined by Sargent & Lundy to not have design sig-nificance.
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,3-LFourth, weEdetermined through our overall review of the cable trays that the components have redundant
-load paths available and do not depend on single welds for structural integrity. As with the other Systems
. Control components, supplied to Byron, typical connec-tions in cable tray assemblies involve two or more welds, and loads are generally' shared between multiple connections within the structure.
Fifth, just as in the case of the other Systems Con-trol components supplied to the site, the design mar-gin which characterizes the basic construction of the cable trays provides further indication of the ade-quacy of these components. Significant design margin is an expected condition on sheet metal weldments, such as those on cable trays, since standard material sizes and configurations are used to construct the tray assembly.
Sixth, standardized design criteria are applied in the design of cable trays that represent worst case load-ing conditions. The existence of such design cri-teria, which result in significant design margins, has been confirmed by the various evaluations of the Sys-tems Control cable trays which have demonstrated ade-
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quate design margins even after weld discrepancies are
'taken into account.
Q.36 Does your answer to Question 35 encompass the recent evaluation performed on cable ladder trays by Sargent
.& Lundy?
A.36 No, it does not. Recent inspections have been per-formed on 17 ladder cable trays and 10 ladder fit-tings.- Torrey Pines is reviewing the inspection results and S&L's evaluation of the results. If our evaluation of this recent review leads us to modify our conclusion on cable trays, I will appropriately supplement my testimony.
ATTACHMENT 1
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The technical resources of GA Technologies Inc. are available through its Torrey Pines Technology. engineering services division. General areas of expertise are as shown in the following listing:
STRUCTURAL ENGINEERING Building, Structure, Concrete Design Seismic Design PIPING AND HANGER DESIG'l Code Stress Analysis STRESS ANALYSIS Static and Dynamic
( System, Comoonent, P.srt Simple to 30 Finite Element SAFETY ANALYSIS Accident Evaluations ,
Probabilistic Analyses System Functional Evaluations Reliability Evaluations EQUIPMENT QUALIFICATION Environmental and Seismic Identification (Q-List)
Procurement (Spares) i ,
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I.. - _.______.______.m.__m___-.-______.m_ _m
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d THERMODYHAMICS~.
System Design and Performance Evaluations Productivity Evaluations-
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ELECTRICAL-
' System-Design.
INSTRUMENT ATID CONTROL Control-System Design, Modeling, Evaluation Data System Design through Operation Instrument Desigt.
NUCLEAR Core Physics / Fuel Cycle Shielding Release Circulations MATERIALS Corrosion / Erosion Welding / Mechanical Properties Friction and Wear
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____-___________:-___________---_________=_____-___ -
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[ ' CHEMICAL Water Chemistry Radiochemistry.
-RADIOACTIVE WASTE MANAGEMEtiT Shipping Storage Disposal QUALITY ASSURAfiCE NRC-Approved QA Program Design, Construction -and Manuf acturing Audit
- Training Quality System Evaluations Implementation Audits LICEllSIfiG
- (. SAR Preparation Responses to f!RC Requests Emergency Response Planning PROJECT !!At1AGEMEflT Organization Data Management and Control Activity and Cost Control l i.
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-ATTAC11 MENT 2
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TPT SERVICES PROVIDED T0 tITILITIES TPT
' UTILITY PLANT tlAME ROLE * . SERVICE PROVIDED i- American Electric Power Primary. Dissimilar metal weld.
analysis Arizona Public Palo Verde Primary Independent design review Service 1, 2, & 3 Secondary . Plans and schedules Human factors-control room Piping stress Eculpment qualification >
Structural design Design report preparation Boston Edison Pilgrim Primary. QA training Control room design review Cincinnati' Gas Zimmer Primary Independent project
& Electric management review Cleveland Electric Perry 1 & 2 Primary Safety related equipment Illuminating identification and soares procurement system
,. Licensing-FSAR review limited life parts i
evaluation QA training Commonwealth Edison Various Primary Q-List software developnent Byron- Primary Auxiliary feedwater ,
i Braidwood reliability evaluation
' Reinspection program consulting La Salle Secondary Probabilistic risk
- assessment Quad Cities Primary Control rod removal and disposal I
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.. . _ _ . . - - . . . _ .,m. __ . . , _ , , _ _ . _ _ , _ . . . . _ . _ _ . _ _ ,. _ . _ __ . _ _ , . _ _ _ , , , _ , , . . . , .._._ _____-. ._ _
F
,J TPT
( UTILITY PLANT NAME ROLE
- SERVICE PROVIDED Consolidated Edison Indian Secondary Probabilistic risk Point 2 assessment Primary Control room design review Consumers Power Co. Palisades Primary Licensing support Technical specification revien Shield cooling pipe sealing program Big Rock Primary Licensing support Point Technical specification review Campbell 3 Primary Boiler assessment and repair consulting Electric Power Various Primary Value imaact analysis Research Institute Fuel tsst data analysis Steam ganerator program technology transfer
( Bimetallic weld program Florida Power & St. Lucie Primary Electrical penetration Light , consulting General Public Oyster Creek Primary Control rod removal and Utilities disposal Motor operated valve analyses Radionuclide activation analyses Houston Lighting South Texas Primary Safety-related spare parts
& Power Project Q-List Equioment oualification Control room design review Illinois Power Primary QA training
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( UTILITY PLAtiT FLAME TPT ROLE
- SERVICE PROVIDED Korea Electric Co. Korea fluclear Secondary Control room revies 5, 6, 7 L 8 (flUREG-0578)
Piping stress analysis Preparation of design reports Seismic equipment qualification review Structural design I&C review and revision Long Island Shoreham Primary Independent construction Lighting Co. review Laboratory services Louisiana Power Waterford 3 Primary Independent design review
& Light Metropolitan Edison TMI Secondary Damage claim analysis Co.
Montana Power Primary Reheater scrubber vibration
& Light -
analysis flew York Power Various Primary Motor coerated valve Authority analyses fliagara Mohawk fline Mile Primary Control rod radiation Power Corp. Point 1 measurement Radionuclide activation analyses flortheast Utilities Millstone Primary Reload fuel design 1&2 evaluation Fire Protection Risk Assessment florthern States Monticello Primary Control rod removal and Power disposal Pacific Gas & Diablo Canyon P rimary Equipment qualification Electric Co. 1&2 packaoc review Radiochemical analyses
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TPT C UTILITY PLANT NAME ROLE
- SERVICE PROVICED Pennsylvania Power Susquehanna Primary Equipment qualification
& Light 1&2 Engineering support Philadelphia Peach Bottom Primary Remote decontamination Electric Co. 2&3 machine design Control rod removal and disposal Control rod activation analysis Public Service Fort St. Vrain Primary Quality assurance audit of Colorado Facility review committee Public Service Marble Hill Primary Independent construction Indiana 1&2 review Auxiliary feedwater reliability evaluation Sacramento Municipal Rancho Seco Secondary High energy piping Utility District Control room design Electric room design (N Radwaste filter modification Seismic qualification review Primary Control room design review Southern California San Onofre Primary Analytical chemistry Edison 1, 2, & 3 Radiochemistry Laboratory services Hot cell services Hot debris removal planning Safety-related spare parts categorization and procurement Radiation monitor system assessment and instrument calibration Indepen'.ient Review of Seismic Design Independent problem analysis ASME Cnde consulting Emergency Preparedness Licensing QA training
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, l TPT C UTILITY PLANT NAME ROLE
- SERVICE PROVIDED Secondary Seismic qualification review Startup probability Licensing Environmental equipment qualificati:n Plans and schedules Emergency planning Southern Services A. Vogtle Secondary Piping stress analysis Seismic equipment qualification Shielding / nuclear samoling Response to NRC standards Pressure /tamcerature containment analysis I&C-effluent radiation monitoring Tennessee Valley Various Primary Equipment qualification Authority Browns Ferry Secondary Probabilistic risk assessment Toledo Edison Co. Davis Besse Primary Limitorque operator reliability Core analysis seminar Piping analysis seminar Electrical system evaluation Taiwan Power Co. Maanshan Secondary Project engineering 1&2 coordination High energy piping TMI review Bid evaluation Radiation analysis Process system design Seismic equipment qualification review Pressure /temoerature containment analysis Kuosheng Secondary Seismic qualification review 1&2
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TPT "TILITY PLANT NAME ROLE
- SERVICE PROVIDED
- Vermont Yankee. -Vermont Primary . Control rod removal and Nuclear Power Yankee disposal Corp.
Virginia Elec. fi Surry Secondary Fuel damage claim evaluation Power Co.
Wisconsin Electric Point. Beach Primary Radiation monitoring system Power Co. assembly Wisconsin Public Kewaunee Primary Control room design review Service Corp.
- LEGEND !
Primary = TPT was the primary contractor Secondary = TPT was a subcontractor -
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p g .1 ATTACHMENT 3 LOUIS 0. JOH:ISON
' CL. Manager, TPT Projects PROFESSIONAL SPECIALTY Project and functional management, engineering design and development, multi-discipline management.
EDUCATION B.S., Mechanical. Engineering, Wichita State,1959 EXPERIENCE Managed the Sho eham nuclear power plant independent construction re-view and provided ~ expert testimony on the -results of the review before the Atomic Safety and Licensing Board.
Responsible for all projects under Torrey Pines Technology, the elgi-neering services division of GA Technologies Inc. Assisted in all phases of the establishment, organization, growth, and profitability of the engineering services business. Projects involved all aspects of nuclear power plant engineering.
Managed all plant engineering effort on the Fort St. Vrain nuclear
( power plant including mechanical, electrical, control, and systems engineering, analysis, and document control functions. Efforts of 100-150 pecole were concerned with operation of the plant and succort during re: note core refueling operations. Directed engineering effort relating to the core outlet temperature fluctuation problem on the plant and plant analyses.
Represented company in federal licensing matters relating to a nuclear reactor. Discerned trenJs, reviewed and attomated to influence reou- '
latory documents, and estimated licensing risks.
Managed a functional group of 100-150 engineers and draf tsmen pro-viding design, drafting, materials engineering and manufacturing engineering service to all site run projects at the Idaho fluclear Engineering Laboratory. Work involved all elements of a nuclear olant (core, structure, vessel, pioing, steam generator, pumos and circula-tors,' valves, irradiation facilities, casks and waste management).
Included technical and leadership training, recruiting and staffing, and coordination of efforts with both local and Washington ilRC offices.
Managed a group of forty engineers engaged in the design and develop-ment of electromechanically driven control valves and piping systens for both high and cryogenic temperature apalications in a radiation and space vacuum envirorment. Technical disciplines included proba-(,' bilistic design analyses, electric 11 and machanical desiqn, and ccm.
. ponent developaent planning, tesy and analysis.
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L. D. Johnson C Page two PROFESSIOltAL ASSOCIATI0lS Registered Professional fluclear Engineer, California 1976.
Member of ASME.
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ATTACHMENT 4 i i PROGRAM PLAN i THIRD-PARTY REVIEW 0F SYSTEMS CONTRA. CORP.
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- ITEMS AT BYRON STATION i
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l PREPARED FOR ISHAM, LINCOLN AND BEALE l
i MAY 22, 1984 l l
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TECHNOLOGY A Drs.on o' GA Technologios inc, summmmmmmum 4-1 l
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TABLE OF 00NTEN!5 PAGE ,
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- 1. SU MMA R Y . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
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2.i ' TAS K DES CR I ETION. . . . . . . . . . . g e . . . .' ; . . . . . . . . . . . . . . . . . . . . . . . . 2-1 1 ' ;
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.w \ s t Th -si.k A - Da ta Co11ecti on. . . . ,. ., . . .', . . . . . . . . . . . . . . . . . . . . . . . . .
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Ta sk B - Records Rev iew . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 Ta:k C - Engineering Evalua tion. . . . . . . . . . . . . . . . . . . . . . . . . . . 2-4 ,
- s. x Ta sk D ' Ins pecti on. . N. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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'Ib sk E - Diccro;ancy Doctmentation. . . . . . . . . . . . . . . . . . . . . . . . 2-6 4
Ta se F - Evalua tion a nd Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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__ __________________._l__I_______________..__ ___________.___.______m___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _
4
- 1. SUMtART This program plan. has : been developed to provide the basis for an objective assessnent of the adequacy of all safety-related hardware supplied by Systems Control Corp. (SCC) for the Byron station. Bis program will be performed by TPf, a division of GA Technologies, Inc., for Isham, Lincoln & Beale. The program is organized into six tasks, as follows:
Task A Data Collection
-Task B Records Review Task C Engir.eering Evaluation Task D Inspection .
Task E Discrepancy Docunentation Task F Evaluation and Report Byron Units 1 & 2 are currently in firal stages of the licensing process. SCC has supplied cable pans and hangers, main control boards, and local panels, all of which have become suspect because of a breakdown in the SCC QA program. As a result, the SCC work to demonstrate acceptability of their products is in ,
question. Ceco has implenented a prcgram of inspections, tests and analyses, to demonstrate that the SCC hardware is acceptable. TFT will review that work and will perform additional inspetiens and analyses, as deemed necessary, to enable TFT to draw defensible conclusions regarding the adequacy cf SCC hardware.
We review will tegin on 5/22/84, and will be exipleted by 7/13/84 ne sunmary schedule fer this werk is shown in Figure 1.
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- 2. TASK DESCRIPTIONS
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The purpose'of this review is to evaluate the acceptability of all SCC-produced
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safet'y-related items in the Byrlon statien.
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The rev1W will be based primarily ,on available records of inspections, tests, and analyses performed by parti,es other than SCC, 'supp1mented by inspections andianilyses performed by Tirf.
Tne program is structured to permit T.'T to make an objective assesment of the adeqincy 'of all Byron items supplied by' SCC. ~
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Four categories of, items will be considered: main cont.rol boards, local instru-ment; panels, cable pans, and cable pan hangers.
TASK A - DATA COLLECTION __
Objective .
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To identify and assemble all available records,
Subtasks, Al _ Identify, by part name and lot er serial'nL" der, all items supplied by
- SCC at the Byron plant,. Prepare a list of the:e items, . by part name.
,, A2 } : Identify, and obtain copies, cf all specifiegticas and drawings which specify requirments for items supplied by SCC. Prepare a checklist listing each inspection, test, or analysis requirM for each item.
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i A3 Identify and list, for each its (or lot of items), each inspection, test, or analysis record associated with that item, and all backup records for disposition of deficiencies (f!CRs).
- Records include specifica tions, drawings, procur ment doements, material-receiving reports, nonconformance reports, engineering analyses, test reports, NRC docments, inspection records, letters, and memos.
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TASK B - REODRDS REVIEN Objective To review available records on SCC itens and evaluate the degree to which those records provide objective evidence of acceptability of SCC hardware at Byron.
Subtasks Al Review a representative sample of inspection and test records identi-fled in Task A to determine if they provide objective evidence of the acceptability of the iten. Use the checklist developed in Task A for verifying test and inspection requirenents.
A2 Record results of the revicw on master list of itens prepared in Task A.
A3 Identify items fcr reinspection to verify accuracy of inspections by each inspecting agency. Include each categcry cf items for reinspec-tion. Perform inspection per Task D.
A4 Frepare a strnmary report, listing for each item or lot of itens supplied by SCC:
a) Inspections and tests performed for which a credible record exists, b) Results of TFT review of record content, c) Result of inspections er test (accept er reject), and disposition of rejectable conditions, d) Identification of all itens for which no credible inspection record exists t
e) Identification of all itens which have 2 or more independent inspection records which do not have the same results.
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TASK C - DGINEERDE EVALUATION Purpose To review tha technical basis used to substantjate acceptability of SCC items, and to perform independent analyses, if required.
'lhe following items will be reviewed for validity:
Cl Main Control Boards ' Review seismic test results, seismic analysis, and similarity justification for those teards not tested. Evalua te lowest margin welds as determined by the seismic analysis.
C2 Local Instrtment Panels - Review analysis that confirms sufficient margin in panel welds.
C3 Hangers - Review adequacy of statistical inspection and analysis con-firming sufficient margin in hanger welds. Review a representative set of 'Verst case" hanger welds (lead, configuration, weld quality) to confirm adequate margin for use.
C4 Cable Pan Parts - Review adequacy of stat,istical inspection and analy-sis confirming sufficient margin in pan welds. Review a representative set of " worst case" pan welds to confirm adequate margin for use.
G Prepare a stamary report including:
a) Description of TFT work performed above.
b) Results and conclusions based on TFT work and justification for conclusions.
c) List of Discrepancy Reports.
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- l TASK D - INSPECTION Purpose To inspect SCC items .nstalled in Byron station.
NOTE: All inspections shall be performed by individuals certified as Level II or III inspectors per ANSI N45.2.6.
D1 Based on results of Tasks B and C, develop list of number of itens to be inspected.
D2 Select specific itens in the plant. Provide written justification for selection and for Unit 1/ Unit 2 selection. -
D3 Prepare inspection checklist based on- drcwing and specification requirements.
D4 Inspect itens and record all results on the checklist, sign and date checklist.
D5 Compare inspection results with that of other inspection reports, if available.
D6 Prepare a summary report, including:
a) List of itens inspected by TFT, with TFT inspection results and other inspection results, if applicable, b) Justification for selection of items fcr inspection.
c) List of Discrepancy Reports.
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TASK E - DISCREPANCY DOCUMENTATION
. Purpose To provide detailed docmentation of each discrepancy
- fcund in the review.
El Reviewers shall . docment any discrepancy on the attached form (Fig.
1). Include sufficient information to permit an assesment of the discrepancy.
E2 Supervisor shall review the Discrepancy Report (DR) for accuracy and clarity of criteria and observed condition. Supervisor shall coordinate his review with a review by the cognizant CECO and/or S&L engineer, to ensure the accuracy of the DR.
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E3 Each DR shall be given unique ID # and a log shall be mair.tair.ed of all DRs prepared.
- Discrepancies include (a) item (s) without a credible inspection record, (b) inspections, tesst or analyses by TPr which are in disagreenent with CECO inspection, test er analyses results, or (c) other conditions which may cast doubt on the acceptability of SCC items.
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-O TASK F - EVALUATION AND REMRT I I
Purpose To evaluate all reviews, analyses, and inspections by TFT and to draw objective conclusions regarding acceptability of SCC itens.
F1 Evaluate all information generated by TFT and prepare report on con-clusions regarding acceptability of SCC items; present conclusions for each type of item. The criteria for acceptability is that the indi-cated as-built hardware must be adequate to withstand design condi-tions and that there is no observed inadequacy of inspection records.
F2 Provide recommendations to Ceco regarding any additional work requireo to provide full' justification for acceptance of SCC items.
F3 Prepare a report with above information and a description of all work performed by TFT, along with records of all TFT inspections, reviews, and analyses.
F4 Prepare testimony on the results of the third party review as required.
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O' TORREY PfMES TECHhwa.OGY A Technologies Inc.
San Den Coutome 92138 BYRON REVIEW - DISCREPANCY REPORT ITEM NAME:
SERIAL / LOT NOS.
REQUIHEMENT(S):
DESCRIPTION OF DISCREPANCY:
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l PREPARED BY 'DATE l
REVIEWED BY DATE 4-11 l
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Proposed Schedule for Review of Systms Control Corp. Items at Byron Station Week Ending: 5/18 5/25 6/1 6/8 6/15 6/22 6/29 7/6 7/13 I. INITIAL EFFORT
( Assembly people, program plan, prepare U procecures)
II. THIRD-PARTY REVIEW OF SYSTEMS CONTROL CORP A. Data Collect, ion U
, B. Records Review V C. Engineering Evaluation U D. Insrecu on U E. Discrepancy Docunent.ation T7 F. Conclusions and report, T7 Fiture 1