ML20094B157
| ML20094B157 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/05/1984 |
| From: | Fuller A, Hate K, Nevill J, Timberlake D, Timerlake D CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20094B134 | List: |
| References | |
| OL, NUDOCS 8411070044 | |
| Download: ML20094B157 (35) | |
Text
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August 9, 1981.,' ;f 7 (Revised Novemb'er 5, 1984) v UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
-In the Matter of )
)
CAROLINA POWER & LIGHT. COMPANY ) and NORTH-CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY' )
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(Shearon Harris Nuclear Power ) Plant) ) APPLICANTS TESTIMONY OF-JAMES F. I'TVI LL, ALEXANDER G. FULLER, DAVID R. TIMBERLAKE AND KUMAR V.' HATE IN RESPONSE TO EDDLEMAN CONTENTION 41
-(PIPE HANGER WELDING)
-8411070044 841105 PDR ADOCK 05000400 P PDR _
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-1 ng,1T.Please' state your names.
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2 gj A.1{~ James F. Nevill, Alexander G. Fuller, David R. Tim-
'3 berlake and-Kumar V. Hate.
- 4 Q . ;2 ~ Mr.' Nevill, by whom are;you employed, and what is
.5 'your' position?
- 6 A". (JEN): I am~ Principal Engineer-Civil, Harris Plant
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, _ '7 Engineering Section, Harris Nuclear Project Department, 8 [ Carolina Power.& Light Company.
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'9 Q .'3 ~ Please-summarize your professional qualifications and
' - - 10 = describe.your involvement with pipe hangers at the Shearon 111 Harris Nuclear-Power Plant.
~12 A.3 (JEN): I received a Bachelor of Science degree in
- 13 . civil Engineering in-1971 from West Virginia Institute of Tech-
'14_
nology, and~I am a. registered Professional Engineer in the
-15 State of North' Carolina'.
- I'have been employed by CP&L in vari--
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ou's engineering assignments at the Shearon Harris site since 17
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Siptember,'1973. A complete statement of my professional qual-ifications is appedded as Attachment 1 to this testimony.
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.19 Since. March, 1982,,I-have been responsible for two Civil-
'20 sub-units o'f the Harris Plant Engineering Section which perform
-21 theLfollowing-functions with respect to pipe hangers: resolu-4 -
22 ' tion of'-; identified field problems,-design of new pipe-supports 123 duesto pipe / system changes, and stress analysis evaluations as-24 -sociated with field changes. 25 Q.4 Mr. Fuller, by whom are you employed and what is your 26 1 position? 4
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n f , s' w ' I :1 A.4' (AGF): I am Principal ~' Engineer-Mechanical (Hanger
- 2 Engineering)',iHarris Plant Construction Sectionof the Harris
?3 ~Nucl' ear. Project Department,' Carolina Power & Light Company.
J4 :Q.5 Please. summarize-your professional qualifications and 5 de' scribe youriinvolvement with-pipe. hangers at SHNPP. 6 ' A'. 5 ( AGF)': 'I received a Bachelor of Science degree in 17 Civil' Engineering in 1973-from North Carolina State University, andII'am~a-registered Professional. Engineer in the State of
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.9 . North Carolina. 'With the exception of thirteen months in 10 1974-75; and eight-months in:1976-77, I have been engaged in en-
- 11 .gineering assignments at the Shearon Harris site'since May, 12' 1973. TA-complete statement.of my professional qualifications.
.13 'i s appended'as Att'chmenta 2 to this testimony. From January,
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-1981, through' September, 1983, I was the lead in the Hanger En-15 gineering group responsible for the technical support of pipe "16 ' hanger installation. I was also responsible for the revision 17 ~of proceduresIfor hanger installation-and the resolution of
'18 :nonconformances involving hanger installations. Since October, 19 1983, when the Hanger. Engineering group was reorganized, I have 120 :been. responsible for. technical support of hanger installation.
~21 -Q.6- 'Mr. Timberlake,;by whom are'you employed and what is.
22 -your' position?-
~23 .A.6 .(DRT): 'I am Senior Engineer-Metallurgy / Welding in
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the-' Harris Plant Construction Section of the Harris Nuclear
.25 ': Project Department, Carolina Power & Light Company.
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6 1 Q.7~ Please summarize your professional' qualifications and 2 describe your involvement with pipe hangers at SENPP. 3 .A.7 (DRT): I received a Bachelor of Science degree in 4 Engineering Operations from North Carolina State University in S '1972. From:1972 to 1980, I worked for various firms as a 6 . welding engineer, sus a pipe welder, and in welding supply. I
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7 am a certified welding inspector, a qualified welder, and a 8 member of the American Welding Society. I have been employed
-9 by CP&L at the Shearon Harris site since August, 1980. A com-10 plete statement of.my professional qualifications is appended 11 as Attachment 3~to this testimony. I have been responsible for 12 the review of pipe hanger sketches from the standpoint of 13 . welding' requirements for field fabrication. I have been re-14 spensible for assigning welding procedures, filler metal and 15 -mandatory inspection holdpoints on' Seismic Weld Data Reports, 16 as well as supplying additional welding instructions as needed.
17 I have also been responsible for resolving field-related 18 welding problems, and have provided training to Quality
.19 Control-Welding inspection personnel and craft personnel. Fi-20 nally, I have been responsible for maintaining and, as needed, 21 revising the. field welding procedure for pipe hangers.
22 Q.8 Mr. Hate, by whom are you employed and what is your 23 position?
- 24 A.8 (KVH): I am employed by Carolina Power & Light Com-25 pany's Corporate Quality Assurance Department at the Shearon 26
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' Harris Nuclear Power Plant as Principal QA Engineer in the
'2 QA/QC_ Harris Plant Secticn.
3 Q.9 Please summarize your professional qualifications and 4 describe your involvement with pipe hangers at SENPP. 5 A.9 (KVH): I received a Bachelor of Science degree in 6 Metallurgical Engineering in 1970 from the Indian Institute of 7 Technology in Bombay, a Master of Science degree in Materials 8 Engineering in 1972 from Mississippi State University, and a 9 Master of Science degree in Management in 1984 from-North 10 Carolina State University. I am a registered Professional En-11 gineer, and have been employed by CP&L in various QA assign-
'12 ments since July, 1974. 'A complete statement of my profession-13 -al. qualifications is appended as Attachment 4 to this
[14 ' testimony. The responsibilities of the QA/QC Harris Plant Sec-15 tion with respect to pipe hangers. include performance of the 16 following functions to assure that the hanger program is ade-17 quate.and complies with regulatory requirements: review of 18 construction specifications, procedures and documentation; weld. 19 inspections;'QA surveillances; and nonconformance identifica-20 tion / resolution. 21 -Q.10 What is the purpose of 'his t testimony? 22 A.lO (AGF): The purpo'se of this testimony is to respond-f23 to Eddleman Contention 41, which states: 24 Applicants' QA/QC program fails to assure that-safety-related equipment is properly 25 inspected ~(e.g. the "OK" tagging of~defec-tive pipe hanger welds at SHNPP). 26
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- e 1 'In its Memorandum and Order of September 22, 1982,'the Atomic L2 LSafStyiand Licensing Board _ clarified the scope of this conten--
3 :sionLby'holdind thatJit does not cover the entire Quality As-34 .surance"(Q')/Qu'ality A Control (QC): program, but rather is limit-
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- 5' ed:to k the assertion "that there exist defective hanger welds 6 that--have'been improperly inspected and approved."
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7 Q.11 .How;is your testimony organized?
;8 A~.11
-(AGF): First we provide background information on l) pipe h' angers, including.an overview of the processes for design
- 10 ;and fabrication, installation and inspections. Second, we~de-11- '
, scribe the relev. ant deficiencies discovered in 1980 and in:
12 1982, and the: resultant reinspection programs and otherocorrec-- i 113 itive~ actions; undertaken. Third, we assess the safety signifi-14 .cance-of these occurrences. Fourth, we describe the enhance-c15 ments'to'Lthe' hanger program, implemented in December;.1983, and-m; ' 16 . demonstrate the effectiveness of that program.in ensuring that. i l7
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the quality of the final' hanger _ product is~ established. Fi-
, 18 :nally, we assess the implications of the hanger program experi-19 ence for the' quality assurance-program.
20 M'r. Nevill, what is a' pipe-hanger? 1 Q.12
-21 , A.12 (JFN): lA pipe _ hanger is a component or structural -* 12 2 . assembly _ designed and installed to support or restrain'a sec-
- 23 ~ tioniof pipe subjected _to a combination of loads, and which
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,, 24 -protects thespipe from stresses'that could impair the pipe's c '- 2 5 ability to perform its' function. For purposes of the QA
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.programtand this testimony,' safety-related pipe hangers may'be p .. s .
4' l2 tequated widh?the term = seismic: pipe' hangers. j d3 Q.13 Please summarize;the-design process for the seismic f4 Lpipe hangers. c5.~13! (JFN): .The design:of seismic pipe supports starts
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iwith'the.p'iping designer and pipe stress analysts.
'6 For SHNPP,
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-7 (the architect / engineer, Ebasco,--is the organization responsible
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g- ~8 . for piping des"ign and' analysis. Thelpiping. group develops pipe 9 : lay-outs,to satisfy' system function ~ requirements and provides
- n 10 -design parameters.for stress analyses ~. g The piping arran'ement V F . ,.
11 is thenistress analyzed for. operating. loads,, thermal! loads, L12 ~ seis'mic loads--and other-appropriate loadings to de'termine loca-
'13 ition,; function, and magnitude,.of. support loads.
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This data is 14~ -: utilized by.the support designer to develop ~ pipe supportcde-
-15 -signs.
'16 -The' supports are-designed'.to. counteract the combined loa'ds
- 17 and!to' prevent the pipe'from being-overstressed. For-SENPP, l18 Bergen-Paterson was the primary design and fabrication"organi-
. , , L19 zation'-for the: pipe supports.-
-20 .Qi14 'Are inspections performed at:the vendor's facility?
;21 A.14 (KVH): Yes. ' Welds received both'in-process and u 22 ffinal.' inspection'by Bergen-Paterson inspectors, and hangers
..; , ' ' - 1 23 lwere-presented to Ebasco-inspectors for-final approval prior to 1 <- > 24 shipment.J Inspections were-conducted' visually by trained.in--
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~25 jspe'ctors using;the Bergen-Paterson design drawing to identify l' .26
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1 size and type of weld and hanger geometry. Prior to the iden-2 tification in 1982 of deficiencies in vendor-supplied welds, 3 : inspection was done on a sampling basis.
- 4 Q.15. How are the pipe hangers installed?
5 JA.15- (AGF): -Early in the hanger erection effort, CP&L 6 studied the hanger erection problems being reported in the in-7 'dustry'and visited several other sites to gain a better under-8 standing of current. hanger erection and inspection problems. 9 It was' concluded that many of the problems being encountered at 10 -other sites during the completion phase could be avoided if in-11 spection started as early as possible. A complete hanger in-12 -spection cannot be-accomplished, however, until both the pipe 13 and hanger are installed in final location. This sometimes 14 'does.not occur until late in the overall construction schedule.
- u. 15 Site-management nevertheless concluded that delaying any hanger 16 . inspection until the finsi phase of construction would deny the
'17 project'an early indication of problems. It was also. concluded 38 that.the absence of any.early preliminary inspection contrib-1 19 uted to the problems being reported at other sites.
20 Based on these considerations, the initial hanger erection
.21 program was set up to include an initial (Phase I) inspection 22 and a. final,(Phase II) inspection. Phase I inspections were 12 3 set _up'to include an intermediate-check of location and an in-24 :spection of any field welding performed up to the point of in-L25 'spection. Phase II inspections were to verify the total hanger 26 l
.c . _ _ . l~ installation after-both pipe and hanger had been adjusted to 2 -finalLlocation and work was completed. In fact, to a great ex-3 ' tent the deficiencies being discussed here were found as a re-
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.-sultiof the early start on inspection activities during Phase I 5 inspections. Consequently, the early inspections accomplished "6 the goal of providing site management with early warning of ;
7 . potential hanger problems. 8 The'_following groups are involved in the installation of 9 seismic hangers: 10 -- Document Control. issues and controls design docu-ill ments. 12 - Harris Plant Engineering Section generates and ap-13 proves design changes required.~
'14 -
Hanger? Engineering (Harris Plant Construction Sec-15 . tion) provides technical support to the craft. 16 - Welding. Engineering (Harris Plant Construction Sec-17 ' tion)'provides technical ~ support.to the craft and 18 hanger engineering. 19 - Construction Inspection (CI) inspects hangers for de-20 sign compliance, including geometry, location, and 21 bill of materials.
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QC performs receipt inspections and inspects hanger 23 welds.
= 24 Installation involves the following basic phases: (1)fre-25 ceipt and processing of design documents; (2) ~ receipt and 26
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1 inspection of' material;1 (3) issuance of hanger' design documents-
- 2 c and material,for construction;'(4:) installation and inspection 3 ar the: hanger; and, (5). final documentation review.
4 :Q'.16-?What is involved in the receipt and processing of 5 design documents? s 6 A.16 -(AGF): Hanger design drawings are received by Docu-7 ment' Control'and are issued to Hanger Engineering for inclusion 8 in.the hanger work' package. 9 Q.17 Mr. Hate, what' presently occurs during the receipt 10 'and inspection of material?
'll A'.17 The hanger material for a particular design
( KVH)': 12 :is. received and inspected by,QC for compliance to the purchase g 13 order (i.e.,' identification, dimensions, damage and shop
?l4 welds).. O 115 LQ.18. What1 presently takes place in connection with the 16 issuance.of the. hanger work package and material for construc-117 ' tion? (
18 A.18 '(AGF): First, an' initial review group of. Hanger En-
- -~19 ~ gineering persdnnel reviews the hanger drawing and' develops a
\'O 20 workfpackage-consisting of:
21 '(1) A/ Seismic Weld Data Report (SWDR) for' weld joint in-22 spection records. ' 23 (2)' A . traveler. for tracking :the status of installation 24 and inspection.
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' 1 (3') -Work directives-for' detailing special instructions if 4
2 required. 3 -('4)_ The hanger; design drawing. t 44 :(5); Field modifications as required. 5
'(6) lA' Material Verification Sheet.
6 Second,'the hanger package is.then "weldmapped" by num-
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bering the welded joint (s) on the hanger. The field joint num-J8 bers are lis'ted on the SWDR for tracking weld acceptance. This 9 #procsdure was instituted in December 1983, per Work Procedure 10 Prior to implementation of'WP-l'39, field welds were L139. f il tracked'by various methods. 112 ~ Third, the package'is reviewed by Welding Engineering to vc ' 13 Ldetermine-the particular welding. procedure specification neces-in 14 .sary in:accor' dance with project' site requirements, mandatory.
' 15 holdpoints for fitup and preheat prior to welding, and to iden-
- i. _. 16 tify unclear, missing, or erroneous welding instructions on the 17 _ drawing. Any additional instructions are placed on the SWDR.
18 : Fourth,6QC Welding then reviews the new SWDR for com-
- 19 pleteness and-accuracy. Documentation for previous welding is c L20 .also reviewed and,:if accepted,-is transcribed forward to the 31 21 inew'SWDRi . Welds not yet.accepte'don the SWDR will be
'22 reinspected along with any additional new welding.
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Finally, the. package is routed to a construction crew
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.24 foreman who requisitions-the material from the warehouse / fab L25 shop'for installation.
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k Q.19; What presently is. involved in the installation and 2 ~ inspection.of a hanger? 3 A.19 (AGF, DRT, KVH): The following steps are involved in 4-
- the installation and inspection proceas:
- S (1) The han~ger members;are fit-up, tack welded in place,
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6 'and examined by Hanger Engineering personnel prior to
'7 weldout. Field Mods (' modifications) are generated by 8 Hanger Engineering personnel to resolve interferences 9 or other. installation problems.
'10 (2) QC welding inspections are performed to insure fit-up 11 compliance and preheat verifications as required by
;12 the SWDR.
13 (3)' The hanger is welded out by qualified welders, y i4 .(4) Final shimming and adjustments are made to the hang-
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16 (5). Welding Engineering personnel examine hanger welds.
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117 .(16) Hanger Engineering personnel examine the hanger for 18 compliance to.the design intent. Field Mods may be 19 generated to report the field condition to HPES
, 20 -(Harris Plant' Engineering Section).
21 :(7) CI (Construction Inspection) inspects hanger ~geome-
-22 try,-location, and other parameters for design com-23 pliance.
24 (8) -QC Welding inspects hanger field welds and records 25 .the weld' joint acceptance on the SWDR. 26 c 4 ______________.__._______.______.____.___._______m.-
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-4 11 . Q .'2 0 : What:is'.the' final-documentation review?
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, A22OI (AGF): Final documentation' review includes verifi-Jcationioffthe follSwing:
'3 documentation has been properly com-4 --pleted and signed-off; pertinent. documentation has been includ--
5' Led inLthe' hanger package; and modifications have been-correctly E :, 6 incorporate'dsinto'the final drawing. L7 _ Q.21 Mr. Hate,'please= describe in more detail the in-8 spection process applicable to pipe hangers, including VendorL
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19 QA,and the site inspections performed by the CI and QC organi-10 zations. 11 A.21' (KVH): CP&L has contracted with Ebasco for vendor 112 surve111ance pertaining to shop fabrication of hangers supplied
. 7 13 .by Bergen-Paterson.
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Ebasco Vendor-QA performs surveillances,
.14 inspections, and1 audits of the vendor's facility and work.ac-
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tivities. . The actions include review of such documents as ma-
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16 terial1 test reports, inspection records and non-destructive 17 test reports and coating records, and performance of shop in--
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18 .spections on. work accomplished. Inspections now include, but 19 are notJ11mited to,. inspection of welds on non-standard parts-20 prior to painting. Nonconformances identified during the shop-a 21 inspections;are documented and resolved. Vendor-caused' 22 ~nonconformances identified by CP&L after receipt of the hanger 23 - on site.are investigated by Ebasco Vendor-QA and reviewed with y 24 Bergen-Paterson management to prevent reccurrence.
-25 26 1, .
1 After completion of final inspection in the vendor's shop, 2 Ebasco issues a Quality Release.(QR) indicating the hanger is 3 acceptable and is ready for shipment to the field. Originally 4 when hangers were received at the site they were accepted based 5 on this QR. The hangers were also checked for identification, 6 documentation, damage, and obvious welding discrepancies prior 7 to release for installation. The quality attributes to be 8 checked during receipt inspection were increased once QC in-9 spections started noting discrepancies with previously accepted 10 shop welds. Statistical sampling of vendor welds was initiated 11 in May 1982. Due to the high reject rate experienced from this 12 statistical sampling, 100 percent receipt inspection of vendor 13 welds was initiated during June 1982. This high reject rate 14 was due in part to the fact that vendor QA and site QC in-15 spectors were using somewhat different weld acceptance 16 criteria. The majority of welds rejected on site were for 17 minor weld defects. Increased vendor QA inspection and stan-18 dardization of weld acceptance criteria have resolved this 19 problem. The inspection of shop weld quality attributes has 20 been retrofit to include hangers received on site prior to 21 June, 1982. 22 Inspection of pipe hangers in the field is performed by 23 Construction Inspection (CI) and QC. The CI inspections 24 address hanger attributes other than welding. 25 26 w
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1 Inspection of. welding performed on site is done by the QC 2 Welding. group. These inspections are performed to assure: 3 compliance with the hanger drawings with respect to weld type, 14 uize and length; acceptability of materials; and weld quality. 5 These inspections'are performed by inspectors who are qualified 6 and certified in accordance with proc'edure CQA-1, and are per-
'7 formed in accordance with procedure CQC-18 (procedure on weld 8 control) and NDEP605.(visual weld inspection procedure), and 9 documented on a SWDR. Acceptance and. rejection of the welds
_10 are noted on the SWDRs. Rejected welds 1.ust be dispositioned. 11 (reworked or waivered) and accepted by a QC inspector prior to 12 final acceptance of the hanger. The SWDR is included in the 13 hanger package and becomes a QA record. SWDRs are reviewed by 14 the QC welding specialist for completeness and accuracy. The
'15 QC welding specialist periodically trends the weld reject rate 16 to determineLif an adverse trend is developing and whether man-17 agement attention is required. Since the implementation in 18 December 1983 of the enhanced hanger program, no adverse trends 19 have been identified; rather, as discussed later, positive re-20 sults have been noted.
21 -Q.22- Were there early indications of pipe hanger problems 22 .at SHNPP?
.23 A.22 (AGF): Yes. On September 3, 1980, the resident NRC
-24 inspector' identified several hangers with unclear and incorrect 25 . weld symbols on Bergen-Paterson Seismic Clasc I pipe hanger 26 w . _ _-__ _--- -
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'l -drawings. Additionally, the NRC inspector identified cases in 2 whic'h the field. applied weld was different from the drawing
'3 requirements and had-not been icentified by QC. This discovery 4 was' cited'as an-infraction in an inspection report dated 5 . November 3,-19'80. Consequently, a site investigation by CP&L 6 into selected hanger drawings.and installed hangers was con-7 ducted. The results indicated that several weaknesses existed 8 in the program forlinstalling an'd inspecting seismic hangers, 9 in that:a. substantial number of seismic hanger drawings 10 . contained erroneous, missing, or unclear welding instructions, 11 and many installed hangers were not welded to meet the design
- g. 12 requirements or quality acceptance criteria. Due to the exten-13 s'ive scope.of the problems identified, it was deemed necessary 14 to reinspect' seismic hangers on which field welding had been i
15 pe rfo rmed.' A final report on theldeficiencies and subsequent
.16 ' reinspection program was submitted to the Staff on May 1, 1981 17 '(and revised on June 11,_1981); and the NRC closed out this-18 it'em on September 14, 1981.
119 Q.23 What did the reinspection program consist of which 20 was initiated as a result of discovering these' problems? 21 A.23 (AGF): Approximately 1800 hanger design drawings
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22 which had been issued to the field were reviewed for missing, 23 unclear, and erroneous weld symbols. These hanger drawings 24 were. issued to QC for reinspection. Of the 1800, approximately 25 1100 hangers were'found to have some completed welds and these 26 n-
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1 were reinspected by the QC inspectors. None of the hangers had 2 yet been completed and finally accepted by QC. (The hangers 3 -had been basically assembled and some welding completed, but 4 final adjustments and/or welding work remained to be done.) 5 Discrepant welds were either reworked by craft personnel or ac-6 cepted by the design organization on the basis of an appropri-7 ate engineering. analysis. 8 Q.24 What corrective actions were undertaken with respect 9 to review of hanger drawings? 10 A.24 (AGF, DRT): Hanger Engineering and Welding Engi-11 neering began reviewing pipe hanger design drawings for miss-12 ing,' unclear, and incorrect weld symbols prior to issuance to 13 the field. Welding Engineering personnel performed the primary 14 review for weld symbol problems. Drawings with problems were 15 reported to Ebasco/Bergen-Paterson for correction via pipe t 16 hanger problem memos written by Hanger Engineering. Revised 17 design drawings were received and reviewed to encure that welds 18 were properly dispositioned. 19 Ebasco discussed the design drawing problems with 20 Bergen-Paterson, which identified the problem to its design 21 personnel. Bergen-Paterson agreed to revise their review pro- ' 22 cedures to insure that design drawings show proper weld sym-23 bols. Drawings being issued from Bergen-Paterson's three de-24 sign offices were routed through a single office to provide 25 more consistent review by Bergen-Paterson engineering 26 personnel. , f ( l',
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s il Q.25 .Were any corrdctive actions undertaken in connection (2 with th'e' welders?-
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13 ^ A.25 (DRT): Yes. . Weld' symbol identification training 4 : classes ;were . conducted by welding. and hanger' engineers. -The
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*' -5 classes consisted of training'on AWS standard weld symbol no-4 ; 6 menclature in accordance'with AWS A2.4-79 as related to
-. 7 Bergen-Paterson pipe hangers. Craft personnel attending these f 8 training classe,s included. superintendents, general foremen,
~9 ' foremen and welders of' pipe and: pipe hangers.
In addition to
-~lb instructions on weld' symbol identification, emphasis was given e L1L -to the importance of welding'the pipe hanger exactly as the de-12 : sign. drawing requires. In-those instances where this is not 113 possible,~due to physical limitations or--drawing errors, . craft
'14 : personnel were. directed to return the hanger drawing to Hanger e 115 Engineering.> e 3 '16 'Q.26 'Weve any other corrective actions initiated?
~17 :A.26 (KVH): Yes. -QC~ personnel attended the weld symbol 18 identification classes Mr. Timberlake just discussed, and addi-
~19 tional classes given within their-~ organization. ~ These classes 20 emphasized-the necessity for inspections to be conducted
~ 21' 7 strictly in accordance with' drawing details and also instructed
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, [22 . QC personnel'to report incorrect design drawings to Hanger En-123 gineering.
24 . Q.27 Was there a subsequent reinspection? 25
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1 A.27' Yes, in 1982. (AGF): Surveillances performed by 2 Ha z ger Engineering identified hangers with documentation errors
- 3 and weld de'fects.
The_. Receipt Inspection Program, revised to 1 4 tencompass; examination of vendor welds, discovered deficient 5 shop welds made by'Bergen-Paterson. Finally, it was determined
. . 6 that inspectors and craftsmen were using an improper technique 7 .in the measurement of skewed tee welds.
8 The widespread scope'of these deficiencies made it neces-9 sary to reinspect seismic pipe hangers welded.or partially
.10 welded out prior to June 26, 1982. The reinspection program 11 addressed both shop and field welds, and the results for each 12 ' hanger were documented on that hanger's individual SNDR and e 13 ~dispositioned on that document.
14 Q.28 'U1at did the 1982 reinspection reveal? 15 A.28 (AGF): The reinspection found: (1) missing and un-
.16 dersized shop and field welds; (2) minor shop and field weld 17 ' defects; and (3) inaccurate.and incomplete QC weld documenta-
-. 18 tion. 19 Q.29 Why did these deficiencies occur in view of the cor-20 re'ctive actions initiated after the discovery of deficiencies 21 in 1980?L 22 A.29 (AGF, DRT, lKVH) : Undersized skewed tee welds were 23 not discovered until the first quarter of 1982, and therefore 24 were not the subject of the efforts in 1980. Further, there 25 had beenino training of craft personnel, and improper training
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c 1 of inspectors, on the technique for measuring the fillet weld 2 size-on skewed tee joints. 3 Similarly, vendor-supplied welds were not part of the 1980 4 reinspection. . While isolated cases of minor weld defects had 5 been identified previously and documented on deficiency and 6 disposition reports which were forwarded to Ebasco for 7 strengthening of the vendor QA programs, the isolated. nature of 8 the defects indicated that the vendor-QA program had been per-9 forming satisfactorily.
>10 Neither did the.1980 reinspection address the documenta-11 tion problems identified in 1982 caused by minimal review of 12 weld records or the absence of a procedure for standardizing 13 the requirements for completing documentation records. Fi-14 nally, the 1980 reinspection relied on the qualifications of QC 15 inspectors and their acceptance of welds as the final word, 16 without routine checks or surveillances on their work.
17 Q.30 What corrective actions and/or preventive measures 18 were undertaken as a result of the 1982 reinspection effort? 19 A.30 (AGF, DRT, KVH): Shop and field welds on installed 20 hangers were-reinspected and deficiencies were either reworked 21 by the craft or evaluated and accepted by the design organiza-22 tion, except for the few hangers currently on design hold. 23 Deficiencies were recorded on the SWDR and acceptance eventual-24 ly recorded on that document by the QC inspection organization. 25 In addition, vendor welds were examined prior to releasing 26 u____
h r f [ :*: 1 . material to the-field for' installation. Deficiencies noted 2 .were'also either_. reworked or accepted by engineering evalua-3 . tion. :This program is.still in progress. 4 In addition,Ethe following measures were implemented: 5 (1) Weld acceptance criteria were revised to provide con-6 -sistent inspection criteria to be used by site and vendor QA 7 inspectors. 8 (2) .Ebasco assigned four vendor QA representatives to the
~
'9 Bergen-Paterson facility and began' performing both in process
^
10 and 100 percent final visual weld inspections. These in-F 11 spections consist of a visual inspection of shop welds prior to 12 coating of-the hangers. After the hangers are coated, they un-13 ~
-dergo a dimensional and coating inspection. (Prior to the cor-14 rective action, Ebasco had one vendor QA representative as-15 signed to the Bergen-Paterson facility who performed random 16 dimensional, coating.and welding inspections when the hangers 17 were ready for' shipment.)
18 .(3) An inspection / documentation procedure specifically 19 'for pipe hanger welding was developed. 20 (4) ~ Routine-audits of each QC inspector's field work were 21 implemented by QC supervisors.
.22 -( 5 ) . Weld documentation was reviewed to insure it'was cor-23 . rect and. complete.
24 (6) Additional training on weld acceptance criteria 25 (including skewed tee welds)'was initiated. 26 u ,
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/ & ,Y 1
Q.31 Mr. Nevill, the witnesses have been describing vari-2 ous deficiencies discovered in connection with the welding of 3 seismic pipe hangers. Are there design considerations which 4 might provide some perspective on the significance of the 5 deficiencies? 6 A.31 (JEN): Yes. There are various input criteria used 7 in support design that induce conservatism in support func-8 tions. I will briefly ' describe these conservative aspects, 9 which are considered inherent to the ' design process but are not 10 routinely utilized in engineering evaluations of a defective 11 condition. 12 (1) Material Properties. Actual mill test reported val-13 ues of material stresses are typically higher than the 14 specified nominal stress properties used in design. 15 (2) Design Allowables. Design codes and regulatory agen-16 cies dictate allowable stresses and loading combinations. Mar-17 gin exists between the stress limits used in design when t, 18 comparing allowable, yi e '.d , and ultimate stresses. Design 19 loading aspects are combined in a manner to assure the gov-20 erning design input provides worst-case analysis. 21 (3) Minimum Weld Size. The design codes require the ap-22 plication of minimum weld sizes. Compared to actual loading 23 conditions, minimum weld size may be larger than the size re-24 quired to resist the design stresses. 25 , 26 ., Pl }x' ' G
,1, e m , ~a.;
u Y x
, 1 ]4)- ' Response Spectra Curves. The engineering application-2 offresponse~ spectra _ curves provides margin due to the need to
>Addres's complexities'in the time-history seismic modeling tech-
~ '
(3 4 nique. Curves are broadened, enveloped, and amplified'for p 5 qualification.and design of. plant systems and structures, which 6 increase the range of frequencies'using peak values as well as-7 increasing _ accelerations throughout the entire frequency range. [ 8 This results in analyses using conservatively higher seismic 9 inputs than will actually occur.
- 1. 0 (5)~' Support-Stiffness. Structural designs are based on 11
~
' stress levels and deflection criteria. ~Since the-pipe analysis-7th 1. 2 dictates deflection limitations,.the support design deflection
.13 criteria rather than-stress levels typically govern the member 14 size:and support configuration. Wold sizing is developed ~from
~ 15 =the. stress' levels, and therefore margin:isL-induced.
116 Where weld problems are. accepted by-engineering evalua-17 tion, various applications of design techniques are available 7 18 to determine' functional acceptance. Examples:are: comparison
- 19 of actual-weld stresses to allowables; additional pipe analysis-20 to reduce the loading on a particular hanger; or computer mod-21 _eling.in place of hand calculations.
22 -Q.32 What is the significance,'then, offthe typical pipe
-23 hanger' welding. deficiencies in light of these design conserva-124 ttisms?
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- A.32L :(JFN): The' types'of weld defects reported primarily
~
12 involved relatively minor instances of undersize, undercut, 13 lack:of fusion and. porosity. Consideration of conservative as-
~
;4 'pects of'the' design criteria indicates the significance of the-a : .. .
S 'typicalLdeficiency to'be minor and to have no adverse impact on
- 6
.g . structural integrity.
c7 E Q.33 For the'1980 and 1982 reinspections, did you fre-8 .quently' rely'on engineering evaluations to disposition pipe 9 hanger welding nonconformances? C
, 10 .A.33 -(AGF): No. The majority of the deficiencies iden-11 'tified in!these reinspections were not evaluated to determine 12 if they;were~ acceptable as is, but were repaired due to the L13 -econom'ics associated with the engineering' evaluation.
On 14 Q;34. Have'further changes been made to the pipe hanger
;15 jprogram since 1982?
116 'A.34 l(AGF,~DRT,-KVH): fYes. An enhanced hanger installa-17 tion /inspectioniprogram was-put'into-place in December 1983 in 18 d
- or'erTto~ provide more posi~tive control of construction, in-
'19
~
zspectionnand documentation activities. The enhanced program 20 was' initiated by QA and Construction management to achieve L21 -these. goals.,.The key elements of the enhanced program are as
.22 -ifollows :
23 .(1) .A work package group _.has been created to. review hang-24 'er work packages-prior to iso;ance to the field. During the 525 review the hanger. sketch is weld mapped for inspection 26 I
-23 .
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- i. :.'
si
-1 documentation and the drawing is checked for constructability.
2 Weld mapping has provided a high level of confidence that welds 3 .are inspected and accepted. (This-is being retrofitted to pre-4 .viously. installed-hangers as well as applied to the installa-r 5 tion of.new hangers.) This review also insures that necessary
'6 documentation and instructions for installation and inspection-7 are present in the package prior to issuance to the field.
8 ' Hangers are also surveyed in the field to' identify attachment
~
9 ' points, 10 L(2) Theiseismic hanger work precedure has been revised 11 and its requirements.-simplified. Generic engineering documents 12 are'for.the most part no longer used as solutions to common 13 . problems. Instead,-field modifications are written for each 14 hanger / detailing necessary changes due to these problems. This 15 lhas greatly reduced the potential for misinterpretation and 16 -subsequent' misapplication of construction requirements. 17 (3) A field hanger engineering support unit-has been 18 Edeveloped whose purpose is'to support the craft during hanger 19 installation. These Hanger Engineering personnel remain in the 20 : field thoughout.the hanger's construction and identify and re-21 solve. installation problems. These efforts produce additional 22 confidence that the design organization's intent .s being met 23 during construction. Field Hanger Engineering personnel also 24 Lexamine the hanger for design compliance and have Welding Engi-25 neering personnel examine hanger welds (both shop and field)
'26 SE "59 d f' .
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':% (
1 priorstb submitting the hanger package to CI and QC for final-
" ~
' 2 inspection. : Hanger Field Mo'ds are generated by Hanger Engi :
[ ?3 neering' personnel to. resolve' problems encountered. These exam-
.4 ;inations by the: Hanger and Welding Engineering personnel will
;5 r generate higher quality l'evels.in the-work being presented for 6
final inspection and thereby render this process more effec-7 ' ti ve . , J ,
~.8 ~ d4) .In addition to CI and QC review, a Hanger Engineering
~ '
9 final. review group has'been formed to review seismic hanger ' 10 : packages prior to' final. turnover.to the' permanent QA records 11 cvault. . Hanger package documentation is verified as being com-
.12 plete.andLaccurate.
13 Q.35 .Is'there any evidence that the enhanced program is
~
14 . effective?
. :15 1A. 35 - (13EI) : Yes. .For, example, in'the second quarter of 16 1984,;approximately 93 percent of the quality attributes
' 17 _ presented by the craft.to CI'for inspection.were found to be 118 : acceptable. .Also, approximately 93 percent of the work 19 -presented by the craft.to-QC for weld inspection was found to 20 . be: acceptable. In addition, an-independent check of inspector 21 . performance for'the period' February to April, 1984, by QA sur-
- .22 .veillance revealed ~a 99.82 percent acceptance rate for
;23 'CI-inspected attributes and a 99.37. percent acceptance rate for 12 4 QC Welding inspected attributes.
25
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126
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' 1 1Q.36. : What 9are' the implications .'of the- pipe hanger welding -
,1.
b 4 [2 experience,'if any, for the effectivenss of the'QA/QC programs n3 .for? construction'of.SHNPP?- O , 4 A.36: (KVH): .The fact that' improvements have been made y 5 ..over a'perio'd of~ time does not undermine my yiew that our!QA/QC {s: :6 .. programs have been, effective lin' discovering and: reporting
, :7 deficienciese Weaknesses were looked for and' identified early
< !fr: ' ' 8 fin,the. hanger program,'and the QA/QC programs were-
'9 : strengthened. As.with any program of procedures, the human el'-
10 -ement exists and~ mistakes will be'made. One' measure of program 7 '11
- c effectiveness', however,.is.the ability to-identify weaknesses
- a. c
, n , .12 -and.: correct..them;-and another is the' prompt implementation.of g
t13 ~
-corrective actions necessary'to preclude. recurrence of identi-
~
'14 ;fied deficiencies. The~ corrective-steps taken.in the resolu-
- 15 tion"of these problemssrepresent a: systematic and prudent ap-316 proach to assure:a safe'and' quality product. As demonstrated 17 .'by.lthe. audit resultstI? discussed above,.the' improvements'inithe
-18 hanger program,. vendor surveillance activities, receipt in-19 .spection and installation inspections, along with increased 20 field surveillances have resulted in a program which assures
> ,' .21
. , that desired'results are and have been achieved.
- - ; i 22 p-
-23 25
, 1 i26 1
s m
se ATTACHMENT 1
.. . JAMES F. NEVILL Principal FIaineer - Civil Date of Birth: January 12, 1947 I. EDUCATION .
>A.
B.S. Degree in Civil Engineering from West Virginia Institute of Technology, 1971 II. EXPERIENCE A.. June 1967 to September 1973 1. Newport News Shipbuilding & Dry Dock Company a. June 1967 to January 1968 - Junior Engineer - Drafting experience with compartment and access plans. Returned to school. b. May 1968 to August 1968 - Junior Designer - Draf ting experience in struutural and welding detail. Returned to school. c. January 1969 to August 1969 - Junior Designer - Drafting experience associated with structural design. Returned to school. d. May 1970 to August 1970 - Designer - Aiding engineers in design. Returned to school. . e. January 1972 to September 1973 - Engineer - Supervision of construction for fabrication of two nuclear submarines. B. September 10, 1973 to Present
- 1. . Carolina Power & Light Company
- a. September 10, 1973 - Employed as a Junior Engineer in the Nuclear Construction Section of the Power Plant Construction Department.
I Located at the Harris Site, New Hill, NC. b. . June 8,1974 - Promoted to Civil Engineer, Nuclear Construction Section, Power Plant Construction Departnent. Located at the Harrfs Site, New Hill, NC. I c. September 27, 1975 - Reclassified as Engineer II, Nuclear Construction Section, Power Plant Construction Department. Located at the Harris Site, New Hill, NC. i d. l August 14, 1976 - Promoted to Engineer III in the Nuclear , Construction Section of the Power Plant Construction Departnent. i Located at the Harris Site, New Hill, NC. I i I
l l P . l 1
. James P. Nevill t a.
November 5,1977 - Promoted to Senior Engineer in the Nuclear Construction Department. Section of the Power Plant Const Located at the Harris Site, New Hill, NC.
- f. June 16, 1979 -
Promoted to Project Engineer'- Civil in the Harris Site Management Section of the P3wer Plant Construction Department. New Hill, NC. Located at the Harris Site, l
- g. June 28, 1980 -
Promoted to Principal Engineer - Civil in the Harris Site Management Section of the Power Plant Construction Department. Located at NC. the Harris Site, New Hill, h. ' July 5,1980 - Transferred to Nuclear Power Plant Engineering Department, Engineer-Civil. Harris Plant Engineering Section, as Principal Located at the Harris Site, New Hill, NC. III. PROFESSIONAL SOCIETIES A". Engineer-In-Training with State Board of Registration for Professional Engineers of liest Virginia. B. Professional Engineer Registered in North Carolina, February 9,1979. J
. . _ _ . _ . . _ . . . _ _ . . - _ y m_ ____ , - , ._ . . . __m_,._,... _ -
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Attachmant 2 Alexandar G. Fu11Gr - Principal Engineer - Mechanical . . a. I. Date of Birth - October 14, 1951 II. Education A.-'BS Degree in Civil Engineering from N. C. State University, 1973. ~ III. Experience A. Summer, 1970-
- 1. Carolina Builders
- a. Salesman.
B. Summers, 1971 and 1972
- 1. N. C. State Highway Commission
- a. Engineering Assistant.
CI May 29, 1973, to Present
- 1. Carolina Power & Light Company
- a. May 29, 1973 - Employed as Junior Engineer in the Construction Section of the Power Plant Engineering & Construction Depart-ment. Located at the Harris site, New Hill, N. C.
- b. September 1, 1973 - Transferred from Power Plant Engineering &
Construction Department to Power Plant Construction Department, Nuclear Construction Section. Located at the Harris site, New Hill, N. C.
- c. August 17, 1974 - Transferred from the Nuclear Construction Section to the Fossil Construction Section. Assigned to Cape Fear Plant working out of Ceneral Office,
- d. January 18, 1975 - Promoted to Civil Engineer in the Fossil Construction Section of the Power Plant Construction Depart-ment. Assigned to Cape Fear Plant working out of General Office,
- e. September 27, 1975 - Transferred from Fossil Construction Section to Nuclear Construction Section. Located at the Harris site, New Hill, N. C.
- f. September 27, 1975 - Reclassified as Engineer II in the Nuclear Construction Section of the Power Plant Construction Department. Located at the Harris site, New Hill, N. C.
^ *
, r .
;' f } >,
LAldxcndar.G.-Fuller - 2'-
- A= . .
g.
. - c August-16,.1976 - Transferred from'Harri. site to, Cape Fear
' Plant as Engineer in the Nuclear Construction Section of
- the Power Plant Construction Department. Assigned to supervise contractor. accomplishment of 'drainge modifica-
- tionssat'ths Cape-Fear Plant.
- h. April 2, 1977 - Transferred from Cape Fear' Plant to Harris
'N.- site as Engineer in the Nuclear Construction Section of .the Power. Plant Construction Department. Resumed duties as civil engineer in the Resident Engineer subunit.
~ 1. March 25,.1978 - Promoted to Senior Engineer in the Nuclear l/
.ment.
Construction Section of the Power. Plant Construction Depart-Located at the Harris site, New Hill, N. C.
- j. July 1,1978 - Transferred to the Miscellaneous Projects Unit in the Nuclear Construction Section'of the Power Plant Con-struction Department. Assigned to supervise contractor accomplishment of the main dam. Located at the Harris site, New H
- k. November 15, 1980 - Promoted.co Project Engineer - Civil in
~*
the Miscellaneous Projects Unit, Nuclear Construction Section,- Power Plant Construction Department. Located at the Harris site, New Hill, N. C. <3h 1. January 31, 1981 - [l~ Transferred to the Pkchanical Engineering Subun: in the Harris Site Management Section of the' Nuclear Plant
-Construction Department. Located at the Harris site,.
New Hill, N. C. m. June 27, 1981 - Reclassified as Project Engineer-Hechanical ?
- in the Herris Site Management Section-of the Nuclear Plant Construction Department. Located at the Harris site, New Hill,
~
N. C.
- n. - October 30, 1982 - Promoted to Principal Engineer-Mechanical in the Harris Site Management Section of the Nuclear Plant Construction Department.
N.'C. Located at the Harris site, New Hill, o.. September 3,~1983 - Reorganization - Group, Department, and Section
~
renamed Department. to Nuclear Generation Group. Harris Nuclear Project Harris PlantHarris PlantN.Construction New Hill, C. Section. Located at the
, IV.'-
~ Professional Societies:
A. Professional Engineer Registered in North Carolina - July 7,1978
~Rev. 8/2/84
r Attachmsnt 3 D;vid R. Timb2ricko .
, Senior Engineer
_=.- I. Date of Birth - June 26, 1950 II. Education A. BS Degree in Engineering Operations fran N. C. State University, 1972 , III. Experience A. June, 1972 to September, 1974
- 1. Newport News Shipbuilding A. Welding Engineer B. February, 1975 to November, 1977
- 1. National Welders, Charlotte, N. C.
- a. District Manager - managed retail welding supply distributorship C. December, 1977 to May, 1978
- 1. Victor Equipment Company, Denton, Texas
- a. Contractor Specialist D. May, 1978 to March, 1979
- 1. Brown & Root, Glen Rose, Texas
- a. Pipe Welder E. April, 1979 to February, 1980
- 1. Brown & Root, Roxboro, N. C.
- a. Welding Engineer F. March 3, 1980, to Present
- 1. Carolina Power & Light Company
- a. March 3, 1980 - Employed as a construction Specialist in the Brunswick Site Management Section of the Power Plant Construction Department. Located at the Brunswick site, Southport, N. C.
n l i- ,
- b. August 1, 1980 - Transferred to the Harris l ' Site Management Section of the Power Plant Construction Department. Located at the Barris Site,.New Hill, N. C. '
- c. November 15, 1980 - Reclassified to Engineer in the Harris Site Management Section of the Power Plant Construction Department.
Located at the Harris site, New Hill, N. C.
- d. January 31, 1981 -- Reorganization - Depart-ment renamed to Nuclear Plant Construction.
- e. March 5, 1983 - Promoted to Senior Engineer in the Harris Site Management Section of the Nuclear Plant Construction Department.
Located at the Harris Site, New Hill, N. C.
- f. September 3, 1983 - Reorganization - Depart-ment renamed to Harris Nuclear Project -
Section renamed to Harris Plant Conrtruction. IV. Professional Societies A. American Welding Society V. Certification A. Certified Welding Inspector (AWS) - Certificate #82055171 ~
~ ~ ~ ^ -~ ~ ^
c.
's-Kumar V. Rato' Principcl QA Engineer -
3 I. Date of Birth 1 January 30, 1947. II. Education and Training A.. BS Degree in Metallurgical Engineering, Indian Institute of Technology, Bombay, India, 1970 B. MS Degree in Materials Engineering, Mississippi State University, State College, Mississippi, 1972 i C. MS Degree in Management, NC State University, Raleigh, North Carolina, 1984 i D. Completed course in " Quality Assurance", Ohio State University, Columbus, Ohio, 1974 III. Experience. A AMBAC Industries, Columbus, Mississippi
- 1. October 1971 - September 1972
- a. Engineering Laboratory Technician
- 2. September 1972 - July 1974
- a. Materials Engineer B. Carolina Power & Light Company
- 1. July ~1974 employed as a QA Engineer in the QA Section of the Power Plant Engineering Department. Located in the General Office, Raleigh, North Carolina.
- s. September 1975 reclassified as a QA Engineer II'in the QA Section of the Power Plant Engineering Department.
Located in the General Office, Raleigh, North Carolina.
- b. June 1976 promoted as a QA Engineer III in the QA Section of the Power Plant Engineering Department. Located in the General Office, Raleigh, North Carolina.
- c. November-1976 transferred and reclassified as a QA Engineer in the Engineering & Construction QA Section of the Technical Services Department. Located in the General Office, Raleigh, North Carolina.
- d. July 1977 promoted as a Senior QA Engineer in the Engineering & Construction QA Section of the Technical Services Department. Located in the General Office, Raleigh, North Carolina.
e y - v,.--w ,.vge--, - , , --.,,-,,..,r-p,-n-n n,-,. m e. w --s,- , m p-w w,-.,-py ,w pp,,me,-m.. -,w,-,,aanvv ynm.,,,q,-,am~,e--
' ~
- o. Juna 1979 promotad as a Projcet QA Enginsse in tha
'1 Engineering & Construction QA Section of the Technical
- , _ ' ' Services Department. Located in the Cencral Office, Raleigh, North Carolina.
- f. March 1981 transferred as a Project QA Engineer in the Engineering & Construction QA/QC Section of the Corporate Quality Assurance Department. Located in the General Office, Raleigh,-North Carolina.
- g. February 1982 promoted a6d transferred as a Principal QA/QC Engineer in the Engineering & Construction QA/QC Section of the Corporate Quality Assurance Department.
l.ocated at the llarrin nite, New lilli, North Carollnn.
-h. February 1983 - SECTION TITLE CilANCE - Principai QA/QC
. Engineer in the QA Engineering Unit of the QA/QC Harris Plant Section of the Corporate Quality Assurance Department.
Located at the Harris site New Hill, North Carolina.
- i. March 1983 reclassified-as a Principal QA Engineer in the QA Engineering Unit of the QA/QC Harris Plant Section of the Corporate Quality Assurance Department.
,. Located-at the Harris site, New Hill, North Carolina.
IV. Professional Societies A. Licensed Professional Engineer, Commonwealth of Virginia, April 1975 b
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