ML20094H503
| ML20094H503 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/09/1984 |
| From: | Fuller A, Hate K, Nevill J, Timberlake D CAROLINA POWER & LIGHT CO. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20094H487 | List: |
| References | |
| OL, NUDOCS 8408140023 | |
| Download: ML20094H503 (35) | |
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RELfico CXE370iiDENC5 00CKETED USNRC August 9, 1984
'84 /.S013 A10:14 UNITED STATES OF AMERICA y ,7 7, . _
NUCLEAR REGULATORY COMMISSION ,jy,,i(TT,9 cc.<; 3 y'ygj.j_ f '
- "Ricr1 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 )
)
(Shearon Harris Nuclear Power )
Plant) )
APPLICANTS' TESTIMONY OF JAMES F. NEVILL, ALEXANDER G. FULLER, DAVID R. TIMBERLAKE AND KUMAR V. HATE, IN RESPONSE TO EDDLEMAN CONTENTION 41 (PIPE HANGER WELDING)
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Q.1 Please state your names.
2 A.1 James F. Nevill, Alexander G. Fuller, David R. Tim-3 berlake and Kumar V. Hate'.
4 Mr. Nevill, by whom are you employed, and what is Q.2 5 your position?
6 A.2 (JFN): I am Principal Engineer-Civil, Harris Plant 7 Engineering Section, Harris Nuclear Project Department, 8 Carolina Power & Light Company.
9 Please summarize your professional qualifications and Q.3 10 describe your involvement with pipe hangers at the Shearon 11 Harris Nuclear Power Plant.
12 A.3 (JFN): 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-16 ous engineering assignments at the Shearon Harric site since 17 September, 1973. A complete statement of my professional qual-18 ifications is appended as Attachment 1 to this testimony.
19 Since March, 1982, I have been responsible for two Civil 20 sub-units of the Harris Plant Engineering Section which perform 21 the following functions with respect to pipe hangers: resolu-22 tion of identified field problems, design of new pipe supports 23 due to pipe / system changes, and stress analysis evaluations an-24 sociated with field changes.
l 25 Q.4 Mr. Fuller, by whom are you employed and what is your )
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1 A.4 I am Principal Engineer-Mechanical (Hanger (AGF):
2 Engineering), Harris Plant Construction Section of the Harris 3 Nuclear Project Department, Carolina Power & Light Company.
4 Please summarize your professional qualifications and Q.5 5 describe your involvement with pipe hangers at SHNPP.
6 I received a Bachelor of Science degree in A.5 (AGF):
7 Civil Engineering in 1973 from North Carolina State University, 8 and I am a registered Professional Engineer in the State of 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. A complete statement of my professional qualifications 13 is appended as Attachment 2 to this testimony. From January, 14 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 procedures for hanger installation and the resolution of 18 nonconformances involving hanger installations. Since October, 19 1983, when the Hanger Engineering group was reorganized, I have 20 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 24 the Harris Plant Construction Section of the Harris Nuclear 25 Project Department, Carolina Power & Light Company.
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- i 1 Please summarize your professional qualifications and Q.7 l 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 5 1972. From 1972 to 1980, I worked for various firms as a 6 welding engineer, as a pipe welder, and in welding supply. I 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 sponsible 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.
l 22 Q.8 Mr. Hate', by whom are you employed and what is your 23 position?
l 24 A.8 (KVH): I am employed by Carolina Power & Light Com-25 pany's Corporate Quality Assurance Department at the Shearon 26 Harris Nuclear Power Plant as Principal QA Engineer in the QA/QC Harris Plant Section.
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Q.9 Please summarize your professional qualifications and 2 describe your involvement with pipe hangers at SHNPP.
3 A.9 I received a Bachelor of Science degree in (KVH):
1 4 Metallurgical Engineering in 1970 from the Indian Institute of 5 . Technology in Bombay, a Master of Science degree in Materials.
6 Engineering in 1972 from Mississippi State University, and a 7 Master of Science degree in Management in 1984 from North 8 Carolina State University. I am a registered Professional En-9 gineer, and have been employed by CP&L in various QA assign-10 ments since July, 1974. A complete statement of my profession-11 al qualifications is appended as Attachment 4 to this 12 testimony. The responsibilities of the QA/QC Harris Plant Sec-13 tion with respect to pipe hangers include performance of the 14 following functions to assure that the hanger program is ade-15 quate and complies with regulatory requirements: I review of i
16 construction specifications, procedures and documentation; weld 17 inspections; QA surveillances; and nonconformance identifica-18 tion / resolution. - -
19 Q.10 What is the purpose of this testimony?
20 A.10 (AGF): The purpose of this testimony is to respond 21 to Eddleman Contention 41, which states:
22 Applicants' QA/QC program fails to assure that safety-related equipment is properly 23 inspected (e.g. the "OK" tagging of defec-tive pipe hanger welds at SHNPP).
In its Memorandum and Order of September 22, 1982, the Atomic 25 1 Safety and Licensing Board clarified the scope of this
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contention by holding that it does not cover the entire Quality 2 Assurance (QA)/ Quality Control (QC) program, but rather is lim-3 ited to the assertion "that there exist defective hanger welds 4 that have been improperly inspected and approved."
5 Q.11 How is your testimony organized?
6 A.ll First we provide background information on (AGF):
7 pipe hangers, including an overview of the processes for design 8 and fabrication, installation and inspections. Second, we de-9 scribe the relevant deficiencies discovered in 1980 and in 10 1982, and the resultant reinspection programp and other correc-11 tive actions undertaken. Third, we assess the safety signifi-12 cance of these occurrences. Fourth, we describe the enhance-13 ments to the hanger program, implemented in December 1983, and 14 demonstrate the effectiveness of that program in ensuring that 15 the quality of the final hanger product is established. Fi-16 nally, we assess the implications of the hanger program experi-17 ence for the quality assurance program.
18 Q.12 Mr. Nevill, what is a pipe hanger?
19 A.12 (JEN): A pipe hanger is a component or structural 20 assembly designed and installed to support or restrain a sec-21 tion of pipe subjected to a combination of loads, and which 22 protects the pipe from stresses that could impair the pipe's 23 ability to perform its function. For purposes of the QA pro-24 gram and this testimony, safety-related pipe hangers may be l
- 25 equated with the term seismic pipe hangers.
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Q.13 Please summarize the design process for the seismic 2 pipe hangers.
3 A.13 (JFN): The design of seismic pipe supports starts 4 with the piping designer and pipe stress analysts. For SHNPP, 5 the architect / engineer, Ebasco, is the organization responsible 6 for piping design and analysis. The piping group develops pipe 7 lay-outs to satisfy system function requirements and provides 8 design parameters for stress analyses. The piping arrangement 9 is then stress analyzed for operating loads, thermal loads, 10 seismic loads and other appropriate loadings to determine loca-11 tion, function, and magnitude of support loads. This data is 12 utilized by the support designer to develop pipe support de-13 signs.
14 The supports are designed to counteract the combined loads 15 and to prevent the pipe from being overstressed. For SENPP, 16 Bergen-Paterson was the primary design and fabrication organi-17 zation for the pipe supports.
18 Q.14 Are inspections performed at the vendor's facility?
19 A.14 (KVH): Yes. Welds received both in-process and 20 final inspection by Bergen-Paterson inspectors, and hangers 21 were presented to Ebasco inspectors for final approval prior to 22 shipment. Inspections were conducted visually by trained in-23 spectors using the Bergen-Paterson design drawing to identify 24 size and type of weld and hanger geometry. Prior to the iden-25 tification in 1982 of deficiencies in vendor-supplied welds, j 26 inspection was done on a sampling basis.
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1 Q.15 How are the pipe hangers insta led?
2 A.15~ (AGF): Early in the hanger erection effort, CP&L 3 studied the hanger erection problems being reported in the in-4 'dustry and visited several other sites to gain a better under-g-
5 standing of current hanger erection and inspection problems.
-6 .It was_ concluded that many of.the problems being encountered at 7 other sites during the completion phase'could be avoided if in-8 spection started as' early as possible. A complete hanger in-9 spection cannot be accomplished, however, until both the pipe 10 and hanger are installed in final location. This sometimes 11 does not occur until late in the overall construction schedule.
12 Site management nevertheless concluded that delaying any hanger 13 inspection until the final phase of construction would deny the 14 project an early indication of problems. It was also concluded 15 that-the absence of any early preliminary inspection contrib-16 uted to the problems being reported at other sites.
17 Based on these considerations, the initial hanger erection 18 program was set up to include an initial (Phase I) inspection 19 and a final (Phase II) inspection. Phase I inspections were 20 set up to include an intermediate check of location and an in-21 spection of any field welding performed up to the point of in-22 spection. Phase II inspections were to verify the total hanger 23 installation after both pipe and' hanger had been adjusted to 24 final location and work was completed. In fact, to a great ex-25 tent the deficiencies being discussed here were found as a re-26 sult of the early start on inspection activities during Phase I I l
1 inspections. Consequently, the early inspections accomplished 2 the goal of providing site management with early warning of 3 potential hanger problems.
4 The following groups are involved in the installation of 5 seismic hangers:
6 - Document Control issues and controls design docu-7 ments.
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Harris Plant Engineering Section generates and ap-9 proves design changes required.
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Hanger Engineering (Harris Plant Construction Sec-11 tion) provides technical support to the craft.
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Welding Engineering (Harris Plant Construction Sec-13 tion) provides technical support to the craft and 14 hanger engineering.
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Construction Inspection (CI) inspects hangers for de-16 sign compliance, including geometry, location, and 17 bill of materials.
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QC performs receipt inspections and inspects hanger 19 welds.
20 Installation involves the following basic phases: (1) re-21 ceipt and processing of design documents; (2) receipt and in-22 spection of material; (3) issuance of hanger design documents 23 and material for construction, (4) installation and inspection 24 of the hanger; and, (5) final documentation review.
25 Q.16 What is involved in the receipt and processing of 26 design documents?
1 A.16 (AGF): Hanger design drawings are received by Docu-2 ment Control and are issued to Hanger Engineering for inclusion 3 in the hanger work package.
4 Mr. Hate, what presently occurs during the receipt Q.17 5 and inspection of material?
6 A.17 The hanger material for a particular design (KVH):
7 is received 'and inspected by QC for compliance to the purchase 8 order (i.e., identification, dimensions, damage and shop 9
welds).
10 Q.18 What presently takes place in connection with the 11 issuance of the hanger work package and material for construc-12 tion?
13 A.18 (AGF): First, the hanger design is surveyed in the 14 field to minimize installation conflicts prior to material 15 issue.
16 Second, an initial review group of Hanger Engineering per-17 sonnel reviews the hanger drawing and develops a work package 18 consisting of:
19 (1) A Seismic Weld Data Report (SWDR) for weld joint in-20 spection records.
21 (2) A traveler for tracking t'w eM- 3 of installation 22 and inspection.
23 (3) Work directives for detailing special instructions if 24 required.
25 (4) The hanger design drawing.
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-(5) Field modifications as required.
'2 (6) A Material Verification Sheet..
3 Third, the hanger package is then "weldmapped" by num-4 bering the welded joint (s) on the hanger. The field joint num-5
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bers are listed on the SWDR for' tracking weld. acceptance. This 6 procedure was instituted in-December 1983, per Work Procedure 7 139. Prior to implementation of WP-139, field welds were 8 tracked by.various methods.
9 Fourth,'the package is reviewed by Welding Engineering to 10 determine the particular welding procedure specification neces-11 sary in accordance with project site requirements, mandatory 12 holdpoints for fitup and preheat prior to welding, and to iden-13 tify unclear, missing, or erroneous welding instructions on the 14 drawing. Any additional instructions are placed on the SWDR.
15 Fifth, QC Welding then reviews the new SWDR for com-16 pleteness and accuracy. Documentation for previous welding is 17 also reviewed and, if accepted, is transcribed forward to the 18 new SWDR. Welds not yet accepted on the SWDR will be 19 reinspected along with any additional new welding.
20 Sixth, the package is routed to the material handling 21 group and the material'is sent from the controlled storage 22 warehouse to a lay down area.
l 23 Finally, the package is routed to a construction crew l 24 foreman who requisitions the material from the lay _down area 25 for installation.
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1 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 process: !
5 (1) The hanger members are fit-up, tack welded in place, 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.
14 (4) Final shimming and adjustments are made to the hang-15 er.
16 (5) Welding Engineering personnel examine hanger welds.
17 (6) 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.
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1 Q.20 What is the final documentation review?
2 .A.20 (AGF): Final documentation review includes verifi-3 cation of the following: documentation has been properly com-4 pleted and signed-off; pertinent documentation has been includ-5 ed in the hanger package; and modifications have been correctly 6 incorporated into the final drawing.
7 Q.21 Mr. Hate', please describe in more detail the in-8 spection process applicable to pipe hangers, including Vendor 9 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 12 surveillance pertaining to shop fabrication of hangers supplied 13 by Bergen-Paterson. Ebasco Vendor QA performs surveillances, 14 inspections, and audits of the vendor'.s facility and work ac-15 tivities. The actions include review of such documents as ma-16 terial test reports, inspection records and non-destructive 17 test reports and coating records, and performance of shop in-18 spections on work accomplished. Inspections now include, but 19 are not limited to, inspection of welds on non-standard parts 20 prior to painting. Nonconformances identified during the shop 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 24 Bergen-Paterson management to prevent reccurrence.
25 After completion of final inspection in the vendor's shop, 26 Ebasco issues a Quality Release (QR) indicating the hanger is 1
acceptable and is ready for shipment to the field. Originally 2 when hangers were received at the site they were accepted based 3
on this QR. The hangers were also checked for identification, 4 documentation, damage, and obvious welding discrepancies prior 5 to release for installation. The quality attributes to be 6 checked during receipt inspection were increased once QC in-7 spections started noting discrepancies with previously accepted 8 shop welds. Statistical sampling of vendor welds was initiated 9 in May 1982. Due to the high reject rate experienced from this 10 statistical sampling, 100 percent receipt inspection of vendor 11 welds was initiated during June 1982. This high reject rate 12 was due in part to the fact that vendor QA and site QC in-13 spectors were using somewhat different weld acceptance 14 criteria. The majority of welds rejected on site were for 15 minor weld defects. Increased vendor QA inspection and stan-16 dardization of weld acceptance criteria have resolved this 17 problem. The inspection of shop weld quality attributes has 18 been retrofit to include hangers received on site prior to 19 June, 1982.
20 Inspection of pipe hangers in the field is performed by 21 Construction Inspection (CI) and QC. The CI inspections 22 address hanger attributes other than welding.
23 Inspection of welding performed on site is done by the QC 24 Welding group. These inspections are performed to assure:
25 compliance with the hanger drawings with respect to weld type, 26 size and length; acceptability of materials; and weld quality.
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These inspections are performed by inspectors who are qualified 2
and certified in accordance with procedure'CQA-1, and are per-3 formed in accordance with procedure CQC-19 (procedure on weld 4 control) and NDEP605 (visual weld inspection procedure), and 5
documented on a SWDR. Acceptance and rejection of the welds 6 are noted on the SWDRs. Rejected welds must be dispositioned 7 (reworked or waivered) and accepted by a QC inspector prior to 8 final acceptance of the hanger. The SWDR is included in the 9 hanger package and becomes a QA record. SWDRs are reviewed by 10 the QC welding specialist for completeness and accuracy. The 11 QC welding specialist periodically trends the weld reject rate 12 to determine if an adverse trend is developing and whether man-13 agement attention is required. Since the implementation in 14 December 1983 of the enhanced hanger program, no adverse trends 15 have been identified; rather, as discussed later, positive re-16 sults have been noted.
17 Q.22 Were there early indications of pipe hanger problems 18 at SHNPP?
19 A.22 (AGF): Yes. On September 3, 1980, the resident NRC 20 inspector identified several hangers with unclear and incorrect 21 weld symbols on Bergen-Paterson Seismic Class I pipe hanger 22 drawings. Additionally, the NRC inspector identified cases in 23 which the field applied weld was different from the drawing 24 requirements and had not been identified by QC. This discovery 25 was cited as an infraction in an inspection report dated 26 November 3, 1980. Consequently, a site investigation by CP&L
1 -into selected hanger drawings and: installed hangers was con-2 ducted. The results~ indicated that several weaknesses existed 3 in-the-program for installing and~ inspecting. seismic hangers,
-4 in-that'a substantial number of seismic. hanger drawings 5 contained erroneous, missing, or unclear welding instructions, 6 and many installed hangers were not-welded to meet the design 7 requirements or quality acceptance criteria. Due to the-exten-8 sive scope of the problems identified, it was deemed necessary 9 to reinspect seismic hangers on-which field welding.had been 10 performed. A final report on the deficiencies and subsequent 11 reinspection program was submitted to the Staff on May 1, 1981 12 (and revised on June 11, 1981); and the NRC closed out this 13 item on September 14, 1981.
14 Q.23 What did the reinspection program consist of which 15 was initiated as a result of discovering these problems?
16 A.23 (AGF): Approximately 1800 hanger design drawings 17 which had been issued to the field were reviewed for missing, 18 unclear, and erroneous weld symbols. These hanger drawings 19 were issued to QC for reinspection. Of the 1800, approximately i H20 1200 hangers were found to have some completed welds and these l 21 were reinspected by the QC inspectors. None of the hangers had 22 yet been completed and finally accepted by QC. (The hangers 23 had been basically assembled and some welding completed, but 24 final adjustments and/or welding work remained to be done.)
25 Discrepant welds were either reworked by craft personnel or ac-26 cepted by the design organization on the basis of an
, appropriate engineering analysis.
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g .;24 What corrective actions were undertaken'with respect 2 to: review of hanger drawings?
3 A.-24 (AGF, DRT): Hanger Engineering and Welding Engi-4 neering began reviewing pipe hanger design drawings for.miss-5 J ing, unclear,~and incorrect weld symbols prior to issuance to 6 the field. Welding Engineering personnel performed the primary 7 review for weld symbol problems. Drawings with' problems were
_8 reported to Ebasco/Bergen-Paterson for correction via pipe 9 hanger problem memos written by Hanger Engineering. Revised' 10 design drawings were received and reviewed to ensure that welds 11 were properly dispositioned.
12 .Ebasco discussed the design drawing problems with 13 Bergen-Paterson, which identified.the problem to its design 14 personnel. Bergen-Paterson agreed to revise their review pro-15 cedures to insure'that design drawings show proper weld sym-16 bols. Drawings being issued from Bergen-Paterson's three de-17 sign offices were routed through a single office to provide 18 more consistent reivew by Bergen-Paterson engineering person-19 nel.
l 20 Q.25 Were any corrective actions undertaken in connection 21 with the welders?
22 A.25 (DRT): Yes. Weld symbol identification training 23 classes were conducted by welding and hanger engineers. The 24 classes consisted of training on AWS standard weld symbol no-25 menclature in accordance with AWS A2.4-79 as related to 26 Bergen-Paterson pipe hangers. Craft personnel attending these l
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1 training classes included superintendents, general foremen, 2 foremen and. welders of pipe and pipe hangers. In addition to 3 instructions on weld symbol identification, emphasis was given 4 to the importance of welding the pipe hanger exactly as the de-5 sign drawing requires. In those instances where this is nct 6 possible, due to physical limitations or drawing errors, craft 7 personnel were directed to return the hanger drawing to Hanger 8 Engineering.
9 Q.26 Were any other corrective actions initiated?
10 A.26~ (KVH): Yes. QC personnel attended the weld symbol 11 . identification classes Mr. Timberlake just discussed, and'addi-12 tional classes given within their organization. These classes 13 emphasized the necessity for inspections to be conducted 14 strictly in accordance with drawing details and also instructed 15 QC personnel to report incorrect design drawings to Hanger En-16 gineering.
17 Q.27 Was there a subsequent reinspection?
18 A.27 (AGF): Yes, in 1982. Surveillances performed by 19 Hanger Engineering identified hangers with documentation errors 20 and weld defects. The Receipt Inspection Program, revised to 21 encompass examination of vendor welds, discovered deficient 22 shop welds made by Bergen-Paterson. Finally, it was determined 23 that inspectors and craftsmen were using an improper technique l l
24 in the measurement of skewed tee welds.
25 The widespread scope of these deficiencies made it neces-26 sary to reinspect seismic pipe hangers welded or partially
I welded out prior to June 26, 1982. The reinspection program 2 addressed both shop and field welds, and the results for each 3 hanger were documented on that hanger's individual SWDR and 4 dispositioned on that document.
5 What did the 1982 reinspection reveal?
Q.28 6 A.28 The reinspection found: (1) missing and un-(AGF):
7 dersized shop and field welds; (2) minor shop and field weld 8 defects; and (3) inaccurate and incomplete QC weld documenta-9 tion.
10 Why did these deficiencies occur in view of the cor-Q.29 11 rective actions initiated after the discovery of deficiencies 12 in 1980?
13 A.29 (AGF, DRT, KVH): Undersized skewed tee welds were 14 not discovered until the first quarter of 1982, and therefore 15 were not the subject of the efforts in 1980. Further, there 16 had been no training of craft personnel, and improper training 17 of inspectors, on the technique for measuring the fillet weld 18 size on skewed tee joints.
19 Similarly, vendor-supplied welds were not part of the 1980 20 reinspection. While isolated cases of minor weld defects had 21 been identified previously and documented on deficiency and 22 disposition reports which were forwarded to Ebasco for 23 strengthening of the vendor QA programs, the isolated nature of 24 the defects indicated that the vendor QA program had been per-25 forming satisfactorily.
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-1 Neither did the 1980 reinspection address the documenta-2 tion problems identified in 1982 caused by minimal review of 3 weld records or the absence of a procedure for standardizing 4 the requirements for completing documentation records. Fi-
'S nally, the 1980 reinspection relied on the qualifications of QC 6 inspectors and their acceptance of welds as the final word, 7 without routine checks or surveillances on their work.
8 Q.30 What corrective actions and/or preventive measures 9 were undertaken as a result of the 1982 reinspection effort?
10 A.30 (AGF, DRT, KVH): Shop and field, welds on installed 11 hangers were reinspected and deficiencies were either reworked
- 12 by the craft or evaluated and accepted by the design organiza-13 tion, except for the few hangers currently on design hold.
14 Deficiencies were recorded on the SWDR and acceptance eventual-15 ly recorded on that document by the QC inspection organization.
16 In addition, vendor welds were examined prior to releasing ma-i 17 terial to the field for installation. Deficiencies noted were 18 also either reworked or accepted by engineering evaluation.
19 This program is still in progress.
20 In addition, the following measures were implemented:
21 (1) Weld acceptance criteria were revised to provide con-22 sistent inspection criteria to be used by site and vendor QA 23 inspectors.
24 (2) Ebasco assigned four vendor QA representatives to the l 25 Bergen-Paterson facility and began performing both in process 26 and 100 percent final visual weld inspections. These l'
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inspections consist of a visual inspection of shop welds prior 2 to coating of the hangers. After the hangers are coated, they 3 undergo a dimensional and coating inspection. (Prior to the 4 corrective action, Ebasco had one vendor QA representative as-5 signed to the Bergen-Paterson facility who performed random di-6 mensional, coating and welding inspections when the hangers 7 were ready for shipment.)
8 (3) An inspection / documentation procedure specifically 9 for pipe hanger welding was developed.
10 (4) Routine audits of each QC inspector's field work were 11 implemented by QC supervisors.
12 (5) Weld documentation was reviewed to insure it was cor-13 rect and complete.
14 (6) Additional training on weld acceptance criteria 15 (including skewed tee welds) was initiated.
16 Q.31 Mr. Nevill, the witnesses have been describing vari-17 ous deficiencies discovered in connection with the welding of 18 seismic pipe hangers. Are there design considerations which 19 might provide some perspective on the significance of the 20 deficiencies?
21 A.31 (JEN): Yes. There are various input criteria used 22 in support design that induce conservatism in support func-23 tions. I will briefly describe these conservative aspects, 24 which are considered inherent to the design process but are not 25 routinely utilized in engineering evaluations of a defective 26 condition.
1 (1) Material Properties. Actual mil test reported values 2 of material stresses are typically higher than the specified 3 nominal stress properties used in design.
4 (2) Design Allowables. Design codes and regulatory agen-5 cies dictate allowable stresses and loading combinations. Mar-6 gin exists between the stress limits used in design when 7 comparing allowable, yield, and ultimate stresses. Design 8 loading aspects are combined in a manner to assure the gov-9 erning design input provides worst-case analysis.
10 (3) Minimum Weld Size. The design codes require the ap-11 plication of minimum weld sizes. Compared to actual loading 12 conditions, minimum weld size may be larger than the size re-13 quired to resist the design stresses.
14 (4) Response Spectra Curves. The engineering application 15 of response spectra curves provides margin due to the need to 16 address complexities in the time history seismic modeling tech-17 nique. Curves are broadened, enveloped, and amplified for 18 qualification and design of plant systems and structures, which 19 increase the range of frequencies using peak values as well as 20 increasing accelerations throughout the entire frequency range.
21 This results in analyses using conservatively higher seismic 22 inputs than will actually occur.
23 (5) Support stiffness. Structural designs are based on 24 stress levels and deflection criteria. Since the pipe analysis 25 dictates deflection limitations, the support design deflection 26 criteria rather than stress levels typically govern the member I
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l 1 size and support configuration. Weld sizing is developed from 2 the stress levels, and therefore margin is induced.
3 Where weld problems are accepted by engineering evalua-4 tion, various applications of design techniques are available 5 to determine functional acceptance. Examples are: comparison 6 of actual weld stresses to allowables; additional pipe analysis 7 to reduce the loading on a particular hanger; or computer mod-8 eling in place of hand calculations.
9 Q.32 What is the significance, then, of the typical pipe 10 hanger welding deficiencies in light of these design conserva- ,
11 tisms?
12 A.32 (JEN): The types of weld defects reported primarily 13 involved relatively minor instances of undersize, undercut, 14 lack of fusion and porosity. Consideration of conservative as-15 pects of the design criteria indicates the significance of the 16 typical deficiency to be minor and to have no adverse impact on 17 structural integrity.
18 Q.33 For the 1980 and 1982 reinspections, did you fre-19 quently rely on engineering evaluations to disposition pipe 20 hanger welding nonconformances?
21 A.33 (AGF): No. The majority of the deficiencies iden-22 tified in these reinspections were not evaluated to determine 23 if they were acceptable as is, but were repaired due to the 24 economics associated with the engineering evaluation.
25 Q.34 Have further changes been made to the pipe hanger 26 program since 1982?
1 An enhanced hanger installa-A.34 (AGF, DRT, KVH): Yes.
2 tion / inspection program was put into place in December 1983 in 3 order to provide more positive control of construction, in-4 spection and documentation activities. The enhanced program 5 was initiated by QA and Construction management to achieve 6 these goals. The key elements of the enhanced program are as 7 gallows:
8 (1) A work package group has been created to review hang-9 er work packages prior to issuance to the field. During the 10 review the hanger sketch is weld mapped for inspection documen-11 tation and the drawing is checked for constructability.' Weld 12 mapping has provided a high level of confidence that welds are 13 inspected and accepted. (This is being retrofitted to previ-14 ously installed hangers as well as applied to the installation 15 of new hangers.) This review also insures that necessary docu-16 mentation and instructions for installation and inspection are 17 present in the package prior to issuance to the field. Hangers 18 are also surveyed in the field to insure that the hanger can be 19 installed with minimal interferences with existing structures.
20 (2) The seismic hanger work procedure has been revised 21 and its requirements simplified. Generic engineering documents 22 are no longer used as solutions to common problems. Instead, 23 field modifications are written for each hanger detailing nec-24 essary changes due to these problems. This has greatly reduced 25 the potential for misinterpretation and subsequent misapplica-26 tion of construction requirements.
1 (3) A field hanger engineering support unit has been 2 developed whose purpose is to support the craft during hanger 3 installation. These Hanger Engineering personnel remain in the 4 field thoughout the hanger's construction and identify and re-5 solve installation problems. These efforts produce additional 6 confidence that the design organization's intent is being met 7 during construction. Field Hanger Engineering personnel also 8 examine the hanger for design compliance and have Welding Engi-9 neering personnel examine hanger welds (both shop and field) 10 prior to submitting the hanger package to CI and QC for final 11 inspection. Hanger Field Mods are generated by Hanger Engi-12 neering personnel to resolve problems encountered. These exam-13 inations by the Hanger and Welding Engineering personnel will 14 generate higher quality levels in the work being presented for 15 final inspection and thereby render this process more effec-16 tive.
17 (4) In addition to CI and QC review, a Hanger Engineering 18 final review group has been formed to review seismic-hanger 19 packages prior to final turnover to the permanent QA records 20 vault. Hanger package documentation is verified as being com-21 plete and accurate.
22 Q.35 Is there any evidence that the enhanced program is 23 effective?
24 A.35 (KVH): Yes. For example, in the second quarter of 25 1984, approximately 93 percent of the quality attributes 26 presented by the craft to CI for inspection were found to be l l 1
acceptable. Also, .approximately 93 percent of the work 2
presented by the craft to QC for weld inspection was found to-3 be acceptable. In addition, an independent check of inspector 4 performance for the period February to April, 1984, by QA sur-5 veillance revealed'a 99.82 percent acceptance rate for 6 CI-inspected attributes and a 99.37 percent acceptance rate for 7 QC Welding inspected attributes.
8 Q.36 What are the implications of the pipe hanger welding 9 experience, if any, for the effectivensa of the QA/QC programs 10 for construction of SHNPP?
11 A.36 (KVH): The fact that improvements have been made 12 over a period of time does not undermine my view that our QA/QC 13 programs have been effective in discovering and reporting 14 deficiencies. Weaknesses were looked for and identified early 15 in the hanger program, and the QA/QC programs were 16 strengthened. As with any program of procedures, the human el-17 ement exists and mistakes will be made. One measure of program 18 effectiveness, however, is the ability to identify weaknesses 19 and correct them; and another is the prompt implementation of 20 corrective actions necessary to preclude recurrence of identi-21 fled deficiencies. The corrective steps taken in the resolu-22 tion of these problems represent a systematic and prudent ap-23 proach to assure a safe and quality product. As demonstrated 24 by the audit results I discussed above, the improvements in the 25 hanger program, vendor surveillance activities, receipt in-26 spection and installation inspections, along with increased
1 field surveillances have resulted in a program which assures 2 that desired results are and have been achieved.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 l
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a:. - ATTACHMENT 1 l
l JAMRS F. NEVILL Principal En"mineer - Civil -
Date of Birth: Jancary 12, 1947 EDUCATION I.
A. B.S. Degree in Civil Engineering from West Virginia Institute of Tecimology,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 - Drafting experience in strus.tural 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 - Supetvision of construction for fabrication of two nuclear submarines. l 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. Located at the Harris Site, New Hill, NC.
- b. June 8, 1974 - Promoted to Civil Engineer, Nuclear Construction Section Power Plant Construction Department. Located at the Harris Site, New Hill, NC.
' c. September 27, 1975 - Reclassified as Engineer II Nuclear Construction Section, Power Plant Construction Department.
Located at the Harris Site, New Hill, NC.
- d. August 14, 1976 - Promoted to Engineer III in the Nuclear Construction Section of the Power Plant Construction Department.
Located at the Harris Site, New Hill, NC.
4 James F. Nevill *
- a. November 5,1977 - Promoted to Senior ragineer in the
' Nuclear Construction Section of the Power Plant Construction Department. Located at the Barris Site, New Hill, NC.
- f. June 16, 1979 - Promoted to Project Engineer"- Civil in the Barris Site Management Section of the PMr Plant Construction Lepartment. Located at the Harris Site, New Bill, NC.
( ,
3 June 28, 1930 - Promoted to Principal Ehgineer - Civil in-
, the Barris Site Management Section of the Power Plant
' Construction Departnant. Incated at the Harris Site, New Hill, NC.
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- h. July 5, 1930 - Transferred to Nuclear Power Plant Engineering Department, Harris Plant Engineering Section, as Principal Engineer-Civil. Located at the Barris Site, New Hill, NC.
III. PROFESSICIfAL SOCIETIES A. Engineer-In-Training with State Board of Registration for Professional Engineers of West Virginia.
B.
Professional Engineer Registered in North Carolina, February 9,1979.
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Att03hment 2
__ Alcxand:r G. Fullcr - i l
Principal Engineer - 4echanical .. . j i
I. Date of Birth - October 14, 1951 II. Education A. BS Degree in Civil Engineering from N. C. State University, 1973.
III. Experience i A. Summer, 1970 l l
1.- parolina Builders
- f. Salesman.
B. Summers, 1971 and 1972
- 1. N. C. State Highway Commission
- a. Engineering Assistant.
- C. 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 General 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 1 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. '
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Alexander G. Fuller - 2'-
- g. August 16,.1976 - Transferred from-Harris 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-tions at the Cape Fear Plant.
, h. April 2, 1977 - Transferred from Cape Fear Plant to Harris j site as Engineer in the Nuclear Construction Section of the j Power Plant Construction Department. Resumed duties as civil engineer in the Resident Engineer subunit.
- i.. March 25, 1978 - Promoted to Senior Engineer in the Nuclear ;
Construction Section of the Power Plant Construction Depart-
, ment. Located at the Harris site, New Hill, N. C.
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- j. July 1, 1978 - Transferred to the Miscellaneous Projects Unit in the Nuclear Construction Section of the Power Plant Con-l struction Department. Assigned to' supervise contractor accomplishment of the main dam. Located at the Harris site, New Hill
- k. November 15, 1980 - Promoted to Project Engineer - Civil in j the Miscellaneous Projects Unit, Nuclear Construction Section, ,
- Power Plant Construction Department. Located at the Harris site, New Hill, N. C.
i, j 1. January 31, 1981 - Transferred to the Nkchanical Engineering Subunit
~
in the Harris Site Management Section of the Nuclear Plant i Const'uction r Department. Located at the Harria afte,
! New Hill, N. C.
i m. June 27, 1981 - Reclassified as Project Engineer-Mechanical
! in the Harris Site Management Section of the Nuclear Plant j Construction Department. Located at the Harris site, New Hill, j N. C.
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- n. October 30, 1982 - Promoted to Principal Engineer-Mechanical in the Harris Site Management Section of the Nuclear Plant ;
Construction Department. Located at the Harris site', New Hill, N. C.
, o. September 3, 1983 - Reorganization - Group, Department, and Section renamed to Nuclear Generation Group. Harris Nuclear Project, Department, Harris Plant Construction Section. Located at the l Harris Plant New Hill, N. C.
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IV. Professional Societies A. Professional Engineer Registered in North Carolina - July 7, 1978 l
6 Rev. 8/2/84 U
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Attcchm:nt 3 David R. Timberlake Senior Engineer I. Date of Birth - June 26, 1950 II. Education A. BS Degree in Engineering Operations for N. C. State University, 1972 III. Experience
, A. June, 1972 to September, 1974
- 1. Newport News Shipbuilding i
l A. Welding Engineer B. February, 1975 to November, 1977 '
- l. National Welders, Charlotte, N. C.
- a. District Manager - managed retail welding supply distributorship
- C. December, 1977 to May, 1978 l 1. Victor Equipment Company, Denton, Texas i a. Contractor Specialist l 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.
j a. Welding Engineer
. F. March 3, 1980, to Present l 1. Carolina Power & Light company
- a. March 3, 1980 - Employed as a Construction Specialist in the Brunswick Site Management i Section of the Power Plant Construction Department. Located at the Brunswick site, Southport, N. C.
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- b. August 1, 1980 - Transferred to the Harris Site Management Section of the Power Plant ;
Construction Department. . Located at the l Harris Site, New Hill, N. C. l l
- 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 Construction.
i IV. Professional Societies
.i A. American Welding Society l V. Certification A. Certified Welding Inspector (AWS) - Certificate #82055171 t
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. AttOchment 4 Ka ar V. Hato' Principal QA Engineer I. Date of Birth January 30, 1947
- II. Education and Trainina A. BS Degree in Metallurg$ cal Engineering, Indian Institute of Technology, Bombay, India, 1970 B.. MS Degree in Materials Engineering Mississippi State University, State College, Mississippi, 1972 C. MS Degree in Management, NC State University, Raleigh, North Carolina, 1984 D. Completed course in " Quality Assur...nce", Ohio State University.
Coltsabus, 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.
. a. 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.
l 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 & Const'ruction QA Section of the Technical Services Department. Located in the General Office,
, Raleigh, North Carolina.
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- o. Jun3 1979 promoted cc o Project QA Engin:Or in the
- Engineering & Construction QA Section of the Technical Services Department. Located in the General Of fice, 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 and transferred as a Principal QA/QC Engineer in the Engineering & Construction QA/QC Section of the Corporate Quality Ansurance Department.
Located at the llarrin nite, New lilli, North Carollnn.
- h. February 1983 - SECTION TITLE CHANGE - Principal 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 1973 i.
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