ML20101D072

Forwards Affidavit of Mk Yates Which Revises Applicant 841130 Answer to Joint Intervenor Item A(7)(e)

ML20101D072
Person / Time
Site:	Waterford
Issue date:	12/18/1984
From:	Churchill B LOUISIANA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Johnson W, Kohl C, Wilber H NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
References
CON-#484-734 OL, NUDOCS 8412210288
Download: ML20101D072 (7)

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SHAW, PITTMAN, PoTTs & TROWBRIDGE A paseTNEnswie Or pmOFEsscNAL CompOmArcNs 1800 M STREET, N. W.

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Christine N. Kohl W. Reed Johnson Administrative Judge Administrative Judge Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Appeal Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Howard A. Wilber i.

Administrative Judge Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Louisiana Power & Light company (Waterford Steam Electric Station, Unit 3)

Docket No. 50-382 - O C i

Dear Administrative Judges:

'On November 30, 1984, Applicant filed its answer to Joint Intervernors' November 7 motion to reopen the record in this g proceeding. Included with the answer were detailed responses, I

in affidavit form, to the many allegations of Joint i Intervenors. LP&L has determined that the original response to j one issue--Joint Intervenors' Item A(7)(e)--warrants expansion

, and clarification to state'the answer more precisely and thus l- avoid misinterpretation of Waterford 3 experience with respect l

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' SHAW. PITTMAN.- PoTTTJ & TROWJRIDGE A PARTNERSMep OF PROFESSIONAL CORWORATIONS Atomic = Safety and Licensing Appeal-Board December 18, 1984 Page 2 to the issue. .Accordingly, we are' submitting by the enclosed affidavit a revised answer to Item A(7)(e). This revision is to be. substituted for the original answer found-at pgs. 42-43 of LP&L's Responses to' Joint Intervenors' specific allegations.

The enclosed affidavit also clarifies LP&L's answer to paragraphs 7 and 10 of JI Exhibit 27. (See pgs. 90-91 of LP&L's Responses.) The affidavit confirms and makes express the implication of the original answer that post weld heat treatment was performed on the particular weld identified in the allegation. There is no substantive change in the response.

S'ncerely,r l -

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1[ s Truce . Churchill Counsel for Applicant cc: Service List Attached i

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. UNITED, STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of )

-)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382 OL

)

(Waterford Steam Electric Station, )

Unit.3) )

AFFIDAVIT OF MICHAEL K. YATES

^

The undersigned, being duly sworn, deposes and says:

.My name is Michael K. Yates. I am Project Manager for Ebasco Services Inc. 'for the Waterford 3 Project. In this position I am responsible for all Ebasco efforts on the Waterford 3 Project, including engineering, procurement,

.and construction.

The original submittal in response to Item A(7)(e) warrants expansion and cisrification to state the answers more precisely and thus avoid misinterpre-tation of Waterford 3 experience with respect to the issue. A revised response is attached. Response to Item A(7)(f) is also included in the attachment but 4

has not been revised.

~

With regard to LP&L's response to JI Exhibit 27, Paragraphs 7 and 10, Page 4 and 5, I wish to clarify that the " peened" weld in question'did receive post weld heat treatment 1n order to remove residual stresses and adverse metallurgical affects that may have been caused by such " peening".

These responses have been prepared by me or under my direct supervision.

They are true and correct to the best of my knowledge and belief.

Dated: December. 17, 1984 I

['UU bk e

State of Louisiana u e Parish of St. Charles Michael K. Yat es i

Sworn to and subscribed before me this 17th day of December, 1984.

/

/

a/fm Notary Public

qq.~4'm t

It'em A(7)(e) 'and (f), ' Motion at 11 Itsis' alleged that:-

' Half of the stainless steel. welding was not " purged" of atmospheric contamination for two million feet of tubing for the containment.

' instrumentation lines. Tiny pockets of " sugaring" formed on the weld surface.- This contamination can lead to cracking of the welds in the

, future. Ibid. .(See Exhibit 8]

Mercury welders often made two'" passes" on welds without pausing lto allow the first pass to cool down. Management pressured the welders to speed up-on their work. Ibid. . [See Exhibit 8]

. Response:

The assertion regarding purging and weld cracking from sugaring is

, - incorrect or misleading. It should be noted that the total installed

- quantity.of stainless steel tubing is approximately 121,000 feet, far less

! than the alleged "two million" feet. Of this, approximately 70,000 feet of ,

stainless steel tubing is, safety related.. The safety-related tubing lines are Safety Class.2 or 3 and cpproximately 12,000 feet thereof is located in the Containment Building. ,

LP&L is confident on several bases that no sugaring of safety significance.

exists on the instrumentation lines.

First, purging of the tubing referenced by.intervenors is not required by

, the Code. Part of the anonymous alleger's confusion (JI Exhibit .8,

paragraph 9) may stem from the fact that the contractor responsible for the installation of most of the stainless steel tubing (Mercury Company) initially " purged" the tubes' (i.e. filled them with inert argon gastin

'- order to exclude atmospheric air) prior to welding the socket weld joint.

' Later, the practice was' discontinued.because it-was unneccessary.

Procedures for control of welding, which are in compliance with Code .

requirements, do not require'that tubing be purged for this type of welding

~

4 application. The reason is' that, unlike butt welds, the geometry of the

. socket weld joint (a male-female. arrangement between the tube and a larger

- bore fitting) does not expose the molten metal during welding.co the air inside the tube. Thus, protection is not required. Further, proper welding of these socket weld' joints required' highly skilled welders. Each welder chosen for this work had to demonstrate his ability by qualification

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using actual job-size materials, i.e. tube diameter and wall thickness.

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. Any indication of burn-through (melting through the tube wall) and subsequent oxidation (" sugaring") was grounds for disqualification.

- Second, for work in the field, welders were supplied with small welding-torches which were easier to. manipulate than the larger standard torches-

used for most other welding applications. They,were also supplied with

- special portable welding machines having very stable welding current

, output. This type of special equipment minimizes the possibility that the

. instrument tubes welds have the " sugared" condition.

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Third, extensive inspection and testing has been performed on the safety-related instrumentation lines in question. Final visual inspections were performed on the lines, including inspection of the welds. In addition, the Safety Class 2 welds received a liquid penetrant examination as required by the Code. Further, system testing has been performed as well

.as hydrostatic testing required by the Code.

" Sugaring" of a weld can occur if the tube wall is " burned-through" during welding. A review of Mercury's Nonconformance Reports indicates that there were approximately 32 instances where burn-through had occurred (31 were found by visual examination and 1 by radiography). The presence or absence of " sugaring" is not noted on these NCRs. In every case, the corrective action was to' cut out the weld and to replace it.

In addition, on Ebasco Nonconformance Reports there were radiographs performed on approximately 40 completed welds for the purpose of verifying proper fit-up between the instrument tube and coupling (i.e. presence of 1/16 inch gap). Any evidence of " sugaring" would have been revealed on the radiographic film, but none was found.

Based on the foregoing, there is reasonable assurance that no sugaring of

-safety significance exists on the instrumentation lines.

The anonymous alleger states in Paragraph 10 of JI Exhibit 8 that the quality of welding was compromised by the welders failing to allow the weld to cool down between passes and implying that the second pass may not have been welded.

The allegation i<, incorrect. The welds have not been compromised. There is no specific requirement that a welder must " pause". The only related requirement in the welding procedure is that the interpass temperature (the temperature of the metal before applying the second pass) shall not exceed 350*F. Experience has shown that a thin-walled tube inserted into a larger mass coupling (an arrangement known as a socket-weld) requires only a few seconds to cool below 350*F.

Neither the Code nor the welding procedure specify the number of weld passes. The weld size requirement for the application was 1/8 inch. For stainless steel tube to coupling socket welds, it does not matter if there is one pass of two passes. The weld size is verified during final inspection.

9 "* 7 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Appeal Board In the Matter of )

)

LOUISIANA POWER & LIGHT COMPANY ) Docket No. 50-382

)

.(Waterford Steam Electric )

Station, Unit 3) )

, SERVICE LIST ChristineRN. Kohl Sheldon J. Wolfe Administrative Judge Administrative Judge Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Board Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 W. Reed Johnson Harry Foreman Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board U.S. Nuclear Regulatory Commission Director, Center for Population Washington, D.C. 20555 Studies Box 395, Mayo Howard A. Wilber University of Minnesota

Administrative Judge Minneapolis, MN 55455 Atomic Safety and Licensing Appeal Board Walter H. Jordan t.

U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C. 20555 Atomic Safety and Licensing

- Board Sherwin E. Turk, Esquire 881 West Outer Drive Office of the Executive Oak Ridge, TN 37830 Legal Director U.S. Nuclear Regulatory Commission Docketing & Service Section (3)

Washington, D.C. 20555 Office of the Secretary L

U.S. Nuclear Regulatory Commission

~ Atomic Safety and Licensing Washington, D.C. 20555 Appeal Board Panel

-U.S. Nuclear-Regulatory Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

^'

LP&L

$(rvic3 Lict-ASLAB Pcg3 Two Mr. Gary Groesch 2257 Bayou Road New Orleans, LA

- 70119 Carole H. Burstein, Esq.

445 Walnut Street

~ New Orleans, LA 70118 Lynne Bernabei, Esq.

Government Accountability Project 1555 Connecticut Avenue, N.W.

Suite 202 Washington, DC 20009 e

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