ML20108E020
| ML20108E020 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/11/1984 |
| From: | Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#484-593, REF-PT21-84 OL, NUDOCS 8412140095 | |
| Download: ML20108E020 (20) | |
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UNITED STATES OF AMERICA-
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NUCLEAR. REGULATORY. COMMISSION ESELO SENHr.r.-
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Q BEFORE THE ATOMIC SAFETY AND LICENSING BOARD"' * '
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and NORTH ' CAROLINA EASTERN
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Docket No. 50-400 OL
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MUNICIPAL PONER AGENCY
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(Shearon Harris Nuclear-Power
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. ADDITIONAL EVIDENCE (Eddleman Contention-41) u
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Applicantsherebymovethe.AtomicSafety-andf}{ censing Board to issue an-order which identifies-and-receives into evi-t-
dance as Applicants' Exhibits 27 and 28,1/ the attachedstwo-o
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final reports, submitted to the NRC Staff pursuant to 40 C.F.R.
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-S 50.55(e), relating to the 1982 pipe hanger 4 reinspection-pro-gram.
These d6cuments, which~were not in existe$ce at the time the-hearing on Eddleman 41yqncluded, are final versions of the x
interim reporta which are-already in the record as Eddleman ex-Y.s l
hibits.
Consequently, as explained more fully below, the[ final 13 i
-r If The record presently contains two documents identified and admitted-as Applicants' E:thibit 25.
In Proposed Tran-script Corrections,'to be filed shortly, Applicants will request that the second Exhibit 25 be renumbered as Exhib-~
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rcporto eccentially do not expand tha r:ccrd, but provide a more complete record.
As the Board is aware, the discovery of pipe hanger welding deficiencies in 1982 and the subsequent reinspection program and corrective actions undertaken by Applicants was one of the subjects of Applicants' direct testimony in response to Eddleman Contention 41.
See 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), ff. Tr. 6663, at 17-20.
As discussed in more detail below, several interim reports on these issues were also admit-ted as Eddleman exhibits during the hearing on Contention 41.
See, generally, Eddleman Exs. 22, 41, 46 and 47.
Proposed Applicants' Exhibit 27 includes a cover letter (NRC-291) dated November 30, 1984 from Mr. Parsons to Mr. O'Reilly (NRC-Region II) and a final report of the same date entitled, " Shop Welding Deficiencies in Seismic I Pipe Hangers Supplied By Bergen-Paterson, Item 95," and " Undersize Skewed Tee Fillet Welds on Seismic I Pipe Hangers, Item 72."
l The first document in Eddleman Ex. 22, CP&L letter No. CQAD 82-519 dated March 24, 1982, is simply a notification to the l
NRC of a delay in completing Applicants' evaluation of *:hether Item 72 (undersized skewed tee fillet welds) is reportable under 10 C.F.R. 5 50.55(e).2/ Eddleman Exhibits 46 and 47 are 2/
The testimony adduced during cross-examination on this ex-l hibit included a description of the problem invclved with (Continued next page) l l l I
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tho occcnd and third intoria 5 50.55(e). rsporto on Itcao 95 and 72.1l A review of proposed Applicants' Ex. 27 against Eddleman Ex. 47 clearly shows that'the Final Report merely reflects the fact that all corrective'and preventive mer.sures have now bekn completed (i.e., as Mr. Fuller testified, there are no longer any Seismic I pipe hangers on engineering hold).
Thus, there are no substantive changes regarding either the scope of the problems encountered or the actions taken in response which would require Mr. Eddleman'to conduct cross-examination on pro-posed Applicants' Ex. 27.
Applicants, however, believe that it would be helpful if the record correctly reflected the-current status of these items previously reportcd under 10 C.F.R.
5~50.55(e), and therefore move the Board to admit proposed Ex-hibit 27.
Proposed Applicants' Exhibit 28 also includes a cover let-ter (NRC-292) and Final Report dated November 30, 1984, (Continued) l the measurement of skewed ~ tee fillet welds and a descrip-l-
tion of the process for determining whether an item is re-portable under 10 C.F.R. 5 50.55(e).-
Tr. 6930-33, 6935-38 (Hate, Nevill,' Fuller).
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There was only limited cross-examination on these exhib-3/-
its.
See Tr. 7001-02-(Fuller on Ex.-46: merely updates first interim report, could report change.in status of corrective actions), 6999-7001 (Fuller on Ex. 47: correc-tive action of reworking welds would require fixing what-ever weld acceptance criteria were not-met, no longer any l hangers on engineering hold).
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cntitisd "Pipa H2ngarc Previoucly Accsptsd by QC Walding In-spectors, Item 96" and " Undersized Skewed Tee Fillet Welds on Seismic I Pipe Hangers, Item 72."4/
Previous reports in the record on Items 96 and 72 are the second document in Eddleman Ex. 22 (CP&L letter CQAD 82-1560 dated September 13, 1982, In-terim Report on Item 96) -- on which there was absolutely no cross-examination -- and Eddleman Ex. 41 (CP&L letter NRC-127 dated October 3, 1983 with attached Interim Report No. 2 on Items 96 and 72), on which there was, again, only limited cross-examination.
See Tr. 6967-70 (Fuller: basis for re-portability; confirmation that procedure QCI-19.3 was issued as part of corrective action).
As with the previous proposed exhibit, Applicants' Ex. 28 does not set forth any new substantive information which would warrant additional cross-examination; admission of Applicants' Ex. 28 would, however, provide the present status on these is-sues.
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While both proposed exhibits deal with undersized skewed tee fillet welds, Applicants' Ex. 27 is concerned with shop welding deficiencies whereas Applicants' Ex. 28 is concerned with field welding deficiencies. -
Far all tha forGgoing rocceno, Applicento rsqusst that tha Board grant the instant motion and admit proposed Applicants' Exhibits 27 and 28 as evidence of record.
Respectfully submitted, i.
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Thomas A.
- Baxter, P.C.
SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1090 Richard E. Jones Samantha F. Flynn CAROLINA POWER & LIGHT COMPANY P.O. Box 1551 Raleigh, N.C.
27562 (919) 836-7707
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Counsel for Applicants Dated:
December 11, 1984 as
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APPLICMIT5 EXHIBIT 27 i
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Applicants' Ex. 27 P. O. Box 101, New Hill, N. C. 27562 November 30, 1934 Mr. James P. O'Reilly NRC-291 United States Nuclear Regulatory Commission Region 11 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30323 CAROLINA POWER & LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT 1986 - 900,000 KW - UNIT 1 SHOP WELDING DEFICIENCIES IN SEISMIC I PIPE HANGERS SUPPLIED BY BERGEN-PATERSON, ITEM 95 UNDERSIZE SKEWED TEE FILLET WELDS ON SEISMIC I PIPE HANGERS, ITEM 72
Dear Mr. O'Reilly:
Attached is our final report on the subject items which were deemed reportable per the provisions of 10CFR50.55(e) and 10CFR, Part 21, on Augu st 13,1982 (Item 95) and November 5,1982 (Item 72). With this report, Carolina Power and Light Company considers this matter closed.
If you have any questions regarding this matter, please do not hesitate to contact me.
Yours very truly, W
2" R. M. Parsons Project General Manager Completion Assurance Shearon Harris Nu:' ear Power Plant RMP/dd Attachment cc:
Messrs. G. Maxwell /R. Prevatte (NRC-SHNPP)
Mr. R. C. DeYoung (NRC) dd2/1
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CAROLINA POWER & LIGHT COMPAN'T SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO.1 FINAL REPORT SHOP WELDING DEFICIENCIES IN SEISMIC I PIPE HANGERS SUPPLIED BY BERGEN-PATERSON ITEM 95 UNDERSIZE SKEWED TEE FILLET WELDS ON SEISMIC I PIPE HANGERS
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ITEM 72 NOVEMBER 30,1984 l
I REPORTABLE UNDER 10 CFR50.55(e)
REPORTABLE UNDER 10CFR21 t
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'SUBJEC T:
Det.c ent nop Aeids on pipe nangers prenoush acceptu by
, Bergen-Paterson (B-P) and Ebasco welding inspectors.
ITEM:
Seismic Pipe Hangers SUPPLIED BY:
Bergen-Paterson Pipe Support Corporation, Laconia, New Hampshire NATURE OF DEFICIENCY:
1.
Missing and undersized welds 2.
Cosmetic weld defects 3.
Undersized skewed tee welds 4.
Deficient welds accepted by B-P inspectors and Ebasco Vendor Quality Assurance (VQA) inspectors DATE PROBLEM OCCURRED:
Prior to October 1,1982 DATE PROBLEM REPORTED:
On August 13,1982 CP&L (Mr. N. 3. Chiangi) notified the NRC (Mr. A. Hardin) that this item (Item 95) was reportable under 10CFR50.55(e) and 10CFR, Part 21. In our November 5,1982 letter, CP&L (Mr. R. M. Parsons) notified the NRC (Mr. 3. P.
O'Reilly) that this item (Item 72) was reportable under 10CFR50.55(e) and 10CFR, Part 21.
SCOPE OF PROBLEM:
Seismic Category I pipe hangers nich were inspected at the source of fabrication prior to Ocuber 1,1932.
SAFETY IMPLICATIONS:
Deficient welds could cause a safety-related pipe hanger to fail' under seismic conditions. As a result, if not correc6ed, they could adversely affect the safe operation of this facility. However, no hangers evaluated to date with th? above type deficiencies have been found to adversely affect the safe operation of this facility.
REASON THE DEFICIENCY 15 REPORTABLE:
The conditions reported in Item 9 5 and Item 72 represent breakdowns in B-P and Ebasco QA programs which allowed supports to be shipped with welds which we e not in accordance with design criteria. This incident was identi.2d as reportable under 10CFR50.55(e) and 10CFR, part 2:, due to the extensive evaluation required and the breakdown in the QA programs.
CORRECTIVE ACTION:
1.
Hangers with shop weld deficiencies were identified during the following processes:
A.
Receipt Inspection.
B.
Inspection in the warehouse prior to hanger issuance to the field.
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C.
Inspection in the !! eld of instal!ed hangers which had not been previously inspected by CP&L for shop weld deficiencies (does not include those hangers that were in Reinspection -See D).
D.
Reinspection of pipe hangers that were installed or partially installed and inspected prior to June 26,1932.
This includes the hangers which were previously reinspected as part of the Corrective Action to NRC ~
Report 50-400/32-03. The June 26,1932 date was selected because the QC weld inspection program was expanded to include shop welds. The hangers which had been installed and inspected prior to June 26,1932 and which were removed, voide' d, or declassified to non-seismic by a subsequent drawing revision were not reinspected.
2.
Approximately 500 hangers with defective shop welds were identified by processes A and B (see above)..
Approximately 1900 hangers were reinspected by Processes C and D. Approximately 40% were identified with shop weld deficiencies.
Deficiencies were resolved as follows:
Welds were cut out.
Design drawing revisions were issued as a result of Engineering evaluation.
Welds were reworked and upgraded to meet the site..
weld acceptance criteria.
3.
Those hangers remaining in the warehouse are contro!!ed as fo!!ows:
Hangers requisitioned f 2r field installation are inspected for compliana to the site weld acceptance
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criteria. Weld acceptance and deficiencies are documented on a Seism.c Teld Data Report (SWDR),
deficiencies reworked or repaired, and final weld 1
acceptance documented on the SWDR.
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NONCOMPLIANCE: -
1.
Site weld acceptance criteria were developed and issued to provide weld inspection acceptance criteria for both field and shop welds based on the AWS DI.1 code and B-P design criteria. (Wel.ds are inspected to CAR-2165-A-003, formerly FCR-H-979).
2.
Ebasco VQA began perfarinind n-process inspections and i
100% inspection of hanger welds on October 1,1932. This -
was performed throughout the remainder of the 3-P purchase order.
3.
Ebasco VQA management regularly visited the B-P Laconi-facility to confer with the Ebasco VQA representative anc.
witness the VQA inspector's activities.
'4.
B-P welders and Ebasco VQA inspectors have received additional training in weld acceptance criteria.
5.
100% shop weld inspections will continue until the remaining shop welds are inspected by our quality control organization.
FINAL REPORT:
The corrective actions stated above have now been completed or implemented.
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APPLICANTS' EXHIBIT 28 i
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Applicante' Ex. 28 P.O. 3ox 101, New Hill, N. C. 27562 November 30,1934 11r. James P. O'Reilly NRC-292 United States Nuclear Regulatory Commission Region II 101 Atarietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30323
. CAROLINA POWER & LIGHT CON 1PANY SHEARON HARRIS NUCLEAR POWER PLANT 1986-900,000 KW - UNIT 1 SEISMIC PIPE HANGERS PREVIOUSLY ACCEPTED BY QC WELDING INSPECTOR - ITEM 96 UNDERSIZE SKEWED TEE FILLET WELDS ON SEISMIC 1 PIPE HANGERS - ITEM 72
Dear Air. O'Reilly:
Attached is our final report on the subject items which wer 1eemed reportable per the -
provisions of 10CFR50.55(e), on August 13,1932 (Item 96) rd November 5,1932 (Item 72). With this report, Carolina Power & Light Company consusrs this matter closed.
If you have any questions regarding this matter, please do not esitate to contact me.
Yours very truly,
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R. St. Parsons Project General 11 nager Completion Assurance l
Shearon Harris Nuc'23r Power Plant i
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11essrs. G. \\taxwell/R. Prevatte (NRC-SHNPP)
Atr. R. C. DeYoung (NRC) i dd2/1 f
f CAROLINA POWER & LIGHT COMPANY SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO.1 FINAL REPORT PIPE HANGERS PREYlOUSLY ACCEPTED BY QC WELDING INSPECTORS ITEM 96 UNDERSIZED SKEWED TEE FILLET WELDS ON i
SEISMIC I PIPE HANGERS ITEM 72 NOVEMBER 30,1984 l
REPORTABLE UNDER 10CFR50.55(e) l i
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SUBJECT:
Deficient field selds on p.pe hangers prenous y accepted oy QC welding inspectors.
ITEMS:
Seismic Pipe Hangers SUPPLIED BY:
N/A - Hangers furnished by Sergen-Paterson, but problem deals with field welds.
NATURE OF DEFICIENCY:
1.
Missing and undersized welds 2.
Cosmetic weld defects 3.
Inaccurate and incomplete QC documentation 4.
QC inspections performed by personnel whose work was suspect 5.
Undersized skewed-tee field welds DATE PROBLEM OCCURRED:
Prior to July 29,1932 DATE PROBLEM REPORTED: August 13,1932 - CP&L (N. J. Chiangi) notified the NRC (A.
Hardin) that this item (Item 96) was reportable under the provisions of 10CFR50.55(e). In our November 5,1932 letter, CP&L (R. M.
Parsons) notified the NRC (3. P. O'Reilly) that this item (Item 72) was reportable under 10CFR$0.55(e).
SCOPE OF PROBLEM:
Approximately 3300 Seismic Category I pipe hangers that were installed or partly installed and inspected prior to June 26,1932 were identified and reinspected. This includes th'e hangers which were previously reinspected as ;vt of the corrective action to NRC Report 50-400/32-03.
The June 26,1932 date was sele:ted because the QC weld inspection program was expanded to include shop welds on installed hangers (refer to item 95). Inspector training was conducted prior-to June 26,1932 to ensure satisfactory inspector performance.
The hangers which had be2n insts;ird and inspected prior to June 26,1932 and which were removec. /oided, or declassified to nonseismic by a subsequent drawing revision were not reinspected.
- SAFETY IMPLICATION:
Deficient welds could cause a safety-related pipe hanger to fail under seismic conditions. As a remit, if not corrected, they could adversely affect the safe operati:q of this facility. However, no hangers evaluated to date with the above type deficiencies have been found to adversely affect the safe operation of this facility.
REASON THE DEFICIENCY 15 REPORTABLE:
The conditions reported in item 96 and item 72 were identified as reportable under 10CFR50.55(e) due to the extensive evaluation required and the breakdown in the QA program.
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CORRECTIVE ACTION:
Approximntzly 1400 hangtrs wtra idsntifisd with d:ficitnt finld walds es a rssult of tha rainspectisn offort. Defici:;nci;s w ra resolved as follows:
Welds were cut out.
Design drawing revisions were issued as a result of Engineering evaluation.
Welds were reworked and upgraded to meet the site weld acceptance criteria.
To ensure that hangers requiring reinspection were not overlooked, Quality Control Instructions (QCI's) require that during the final
, re. view process the SWDR's in the hanger work package will be checked to ensure that inspections performed prior to June 26, 1982 have been subsequently reinspected and accepted.
PREVENTIVE MEASURES
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TAKEN TO AVOID FURTHER NON COMPLIANCE:
1.
A pipe hanger inspection documentation instruction, QCI 13.2 (formerly 19.3) was developed and issued.
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Additional training classes were held with required attendance for both craft and QC weld inspection personnel involved in pipe hanger inspection. Training classes covered items such as measurement of skewed-tee welds, visual acceptance criteria, proper documentation, applicable work procedures, etc.
3.
New QC weld inspector candidates are interviewed by the.
QA/QC Specialist in addition to passing a written examination to ensure they are aware of project i
requirements pertinent to their assignments.
4.
Each inspector's documentation or weld inspections is reviewed after the final inspection to ensure completeness l
and correctness.
5.
Supervisory audits are routinely performed in accordance l
with Quality Assurance Instruction (QAI) 1.3 on each QC inspector's field work to ensure his satisfactory performance and to ensure that the work complies with the design
. documents.
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A system was developed to aid in the resolution of tr.chnical inquiries that inspector supervision is unable to resolve.
l Technical inquiries are stated on a Request for Information l
(RFI) form and forwarded to the QA engineering unit which l-was established on site to provide engineering support for
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inspection activities.
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PREVENTIVE MEASURES TAKEN TO AVOID FURTHER NONCOMPLIANCE (cont'd):
7.
Site weld acceptance criteria were developed and issued to provide weld inspection acceptance criteria for both field and shop welds based on AWS Dl.1 code and Bergen-Paterson design criteria. Procedure NDEP-605 was issued to address the specific conditions governing pipe hanger weld inspections. (Welds are inspected to CAR 2165-A-003, formerly FCR-H-979)
FINAL REPORT:
The corrective actions stated above have now been completed.
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December 11, 1984 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CAROLINALPOWER AND LIGHT COMPANY
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and NORTH CAROLINA EASTERN
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Docket No. 50-400 OL MUNICIPAL POWER AGENCY
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(Shearon Harris Nuclear Power
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Plant)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Motion to Re-ceive Additional Evidence (Eddleman Contention 41)" were served this llth day of December, 1984, by deposit in the U.S. mail, first class, postage prepaid, upon the parties listed on the attached Service List.
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Thomas A. Baxter Date:
December 11, 1984
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY.AND' LICENSING BOARD In the Matter of
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CAROLINA POWER & LIGHT COMPANY
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Docket Nos. 50-400 OL l
and NORTH CAROLINA EASTERN
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50-401 OL MUNICIPAL POWER AGENCY
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(Shearon Harris. Nuclear Power
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Plant, Units 1 and 2)
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SERVICE LIST I.
l James L. Kelley, Esquire John D.
Runkle, Esquire L
Atomic Safety and Licensing Board conservation Council of l
U.S. Nuclear Regulatory Commission North Carolina-Washington, D.C.
20555 307 Granville Road Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire i
Atomic Safety and Licensing Board Edelstein and Payne l
U.S. Nuclear Regulatory Commission P.O. Box 12607 Washington, D.C.
20555 Raleigh, North Carolina 27605 Dr. James H. Carpenter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory Commission Apex, North Carolina 27502 Washington, D.C.
20555 Charles A. Barth, Esquire Mr. Wells Eddleman Janice E. Moore, Esquire 718-A Iredell Street i
Office of Executive Legal Director Durham, North Carolina 27705 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Docketing and Service Section Richard E. Jones, Esquire Office of the Secretary Vice President and Senior Counsel U.S. Nuclear Regulatory Commission Carolina Power s Light Company Washington, D.C.
20555 P.O. Box 1551 l
Raleigh, North Carolina 27602
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Mr. Daniel F. Read, President Dr. Linda W. Little CHANGE Governor's Waste Management Board P.O. Box 2151 513 Albemarle Building Raleigh, North Carolina 27602 325 North Salisbury Street Raleigh, North Carolina 27611
Brrdicy W. JcnOs, E2quira U.S. NuclCor R0gulatory Conunicoicn Region II.
-101 Marrietta Street Atlanta, Georgia 30303 Steven F. Crockett, Esquire Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P.O. Box 991 Raleigh, North Carolina 27602 Administrative Judge Harry Foreman Box 395 Mayo University of Minnesota Minneapolis, Minnesota 55455 Ice-Federal Reoorters, Inc. (3) 444 North Capitol Street Washington, D.C.
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