ML20112D951

Errata & Amends to Applicant Proposed Findings of Fact & Conclusions of Law Re Safety Matters,Including Pages 87,102, 104,B-4 & B-9

ML20112D951
Person / Time
Site:	Harris
Issue date:	12/21/1984
From:	Baxter T CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:
Shared Package
ML20112D940	List: ML20112D938 ML20112D951
References
OL, NUDOCS 8501140552
Download: ML20112D951 (6)

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to reports received regarding undersized skewed tee fillet welds at other plants. As explained by Applicants' witness Timberlake, clear criteria for the measurement of skewed tee fillet welds were not included in the 1975 edition of AWS D-1.1 utilized at the Harris site. These criteria were added in a subsequent revision to the Code. Tr. 6945-48 (Timberlake).

\fter identifying this problem, additional training was pro-vided to craft and QC welding inspection personnel which uti-lized a figure from the 1981 edition of AWS D-1.1 that clearly outlined the proper techniques for measurement of skewed tee fillet welds. When this technique was implemented by CP&L, un-dersized shop welds were also identified. Tr. 6947 (Tim-berlake); see also, Nevill et al. at 18-20; Tr. 7125 (Pere, Tingen and Douglas).

131. The second problem involved the identification by CP&L personnel of defects on shop welds made by Bergen-Paterson. The cause of this problem was determined to be the use of different weld acceptance criteria by Bergen-Paterson than were utilized at the Harris site.44/ Nevill et al. at 17-20. In order to remedy this situation, Applicants imple-mented a revised set of weld acceptance criteria -- based in 44/ Bergen-Paterson, as a supplier to many nuclear utilities, utilized'ASME Section III, Subsection NF as the basis for their acceptance criteria, while Applicants utilized AWS D-1.1 as their acceptance criteria. Tr. 7034 (Timberlake).

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routine checks or surveillance of their work. To resolve these problems, procedure NDEP-605 (Eddleman Ex. 39) was issued to provide specific guidance to QC welding inspectors on condi-tions governing pipe hanger weld inspections.46/ Tr. 6964-66 (Hate, Timberlake); Eddleman Ex. 41, Attachment at 3. Finally, a program of routine audits of each QC inspector's field work by QC supervisors was implemented in order to provide a double-check on the quality of inspections. Nevill et al. at 20; Tr. 7056 (Hate).

132. The third area of concern identified in 1982 related to documentation errors caused by minimal review of weld records and the absence of a procedure for standardizing the requirements for completing documentation records. Nevill et al. at 19. To resolve this problem, procedure QCI-19.3, Seismic Pipe Hanger Documentation System (Eddleman Ex. 25), was issued to provide concistent guidance for completion and review of pipe hanger weld inspection documentation. Also, weld docu-mentation completed by the QC welding inspectors was reviewed after each phase of inspection to insure that it was correct and complete. Nevill et al. at 20; Tr. 6773-74 (Hate), 6969-70 (Fuller); see also, Eddleman Ex. 41, Attachment at 2; proposed Applicants' Ex. 28, Attachment at 2.

46/ Previously, visual inspection of hangers was governed by NDEP-601, which was written primarily to cover weld inspection criteria for ASME-Code class piping, rather than structur-al/ hanger welding. Tr. 6964-65 (Timberlake).

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of fire barriers in the SHNPP is proper. Tr. 4670-72 (Kelley,

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Eberly); see also, Eberly and Ferguson at 11.

153. There was considerable discussion during the hearings i

regarding the use of doors that have not been fire tested.

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i See, e.g., Tr. 4413-42 (Serbanescu); 4713, 4783-85 (Eberly, ,q7

-Ferguson); 4785-806 (Board, Parties, Eberly). The Staff noted

that the qualification of fire doors was an "open item" with respect to the Staff's review of the adequacy of the SHNPP fire

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h protection program.5s/ Eberly and Ferguson at 21. Both Staff and Applicants argued, however, that the qualification of fire

] doors was not relevant to Eddleman Contention 116. Staff coun-l i sel noted that the open item was mentioned in the Staff testi-mony as part of its responsibility to keep the Board and the

parties informed, not because it was relevant to the conten-

[ tion. Tr. 4788 (Moore). Applicants stated that they under-l stood this aspect of Eddleman Contention 116-to question the i

Ss/ Subsequent to the presentation of the Staff's case on Eddleman. Contention 116, but prior to the close of the hearing, E the Staff completed its review of the fire doors and found

" Applicants' specialty fire doors are an' acceptable deviation i from.Section C.5.A of the NRC Staff guidelines.. . . . The l- Staff no longer considers the fire doors an "open item." Joint

!' Affidavit of Randall Eberly-and Dennis J. Kubicki concerning.

! SER Open Item 8 (Acceptability of Fire Doors), dated

l. November 9, 1984.- See Tr. 6908-13. The' Board admitted the

. Joint Affidavit into evidence as Staff Ex. 8 after providing Mr. Eddleman'an opportunity to examine'Mr. Kubicki.- Tr.

l 7432-33 (Conference Call, December 17, 1984). The Board also admitted'into evidence during the' December 17, 1984 Conference call Applicants' November 8, 1984 submittal providing-addition-al'information to the Staff regarding fire < doors. 'Tr. 7420; Eddleman Ex. 61.

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at 2-3. Finally, the' majority of the special doors open to the exterior, where a fire barrier is less important.59/ Id.; Tr.

4418 (Serbanescu). Thus, the evidence in the record demon-strates that the special doors will provide adequate fire pro-tection.

154. Applicants have demonstrated that Fire Areas are bounded by rated fire barriers or the equivalent, and the ques-tioning of the use of the term "where practical" by Mr.

Eddleman is not of any consequence.

4. Fire Hazards Analysis 155. The fourth issue raised by Eddleman Contention 116 is a generalized criticism of Appendix 9.5A of the FSAR, claiming the Applicants have not demonstrated "the adequacy of fire pro-tection measures'in all cases." Contention 116 finds fault with the " estimates" of the BTU content of combustible materi-al, smoke generation and removal rates, measures to reduce or mitigate fire effects, detection capability and fire brigade response and effectiveness. In response to this aspect of (Continued)

Staff also took into account fire detection and suppression systems in the vicinity of the special doors. Tr. 7427-28.

59/ There is no safety-related equipment on the outside of an exterior door that is threatened by a fire from the inside.

Nor is there a combustible load that could create a fire hazard from the exterior to threaten safety-related equipment inside the door. See Eddleman Ex. 61.

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f Staff Ex. 7 Aff aat tt of Armando S. 7432 7432

'#' Masdiantonio; Richard A.

Kendalb and Robert C. * "

• Jones, Jr. in Further Response to Eddleman Contention 9A  :

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Staff Ex. 8 Joint Affidavit of Randall 7433 7432

./' Ebarly and Dennis J. Kubick; f , concerning SER Open Teem 4 y, 4 8(Acceptability [ofFire

Doors) 7 s z i , g 5,

, , WE Ex. 2 NFPA-31, pages 4386 49004/ 'f s

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WE Ex. 3 NFP,1-30,pages"d-i 4186 4300 b/

4 WE Ex. 4 NFPA-30, pages 4386  ;

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8, 9, 12-15  ; _

WE Ex. 5- NFPA-30, pages 16-19, 4388 4900 b/

30-35', 38-45 .

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[' WE Ex. 6 NFPA-30, pages 68-75  ? 4390-(I 4900 b/ , ,

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WE Ex. 7 NFPA-30, pages9E-79 4390 '

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WE Ex. O NFPA-30, pages'88-89, '

4391 4900 I 106-107

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WE Ex. 9 NFPA-30, pages 126-133 4391.'

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1. s 4 WE Ex. 10 e !EbascoSpeditica[ ion' 5893 5943 g

.[j CAR-SH-CH 5,'" Concrete," t a 3 (Revislor.< 11) ( ' " ), . ,'

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WE Ex.' 11 Technical Procedure TP-15 5922 '

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" Concrete Placement i .

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Inspection" (Revision 11) y ib fA

% 'I j f' 4 - . s r 4/ See Tr. 4899-4900: Eddleman Exi. 2 through 9 admitted for limited purpose-of demonstrating existence of Code, not' to prove any technical issue,on the merits. i

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' \- Exhibit Identified At Admitted At Number Description Transcript Page Transcript Page 3 '.

Attachment to CP&L WE Ex. 57 7223 Letter of Response to NRC Report RII: JWY 50-400/83-20 WE Ex. 58 CP&f- letter dated 6/11/81 7223 partially from Chiangi to O'Reilly admitted 3y with attached Final 7251-72526/

i Report, Weld Symbol Errors and Misapplication of Weld

, , on Bergen-Paterson Pipe .

Hangers t WE Ex. 59 Group of Seismic Weld 7224 partially

[' Data Reports, cover sheet admitted entitled "E-41, Weld (see n.5 Inspection Reports supra)

. Produced in 1984" 7279 WE Ex. 60 Affidavit of Chan Van Vo, 7362 dated October 6, 1984 WE Ex. 61 CP&L letter dated November 7419, 21 7420 8, 1984 from S.R. Zimmerman L7N to H.R. Denton, response to SER Open Item 8 L e ~ *,-

JI Ex. 1 Joint Contention I from 2455 2456

" Admitted Contentions" dathd January 21, 1983 s .

rg JI Ex. 2 Excerpt from FERC Form 2466 2497 No. 1, Annual Report of

,y, CP&L dated December 31,

< r 1983

'JI Ex. 3 ACRS letter 2516 REJECTED, 2623 JI Ex. 4 CP&L letter NRC-111 from 2516 2749 R.M. Parsons to J.P.

O'Reilly (NRC) in response to IE Report 50-400/83-22-02

'6/ Portiond of attached report dealing with HVAC, Cable Tray and Conduit'Sup-ports (pp. 3, 4 and Exhibits 4 and 5) were not admitted.

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