ML20198C952
| ML20198C952 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/22/1986 |
| From: | Brandt C EBASCO SERVICES, INC., TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20198C917 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8605230098 | |
| Download: ML20198C952 (13) | |
Text
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... c hMt eq c. { Adis M' 23 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY'AND LICENSING BOARD In the Matter of
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TEXAS UTILITIES ELECTRIC
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Docket Nos.
50-445 and COMPANY, - al.
)
50-446 et
)
(Comanche Peak Steam Electric )
(Application for Station, Units 1.and 2)
)
Operating Licenses)
TESTIMONY OF C. THOMAS BRANDT REGARDING INSPECTION AND TESTING OF NON-ASME COMPONENTS AND SYSTEMS Ol.
Please state your full name, residence, and educational and professional qualifications.
Al.
My name is C. Thomas Brandt.
I reside in Fort Worth, Texas.
I am employed by Ebasco Services, Inc. at Comanche Peak Station.
A description of my educational background and professional qualifications has been previously received into evidence as Applicants' Exhibit 141D.
Q2.
What is the purpose of your testimony?
A2.
The purpose of my testimony is to describe the various insp$ction, verification, and testing programs which exist at Comanche Peak Station for non-ASME components.
Q3.
Please summarize your testimony.
A3.
There are three parts to my testimony.
The first part discusses the QC inspection program for non-ASME components and systems at Comanche Peak.
This program involves numerous instances of multiple inspections and verifications
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8605230098 860519 PDR FOIA CARDE85-59 PDR
2-s which provide assurance that construction discrepancies are
. identified by QC inspections and corrected in a timely manner.
My testimony highlights examples of this QC inspection process.
The second part of my testimony discusses further inspections and tests which are performed after installation of non-ASME components which further assure the proper function and overall quality of the equipment.
The s'e inspections and tests are in addition to the multiple QC inspections.
Again, my testimony highlights several specific examples.
The third part of my testimony describ6s indepandent audits, inspections, and investigations conducted by outside sources to assure QC inspection program ccmpliance and acceptability of installed components ar.d systems.
Q4.
How do these multiple inspections and tests provide assurance of the acceptability of installed systems and j
components?
1A 4.
All 1nspection attributes will be directly inspected at least once during the QC inspection process.
In addition, in many instances multiple inspections and tests of the same components provide additional opportunities for discrepant conditions to be detected.
These cumulative inspections and tests provide a high level of assurance that such conditions e
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.s will be identified and corrected prior to operation of Comknehe Peak svea if they had not been detected in the initial QC inspection.
QS,
.Please describe the non-AGME QQ inspection prograc.
AS, the non-ASME QA ' program requires a series of QC in,spections
'which are described in intricate deteil in inspection pececaurgs.and Anstructions.
'rla attributes for thest ihspeptions are outlined 6n Inspecti6n heports, Tne program includes numercas in process inspectiona; and post-scnatguction acce.ptabilitf inspections and accsptance testing.
The nonrA$ME QC inspectiofs program covers' font major disciplines:
i (1)
Civil -,whith incicdet coherste,, s lis, hilti tcIts, and protective cootings.
(2)
$lectricEl
- which includes all electrical
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(3)
Mechanical -+ Whleh includes mechanical instrumentation and Radwaste Management Systec
- piping, (4)
Supports -- which dneludse cable tray a.nd conduit supports, pi,pe wh4p restraints, and class v pipe supports.
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In each of those disciplines, the QC inspection program provides multiple cpportunities to detect unacceptable conditions which may have eluded detection in earlier inspectionsa Q6.
Please provide an example from the Civil discipline where QC inspeutions subsequent to initial inspections provide an additional opportdnity for identifying previously undetected discrepancies.
A6.
A good ekample in the divil discipline is protective ccatings.
The nature of the QC inspection process allows unacceptable conditions which have been undetected on initial inspect. ion to 'oe datected on subsequent in spec ti,ons.
All coating systems consist of multiple applications of coating material, each.of which is inspected.
Unacceptable conditicns are likely to be observed in subsequent coats, as each subsequent application is applied and inspected.
For instance, an unacceptable condition (e.g.,
surface contamination) on the bare steel substrate not detected in the inspect. ion of the substrate may also be observed and identified during inspection of 'he prime coat.
t Q7.
Please provide examples from the Electrical discipline where QC inspections subsequent to the initial inspection provide an additional opportunity for identifying previously undetected discrepancies.
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.a A7.
Any electrical system is a multi-component system.
It typically consists of electrical equipment, electrical instrumentation, cable and its associated termination hardware, and conduit and cable tray and its associated hardware.
As the " system" is constructed in a defined sequence, there is ample opportunity for discrepant
.t conditions not initially identified for any single component to be identified during subsequent installation of other associated components.
For example, conduit that was installed incorrectly (e.g.,
size, number and flattening of bends, interior cleanliness) could be identified by subsequent QC inspection I
such as during the cable pulling activities for that a
particular conduit.. Cable which was installed incorrectly (e.g.,
type,-size, identification or separation) could be.
identified during various QC inspection points such as separation inspection, termination inspection, or during meggering (insulation resistance testing) activities.
Similarly, inadequately installed cable trays (e.g.,
incorrect identification, damage, color coding) may also be identified during separation or cable pulling inspections or meggering activities.
Additional assessments of the adequacy of installation of electrical equipment and e
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i instrumentation are provided by the post construction verification inspection, and testing, discussed below in A13.
Q8.
Please provide examples in the Mechanical discipline where QC inspections subsequent to the initial inspection provide an additional opportunity for identifying previously undetected discrepancies, j
A8.
Both elements of the Mechanical discipline (Radwaste Management System (RWMS) piping and mechanical instrumentation) receive-in-process inspections and multiple final inspections by QC inspectors.
RWMS piping was originally inspected visually by Welding Engineering.
Subsequently, in order to satisfy the NRC's new Branch Technical Position ET-SB-ll-1, a QC inspection program was developed in addition to the original inspection by Welding-Engineering to assure compliance with the Branch Technical Position.
This program included visual inspection of all pipe welding, welded attachments to piping, and support location.
Also, subsequent to these QC inspections, QC performed a walkdown inspection of the system prior to hydrostatic testing.
Mechanical instrumentation receives numerous in-process QC inspections during the fabrication process.
For example, QC monitors tube bending operations, installation of Swagelok fittings,.and material identification.
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..e Additionally, upon initial completion of an instrument run QC performs a final inspection of that installation in which all quality attributes are verified (e.g.,
support span, configuration, and location, tubing size, color coding).
J Subsequent to this inspectioni QC performs walkdown inspections prior to hydrostatic testing and again prior to system turnover to Startup.
Attributes such as proper bend radius, tubing size and color coding and tubing support may be observed and discrepancies noted at any point in these inspections.
Q9.
Please provide examples in the Supports area where QC ipspections subsequent to the initial inspections provide an additional opportunity for identifying undetected discrepancies.
A9.
Conduit and cable tray supports are installed using a
. Construction Operation Traveller.
These travellers are i
prepared by Construction defining the step-by-step fabrication and installation processes.
QC hold points are 4
established by Quality Assurance on each traveller --
describing the QC inspections required at each interval of the fabrication and installation process -
prior to release to Construction.
These travellers contain an average of 20 l): inspection hold points for conduit supports and an average of 14 QC inspection hold points for cable tray 4
supports.
The nature of the traveller itself allows for f
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. s identification of discrepant items during each stage of the inspection process even though they may have previously'been inspected and accepted.
Additionally, conduit supports receive a final inspection in which support span and 0
capacity are verified as acceptable for each support on the entire run of conduit.
Attributes for which such inspections have previously been performed may also be observed and deficiencies identified during this final inspection.
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Pipe-whip restraints are also installed utilizing the Construction Operation Traveller.
However, in this case, the traveller is prepared by the Civil Engineering Department prior to establishment of QC inspection hold points by Quality Assurance.
The fabrication and installation of these structures employ welded construction to the maximum extent possible.
On a typical pipe whip restraint weld, QC verifies fit-up, cleanliness, and preheat prior to commencement of welding, and performs visual examination of all welds.
QC also performs non-destructive examination (i.e., PT, MT, or UT) on the majority of the welds.
Thus, the QC inspection process for pipe whip restraints also provides multiple opportunities for identification of discrepant conditions by QC.
Q10. Will the same QC inspectors perform these cumulative inspections?
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.c A10. Not likely.
There are numerous QC inspectors in each non-ASME discipline, and in most cases inspections performed after the' initial inspection for a specific QC attribute are performed by QC inspectors different from the one who performed the initial inspection.
Moreover, in most cases, s
inspectors who perform inspections subsequent to the initial inspection are qualified to identify discrepancies that may
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not have been identified in the initial inspection.
In sum, there is a high level of assurance that discrepancies that may not have been identified in the initial QC inspection because of the particular inspector involved will be detected by another inspector in one of the later QC inspections.
Qll. Are there means other than the non-ASME in process QC inspection program described above by which overall product quality and safe system operability are assured?
All. Yes.
The measures which provide additional assurances vary with each of the four disciplines I have previously discussed.
These include additional inspections and testing of components and systems.
012. Please provide examples of these measures for the Civil discipline.
A12. In addition to the cumulative QC inspection process described previously with respect to protective coatings, the majority of the protective coatings applied prior to
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November, 1981, were reinspected utilizing destructive testing to assure their integrity.
Also, a final walkdown visual inspection of the coatings is performed by Engineering prior to turnover to Operations.
Q13. Please provide an example of additional inspections or tests which are performed for the equipmant in the Electrical area.
A13. For all electrical installations, there are several separate inspections and/or tests in addition t'o the QC inspections previously discussed.
This applies to.all cable installations, all electrical equipment installations, and all conduit and cable tray installations.
First, all electrical installations are verified to be acceptable
'e.g., separation,' bend radius, damage, hardware in place) immediately prior to turnover during a post-construction verification inspection by'QC.
- Second, subsequent to this' post construction verification inspection, each component receives prereq6isite testing by Startup to verify component functionability.
This testing does not go to specific QC inscection attributes, but demonstrates proper and safe 6perability of the installation... Th'ird, each electrical system'also receives further preoperational or acceptance testing by Startup.
This testing confirms system operabilityl O
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Q14. Please provide an example of additional inspections or additional tests which are performed on equipment in the Mechanical area.
A14. Non-ASME mechanical components (RWMS piping and mechanical instrumentation) are all subjected to three additional layers of confirmatory testing.
First, RWMS piping and mechanical instrumentation are subjected to hydrostatic (pressure) testing.
The requirements for these pressure tests are described in the ASME Code for mechanical instrumentation and in ANSI B31.1,
" Power Piping," for RWMS pipe.' During these pressure tests QC visually examines every weld that has not previously been hydrostatically tested, every high stress point, and all base metal repairs.
Secondly, both RWMS piping and mechanical instrumentation are subjected to prerequisite testing to assure that each component functions as intended.
Finally, RWMS piping systems and mechanical instrumentation systems undergo preoperational or acceptance testing by Startup to assure system operability.
The' preoperational tests for mechanical instrumentation include the hot functional testing program.
Q15. Please provide an example of additional inspections or tests which are performed on equipment in the supports area.
s A15. An example of an additional inspection in the Supports area is the case of Class V pipe supports.
Subsequent to the original QC inspection, the location and donfiguration of those Class V supports within the scope of the IE Bulletin 79-14 As-Built Program were verified by Technical Services Engineering.
Any necessary corrective action resulting from this as-built verification is completed prior to system turnover to Operations.
Additionally, a large number of Class V supports, including all on the diesel generators and in the fuel building, were reinspected by QC to verify adequacy of the original'QC inspection, and to verify that no damage or unauthorized modifications had occurred to the support after its initial inspection.
Also, all skewed fillet welds on i
Class V supports have been reinspected.
Finally, the design function and operability for many of the Class V supports have been verified by Design a
Engineering and Startup during the hot functional testing program.
Q16. Has the non-ASME program and QC inspection process at Comanche Peak ever been reviewed or audited by any independent organizations?
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A16. Yes.
Numerous independent organizations have conducted inspections, audits and investigations of the adequacy of the non-ASME QA program.
During the last'two years alone, the following audits, inspections and investigations have been conducted:
an INPO audit and field inspection; an NRC CAT field inspection and audit; two complete building turnover inspections by NRC Region IV; an NDE audit and field inspection by NRC Region I; audits, surveillances, and field inspections conducted by TUGCO QA; audits and field inspection conducted by Cygna; a continuing field inspection and investigation process implemented by NRC Region IV and Region IV RRI.
Q17. What is the significance of all of these independent audits, inspections, and investigations?
A17. These. additional independent-audits, inspections, and investigations have provided a further opportunity by which construction discrepancies not identified by original QC inspections could be detected.
Q18. Does this complete your testimony?
A18. Yes.
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
Docket Nos. 50-445 TEXAS UTILITIES ELECTRIC
)
50-446 COMPANY, ~ al.
)
et
)
(Comanche Peak Steam Electric
)
(Application for Station, Units 1 and 2)
)
Operating Licenses)
TESTIMONY OF JAMES KELLER REGARDING PRE-SERVICE INSPECTION AND IN-SERVICE INSPECTION OF ASME COMPONENTS AND SYSTEMS Ol.
Please state your full name, residence, job title, and educational and professional qualifications.
Al.
My name is James Keller.
I reside in Granbury, Texas.
I am employed by Westinghouse Electric Company at Comanche Peak Steam Electric Station in Comanche Peak Project Engineering as the Field Engineering Supervisor.
My educational and professional qualifications are attached to this testimony as Attachment 1.
Q2.
Please describe your technical duties.
A2.
I am currently responsible for overseeing and coordinating the development and implementation of the pre-service inspection program (PSI) which is carried out for ASME piping, welds, hangers, and equipment.
I also have responsibility for coordinating develop ent of the in-61$85-59
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e service inspection program (ISI) which is the responsibility of TUGCO Operations and will cover ASME equipment once the plant begins operating.
Q3.
What is the purpose of your testimony?
A3.
The purpose of my testimony is to describe those aspects of, the PSI and ISI. programs which provide independent inspection and verification of the quality of ASME components.
Q4.
What is the PSI program?
A4.
The pre-service inspection program for Comanche Peak Station fulfills the requirements of the ASME Boiler and Pressure vessel Code,Section XI, 1980 Edition.
The program includes:
Non-D'estructive Examination of Welds Hydrostatic Testing of Piping Pump Examination Valve Examination Component Support and Attachment Examination The PSI program is performed during the construction and start-up phases of the station.
QS.
Which of the activities listed above in the PSI program are cumulative to other inspections or tests?
AS.
The non-destructive examination of welds conducted as part of the PSI program is cumulative to construction inspection and. testing of welds.
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Q6.
Please describe the non-destructive examination of welds which is carried out in the PSI program.
A6.
The PSI program includes ASME Class 1 and Class 2 systems and components.
The particular testing differs for each class of equipment.
All welds on ASME Class 1, equipment (piping, supports and attachments or appurtenances) are subject to non-destructive examination.
The examinations include ultrasonic, or volumetric, tests (UT) and surface tests, as required by ASME Code Section XI.
The surface test may be either a penetrant test (PT) or a magnetic particle test (MT).
For ASME Class 2 equipment, PSI is performed on a sample of the welded joints.
The sample is carefully chosen to include those joints with the largest measured discontinuity and the joints which analysis has shown to be the high stress points.
The overall weld selection process is intended to include all worst cases and the sample will be no less than 50% of the welds on the main steam system and 25% of the welds on the balance of the Class 2 systems.
The NRC reviews and approves the selection of welds for inclusion in the PSI program.
The actual PSI tests performed for Class 2 welds are a volumetric examination (UT) and/or a surface test (PT or MT) as required by the ASME Code.
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Q7.
How is the PSI program described above cumulative to other construction inspection and testing of welds?
A7.
ASME Code Section III requires inspection and testing of welds during construction for all ASME Class 1 and Class 2 components.
At Comanche Peak Station, this activity is performed by Brown & Root.
The ASME Section III testing includes x-ray (RT) and dye tests (PT) of the welds.
The PSI tests described above are conducted over and above these construction tests and provide further assurance of the quality of the welds.
Any problems uncovered by PSI are referred to site Engineering for investigation and corrective actions.'
Q8.
Is there any overview of PSI program results?
A8.
Yes.
All tests are observed by an Authorized Nuclear In-
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service Inspector (ANII) and by TUGCO QA/QC observers.
All test results are documented and will become part of the permanent plant records.
0 9 '.
What is the ISI program?
A9.
The in-service inspection program has been developed in accordance with the provisions of ASME Code Section XI.
The program is a long-term program which, as its name indicates, will be carried out during operation of the plant.
The program will be reviewed and approved by the NRC prior to licensing.
Q10. How does the ISI relate to PSI?
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5-A10. During the first ten years of operation, ISI will include inspection of all welds inspected in PSI.
Inspection will be the responsibility of TUGCO Operations.
The PSI results provide the baseline data for comparison with ISI results.
Any degradation in a weld can, therefore, be detected and corrective action can be taken.
This provides another separate verification of the adequacy of ASME welds and provides assurance that inadequate welds will be identified even after many operational cycles.
Oll. Does this conclude your testimony?
All. Yes.
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