ML20205F377
| ML20205F377 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/06/1986 |
| From: | Brombach T CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20205F366 | List: |
| References | |
| 2.206, NUDOCS 8608190176 | |
| Download: ML20205F377 (31) | |
Text
.
ATTACHMENT 2 T
t 9
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE DIRECTOR, OFFICE OF NUCLEAR REACTOR REGULATION In the Matter of )
)'
CAROLINA POWER & LIGHT COMPANY ) Docket No. 50-400 AND NORTH CAROLINA EASTERN MUNICIPAL ) (10 C.F.R. 5 2.206)
POWER AGENCY )
)
(Shearon Harris Nuclear Power Plant) )
AFFIDAVIT OF THOMAS W. BROMBACH County of Wake )
) ss.
State of North Carolina )
Thomas W. Brombach, being duly sworn according to law, de-poses and says as follows:
- 1. I am employed by Carolina Power & Light Company
("CP&L") at the Shearon Harris Nuclear Power Plant as a Project Specialist / Inservice Inspection. In this capacity I am responsi-ble for non-destructive examination ("NDE") of Class 1, 2 and 3 components, piping and their supports to ensure applicable requirements of ASME Code Section XI and 10 C.F.R. S 50.55(a) are met. My business address is Shearon Harris Nuclear Power Plant, Route 1, Box 101, New Hill, North Carolina 27562.
- 2. I have been' actively engaged in NDE and inservice inspection programs at nuclear power plants since 1976. I have
$gOe1}gock $0 0
1
s.
b received extensive NDE training, including ultrasonic testing, visual inspection and eddy current testing / examination. While employed by Virginia Electric and Power Company from 1976 until 1982, I was certified as an NDE examiner. From 1978 to the present I have been employed in supervisory positions, overseeing NDE and inservice inspection activities. Beginning with my early training and experience in the United States Navy, I have seven-teen years of hands-on experience in power plant operations, maintenance and testing. A complete statement of my professional qualifications and experience is appended hereto as Attachment A.
I have personal knowledge of the matters stated herein and be-lieve them to be true and correct.
- 3. The purpose of this affidavit is to address certain issues raised in a " Request for Institution of Proceedings Pur-suant to 10 CFR 2.206" dated July 2, 1986 (" Request"), specifi-cally those allegations regarding inservice inspection of Harris safety-related piping welds. Request at 9-10. Those allegations are based entirely on " problems" described in a January 1, 1986 letter to Atomic Safety and Licensing Board Chairman James L.
Kelley from Ms. Patty S. Miriello ("Miriello Letter") attached to l
the Request. I will show that the allegations, which have previ-ously been investigated by CP&L's Quality Check Program and the NRC I&E, Region II, are without any foundation whatsoever.
- 4. Before addressing Ms. Miriello's allegations I note, for the record, the extent of her qualifications and experience J
s b
to form an opinion regarding NDE of piping welds. During the period beginning in April 1984 through February 1985, Ms.
Miriello was employed by Nuclear Energy Services (NES) as a Data
~
Controller. NES was retained by CP&L to provide NDE testing ser-vices for preservice baseline inspections and examinations of safety-related piping at the Harris Plant. I was responsible for overseeing NES activities. As a Data Controller, Ms. Miriello was responsible for assigning each data sheet with a unique num-ber and reviewing the data for completeness, legibility and accu-racy of certain information. Ms. Miriello coordinated the re-quired reviews by tho NES Technical Reviewer, CP&L reviewers and the Authorized Nuclear Inspector ("ANI"). Her role was purely administrative. While she has an engineering degree and was com-pensated at an Engineer I level by NES, her role and assigned responsibilities were those of a technician. Ms. Miriello was not qualified by training or experience to perform NDE examina-tions or to interpret data from such examinations.
- 5. The Request alleges "approximately 10% of the welds in the inservice program at the Shearon Harris plant are defective and improperly documented." Referring to an f.nstance where data on a calibration data sheet were revised, it is alleged: "These inservice inspection records were altered and changed without following the proper NRC procedure for record revisions on pipe welds." Request at 9-10. The sole basis for these assertions of
- defects in welds and tampering with records is Ms. Miriello's .
I J
s
's letter. Yet, Ms. Miriello never actually points to a defect in welds but rather raises her " concern" that "this sort of thing" (referring either to two NDE examiners disagreeing about " indica-tions" in welds or unauthorized revisions to data sheets) "oc-curred to the best of [her] knowledge in at least 10% of the welds in the inservice inspection program." Miriello Letter at 4.
- 6. In fact, the inservice inspection ("ISI") program is not designed to confirm the quality of construction. Each weld on safety-related piping systems has been inspected by radio-graphy and/or surface examination and the results reviewed for quality and documentation by QA personnel. ISI, rather, is a programmed system of planned, repetitive tests, inspections and examinations carried out prior to initial operations and at regu-lar intervals throughout the service life of an operating nuclear plant. Prior to plant operation, preservice tests and examina-tions establish a baseline against which to compare the results of subsequent inspecticns. Pipe welds are examined by ultrasonic NDE testing to establish baseline data. ISI during plant life can help identify conditions in safety-related systems and compo-nents which could lead to failures, can serve as the basis of ex-tending the design life of plant systems and components, and can enhance reliability. CP&L does not, however, rely on the preser-vice baseline inspection to assure the quality of construction.
-4 J
r
'a
- 7. Ms. Miriello's only specific allegation refers to cali-bration data sheets attached to her letter. Ms. Miriello states:
" Inspection Sheet A [ Attachment 1 to the Miriello Letter] was turned into me and was an official document which could only be revised through a revision process according to plant proce-dures." Ms. Miriello describes how NES Level III lead Technical Reviewer, Mr. Ron Saunders, "took the sheet back" and after argu-ing with the NES inspector, Mr. Mel Perry, about the results on the data sheet, returned it to Miriello with new pages as indi-cated by reference to Sheet B (Attachment 2 to the Miriello Let-ter). Miriello Letter at 2. Ms. Miriello finds this procedure
" questionable." She notes "that the mention of a weld or repair weld was eliminated from page 4 of the original Mel Perry turned in." She claims, "[allso removed was the listings of indications in this weld, referring specifically to indications #9 and #12."
Id. at 2-3.
- 8. In an unannounced inspection by the NRC I&E, Region II, held December 2-6, 1985, CP&L's preservice inspection of safety-related piping welds at Harris was reviewed in detail. The NRC IEE inspectors had previously been provided with copies of the same data calibration sheets attached to Ms. Miriello's letter.
The Inspection Report of the results of the inspection (Report No. 50-400/85-48 dated July 15, 1986) is appended hereto as Attachment B. The NRC inspectors' review of Preservice and In-service Data Control Procedure, IST-101 Rev. I and the manner in J
n which revisions were made to NES data sheets, led to a notice of violation (Severity Level V) for failing to correct data sheets as prescribed in Paragraph 5.2.e of IST-101 -- which requires corrections to be completed by a single line drawn through the incorrect entry, initialed and dated by the responsible individ-ual, and the corrections made. While thu NRC found fault with the method used to correct errors on data sheets, independent inspections of the welds in question by NRC inspectors confirmed in all cases the correctness of data as revised. ,In fact, the NRC inspectors themselves noted a problem in defining the bound-ary of the weld metal in the welds in question which " caused many of the data corrections made by the NDE lead examiner and could be identified in nany cases as ultrasonic beam redirection to the ID (inside diameter]." Attachment B at 7-8. The mention of "a weld or repair weld" that "was eliminated from page 4" referred to by Ms. Miriello was a proper correction as the refer'ence to the repair weld was not applicable to the entire weld circum-ference. This notation, however, was not removed from page 3 of 5 on Sheet B and was in the same location on indication #1 as indication #2 on page 2 of S. Indication #9 and #12, claimed to have been removed from the dsta sheet, were not removed. Only the classifications of these indications were clarified. On Sheet A they were noted as " geometric reflectors or small indica-4 tions," on Sheet B they were specifically noted, correctly, as
" geometric reflectors."
l t
i J
n b
- 9. NES and CP&L had interpreted Procedure IST-101 as requiring changes pursuant to Paragraph 5.2.e only after the NES review process was complete. NES had viewed Sheet A as an inprocess document, as it had not been reviewed or accepted by the lead Technical Reviewer, Mr. Saunders. Thus, rewriting a data sheet with incorrect entries was not viewed as inconsistent with the procedures as long as the lead Technical Reviewer had not accepted the data. This issue rc.ises no more than an honest difference in interpretation of a procedural requirement.
- 10. Ms. Miriello quotes selectively from the ASME Boiler and Pressure Vessel Codes,Section XI, and asserts that CP&L's practices are in violation of the ASME Code. Miriello Letter at 3. In fact, CP&L's Ultrasonic Testing Procedure IST-501 re-quires recording all indications that exceed 20 percent of the reference level. The ASME Code Section XI, Article IWA-2232 (b)(1), states that "for examination of welds reflectors that produce a response greater than 50% of the reference level shall be recorded." Note that the indications that Ms. Miriello brings to the Director's attention -- all with a response less than 50% -- need not be recorded, based on the requirements of the ASME Code as adopted in 10 C.F.R. 5 50.55a. CP&L has adopted a standard for recording indications that is 50 percent more strin-4 gent than required by Code to acquire a very conservative base-line data, providing useful information if recording criteria ever change with new code additions and subsequent years of plant life.
1
i 4
- For the record, Ms. Miriello never brought the data 11.
I sheets attached to her letter to my attention nor did she bring any similar concerns to my attention while she was employed by NES. When Ms. Miriello was terminated from employment at Harris and was interviewed by QA personnel as part of the Quality Check Program, she never brought to Quality Check personnel any allega-tions with respect to quality of the welds at the Harris Plant.
Instead, she took unauthorized copies of weld data sheets for her later use.
- 12. Ms. Miriello makes something of a file kept by Mr. Ron Saunders of ISI records that were " changed on the side without a revision as required by procedure." Miriello Letter at 5. This file kept by Mr. Saunders was reviewed by me, by the ANI and by the NRC. This review showed that the NDE data was not being incorrectly changed or revised. All parties accepted Mr.
Saunders explanation that he had viewed the revision procedure not applicable to inprocess documents that had not been finalized by the lead NES Technical Reviewer.
- 13. It is untrue that I cautioned Mr. Stark, the ANI, or Ms. Miriello to keep discussions to themselves when the NRC was around. See Miriello Letter at 7.
- 14. For the record, I never received phone calls from I&E, Region II, or anyone else alerting me in advance of inspections.
When NRC inspectors arrive at the Harris Plant they hold an en-trance interview with applicable plant personnel and discuss the ,
i
a areas of interest. These meetings are often held early in the morning and might account for my informing Plant personnel of a pending inspection. Sea Miriello Letter at 7.
- 15. In summary, Ms. Miriello may have identified a techni-cal discrepancy in the way NES corrected preliminary data in data sheets. The information presented in Ms. Miriello's letter does not support the assertion that any welds in the safety-related piping at the Harris Plant are defective or that there has been any intentional alteration of inspection records.
Her allegations have been investigated by NRC I&E, Region II, the CP&L Quality Check Program and by me and were found without basis.
CA hip _ ,
ThomasW.Brdgbach \
Subscribed and sworn to before me this LA day of August, 1986.
E l/ &
My Commission Expires: 3[2 C 8~/
s
', 4
,, ATTACHMENT A Resume THOMAS W. BROMBACH EDUCATION MILITARY
- Basic Propulsion and Engineering School
- Machinist Mate "A" School
- Water Treatment School
- Power Plant Maintenance School
- Damage Control School
- Fire Fighting School
- Submarine School
- Nuclear Power School (25 weeks)
' Hydraulic and Pneumatic School
- AC & R School
- Magnetic and Liould Penetrant School -
- 3M Records Manacement School l
- Radiological Control School '
l CIVILIAN
- High School Graduate
- 5 Semesters of Collece
- Continuing Education Units Awarded for
-Magnetic Particle Insoection '
-Liquid Penetrant Inscoction
-Ultrasonic Weld Inspection
~ASME Section XI Short Courses
- Formal 5 1/2 Year Journeyman Power Plant Mechanic Apprenticeship
,
- Company Sponsored Schools: ,
-Dresser Valve School I
-Radiation and Radiological Control School
-Grinnel Valve School
-Milton Roy Pump School
-Non-destructive Testing Schools for MT, PT,
. VT and Eddy Current Tube Inspection
-Multifrecuency Eddy Current Examination l ,, ,,,
-Personnel Manacement l
-Aberrant Behavior
, PROFESSIONAL MEMBERSHIPS l
l ,American Society of Mechanical Encincors
', 9 *
,, ATTACHMENT A Resume THOMAS W. BROMBACH EDUCATION MILITARY Basic Propulsion and Engineering School
- Machinist Mate "A" School
- Water Treatment School Power Plant Maintenance School Damage Control School Fire Fighting School
- Submarine School
- Nuclear Power School (25 weeks)
Hydraulic and Pneumatic School
- AC & R School
- Magnetic and Licuid Penetrant School ~
- 3M Records Manacement School Radiological Control School '
CIVILIAN High School Graduate
- 5 Semesters of Collece
- Continuing Education Units Awarded fort
-Magnetic Particle Inscoction -
-Liquid Penetrant Inspection
-Ultrasonic Weld Inspection
-ASME Section XI Short Courses
- Formal 5 1/2 Year Journeyman Power Plant Mechanic Apprenticeship
- Company Sponsored Schools:
-Dresser Valve School -
-Radiation and Radiological control School
-Grinnel Valve School
-Milton Roy Pump School
-Non-destructive Testing Schools for MT, PT,
_ VT and Eddy Current Tube Inspection
-Multifrequency Eddy current Examindtjen
-Personnel Management
~~ ' ~ ~
-Aberrant Behavior PROFESSIONAL MEMBER.9 HIP,.9
,American. Society of Mechanical Engineers J
EMPLOYMENT September 1982 CAROLINA POWER .& LIGHT COMPANY to SHEARON HARRIS NUCLEAR POWER PLANT Present Project Specialist / Inservice Inspection Scoce of Responsibility Responsible for developing and maintaining the Harris Plant's inservice inspection ("ISI") program in accordance with, and as required by, ASME Code Section XI to assist in meeting NRC, plant Technical Specification, operating license, and other related plant and regulatory requirements. The ISI program is developed based on the latest regulatory require-ments. The ISI program provides direction and support of inservice inspection related tests such as hydrostatic testing, weld inspections, and eddy current testing.
Major Functions
- 1. Developing and maintaining an inservice inspection -
program for welds by working with Operations and Mainte-nance. -
- 2. Coordinating inservice inspection activities and schedules.
- 3. Developing, updating, and maintaining ASME Code Sec-tion XI inspection programs.
- 4. 'aintaining interface responsibilities amonc the M
Plant's organizations to ensure the ISI program is imple-mented effectively.
- 5. Analyzing and providing resolution to Plant problems resulting from ISI.
- 6. Preparing and monitoring budcet items certaining to ISI.
- 7. Staying updated on changes to, and latest recuire-ments of, the ASME Code.
- 8. Responsible for ensuring the proper maintenance of inservice inspection records, deficiencies and resolu-tions. .
l
. l f
March 1976 VIRGINIA ELECTRIC AND POWER COMPANY to SURRY NUCLEAR POWER STATION ,
August 1982 Engineering Supervisor of Non-destructive l Testina and Evaluation Scope of Responsibility Performed unit and component testina in the field of non-destructive examination and provided evaluation of test re-sults to insure component and vessel integrity.
Maior Functions
- 1. Conduct inservice and preservice inspections to assure compliance with ASME Code Section XI and plant technical specifications.
- 2. Provide non-destructive testing services for the station, i.e.: PT, MT, RT, VT, UT and ET, in accordance with ASME Code Sections III, IV, IX and XI and other designated applicable codes as required.
- 3. Coordinate inspection services with the desig-nated ANSI to ssure full compliance with the ASME Code in effect.
- 4. Provide eddy current examination services to meet the reauirements of USNRC Reculatory Guide 1.83 and ASME Code Section XI for steam genera-tors.
- 5. Provide eddy current examination services in ex-amination of condenser and other various heat exchanger tubing.
- 6. Prepare and submit inservice, preservice and eddy current reports.
- 7. Assist Engineering in identifyino generic prob-lems and working toward solutions.
- 8. Support and implement additional training pro-grams for NDT technicians to keep personnel abreast and trained in new field developments.
- 9. Establish and maintain appropriate records man-agement of all work conducted.
- 10. Prepare and submit budgets for procurement of equipment, supplies and arrange for contractor i
and vendor services.
. _ ._ _- _ _ . _ _ -. - -- - _- - . _ _ _ - - - _ . _ - - _ _ _ - _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ ~ _ _ _ _ -
, , e ,
e
- 11. Provide schedules and commitment dates during plant outages for' inspection services.
- 12. Review and implement non-destructive examination procedures.
w (
- 13. Certified in accordance to ASNT-TC-1A as a LEVEL II in Visual, Liquid Penetrant, . Magnetic Parti-
- cle and Eddy Current examinations and LEVEL I in
. Ultrasonic Testing.
Also prior to being promoted to a supervisory position, I was a journeyman mechanic providing round-the-clock maintenance and repair to all station eauipment, i.e.: pumps, valves, hy-draulic and pneumatic systems, HVAC, steam turbines and auxil-lary systems on both the primary and secondary sides of the L plant. A collateral duty was to travel to various fossil fuel plants within the.VEPCO system and conduct maintenance and re-pair on high pressure power boilers, coal systems and other plant systems.
II September 1975 NEWPORT NEWS SHIPBUILDING AND DRYDOCK, CO.
to ,
Newpo.rt News, VA March 1976
- Power Plant Operator, Utilities Department
, Assioned to the operation of the main power plant and all substations -- maintaining and operating 600 lb. boilers, air compressors and related equipment supplying power steam and compressed air to the shipyard.
September 1974 COLLEGE OF DUPAGE to " Glen Ellyn, Illinois September 1975 Assistant Chief of Plant Operations i
l I
Responsible for the operation of the steam generating and air conditioning plant, in addition to which, performed all ra-pairs as necessary to its plumbing, hydraulic, pneumatic and electrical systems. Collaterally responsible for the mainte-nance of the buildings and all service support systems.
3* April 1974 FACTORY MUTUAL ENGINEERING CO.
to Chicago, Illinois September 1974 Boiler & Machinerv Inspector j' Conducted on-site physical inspections of steam generating power plants and machinery for compliance with ASME, state and local codes.
January 1969 UNITED STATES NAVY to E-4 Machinist Mate December 1973 l
8 ATTACHMENT B n Etig%
UNITED STATES RECEIVEE ".".1 3. "388 e NUCLEAR REGULATORY COMMISSION y REGION ll
- 0 101 MARIETTA STREET,N.W.
E f ATLANTA, GEORGIA 30323
\.....,/ JUL 151986 -
Carolina Power and Light Company ATTN: M.. E. E. Utley Senior Executive Vice President Power Supply and Engineering and Construction P. O. Box 1551 Raleigh, NC 27602 Gentlemen:
SUBJECT:
REPORT NO. 50-400/85-48 On Decembe- 2-6, 1985, NRC inspected activities authorized by NRC Construction Permit No. CPPR-158 for your Harris facility. At the conclusion of the inspec-tion, the findings were discussed with those members of your staff identified in the enclosed inspection report. -
Areas examined during the inspection are identified in the report. Within these -
areas, the inspection consisted of selective examinations of procedures and representative records, inte. views with personnel, and observations of activities in progress. The inspectors also conducted iridependent measurements, utilizing Region II ultrasonic equipment at your site, to verify your capability for performing ultrasonic examinations and analyzing examination results.
The inspection findings indicate that certain activities violated NRC require-ments. The violations, references to pertinent requirements, and elements to be included in your response are presented in the enclosed Notice of. Violation.
Your attention is invited to unresolved items identified in the inspection report. These matters will be pursued during future inspections.
The responses directed by this letter and the enclosures are not subject to the clearance procedures of the Office of Management and Budget issued under the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this letter, please contact us.
. Sincerely, 0
i WY 4 fAL id M. V relli, Chief R actor Projects Branch 2 Division of Reactor Projects
Enclosures:
(Seepage 2)
,., JUL 151586
% Carolina Power and Light Company 2
^
Enclosures:
- 1. Notice of Violation
- 2. Report No. 50-400/85-43 cc w/encls:
R. A. Watson, Vice President i Harris Neclear Project
- *E ""
- OI b' W kIIh '#1kfit be0$r$$
. k!Sageh # I i
e e
9 d
4 5
f l
I l _
)
l 4
ENCLOSURE 1 NOTICE OF VIOLATION Carolina Power and Light Company Docket No. 50-400 Harris License No. CPPR-158 The following violations were identified during an inspection conducted on December 2-6, 1985 and a subsequent in-office review on December 12, 1985. The Severity Levels (10 CFR Part were assigned 2, Appendix C). in accordance with the NRC Enforcement Policy 1.
10 CFR 50.55a paragraph (g) subparagraph (2) allows the licensee to use the American Society of Mechanical Engineer (ASME) Code Section XI, 1980 Edition with addenda through the winter 1981. Carolina Power and Light Company's Inservice Inspection Program delineated in Procedure Number ISI-201 Revision 1, the ASME Code,1980 Edition, with addendas through winter 1981. -
Contrary to the above, Nuclear Energy Service, Inc. (NES) Inservice Inspection Procedures IST-501 (Rev.1) and IST-401 (Rev.1) were written to the ASME Code,1980 Edition with addendas through winter 1982.
This is a Severity Level V violation (Supplement II).
2.
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accom-plished in accordance with these instructions procedures or drawings. NES Preservice and Inservice Data Control Procedure IST-101 Rev.1, Para-graph 5.2.E. requires that corrections to data reports are to be completed by a single line drawn through the incorrect entry, initialled, and dated by the responsible individual when the correction is made.
Contrary to the above, on December 2-6, 1985, examination data sheets were observed where the NES Nondestructive Examination (NDE) Lead Examiner, had written " rewrite" on initial examination data sheets that had been signed by an NDE examiner and given a control number. In some instances technical entries of evaluations were changed on the rewritten data sheets.
This is a Severity Level V violation (Supplement II).
Pursuant to 10 CFR 2.201, you are required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the. results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.
-- _ __,-%, - . _ . .r. ., . _ . , _ , -__ v--
O
\ Carolina Power and Light Company 2 Docket tiu. 50-400 Harris License No. CPPR-158 Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.
Date: JUL 151986 e
i e
l i
I- - - - - - . - -- - __ .__ _ .._ ,_ ,__.. _._ ___ __ _ , , _ __ _ _ _ _ _ _ _ _ _
. UNITED STATES
[A strg% NUCLEAR REGULATORY COMMISSION O 1 RE21 N 11 7 o 101 MARIETTA STREET,N.W.
b U f ATLANTA, G EORGI A 30323
\ .... /
+
Report No.: 50-400/85-48 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket No.: 50-400 . License No.: CPPR-158 Facility Name: Harris 1 Inspection Conducted: December 2-6, 1985 Inspectors: iv 7 /- /L 8s R. W. Newsomh Date Signed kld.Etriey Juw b, /-N !L -
J. f Date Signed Approved by: w - -
/ /!/3 6 J. . Blaire, Section Chief D&te Signed E ineering Branch .
D vision of Reactor Safety
SUMMARY
Scope: This routine, unannounced inspection entailed 65 inspector-hours at the site in the areas of preservice inspection (PSI) of safety-related piping welds including review of procedures, observation of work, data review and evaluation",
and independent ultrasonic verification examinations; also, general observation of construction activities, construction progress and material storage.
Results: Two violations were identified - Preservice examination procedures incorrectly reference subsequent code addendas - paragraph 6.a.(5): Failure to follow procedure for correction of examination data, paragraph 6.a.(6).
9
I
\ l REPORT DETAILS
- 1. Persons Contacted Licensee Employees
- J. Harness, Assistant Plant Manager
- N. J. Chiangi, Manager, Quality Assurance / Quality Control (QA/QC)-
- C. R. Gibson, Assistant to Plant Manager
- R. 8. Van Metre, Manager, Technical Support
- C. L. McKenzie, Director, OA/QC, Operations
- C. R. Osman, Principal QA/QC Specialist
- T. W. 8rombach, Project Engineer, Inservice Inspection (ISI)
- P. W. Howard, Regulatory Compliance
- M. G. Wallace, Regulatory Compliance Other licensee employees contacted included construction craftsmen, -
engineers, technicians, security force members, and office personnel.
Other Organization ~
- R. Saunders, level III Examiner, Nuclear Energy Service, Inc. -
NRC Resident Inspector
- G. Maxwell, Senior Resident Inspector
- Attended exit interview
- Attended exit interview and contacted by telephone on December 12, 1985
- Contacted by telephone on December 12, 1985 '
i 2. Exit Intec<few
' The inspection scope and findings were summarized on December 6,1985, with those persons indicated in paragraph 1 above; on December 12, 1985, Region II held a conference telephone call with the persons indicated in paragraph 1. The purpose of the call was to inform the licensee that after further review of the PSI data and procedural requirements, and in-office discussions between the inspectors and regional management it was concluded that one item reported on December 6, as an unresolved item - (Preservice l examination procedures incorrectly reference subsequent code addendas) would be upgraded to a violation.
unresolved . item) were alsoTwo new additional items (one violation and one
~
reported to the licensee. The inspectors described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee. The following new l
items were identified during the inspection and subsequent in-office review.
[ .
L
^
i 1* .
l t
1 2 (0 pan) Violation-50-400/85-48-01, Preservice Examination Procedures Inccrrectly Reference Subsequent Code Addendas - paragraph 6.a.(5).
(Operd Violation 50-400/85-48-03, Failure to Follow Procedure for Correction -
of Ex tr.lination Data - paragraph 6.a.(6).
(0 pen) Unresolved Item 50-400/85-48-02, Power Wire Brushing Prior to Surface Examinations - paragraph 6.a.(3),
(0 pen) Unresolved Item 50-400/35-48-04, Independent Technical Review of Examination Data - paragraph 6.a.(7).
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during tnis inspection.
- 3. Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection. -
- 4. Unresolved Items .
Unresolved Items are matters about which more information is required to determine whether they are acceptable or may involve a violation or deviation. Two new unresolved items identified during this inspection are discussed in paragraphs 6.a.(3) and 6.a.(7).
- 5. Independent Inspection Effort (92706)
The inspectors conducted a general inspection of the containment, auxiliary' building, and material storage areas to observe construction progress and construction activities such as welding, material handling, housekeeping an'd storage. The inspectors did not observe any questionable workmanship. The inspectors also observed that material protection, handling, and storage appeared adequate.
Within the areas examined, no violations or deviations were identified.
- 6. Preservice Inspection (PSI)
The inspectors examined documents, activities, and records, as indicated below, to determine whether PSI was being conducted in accordance with applicable procedures, regulatory requirements, and licensee commitments.
The applicable code for PSI is the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME B&PV) Code,Section XI,1980 edition with addenda through' winter 1981. Nuclear Energy Services (NES) has responsibi-lity as the PSI contractor. However, nondestructive eddy current
! examinations had been conducted by Conam Inspection and Technical Services Laboratory (TSL) . NES Level III examiners are performing the ultrasonic examination evaluations.
1 r
g 3
- a. Review of Procedures (730528)
(1) The following procedures were reviewed in the areas of procedure approval and qualification of NDE personnel:
Procedure No. Title IST-501 (R1) Chg. 1/1 Procedure for Ultrasonic Examination of' Piping Systems (NES) 80A5051(RO) Ultrasonic Examination Procedure for Reactor Vessel Welds From the 00 Surface 80A5036 (RO) Procedura for the Operation of the RPV ID Examination Positioning Device for the Inside Surface Ultrasonic Examination of the -
Reactor Pressure Vessel for Shearon Harris Nuclear Power -
Plant Unit 1 80A5037 (R1) Automated UT Examination Procedure '
for Reactor Vessel Shell Welds (Plus Field Changes FC-1 through FC-7) 80A5040 (RI) Automated Ultrasonic Examination l . Procedure for Reactor Vessel Nozzle to Shell Welds ,
80A5050 (RO) Manual Ultrasonic Examination Procedure for Vessel Nozzle Safe End Welds (Plus Field Change FC-1)
IST-401 (RI) Chg. 1/1 Liquid Penetrant Examination (Color Contrast, Solvent Removable) NES IST-604 (RO) Multifrequency Eddy Current Procedure for Westinghouse 04 Steam Generator Tubing Using The MIZ-18 Digital Eddy Current System (Conam Inspection)
! IST-101(RI) Preservice and Inservice Data Control Procedure (NES) l l
y 4 (2) The inspectors also reviewed the above listed ultrasonic examina-tion procedures to ascertain whether they had been reviewed and approved procedures.in accordance with the licensee's established QA The above procedures were reviewed for technical adequacy and conformance with ASME,Section V Article 5 and other license commitments / requirements in the below listed areas: type :
of apparatus used, axtent of coverage of weldment, calibration requirements, search' units, beam angles, DAC curves, reference 1 level for monitoring discontinuities, method of demonstration of penetration, ifmits for evaluating and recording indications, recording significant indications, and acceptance limits.
(3) The inspectors also reviewed the liquid penetrant procedure, IST-401, to ascertain whether it had been reviewed and approved in accordance with the licensee's established QA procedures. The above procedure was reviewad for technical adequacy and conformance with ASME,Section V, Article 6, and other licensee commitments / requirements in the following listed areas: specified' me thod , penetrant materials identified, penetrant materials nalyzed for sulfur, penetrant materials analyzed for total halogens, acceptable pre-examination surface, drying time, method-of penetrant application, surface temperature, solvent removal, dry surface prior to developing, time and method for applying '
developer, examination technique, and evaluation technique.
While reviewing the liquid penetrant examination procedure, the inspectors noted that power wire brushing of surfaces prior to liquid penetrant examination was allowed by the procedure. This practice may close surface openings and be detrimental to the penetrant examinations. This concern was discussed with the , ,
licensee who has agreed to address the power wire brushing issue and make appropriate changes to resolve the issue. Pending NRC review of the actions taken regarding this concern the matter will i be identified as Unresolved Item 50-400/85-48-02, Power Wire Brushing Prior to Surface Examinations.
(4) The inspectors reviewed Eddy Current Procedure, IST-604, for technical content relative to: multichannel examination unit, multichannel examination equipment is specified, examination sensitivity, material permeability, method of examination, method of calibration and calibration sequence, acceptance criteria, qualification of NDE personnel, and procedure approval.
(5) During the review of procedures IST-501 (R1), Ultrasonic Examina-tion and IST-401 (R1), t.iquid Penetrant Examination, the inspectors noted that these . procedures were written to satisfy the requirements of ASME Section XI 1980 edition with addenda through winter 1982. Since the " Code of Record" committed to by the licensee is the ASME Section XI 1980 edition with addenda through
% 5 winter 1981, as stated in their Preservice Inspection Program (RI)
~
submitted to the Office of Nuclear Reactor Regulation (NRR), the inspectors discussed this discrepancy with the licensee. The licensee indicated that he had discussed this point with NRR but was unable to produce documentation supporting this discussion and there did not appear to be a formal request to NRR which would allow the licensee to use the winter 1982 addenda. The licensee is in violation of Title 10 code of Federal Regulations Part 50.55a paragraph (9) subparagraph (2) which requires the licensee to use ASME Section XI 1980 Edition with addenda through winter 1981 if authorization from the Director of the Office of Nuclear Reactor Regulation has not been obtained. This item is identified as Violation 50-400/85-48-01, Preservice Examination Procedures Incorrectly Reference Subsequent Code Addendas.
(6) On December 4, 1985, the NRC inspectors conducted verification examinations on a selected sample of welds that included examples of welds where technical changes to the examination data had been-made as a result of data rewrites. The NES NDE lead examiner was invited to accompany the inspectors during these verification -
examinations and it quickly became apparent that the NDE lead examiner was very familiar with the examination of the specific welds involved although in some cases there was no documented evidence that he had ever examined the weld. The lead examiner knew specific locations of welds even when they were not visually discernible due to surface contouring for PSI and in one case because of cladding on the pipe base material. He was also able to tell the inspectors how to manipulate their transducer to see specific indications and how and where te dampen specific signals when it appeared that the signal could not be dampened. The NRC, inspectors verification examinations were performed using Region II's ultrasonic equipment and the examinations compared favorably with the final examination data and evaluations made by NES (see paragraph 6.b.2 of this report for sample selection and conclusions by the inspectors).
On December 5,1985 the NES NDE lead examiner was requested to perform a liquid penetrant examination on a weld where the initial examination data indicated that the rewrite had altered the reported results. The re-examination confirmed the results reported in the final report with some small differences noted in the reported indication size. The inspectors did not detect any problems with the final examination data when compared to the components involved.
During the inspectors in-office review on December 12, 1985, of the Preservice and Inservice Data Control Procedure, IST-101 Rev. I and NES inspection data reports obtained by Region II, changes were observed to technical entries on data sheets prior to the completion of the NES review process that were not in
V 6 accorda'nce with paragraph 5.2.E. of the data control procedure. 1 Paragraph 5.2.E requires that corrections to data reports are to be completed by a single line drawn through the incorrect entry, initialled and dated by the responsible individual when the correction is made. Examination data sheets were observed in some instances where the NDE lead examiner hid written " rewrite" on the i initial examination data sheet that had been signed by the ;
examiner and given a control number. In most cases a new data sheet would be submitted on the same day as the initial data sheet, however in some instances technical entries or evaluations would change with no explanation or evidence of additional investigation. The methnd used to correct examination data sheets was not in accordance with paragraph 5.2.E. of the data control procedure IST-101, and is in violation of 10 CFR-50 Criterion V.
This item was reported as Violation 50-400/85-48-03, Failure to Follow Procedure for Correction of Examination Data.
(7) In addition to the item reported aoove, the inspectors review of -
NES Procedure IST-101, R1, revealed that the diagram for data flow, illustrated in Attachment 1 cf the procedure, delineated the -
NES NDE lead examiner to review the examination data for technical and administrative accuracy and then in a subsequent step allowed the same individual to sign-off the data as the technical reviewer. This method of controlling data is inappropriate when it results in the individual signing off data that he previously had input to. The licensee was notified of this conflict in data review / flow on December 12, 1985, when the itsu was reported to l the licensee as Unresolved Item 50-400/85-48-04, Independent Technical Review of Examination Data.
- b. Observation of Work and Work Activities (730538)
The inspectors observed a limited amount of work activities due to the limited number of examinations being performed and the time required for independent ultrasonic verification examinations utilizing Region II equipment and personnel. The inspectors reviewed certifica-
! tion records of equipment, materials, and NDE personnel which had been and will be utilized during the required PSI examinations. The reviews conducted by the inspectors are documented below.
(1) Examiner Qualification The inspectors reviewed the qualification documentation for the below listed NES, CONAM and TSL examiners in the following areas:
- l. employer's name, person certified, activity qualified to perform, effective period of certification, signature of employer's designated representatives, basis used for certification, and annual visual acuity, color vision examination and periodic recertification.
t 7 Method - Level Examiner (CONAM) UI PT MT RT EC JEC - - - -
II A GRT - - - -
II ltd REM - - - -
III Method - Level Examiner (NES) UT PT MT RT EC MOA I II I - -
CAA II II II - -
RSB II II - - -
PNG I II I - -
GG II II II - -
JTH II - - - - -
SM -
II II - -
MS -
II II - - -
RTS III III III - - -o Method - Level -
Examiner (TSL) UT PT MT RT EC j RMB - - - -
III SDG - - - -
II l
, CMC - - - -
I (2) The inspectors conducted verification ultrasonic examinations ~
using Region II's equipment on portions of the below listed welds.
The examinations were performed in order to evaluate the technical adequacy of the ultrasonic examination procedures being used to perform preservice ultrasonic examinations and to assess the validity of the information being reported by the ultrasonic i examiners. The ultrasonic examination procedure used to perform the verification examinations was IST-501 (RI) Chg. 1/1.
Weld ID ISO No. Size 1-SW-FT-601 1-ISI-SI-29 3" S1-13-1-SW-4 1-ISI-CS-7 4" i 1-CT-SW-E4 1-ISI-CT-1 8" 1-RC-SW-A3 1-ISI-RC-23 6"-
RC-2-FW-7 1-ISI-FW-MS-RC-2 31" 1-AF-SW-84 1-ISI-AF-7 4"
) '
I T 8
i The v.erification ultrasonic examinations conducted by the inspectors indicated that the procedures being used to conduct the preservice examinations are adequate and that the information being report:d by the ultrasonic examiners compares favorably with the verification examinations. The verification examinations also indicated that a conservative examination was being performed.
The only problem encountered by the inspectors was in defining the boundary of the weld metal in pipe joints due to the quality of surface grinding and in one specific instance, due to clad welding on the pipe base metal. The inspectors were able to over come this problem by using an additional instrument and a compressional wave transducer to continuously monitor the inside diameter (IO) surface configuration. These problems caused many of the data corrections made by the NDE lead examiner and could be identified in many cases as ultrasonic beam redirection to the 10.
(3) The following listed ultrasonic equipment and materials certifi- -
cation records were reviewed:
Ultrasonic Instruments -
Manufacturer / Model Serial No.
Sonic MXI 781306 KK USL-48 212200 AI S-80 10244-9 Minature Angle Beam Calibration Blocks Serial No. 783913
- Serial No. 785363 Ultrasonic Couplant Batch Numbers Ultragel II 8336 & 8443 Ultrasonic Transducers Size Frecuency Serial No.
.5" 2.25MHz E20000 1.0" 1.0MHz J22462 1.0" 1.0MHz J22463 1"x1" 1.0MHz F30199
.5" 2.25MHz L-19108
.5"x1.0" 2.25MHz 8 3388
.312"x.625" 2.25MHz A 3342 I
- - - . _ _ . - - - y
- - _ _ _ _ _ _ _ _ - _ ---,--,.m-, -- - - - , - ,
9 (4) Magnetic particle yoke serial number 6853 was used for the performance of PSI examinations. The inspectors reviewed the lift test qualification documentation to verify controlling document requirements were met.
(5) The inspectors observed the liquid penetrant examination of weld 1-RH-SW-0198 on ISO 1-ISI-RH-2. The observation was compared with the applicable procedure and the Code in the following areas:
specified method, penetrant materials identified; penetrant materials analyzed for halogens and sulfur; acceptable pre-examination surface; drying time; method pf penetrant application; penetration time; surface tempera ture; solvent removal; dry surface prior to developing; type of developer; examination technique; evaluation technique; and reporting of examination results.
The above examination resulted in the enhancement of two linear indications, one indication was above the other and both measuring-3/32" in length. Both indications were acceptable to Section XI of the ASME Code and compared favorably to the licensee's final -
liquid penetrant examination data sheet. -
(6) The inspector reviewed the below listed penetrant material .
certification records to ascertain if the sulfur and halogen content of the material was within acceptable content limits.
Materials Batch Number Liquid Penetrant 828058, 83K052, 83M015 Cleaner / Remover 82X080, 84J040, 84M021 Developer 82J062, 84J002, 83LO94 -
(7) The inspectors reviewed the qualification documentation for the below listed TSL & CONAM eddy current equioment to verify controlled documents were met.
TSL MIZ-18's Serial Numbers 052 & 075 CONAM MIZ-18 Serial Number 007 (8) The inspectors reviewed certification documentation for the eddy current calibration standard identified as Z1292, Heat No. 2185.
- c. PSI Data Review and Evaluation (73055)
Records of completed nondestructive examinations were selected and reviewed to ascertain whether: the method (s), technique and extent of the examination complied with the ISI plan and applicable NDE procedures; findings were properly recorded and evaluated by qualified personnel; programmatic deviations were recorded as required; personnel, instruments, calibration blocks and NDE materials (penetrants, couplants) were designated.
l
O 10 V
(1) Records selected for this review are listed below:
Iso. No./ Item Weld I.D. NDE Method 1-ISI-FW-MS-RC-1 1-MS-SW-86 UT 1-MS-SW-83 UT 1-RC-SW-N5 UT 1-RC-SW-06 UT 1-RC-SW-P6 UT 1-ISI-RH-2 1-RH-FW-17(A) UT 1-ISI-51-29 1-SW-FW-601 UT 1-ISI-CS-7 S1-13-1-SW-4 UT 1-ISI-SI-10 SI-SW-C8 UT 1-ISI-CT-1 1-CT-SW-E4 UT 1-ISI-CT-14 1-CT-FW-185 UT 1-ISI-RC-23 1-RC-SW-A3 UT 1-ISI-FW-MS-RC-2 RC-2-FW-7 UT 1-ISI-AF-7 1-AF-SW-84 UT -
1-ISI-FW-MS-RC-2 1-FW-FW-486 UT 1-FW-SW-E3 UT _
~
Reactor Vessel Shell 1-SH-RV-010 UT Weld 1-SH-RV-004 UT .
Reactor Vessel Inlet Nozzle to Shell Weld UT Nozzle at 335' Reactor Vessel Inlet Nozzle to Shell Weld UT Nozzle at 95*
Nozzle to Safe End Reactor Vessel Safe UT End at 335' Reactor Vessel Safe Nozzle to Safe End UT End at 145*
1-ISI-FW-MS-RC-3 1-MS-FW-255 MT 1-MS-SW-A3 MT 1-MS-SW-A3A MT 1-MS-SW-A3B MT 1-RC-SW-03 PT 1-RC-SW-P8 PT 1-RC-SW-N6 PT 1-RC-FW-5 PT 1-RC-SW-02 PT Reactor Vessel Safe 1-SH-SR-01 PT End
11 4
1-ISI-RH-2 1-RH-SW-0198 RH-2 PT RH-FW-17 RT CT-15 *CT-FW-185 CS-7 RT
- SI-13-1-SW-4 RT SI-10 SI-SW-C8 RT RC-23 *RC-SW-A3 SI-29 RT SI-FR-601 RT RH-2 RH-SW-019 RT CT-1 *CT-SW-E4 AF-7 RT
. *1-AF-SW-84 RI
- Construction radiographs were reviewed to confirm ultrasonic signal reflector locations.'
(2) The eddyinspectors current examinations.reviewed records of the Steam Generator (SG) tubing The reviews were compared with the applicable procedures and the Code in the following areas: the multi-channel eddy current examination equipment has been identified including indicator, meter, tube, strip recorder, and -
tape; method for maximum sensitivity js . applied; method for determining material permeability recorded; material permeability _
has been recorded; method of examination has been recorded; examination equipment has been calibrated in accordance with the -
applicable performance reference; amplitude and phase has been calibrated with the proper applicable calibration reference and is recalibrated at predetermined frequency; 100% coverage of steam generator tubes occurs during the examination; and acceptance criteria is specified or referenced and is consistent with the procedure or the ASME B&PV Code.
The tubes selected for review by the NRC inspectors were ~
originally examined by CONAM and sometime later independently examined again by TSL. The objective of the examination by TSL l
was to assure the validity of tra examinations conducted by CONAM.
The data comparisons made by the NRC inspectors indicated that with the exception of a few minor deviations due to probe speed
- and independent calibration curves the data generated by the two independent examinations compared favorably. Examination data for the tubes listed below was used by the NRC inspectors to make this comparison.
). 12 TUBE 10 Row - Column SG-A T- 6 15 - 74 15 - 86 41 - 74 10 - 8 29 - 14 SG-8 5- 1 20 - 45 33 - 46 15 - 50 22 - 33 41 - 29 SG-C 14 - 77 29 - 29 5- 23 . .
21 - 21 22 - 33 -
31 - 34 Within the areas examined, no violations or deviations were identified, except as reported in paragraphs 6.a(5) and 6.a(6) above. ,
T
1 i
Farm 80248 ATTACHMENT 3 i 5/s4 i QCP Case Number ]
(Assigned by QCP Coordinator) l DfPLOYEE EXIT QUESTIONNAIRE
- 1. Were you provided o entation on the Harris Nuclear Project Quality Check program? Yes No
- 2. Have you reported any concerns or allegations in regard to the design, ,
fabrication, construction, test, start- or inspection of the Harris '
Nuclear Project? Yes No *
- 3. If you reported concerns or allegati*ons, were he results satisfactory?
Yes No Not applicable
- 4. Do you have any remaining concerns or allegations which you have not reported?
Yes] No If answer is YES, complete QCR form.
- 5. What is yourreason / for leaving the Harris Nuclear Pro et?
/,2 C.<,# l q . Y .A2 M .
The attached Q ity Chack Report form may be used at some later time for reporting concerns or allegations which you'may have reported previously without satisfactory results or ich you have not r port /
70YY Date $~l Y ~
l l
Signature. / . ld ' .
NearP jt WYd M8b t
Data Commenced Work Name ATM M /71/A /6L.4.0 (print) at Harris Project .
N Address $8, O(l# .32IO 7/ Telephone No. d f /gk ARL E / G/V, /I! 0. 2 *76 //
The QCP Coordinator or one of his representatives will assist if needed in filling out this form or the attachment.
Date 8"/ h - h I ,
Notes: $fb .A A . mh } & hCk kW -
u>
~
. /D A Y L%
Attachment:
Quality Check Report form (To be provided to employee)
I 1
l
- _ _ _ . . - - - . - _ _ --. - - _ - . - _ _ - _ . . - . _ . - - _ _ _ . - - - , - . _ . . . - . .