ML20205G837
| ML20205G837 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/07/1985 |
| From: | Oneill J CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Bright G, Carpenter J, Kelley J Atomic Safety and Licensing Board Panel |
| References | |
| CON-#485-134 OL, NUDOCS 8511130359 | |
| Download: ML20205G837 (16) | |
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SHAW. PITTMAN. PoTTs & TROWBRIDGE
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WASHINGTON. D. C. 20036
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November 7, 1985 James L. Kelley, Esquire Mr. Glenn O. Bright Chairman Atomic Safety and Licensing Board, Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. James H. Carpenter Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 In the Matter of Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency (Shearon Harris Nuclear Power Plant)
Docket No. 50-40064.-
Administrative Judges Kelley, Bright and Carpenter:
As a result of a stipulation with the Conservation Council of North Carolina, Applicants agreed to perform an eddy current re-testing of a sample of three percent of the steam generator tubes of the three Harris Plant steam generators.
Tr. 8891-92.
As we indicated in our letter of October 25, 1985, which for-warded to the Board and the parties Applicants' pre-filed testimony and exhibits, Applicants intend to present the re-sults of the eddy current re-testing at the hearing commencing November 12, 1985.
Enclosed find the following evidence on this issue which Applicants propose to offer at the hearing:
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l 8511130359 851107 PDR ADOCK 05000400 C
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Y-SHAW, PITTMAN, PoTTs & TROWBRIDGE
' A PARTNERSMsp OF PROFESS #ONAL CCRoomATIONS Administrative Judges November 7, 1985 Page'2-
'1.
Letter from Robert M. Barnes, Technical Service Laboratory, to Thomas Brombach, Carolina Power & Light Company, dated October 29, 1985, reporting on the eddy current examination of a sample of Harris Plant steam generator tubes.
- 2.
Replacement pages 19-22 for Applicants' Testimony of Harold R.
Banks, Roland M.
Parsons, George L. Forehand and Thomas W.
Brombach on Evaluation and Reinspection of Work Performed by Employees Implicated in Possible Drug Activity (CCNC Contention WB-3) (which includes a revised Question 27 and the Answer by Mr. Brombach).
Also,-find enclosed replacement pages 11 and 12 for Appli-cants' pre-filed exhibit entitled:
Report to Nuclear Regula-tory Commission Staff of Evaluation and Reinspection of Work Performed by Employees at the Shearon Harris. Nuclear Power Plant Project Who Have Been Implicated in Possible Drug Activi-ty.(Revised 10/15/85).
These revised charts correct minor er-rors in-the reasons for terminations of certain of the identi-fled employees.
Corresponding changes to the text of the proposed exhibit will be offered at the hearing.
sp tful subm3tted
/
Joh H. O'Neill, Jr., P.
Cou el for Applicants JO ' N/dy Enclosures cc:
per Certificate of Service
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COLHETED November 7, 1985 UStac
'85 NOV 12 M1 :23 UNITED STATES OF AMERICA NUCLEAR RPGULATORY COMMISSION CFfiCE OF SECREI;,.i -
00CXETING 4 SERV:P BRANCH.
BEFORE THE ATOMIC SAETY AND LCIENSING BOARD In the Matter of
)
)
CAROLINA POWER & LIGHT COMPANY
)
Docket No. 50-400 OL and NORTH CAROLINA EASTERN
)
MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant)
CERTIFICATE OF SERVICE i
I hereby certify that copies of the supplemental testimony and exhibits-listed in the foregoing letter from Applicants' counsel to the Board were served this 7th day of November, 1985,'by deposit in the U.S. mail, first. class, postage pre-paid, to the parties identified on the attached Service List, and'by Federal Express mail service or hand delivery to the parties identified by an asterisk.
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John H O'Neill, Jr.,
P. C'.
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)
UNITED S?ATES-OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In;the Matter of
)
)
CAROLINA-POWER E LIGHT COMPANY
)
Docket No. 50-400 OL and. NORTH CAROLINA EASTERN
)
MUNICIPAL POWER AGENCY
)
)
(Shearon Harris Nuclear Power
)
Plant)
)
SERVICE LIST
- James L. Kelley, Esquire
- John D. Runkle, Esquire Atomic Safety and Licensing Board Conservation Council of 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 Atomic Safety and Licensing Board Edelstein and Payne 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
,e Charles A. Barth, Esquire Mr. Wells Eddleman Janice E. Moore, Esquire 806 Parker Street Office of Executive Legal Director Durham, North Carolina 27701 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 & Light Company Washington, D.C.
20555 P.O.
Box 1551 Raleigh, North Carolina 27602 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
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- Bradley W. Jones, Esquire-U.S.. Nuclear Regulatory Commission
' Region II 101 Marrietta Street Atlanta,-Georgia 30303 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
- H. A. Cole,-Jr., Esquire-Special Deputy Attorney General 200 New Bern Avenue Raleigh, North Carolina 27601 r
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APPLICANTS' EXHIBIT ss..
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SERVICE I
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,85 NOV 12 41 :23 October 29, 1985 0FFICE 0: SECREits.
00CXETmG & SERVlu BRANCH Carolina Power & Light Shearon Harris Nuclear Power Plant Post Office Box 165 New Hill, North Carolina 27652 Attention hi. Thomas Brombach
Subject:
Eddy Current-Examination of Steam Generator "A",
"B",
and "C" at Shearon Harris Nuclear Power Plant The
.following is an explanation and the results of the examination, independent interpretation and data comparison of Technical Service Laboratory (TSL) to CONAM results.
Purpose of Examination T
The objective of the examination was to sample three percent (3%)
of each subject steam generator, perform data interpretation without prior knowledge of any previous test results and then compare test results of CONAM to assure that they corroborate..
Methodology of Examination TSL's method for this examination was to use the MIZ-18 eddy current equipment, an A.610 eddy current
- probe, the same calibration standard (serial Z-1292),
and same frequencies and test procedures that were used on past baseline examinations.
Additionally, to provide the highest confidence in TSL's reporting the proper tube identification number for each tube
- examined, a
Carolina Power and Light (CP&L) representative visually verified the tube sheet template identification number and saw that it matched the computer display identification number prior to the collection of data for that tube.
Also a
second independent auditor for (CP&L) monitored this complete operation.
N 6
After data collection, data interpretation was performed without prior. knowledge of any prior test results.
Finally a
comparison of reported indications between TSL and CONAM was reviewed by CP&L and TSL.
Results of Data Comparison After a comparison of the data interpretation results from TSL and
- CONAM, it was found that with a few minor deviations for locations and voltage size, all degradation that CONAM and TSL reported had' the same tube identification numbers.
The variations due to probe speed, independent calibration curves for a
given data set and measuring the same signal are well within the expected range for two independent examinations.
No reasou can be found to doubt the validity of data interpretation or tube identification by CONAM.
The following information is supplied for your records:
Enclosure #1
~
S/G "A" Listi'ng of tubes examined and tube sheet mapping.
Enclosure #2 S/G "A"
Data reporting degradation and tube sheet mapping.
Enclosure #3 S/G "A" Data Analysis report.
P Enclosure #4 S/G "B" Listing of tubes examined and tube sheet mapping.
. Enclosure #5 S/G "B"
Data reporting degradation and tube sheet mapping.
Enclosure #6 S/G "B" Data Analysis report.
Enclosure #7 S/G "C" Listing of tubes examined and tube sheet mapping.
Enclosure #8 S/G "C"
Data reporting degradation and tube sheet mapping.
Enclosure #9 S/G "C" Data Analysis report.
2
i i
Enclosure #10 -
Equipment Calibration Letters.
Enclosure #11 -
Personnel Certification.
Enclosure #12 -
NDE Procedures.
I would like to thank you for the opportunity of providing this service for you and look forward to future combined efforts.
Respectfully, Yb W
Robert M.'Barnes Corporat/LevelIII, ET Techniedl Service Laboratory
/bc cca Don Councill Stan Turner I t t
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-00CMETED USNRC
- 85 NOV 12 A11:23 GFFICE OF SECRLIAfi-00C6ETING & SEftv!(r.
BRANCH
' Replacement pages 19-22 Applicants' Testimony of Harold R.' Banks, i
Roland M.. Parsons, George L.
Forehand and
- Thomas W. Brombach on Evaluation and Reinspection of' Work Performed by Employees-Implicated in Possible Drug Activity
. (CCNC Contention WB-3) 1
I-w who performed work at the Harris Plant and who were identified in an affidavit filed by intervenors as implicated in drug ac-tivity.
Three reels of data were randomly selected from each of the three steam generators, representing five percent of the total number of steam generator tubes examined by Conam.
In-cluded in the sample were tubes with no quantifiable indica-tions and others that had identified anomalies requiring evalu-ation.
EPRI used-the same procedure, data analysis system and calibration system as those.used by Conam personnel.
Based on its review of the data on the tapes, EPRI concluded that the data acquisition had gone very smoothly and validated Conam's use of procedures, selection and application of the defect sizing criteria and interpretation of the eddy current signals.
Thus, EPRI confirmed'Conam's eddy current testing and examina-tion results.
Q26. Is the sample size of the number of tapes reanalyzed sufficient to assure a high confidence level of the validity of the original work?
A26. (TWB) Yes.
The five percent sample of data is greater than.the sampling requirements of NRC Regulatory Guide 1.83, which requires a three percent sample of the total number of tubes to be inspected during inservice inspections.
Q27. As a result of the stipulation with intervenors, Applicants agreed to perform an additional eddy current testing.
of a sample of three percent of the steam generator tubes of,
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the three Harris steam generators.
(Tr. 8891-92).
How-was the
' eddy current re-testing of the sample of steam generator tubes conducted and what were the results?
A27..(TWB)
I first randomly selected for-re-testing 135 tubes from each steam generator across the entire tubesheet.
In addition, I added to the sample all steam generator tubes identified by Conam as having recordable indications and a sam-ple of the tubes included in the Conam data that was analyzed by EPRI.
The number of tubes selected for re-testing actually.
yielded a four percent cross section of the total number of steam generator tubes.
. Technical Services Laboratory ("TSL") of Greenville, South Carolina, was selected as the vendor to carry out the t
re-testing program, with a Level III analyst from Zetec, Inc.
acting as a consultant.
The.five technicians from TSL and the consultant from Zetec were subjected to a urinalysis drug screening prior to performing any work.
All had negative re-sults.
n TSL utilized the same examination techniques, equipment, and calibration standards previously used by Conam.
The entire re-testing process was closely monitored by Harris Plant QA/QC personnel with visual verification of template installation and tube identification.
The re-testing was also periodically mon-itored by the NRC resident inspector and Region II I&E person-I-
nel.
The eddy current re-testing of the sample 7f steam gener-ator tubes was accomplished during the week of October 21, 1985.
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TSL issued a summary report of the 'results of the eddy current re-testing on October 29, 1985 (Applicants'
-Exhibit __).
. Interpretation.of the data was first performed without_ prior knowledge of the Conam test results.
Thereafter,.
a comparison offreported-indications was made'between the re-sults of 'the TSL and Conam data interpretation.
All indica-
'tions of flaws.in steam generator tubes reported by Conam and
'TSL had the same tube identification numbers.
Minor variations attributed to probe speed, independent calibration curves for a given data set and measurements of the same signal were well
.within the expected range for two independent examinations.
TSL concluded that no reason could be found to doubt the
~~ validity.of data interpretation or tube identification previ-ously reported by Conam.
'Thus, the re-testing program simply confirmed again --
what we have known.all along -- that the data acquisition by Conam had been conducted correctly and that Conam's use of pro-cedures, selection and application of defect sizing criteria and' interpretation of the eddy current signals had been per-b formed to acceptable industry standards.
Q28.HWhat conclusions do you draw from your evaluations
.and reinspections of employees implicated in possible drug ac-tivity?'
A28. (HRB, RMP, GLF)
We believe that Applicants have an effective program to evaluate the quality of work performed by-employees-implicated in possible drug activity.
Safety-related I ;
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-- craft work was evaluated and found to be subject to inspec-tions.
A' sample of the work inspected by quality inspectors
- implicated'in possible drug activity was reinspected.
The sam-pie size was determined in accordance with Military Standard,
105-D.
The results of the reinspections show the inspector proficiency was 99.6% -- virtually the same as the overall in-spector proficiency.
No safety-related deficiency has been found in any reinspection.
This provides additional confidence
. that the Harris Plant Construction QA Program is working effec-tively to assure the quality of the construction activities at the Harris Plant.
It demonstrates that use of drugs has not adversely affected the quality of Harris Plant' construction.
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DOCXETED USMC
'85 NOV 12 All:23 GFFfCE OF SEtat TAs +
00CXETING & SEPyrrf BRANCH Replacement pages 11 and 12 Report to Nuclear Regulatory Commission Staff of Evaluation and Reinspection of Work Performed by Employees at the Shearon Harris Nuclear Power Plant Project Who Have Been Implicated in Possible Drug Activity (Revised 10/15/85)
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Chart II-2 Breakdown by Job Classifications CP&L Employees not Working'as Inspectors 11 Daniel Overhead and Clerical 19 Daniel Craft Carpenter 5
Electrician 57 Utility 18 Pipe Fitter 23 Field Engineer 2
Iron Worker 11 Painter 6
Instrument 12 Truck Driver 3
Rebar
-1 Sheet Metal 6
Concrete Finisher 1
Equipment Operator 1
Subtotal 146 146 1
Inspectors CP&L 5
- Technical Service Division 9
Daniel 13 Subtotal 27 27
.0ther Contract Employees 15 Total 218
- Technical Service Division is a division of Daniel International. --~
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Chart II-3 Job Classification by Reason for Termination 1
2 3
4 5
6 Total CP&L Non-Inspectors 5
2 0
4 0
0 11
~0ther Contract Employees 0
0 1
14 0
.0 15 Daniel Overhead 2
5 3
6 3
0 19 Craft' Carpenter 0
2 2
1 0
0 5
Electrician 1-8 17 24 0
7 57 Utility 1
3 11 2
1 0
18 Pipe Fitter 0
5 6
10 1
1 23 Field Engineer 1
-0 1
0 0
0 2
Iron Worker 1
1 6
3 0
0 11 Painter 0
1 2
3 0
0 6
Instrument 1
7 0
4 0
0 12 Truck Driver 0
3 0
0 0
0 3
Rebar 0
0 0
1 0
0 1
Sheet Metal 0
2 4
0 0
0 6
Concrete Finisher 0
0 1
0 0
0 1
Equipment Operator 0
1 0
0 0
0 1
Inspectors CP&L 4
1 0
0 0
0 5
Technical Service Division -3 3
0 3
0-0 9'
Daniel 4
6 0
2 1
0-13
> Total:
23 50 54*
77 6
8 218 Reason for Termination 1 - Positive Test Results 2 - Refused-Test / Search 3 - Possession 4 - Suspicion 5 - Arrest for Off-Site Activity 6.- Arrest for On-Site Activity
- Thirteen individuals of.this number were established as using drugs ima site.
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