ML20205M828
| ML20205M828 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/11/1986 |
| From: | Shamblin D COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20205M802 | List: |
| References | |
| OL, NUDOCS 8604150392 | |
| Download: ML20205M828 (16) | |
Text
PCLATED CORflESPON0%
o April 11, 1986 4
DOCHETED UNITED STATES OF AMERICA-USNRC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIN O Ebl4 P2:15 trre In the Matter of
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COMMONWEALTH EDISON COMPANY
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Docket Nos. 50-456
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50-457 (Braidwood Station Units 1 and 2)
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TESTIMONY OF DANIEL L. SHAMBLIN (ON ROREM Q.A. SUBCONTENTION 8.D, 8.E and 8.F)
(Housekeeping and Equipment Protection)
Q.1.
Please state your full name for the record.
A.I.
Daniel L.
Shamblin.
Q.2.
Who is your employer and what is your occupation?
A.2.
I am employed by the Commonwealth Edison Company (CECO).
I have been working at Braidwood Station since' April 1983.
My title is Project Construction Superintendent, Project Construction Department.
Q.3.
Please state your educational background and professional experience.
8604150392 860411 PDR ADOCK 05000456 T
PDR s
A.3.
I have the following degrees:
Bachelor of Science in Civil Engineering from Michigan Technological University - Graduated 1972.
Masters Business Administration from the University of Chicago - Graduated 1982.
I am a Registered Professional Engineer in the State of Illinois.
I have been employed by CECO since July 2, 1972.
Prior to my transfer to Braidwood Station, I was assigned to LaSalle County Nuclear Power Station.
At LaSalle County Station, I was Project Construction Superintendent responsible for start-up construction support of Unit 1 and construction completion of Unit 2.
Prior to this position, I was assigned as Staff Assistant to the LaSalle County Station Project Manager.
My responsibilities included advising the Project Manager on construction related matters as well as assisting the Project Engineering Department during Unit 1 & 2 piping support design.
My next previous assignment was Project Coordinator -- LaSalle County Station.
I reported to the Manager of Projects.
My duties included coordination and preparation of schedules and budgets, as well as troubleshooting for major project problems.
I
In 1978, I was assigned as Staff Assistant to CECO Vice Presidents Byron Lee and Cordell Reed.
I performed various duties assigned by them.
Between 1973 and 1978, I was a Construction Field Engineer at La Salle.
I was responsible for Main Building construction.
Prior to 1973, I was assigned as a Construction Field Engineer at CECO's Zion Nuclear Power Station.
Q.4.
What are your responsibilities with respect to the Braidwood Project?
A.4.
My primary responsibility is completion of the Braidwood Station construction work in a cost effective and quality manner.
To accomplish this task, my duties involve:
- 1. Maintaining work progress on the latest construction schedule.
- 2. Preparing and monitoring of construction budgets and cashflows.
- 3. Implementing the CECO Quality Assurance Manual procedures and monitoring on-site Contractor Quality Control procedures and performance to ensure the quality of construction.
- 4. Directing and coordinating the activities of on-site Contractors.
- 5. Supervising CECO Field Engineers, Construction Supervisors and Administrative personnel, including reviewing salaries and developing them professionally.
_4_
As part of my duties, I have overall responsibility for assuring that, during construction, plant cleanliness is l
maintained and that maintenance and preservation of materials and equipment to prevent their damage or deterioration is effectively undertaken at Braidwood.
Q.5.
What is the purpose of your testimony?
A.5.
My testimony addresses Intervenor's Quality Assurance subcontentions 8.D, 8.E, and 8.F which concern three plant housekeeping and equipment protection issues.
A statement of the subcontentions is attached to my testimony as.D, 8.E, and 8.F (Shamblin-1).
Specifically, l
my testimony explains the examples of noncompliance issued as a result of inspections conducted by NRC Staff inspectors upon which subcontentions 8.D, 8.E, and 8.F are based.
My testimony also describes the corrective actions taken by CECO to resolve these examples of noncompliance and the on-going and future plans with respect to plant housekeeping and equipment protection activities at 4
Braidwood.
Q.6.
Please describe the the NRC examples of noncompliance.
A.6.
During inspections of Braidwood which were conducted in February and March 1985, the NRC determined that, contrary to the requirements of CECO's Quality Assurance Manual, Quality Requirement Q.R.
2.0, which commits to Regulatory
Guide 1.37, Revision O, Regulatory Guide 1.38, Revision 2, and Regulatory Guide 1.39, Revision 2, and Criterion XIII of 10 CFR Part 50, Appendix B, two were identified involving housekeeping deficiencies and one deficiency was identified involving equipment protection.
Housekeeping and equipment protection generally concern the maintenance of cleanliness at a nuclear plant during either its construction or operational phase, including the maintenance and preservation of materials and equipment important to safety to prevent their damage or deterioration.
Although the NRC identified three examples of noncompliance falling into these categories during its inspection, three separate and unrelated problems were involved.
The NRC reported these matters as a single item of noncompliance in Inspection Report Nos. 50-456/85-08 and 50-457/85-08, dated April 18, 1985.
Q.7.
Please describe the NRC item of noncompliance that forms the basis of subcontention 8.D.
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A. 7.*
The NRC inspector observed this example of noncompliance while viewing a test of the activation of the recirculation mode of the Emergency Core Cooling System (ECCS) pumps and Containment Spray pump.
The inspector observed that, contrary to ANSI N45.2.1-1973, shoe covers were not being worn while in the containment recirculation
sump area cleanliness zone, although they were being worn j
in the reactor refueling cavity.
In addition, during the i
test, the NRC inspector noted some debris, primarily paper, in the sump and surrounding area that had entered the pump suction flow path.
Q.8.
Mr. Shamblin, were special housekeeping and equipment protection measures in place during the conduct of the ECCS full flow test?
A.8.
Yes.
An overall ECCS Full Flow Test cleanliness program was established by CECO to maintain the as-flushed system cleanliness, to prevent the accidental or inadvertent dropping of material into the containment recirculation sump and reactor refueling cavity (and its subsequent ingestion into the ECCS and Containment Spray pumps) and, finally, for personnel protection.
The cleanliness program was an extensive detailed plan which included the use of guards, restriction of personnel, access controls and construction of an enclosure around the containment recirculation sump area and reactor refueling cavity.
This cleanliness program had been reviewed with the NRC prior to its implementation.
CECO also took a number of steps to ensure the cleanliness of the system and its freedom from debris just prior ~to the test.
For example, prior to commencing the test the
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A containment recirculation sump was hand wiped to remove any foreign material.
Immediately prior to the test, the sump area was again examined by the testers and shift i
personnel.
Some debris was found and removed at that time.
1 0.9.
Do you dispute the NRC inspector's observations noted in A.7.?
A.9.
No.
Shoe covers were neither required by the cleanliness program, nor provided for, nor worn by personnel entering f
the recirculation sump area during this test.
Shoe covers were put in the reactor refueling cavity cleanliness zone as personnel protection.
Since personnel would be-required to enter the reactor refueling cavity and since there would be water in the cavity, shoe covers would preclude getting wet feet.
This situation would not be present in the recirculation sump; consequently shoe covers were not placed in this cleanliness zone.
We agree that a paper-like material was in the j
recirculation sump and had entered the pump suction flow l
path.
We are confident that paper-like material was purge dam material which had not totally dissolved during flushing operations.
This confidence is based on the fact that the detailed cleanliness program had been established and implemented for the ECCS Full Flow Test and visual 1
observation of CECO engineers.
Purge dam material is a paper like substance used during pipe welding.
It remains j
in the piping after welding and usually dissolves over j
time during flushing and preoperational testing operations as it is water soluble.
It would not be unusual to flush out undissolved p,rge dam material from the piping during a test such as the ECCS Full Flow Test.
i Q.10.
What action has CECO taken to correct the example of noncompliance?
A.10.
CECO took immediate action upon notification of the NRC concern to place shoe covers in the containment recirculation sump area and to change its program to require that the shoe covers be worn in the containment recirculation sump area for the remaining portion of the test.
Since the purge dam material would eventually dissolve, no corrective action was necessary to remove it from the piping system.
l A training session was also conducted with start-up f
testing personnel apprising them of this incident.
The training included a discussion that specification of i
cleanliness requirements needs be followed-up and that any established cleanliness requirements be discussed during testing briefings.
This training also included a l
discussion of general housekeeping requirements to be
employed during testing.
Since the ERCS Full Flow Test configuration is an infrequent event, current procedures 1
combined with the training referred to above, plus the i
infrequency of the test configuration, are sufficient to prevent recurrence of a similar incident.
Q.11.
Please describe the NRC item of noncompliance which forms the basis of subcontention 8.E.
A.11.
On March 15, 1985, during a housekeeping tour of the Residual Heat Removal Pump and Containment Spray Pump Rooms, the NRC inspector observed that the permanent pipe spool pieces (i.e.,
fabricated lengths of pipe) in the pumps' suction lines had been removed and replaced with temporary pipe spool pieces containing strainers.
In the NRC inspector's view, the permanent pipe spool pieces, which were being stored in the pump rooms, were required 2
to have covers, caps, plugs or other closures intact.
j This protection is required to protect pipe flange faces or pipe end weld preps from damage as well as to prevent debris from being placed in the open piping.
The NRC inspector observed that the pipe spool pieces were only covered by tape that was not always intact.
Further, the NRC inspector considered tape an inadequate protective Cover.
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Q.12.
Were the pipe spool pieces identified by the NRC inspector stored with protective coverings?
A.12.
Yes.
The pipe spool pieces identified by the NEC had been temporarily stored with their ends taped closed with heavy duty tape for protection of the flange face surface.
This heavy duty tape is commonly used for'many applications on nuclear power plants under construction.
It is purchased to meet certain chemical content requirements in order to avoid problems such as chlorine contamination of stainless I
j steel materials.
The tape had been applied in strips across the pipe spool flange face until the entire opening 4
was closed.
However, some of the tape coverings were not intact at the time of the NRC inspection.
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Q.13.
Is tape an effective protective material for use in storing pipe spools?
A.13.
Tape is an effective protective covering material for protection of pipe spools while the pipe spools are in temporary storage.
Temporary storage is defined as that period when the pipe spool is being erected and.must be left overnight or for a very short period.
Taping the open pipe end for the short period is an adequate l
protective covering to prevent entry of foreign debris.
During more prolonged storage within the Main Building or permanent storage in an outside laydown area, protective coverings must be metal, plastic, wood, or other durable 4
e material which is adequately secured with tape or other qualified adhesive.
The pipe spools inspected by the NRC were being stored on a prolonged basis.
0.14.
What action has CECO taken to correct this example of noncompliance?
A.14.
At CECO's direction, Phillips, Getschow Company (PGCo),
the mechanical contractor, replaced all pipe spool piece covers for the Residual Heat Removal and Containment Spray Suction Lines with wooden covers.
PGCo management also issued a memo to appropriate field foremen reminding them of requirements necessary for maintaining cleanliness of piping during installation.
CECO additionally issued a directive to PGCo outlining when tape can or cannot be used as a protective covering method.
Q.15.
Do other means exist to assure that permanent pipe spool pieces are protected against damage or deterioration?
1 A.15.
Yes.
In addition to protective coverings on pipe spool ends or faces, the cleanliness and integrity of piping ar.d weld preps or flange faces is also verified by PGCo at-t' tie time of installation in accordance with procedures QCP-B28, " Fabrication and Installation of ASME Section III and Safety Related Large Bore Process Piping Systems," and PGCP-15, " Bolted Connections."
In practice, these procedures assure that at the time of final assembly all r
significant dirt and debris are removed from piping segments and that piping spool weld prep ends or flange faces which may have been damaged are subsequently repaired.
Q.16.
Please describe of the NRC example of noncompliance which forms the basis of subcontention 8.F.
A.16.
On March 15, 1985, the NRC inspectors toured the Unit 1A Positive Displacement Charging Pump Room (PDCPR).
An accumulation of construction materials, such as plastic sheeting, empty cans, rags and wood scaffolding was in the room.
The NRC again toured the room on March 21, 1985, and found the room in the same condition.
The NRC inspectors considered the lack of housekeeping an example of a violation of NRC Regulatory Guide 1.39, Rev. 2 and ANSI N45.2.3-1973.
Q.17.
What is the concern with respect to the presence of debris in the 1A Positive Displacement Charging Pump Room?
A.17.
The apparent concern of the NRC is that the presence of debris in the 1A PDCPR was indicative of a housekeeping problem.
CECO believes no plant-wide housekeeping problem existed in March, 1985.
This belief is based on the fact that while at any given time isolated areas of the plant may appear untidy, Quality Assurance walk-through surveillances indicate no generic breakdown of
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i housekeeping measures.
In addition, clean up crews are i
assigned on a continual basis to clean plant areas.
i Q.18.
What action has CECO taken to correct the example of 1
noncompliance?
A.18.
CECO verbally instructed G.K. Newberg Construction Company 4
(GKN), the contractor responsible for cleanliness control in this area, to clean the area.
CECO also issued a letter to GKN discussing this discrepancy in the cited area and directed that appropriate field personnel be informed of this problem.
GKN has informed the appropriate personnel.
)
0.19.
Was plant housekeeping and equipment protection covered in the recent systematic assessment of Licensee Performance report, called SALP-57 A.19.
Yes.
Q.20.
What was the conclusion stated in the SALP-5 report on the subject of plant housekeeping and equipment protection?
A.20.
As a result of various NRC inspections conducted during the last nine months of 1985 identifying examples of housekeeping and equipment protection problems, the SALP Board concluded that a general plant housekeeping problem existed.
As a result, a Category 3 rating was given in t
this area.
CECO does not agree because we believe the 4
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recent NRC examples of housekeeping and equipment protection problems are isolated instances and do not represent a trend.
Overall, CECO considers our housekeeping and equipment protection program effective for the construction phase of a nuclear project.
Nevertheless, CECO is committed to continuing their comprehensive and aggressive programs to improve both CECO and contractor performance with respect to housekeeping and equipment protection at Braidwood.
J CECO responded to this SALP Board recommendation with their plan addressing Braidwood housekeeping and equipment protection transition to operation.
The elements of this plan include the following:
- 1. Thorough cleaning and painting of certain plant areas and limiting access to those areas.
- 2. Removal of excess scaffold, tool boxes, and scrap materials.
- 3. Bans on eating, newspapers, and cans in specific plant areas.
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- 4. Periodic welding lead, drop cord and hose roll-ups.
- 5. Implementation of operational plant housekeeping and equipment protection procedures.
- 6. Increasing worker apareness of operational plant housekeeping and equipment protection requirements.
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Q.21.
Do you expect the program to be successful?
A.21.
Yes.
This program is similar to programs implemented at this stage in construction at CECO's recently completed i
LaSalle County and Byron Stations.
Q.22.
What action will be taken to assure that once satisfactory housekeeping and equipment protection conditions are achieved that these conditions will be maintained?
A.22.
As stated above, one of the elements of the transition to operation plan is increasing worker awareness.
The steps i
planned to increase worker awareness'of operational plant housekeeping and equipment protection requirements will j
emphasize maintenance of a clean work area and continued l
l protection of plant equipment.
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8.D.,
8.E., and 8.F.
(Shamblin - 1) 8.
Contrary to Criterion.VIII, Identification and Control 4
of Materials, Parts and Components," of 10 C.F.R. Part 50, Appendix B, Commonwealth Edison Company has failed to ensure that measures are established for the identi-fication and control of materials, parts and components including partially fabricated assemblies in order to prevent the use of incorrect or defective material, parts or components.
8.D.
Shoe Covers were not worn by personnel entering the recirculation sump area during BWPT EF-ll and some debris was noted in the sump water during preoperational test.
(Inspection Report 85-08, Exhibit 23.)
8.E.
Permanent spool pieces for Residual Heat Removal Suction Lines and Containment Spray Pump Suction Lines were found inadequate or non-existent coverings for protection against damage or deterioration of these components.
- (Inspection Report 85-08, Exh. 23.)
8.F.
During tours of the lA positive displacement i
charging pump room, the following was observed; empty cans in the room cooler, plastic sheeting strewn about the area, partially eaten food i
items, accumulation of flammable material and a layer of dust on all equipment in the room.
(Inspection Report 85-08, Exh. 23.)
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