ML20209B906
| ML20209B906 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/02/1987 |
| From: | Tracy S EMPLOYEE'S LEGAL PROJECT |
| To: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20209B814 | List: |
| References | |
| NUDOCS 8704280539 | |
| Download: ML20209B906 (153) | |
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.- u EmpI;yee's Legal Project P.O. Box 633 Amesbury, MA 01913 (617) 388-9620 ,
April 2, 1987 Jacque Durr U.S. NRC 631 Park Ave.
King of Prussia, PA 09406
Dear Jacque,
Enclosed is the Update on the ELP's response to your report No. 50-443/86-52. It includes some new allegations.
Please contact me if you have any questions.
l l Do you know when you will be returning to the Seabrook plant for your reinspection, and do you.want to meet with Doug.
! Richardson and Raymond Lavoie before your reinspection to clarify the locations of equipment?
Sincerely,
! O !
Sharon Tracy Project Coordinator l
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8704280539 870416 PDR ADOCK 05000443 O PDR i
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EmpI2yee's Legal Project P.O. Box 633 '
I Amesbury, MA 01913 (617)388-9620 .
l j UPDATE OF ELP DRAFT RESPONSE E NRC SPECIAL INSPECTION NO. 50-443/86-52 a
COtfI'IRfrS i
! Introduction...................................... 1 Concrete.......................................... 2 Cold Pulling...................................... 4 Service Water System.............................. 5 f
- Service Water Line Welds.......................... 7
( .
l Pi p i ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Training......................................... 10 Document Control and Design Control. . . . . . . . . . . . . . 13 Conclusion....................................... 16 EXHIBITS A. . . . .ELP Draft Response to NRC Special Inspection No. 50-443/86-52 B.....NRC Report No. 50-443/84-12 (applicable sections) :
C. ....PStil Correspondence With NRC, 6/11/84; 2/25/85; 3/29/85 D.....INPO Evaluation of Seabrook Station,12/84 (applicable sections)
E. .... Direct Testimony of Gregory C. Minor and Lynn K. Price on Behalf of State of Vermont Department of Public Service (applicable sections) ,
G. . ... Direct Testimony of Minor and Price, Vol. II, Ar*.achments, Section l
l' 'MHB-9,' Pullman-Higgins Problems -
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! II. ....Seabrook Station Worker's Critique of NRC Report No. 50-443/84-12 I.....New Safety Problem: Welds in Service Water Pipe J.....NRC Safety Evaluation Report 6/86 (applicable sections)
Empl:yee's Legal Project P.O. Box 633 Amesbury, MA 01913 (617)388-9620 .
. April 2, 1987 UPDATE OF ELP DRAFT RESPONSE E NRC SPECIAL INSPECTION NO. 50-443/86-52 ItTI'RODUCTION This is an Update of the ELP Draft Response to NRC (Nuclear Regulatory Commission) report No. 50-443/86-52 on 61 allegations of safety problems in Seabrook Station's design, construction, and documentation made through the l ELP by former Seabrook Station enployees. Although the NRC said the inspection l found no safety problema, this Update, and the ELP Draft Response (Exhibit A), calls the tmC conclusions into question.
l The ELP Draft Response, released February 8, 1987, relied primarily on information found in NRC report No. 50-443/86-52, and on critiques by l former workers who had made the allegations. This Update relies on
- additional information received by the ELP since the Draft Response was prepared. This Update also includes some new allegations which substantiate previous statements regarding problems with piping and welding (Exhibit I).
l It is apparently NRC policy to put the burden of proving allegations on the allegers, people who do not have access to the documents and equipment i necessary to prove their statements. The NRC does not prove the allegations j .
false, rather, allegations are found to be " unsubstantiated," meaning the NRC hasn't proved them to be true. Also, in some cases, for instance imC
! report No. 50-443/84-12 (Exhibit B), the NRC describes problems as 1
" unresolved," but it is not clear what actions will be taken to resolve them.
Perhaps the NRC did not have access to documents cited in this Update, and thus arrived at the conclusion that the allegations raised were not.
safety problems.'In any case, the NRC has neither the resources nor the-staff needed to undertake a full-scale investigation of these issues.
Issues raised here point to plant-wide problems which call into question the safety of the entire plant. Only a conprehensive, independent, investigation of the entire plant's design, construction, and all documents related to those areas, can resolve serious questions about the plant's safety. Such an investigation should be ordered by the NRC immediately, before the plant is activated, and before systems requiring investigation become radioactive.
CONCREIE
'Ihere are major unresolved cracks in Seabrook. Station's Unit I containment, waste process building and equipment vault. The walls shrank or settled, causing cracking. Thus, because they are weak spots, any stresses on the walls are directed toward the cracks. The repaire made so far don't j address causes of the cracking, and they.merely plug the leak from the inside.
l NRC Report No. 50-443/86-52, to which this analysis responds, l in the section on allegations 4 and 17, concludes there are cracks, but that the cracks are expected and permissible if they do not affect the structural integrity of the concrete. However, a 1984 NRC report (Exhibit B) shows groundwater infiltration into these cracks can affect the concrete 2
and the reinforcement bar.
Patening on the inside of the walls does not stop groundwater from affecting the rebar. In NRC Report No. 50-443/84-12 (Exhibit B) section 3.3b, tle NRC said in the review "...of waste process building exterior-concrete wall crack repairs and observation of their present 1
condition... waterproofing membrane was found not to acconplish its intended-purpose."
In that same report and section, the NRC identified possible future changes in groundwater chemistry which could cause rusting of steel bars t
and affect the concrete as well as the steel, and stated, "%is is an unresolved item nunber 50-443/84-12-01." h e report also states the steel reinforcement bars would possibly be subjected to continual groundwater contamination, resulting in oxidation and swelling of the rebar.
NRC report No. 50-443/84-12 (Exhibit B) section 3.4 said, "% e control methods of repair called for-chipping out of concrete to enlarge the crack <
I to the required width and depth as specified for application of the special-capillary waterproofing (CP) mortar, identified as Vandex C.P. conpound."
According to a Vandex dealer, Vandex C.P. coupound is a cementitious material. It is designed for static crack repair in concrete; it does not eliminate the original cause of cracking, nor does it prevent further crackinc. It cannot resolve the potential for more leaks at the reapired site, nor can it be determined how deep the crystalline growth of the compound penetrates. It is questionable whether the compound penetrates through the entire crack. It probably goes only deep enough to act as a superficial patch. (See alco Exhibit H, pages 1 and 2.)
4 A more effective trade practice for patching cracks of this type is an l 3
E
' epoxy injection application. This method is more expensive than the use of Vandex, but is not being used.for these repairs according to workers still on site.
COLD PULLING (See also ELP Draft Response, pages 3-6, Exhibit A)
Cold pulling, also known as cold springing is a prohibited practice, and . .
is defined in NRC Report 50-443/86-52, page 74: "No mechanical means could be used to move pipe more than one-eighth of an inch off its centerline position." In Report 50-443/86-52, the NRC tried to establish there was r . only a single instance of cold pulling. On page. 92, the NRC states workers were aware of the requirement and the need to iglement it. However, several studies cited below, as well as information in Report 50-443/86-52 itself, provide information suggesting cold pulling was not uncommon. _
Public Service Cogany of New Hagshire (PSNH) correspondence June 11, 1984 to the NRC ( m hibit C) states installation procedures were revised and crafts supervisors and QA/QC personnel were retrained in cold pulling requirements. The letter also refers to an investigation of a possible generic problem with the use of tooling claws (a means of mechanically forcing pipe into place), but notes the company does not believe the cold pulling problem meets reportability criteria under 10CFR50.55 e , and apparently the NRC agreed. A 10CFR50.55e problem denotes one serious enough to affect the safety of the plant.
But two further pieces of correspondence from PSmi, dated 2/25/85 and 3/29/85 (Exhibit C) state that their final report.only covered lines which were co gletely welded and that they were still determining which piping ,1 may have been omitted from their report.
1 4
An INIO (Institute vr Nuclear Power Operations) Evaluation of Seabrook
, Station Construction Project, December-1984, (Exhibit D, pages 14 to 16) found problems in the control of construction processes. NH Yankee's responded to that criticism by stating that for ASME III piping (safety-related piping) __.
"the engineering specification addressing requirements for cold pulling of pipe has been revised to allow more precise interpretation and inplementation."
Cold pulling must have been a greater problem than the NRC acknowleges in Report 50-443/86-52 since engineering specifications were rewritten, installation procedures were revised, and quality assurance, quality control (QA/QC) personnel and supervisors were retrained. See also ELP analysis (Exhibit A, pages 3 to 6). All of these changes occurred after the time the NRC said the cold pulling issue was satisfactorily resolved, according to Report No. 50-443/86-52, pages 74 and 75.
SERVICE WATER SYSTDi (A safety-related system)
The ELP has stated the concrete coating of the service water lines broke off during testing, and that only the elbows in the lines were replaced.
The tac report No. 50-443/86-52 did not deny these statements, but said the lines had been inspected for cold pulling, no evidence was found of that practice, and said this was not a safety problem. Ilowever, there is evidence there was cold pulling in those lines which caused the cracking, and that cold pulling has resulted in safety problems.-
l i
NRC Inspection report No. 50-443/84-12 (Exhibit B) addresses an allegation of cold pulling in the service water system line in the pipe slot area l between the Waste process Building and the Diesel Generator Building. The NRC found, "It is probable that some " popping" noise could be heard when the 5
r pipe is stressed." @e NRC report concluded that cracking of the service water pipe cement lining, although unlikely, could occur if excess force was .
applied to the pipe. .
In NRC Report No. 50-443/86-52, an allegation stated that.when the .
service water system lines were . tested, some of the inside cement coating -
broke off. The NRC dismissed this allegation citing report No. 50-443/84-12 (Exhibit B), saying "Ebr cement-lined service water (SW) pipe, the staff reviewed records and drawings, interviewed engineering and supervisory perscnnel and observed concrete lining inside pipe. The staff entered the 42-inch pipe r .
and visually-inspected approximately,40 linear feet...the staff visually inspected accessible interior and exterior portions of the SW pipe in several areas..."
liowever, the allegation reported on in NRC Inspection No. 50-443/84-12 referred to the area between the Waste Process Building and the Primary.
Auxiliary Building, not between the Waste Process Building and the Deisel Generator Building. The NRC conducted their inspection in the wrong location (Exhibit !!, pages 2 to 3).
In the pipe slot, cold springing was used to fit up pipes ranging from 24-inch to 42-inch diameters with lengths no longer than 14 feet. The NRC cites a manual on cement lined pipe saying there was no problem with deflecting a 72-inch by five-sixteenth inch pipe with no impairment of the one-quarter inch lining, but neglected to state the length of the pipe deflected, and over what distance the. deflection was absorbod. It should be noted that the service water lining is thicker and less tolerant of deflection.
l Inspection report No. 50-443/86-52 uses the findings from report No. 50-l l
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- 443/84-12 to dismiss the allegation that the cement lining of the service water pipes was breaking off. But Inspection Report No..50-443/84-12 was ,
conducted before the hydrostatic start-up testing,cin the wrong location, r ..
'and only looked at 40 linear feet of pipe. Inspection report No.50-443/84- -
i 112 ,'Section 4, says, "In addition it zis possible that cracks could occur duem to mishandling during transportation."
i Based on this assessment of the NRC inspection reports, it seems quite likely that future problems could occur in the service water system..
_i Indeed, one iniormant".recently said there is grit in the valves in the service water system.
.l 'Ihe service water system is a safety-related system. cold pulling was a.
- a -
problem in this system, and seems to have caused detrimental-(and possibly.
dangerous) effects. Therefcre, it is quite possible this is a safety .
proalem requiring extensive evaluation and repair.
l 1
I Fct a more conprehensiv9 analysis of NRC Report No. 50-443/84-12 Secticn 4 by the individual who made the original allegations, see i
Exhibit H.
i I
I l SERVICE WNIER LINE WEIDS l A recent problem presented to the ELP describes poor welds in the i
service water lines due to porosity and mismatch. The problem, described in more detail in Exhibit I, also mentions the use of pipe alignment clamps, l possibly inappropriately. It also substantiates previous allegations of poor welder training, inexperienced welders, and poor weld inspections, j 7
F 1
This individual can specifically identify 3 bad welds in the service water !
system which should not have passed inspection, but which did. Possibly many other welds in this area are suspect as well.
PIPDG 2 e ELP response to NRC Report 50-443/86-12 (Exhibit A) states that the imC report calls into question the entire piping system of the Seabrook plant.
Further information cited below substantiates this statement.
In 1984 a Seabrook worker told the NRC that the welds in the pipe tunnel suffered from excessive suck back, lack of fusion, center line shrinkage, and unconsumed ring. %e crew cut out six of the 100 welds and found each of them had up to 75 percent.of their root below accepted standards. During work on this system, the pipe was classified as a safety related system.
After the problems were discovered, the system was downgraded. NRC report No. 50-443/84-12 (Exhibit B) which resulted from these allegations, stated the system was not safety related, and that some accessible welds were examined. The author of the allegations has prepared a more extensive rebuttal of the NRC's findings which is found in Exhibit II, pages 3 and 4.
lie believes all of the welds in the pipe tunnel are questionable, as are the Diametric welds fabricated in Turbine I building since the same process was used there.
Another problem raised by the same worker and dealt with by the NRC in the same report were prefabricated sections of welded pipe manufactured by Dravo. Many tities the joints did not meet ASME codes (Exhibit 11, page 6;.
lie observed the same problem of inproper Dravo welds in the radioactive tunnel. When he tried to call them to the attention of the Pullman-liiggins 8
s quality assurance inspector, he was told that Dravo shop welds were not iG e +sPullman-Higgins't concern (Exhibit H,' p.6)..He believes this issue was not:
. resolved in NRC report 50-443/82-12 (Exhibit B). @is shows a problem in-vendor surveillance and quality assurance / quality. control.of manufactured ~~
equipment.
Another problem this worker believes was unresolved was separation of the nozzles from the steam generators. It was discovered that one of the nozzles (the only one inspected and repaired as far as he knows) was un .
contaminated by large amounts of slag. W e other:three were never repaired as far as he knows (Exhibit I, p.5).
In a Safety Evaluation Report dated May 28, 1986, the NRC granted the utility a waiver on inspecting these welds (Exhibit J, page 4)..However, the type of testing the utility had already done, which the NRC found acceptable, would probably not have discovered the serious problem of separation of the steam generator nozzles from the steam generator (Exhibit' -'~'
I, p. 5).
More general proof of piping problems is found in other documents. An 11/82 INPO report said, "The piping contractor's activities were the most' significant area of weakness identified during the evaluation. The areas '
of weakness identified by this evaluation reinforce the need for the project to continue to monitor closely work performed by this contractor, -
and to consider other remedial actions that would prove effective in improving work quality and schedule performance. Areas of weakness relate d ,
to contro of documents, including. design: changes, Work planning and supervision, craft training and quality control" (Exhibit G, p. 5).
9
It seems these problems were not sufficiently resolved subsequent to the INPO report. For exanple,4/23 to 5/4 and 5/14 to 5/25,1984 Construction -
Appraisal Team Executive Stimary (Exhibit G, p.15) says, " Weaknesses
- involving piping support installations'have been previously identified by ' -
NRC region I. Many of these weaknesses have existed for some time. The NRC -
CAT inspectors noted similar programatic weaknesses with regard to installation activities in the mechaniccal construction area...."
'Ibe 9/24/84 Yankee Atomic Electric Conpany Audit Report says, "The same r deficiencies closed in P-H internal audits are recurring and being addressed in YAEC audits" (Exhibit G, p.16).
TRAINING NRC Report 50-443/86-52 found no significant training problems, and says that United Engineers (UE&C) and Yankee Atomic found no significant
. -deficiencies. Furtherrore, the report says training. adequacy-is proven by -
a-the high construction quality at the plant. However, NRC report 50-443/86-52 failed to examine documents cited below which contradict those conclusions. In particular, the 1984 INIO report (Exhibit D, pages i 2,5,20,23,24) shows there were training problems as late as 1984, when l construction was 90% couplete. Since there were apparently noticable problems in training at this late date, what assurances are there that the plant was built by properly trained personnel?
Yankee Atomic' Electric Conpany (YAEC) audit No. SA565CS184 (12/81) i
- r. 7 A recomended "a nore conprehensive' indoctrination tra'ining and assessment program be established and that more corporate support to the field be provided." Quality assurance training on site is referred to as 10
indoctrination (Exhibit G, p. 2).
YAEC audit No. SA784CS319 (12/83) says, "It is evident that there is a need for changes .in Pullman-Higgins', training program to enconpass the. ..
construction and engineering personnel...(there is) a need for Pullman-
.Higgins management to display a proper sense of urgency. relative to ,
identified program deficiencies." (Exhibit G, p.13).
YMSD Monthly Report Notes No.58 (Exhibit G, p.ll) concerning a stop work order on all safety-related work by Pullman-Higgins cites the need to
> + ' assure'"that"the~necessary training for those personnel responsible to assure design control is being maintained as conducted." This document inplies Pullman-Higgins did not conduct a consistent training program.
INIO Project Evaluation 11/82 (Exhibit G, p.5) . says,_" Areas of weakness .
relate to control of documents, including design changes, work planning and supervision, craft training, and quality control."
1NPO Evaluation of Seabrook Station Construction Project, 12/84, (Exhibit D) repeatedly cites needed improvements in training:
Page 2: " Improvements were reconmended in a number of areas. The following are considered to be among the most important... increased enphasis on training craftsmen and inspectors in site requirements. Include provisions _
to retrain personnel.as requirements change."
NH Yankee's response to INPO's finding of inadequate craft supervision was, "In January 1985 all I&C (Instrumentation and Control) craft pipefitters, supervisors, engineers, and QC inspectors received intensive training on the Field Instrumentation Proceedures, Appendix B of 10 CFR 50, weld symbol 11
r i
nomenclature, and general Nuclear Quality Assurance Manual.(QA)
'.- requirements" (Exhibit D, p.5).
~
i
% e same report (pages-14 and 15) shows foremen had to be retrained and -
then trained again in field. electrical procedures because of recurring i
- reworks due to ~ damaged cable.' However,- NRC report 50-443/86-52, in-1 dismissing allegations of damage to cables during construction said,
...there is no evidence to indicate that these instances involved safety
- related cables." '
t t
- % e 12/84 IN m report (Exhibit D, p.15) also cites problems with hangers, pipe installation, and welding processes. NH Yankee responded by saying "We -
site,is presently reviewing training needs for. supervisory personnel.as. _ - . .
i' well as craft personnel to clearly establish resposibility for quality and -
- training programs," for ASME III (nuclear related) piping. The same report.
pages 20 and 21, says, "Inprovement is needed.in the training of-l; craftsmen and quality control- (QC)' inspectors.~Some craftsmen and QC- - -
. oinspectors are not effectively trained in. installation procedures and acceptance criteria." And on pages 23 and 24, the INPO report cites ,
- concerns about inadequate quality control inspection work and recommends i
the utility "... provide ~ training.to both QC inspectors and craftsmen to l
4 ensure their understanding of..~. program requirements." Again, on pages 34 .
and 35, the IN N report cites plant operators' lack of knowlege of plant
- systems and eauipment and recommends improved training.
l t
l NRC report'No. 50-443/86-52 said the NRC and other sources showed no
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-> significant problems in training,-and stated the quality of cons:ruction i proves the point. However, documents cited below show only a few of available exanples of serious problems in construction quality.
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Testimony by MHB, nuclear consultantsccites. repeated problems with.. . .
Pullman-Higgins installation of the piping system (Exhibit E, p. 71 and'72).
i
- A' letter from the PSNH Site Manager to UE&C Resident Construction Manager, 6/20/80, (Exhibit G, p. 1) says: " W e quality of pipe welding-
-which we have been getting at Seabrook Station is cause for serious concern. W e rejection rate for radiographed safety class welds performed-by Pullman-Higgins was 38% as of 6/10/80. % e rejection rate for weld
> repairs was 50% for the same period., From the period 5/1/80 to 6/10/80 the rejection rate for both new weld and repairs was 60%.. .. The above exanples show an unacceptable situation wherein the quality of welding is poor and seems to be worsening."
An 8/8/83 Systematic Assessment of Licensee Performance: Sumary. of _ . . . . . ,
Results (Exhibit G, p.11 & 12) says, "%e Piping Systems and Supports ,
functional area has been a continued area of concern..." and refers to an 11/81 INPO sponsored Self-Initiated Construction Evaluation which cites-
...the piping contractor's activities as the most.significant area of. _
weakness."
Document Control and Design Control 1
NRC Report 50-443/86-52 said only one violation of document control was
.found and corrected, and.that." isolated cases of' outdated drawings were e, .
found.during these sinspections, and in each case, the situation was 1
corrected" (pages 64 and 65 NRC Report No. 50-443/86-52). In the incident l cited in this allegation, the NRC 'said the drawing used by the workman l
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"could have been correct for the portion of the drawing being used."
Issues which are raised here include late and inconplete revision of .
" documents; craftsmen working with outdated documents; construction flaws - . - -
due to poor document control; ineffectiveness of corrective measures; and -
the wide scope of the document control problems. In the related area of design control, the following issues arise: inadequate review of design changes; procedural changes which allow existing (previously unacceptable) situations to stand; and construction flaws due to design control problems.
MHB, a nuclear consulting firm, cites the inability of UE&C to control the
. design change process (this process encompasses document control) as one of two significant problems at the plant (Exhibit E, p. 54). On page 71 of the same report, MHB. states that one of the major problems P-H-had was
" keeping the necessary drawings and records up to date. This problem was compounded by an inefficient document control cycle."
F o Four'ECA (Engineering Change Authorization) Task > Forces failed to improve performance in document and design control, and the 1984 INPO report (Exhibit D, p.2) recommends that .one of the most inpertant improvements to be made is "to inprove the quality of preparation a.nd review and the tinely issuance of Engineering Change Authorizations."
ECAs are the mechanism by which problems requiring changes to the design of the plant, or to construction procedures used in the plant, are resolved.
A 1982 Construction Appraisal Team Report (Exhibit E, p.74) identified concerns with P-H's design control problems, saying, " Audit reports of the 14
. piping subcontractor revealed several specific problems, which when viewed collectively, indicated a programmatic-weakness. 'Ihese were-identified by the licensee's audit program circa mid-1981. Although efforts to resolve these problems have been initiated, they.have been ineffective. Response by .~
P-H to these audits provided acceptable corrective action for the individual deficiencies, but did not acknowlege or respond to the recommendations for correction of programmatic or repetitive problems.
A 10/82 UE&C memo (Exhibit E, p. 77) cites ". ..several exanples of P-H W >
- construction. aid drawings which did not agree with the UE&C drawings. Piece marks were different, revisions were different, and dimensions were incorrect, just to name a few. Steve Madaras, a design supervisor in the field, showed us P-H construction aid drawings where dimensions were incorrect up to 13 inches off. Steve indicated that P-H was making changes--
and not informing UE&C, thereby causing the possiblity of.more interferences. We were also told that there is not a check of P-H. drawings ;
to see if they agree with our UE&C drawings. Steve also indicated that UE&C changed their NQA manual to indicate that checking P-H drawings against UE&C drawings was not required."
A Pullman-Higgins letter to UE&C 11/18/82 (Exhibit G, p. 6) says "...we cannot guarantee that piping and pipe support erection is being performed in accordance with the latest design documents."
This information refutes the NRC statement in 50-443/86-52 that there is only one case of problems with docunent control, and that design control was only a problem in isolated instances. The above cites are only a few exanples to be found in documents available to the ELP, but they show a 15
serious document and design control problem.
Exanples of construction flaws which: occurred:because of document control ~'
problems include:
Cygna, a consulting firm, said "...over 50% of hangers in process have required redesign (Exhibit G, p. 7).
An 11/10/82 letter from UE&C to P-H (Exhibit G, p.6) says, "... erection F >
"in process' and final. inspection
- are performed to the P-H drawings and not in accordance with the UE&C design drawings." A Quality Assurance Audit Report NH-590 to which that letter refers says,"...out of a sample of 66 hanger drawings. selected from work in progress, 16 were observed to have a later revision or ECAs issued against them."
%.A -further example-of problems caused by poor document and design control :~
can be found on pages 7 &nd 8 of the ELP draft, response,to NRC report 50-443/86-52 (Exhibit A).
CONCLUSION
'Ihe information in this Update of the ELP Response to NRC Report No. 50-443/86-52 was found in only a few, and sometimes incomplete, documents, documents which the NRC apparently neglected to refer to in i
- preparing report No.- 50-443/86-52. Either those documents Were unavailable t- to:the NRC,'or the investigators did notofeel-they were applicable. In any case, information cited in this Update shows many of the allegations dismissed by the NRC in their report are substantiated. It also shows NRC 16
i report No. 50-443/84-12 did not adequately address safety problems raised- l
- by ,a worker in 1984. How many other NRC reports.did not have adequate and appropriate materials to work.with,' and.therefore. reached. incorrect - a.
conclusions?-
Only;a>conprehensive. independent investigation would be adequate to -
resolve the safety questions raised by the overwhelming evidence available both in utility and NRC documents, and in the construction of the plant itself. As further information becomes available to the ELP, the Project will continue to expand on this Response.
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i EMPLOYEE'S~ LEGAL PROJECT DRAFT RESPONSE TO NUCLEAR REGULATORY
. COMMISSION SPECIAL' INSPECTION NO. 50-443/86-52 i-
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Empl:yee's Legcl Project P.O. Box 633 Amesbury, MA 01913 (617)388-9620
. Employee's', Legal Project Draft Response to'NRC Special Inspection No.-50-443/86-52 INTRODUCTION This is an analysis by former Seabrook nuclear plant employees of
, the Nuclear Regulatory Commission's (NRC) Special Inspection t i-
- ' Report /No.- 50-443/86-52.'The'NRC Report ostensibly dismisses former employees' concerns about safety violations in the Seabrook nuclear plant's design, construction, and documentation'.
The NRC terms these concerns "not, substantiated."' The Employee's Legal Project (ELP) and these former employees believe the NRC report raises.more questions about the Seabrook nuclear, plant's overall safety than-their original' allegations" did.
Most of the information used in this analysis comes directly from information provided by the NRC in their special report; the page numbers and allegation numbers refer to the NRC's report. In '
several cases, some meaningful-historical information is included to give a context for questions allegers have raised concerning the NRC. report.
It may be helpful to provide here a brief-outline of how the NRC Special Report and this analysis of it came to be. In September, 1986, the ELP made public a number of safety concerns raised by 1
former Seabrook nuclear plant employees who asked their r.#,,..'-identities remain confidential. cThose allegat' ions were , sent to.
Massachusetts. Governor Dukakis,'were made public at-a press.-
. conference,-and were simultaneously.-sent'.tolthe NRC's Region 1- m 1 head, Richard :Starosteckin with -whom the: ELP: had already been cin~: 1 car contact. Starosteck-i;had.been reassigned,nand-William-Kane took: '
"~
-his place. Apparently:during that transition,'the~ELP's information was misplaced. The NRC received it a week later from a media source. The NRC restated, numbered, and categorized the allegations.
In October,'two former.Seabrook employees, Douglas Richardson, who hud been an as-built piping inspector for1 Pullman-Higgins, and Raymond.Lavoie, a former electrician, made.their-concerns. .
about safety problems at the Seabrook plant public atia. press conference.-iIn early. November, the NRC,sent up a ' team of 6 inspectors to investigate the allegations. Engineer Jacque Durr F - '
interviewed ELP coordinator'Sharon Tracy'on November 4 in the presence of the ELP attorney to " clarify" allegations frcm o
anonymous former Seabrook workers. Later that evening he !
interviewed Raymond Lavoie, whose own attorney-was~present. The next day, he interviewed Douglas Richardson.
Within two weeks,,the NRC-investigators had completed their work;-
o ' the Special., Report-was released on December 24,vl986..
l l
l 2 H
. . _ . . ~ .
The first section of this response to the NRC report analyzes t~ i information cited by the-NRC throughout their report regarding .
cold pulling, poor design control.and-construction practices, training, and. quality assurance..The.ELP analysis then examines. ,
and critiques specific NRC allegation-responses and asks questions elicited-by the-NRC-report: Does'the.NRC information-show a major breakdown in design control, construction practices, training, and quality assurance and control by both the major piping contractor and the licensee and a breakdown in NRC
, oversight? ;Are NRC assurances that procedures exist to i
prohibit certsin unsafe practices enough to show those practices 1
3 did not take place?
4 -
This is an analysis of one.small NRC.. report out of many, many others written over the years.-What questions would be. raised by an analysis-of those-other reports? It should be noted-that the NRC says in their report that the agency-has put in 20,000 man-hours of Seabrook plant investigation. On the surface, that may seem substantial, but it works out to one full-time person on the job for the life of the construction; not much when the magnitude' of the project is considered.
- OVERALL QUESTIONS RAISED BY NRC REPORT 50-443/86-52 Cold Pul' ling (Cold Springing) '
Pullman-Higgins (P-H) was the piping contractor for the Seabrook 3
-nuclear. plant. Various sections of the' report seem to show P-H was unaware of regulations prohibiting " cold pulling" (" cold
' stretching" or " cold springing). This is a practice where pipes which don't fit up properly are forced into place using a come'-
along or ropes and pulleys, thus putting undue stress on the ' ~ ' '
pipes and-welds.
Allegations #40 and #46 on page 74 show the scope of the problem.
After the licensee discovered P-H was engaged in cold pulling, "the licensee determined that the contractor was not fully t- c cognizantrofrthe>detai-1s of~ Specification"No. 9763-006-248-51 which required that no mechanical means could be used to move pipe more than 1/8 inch off its centerline pos'ition."
Allegations #40 and'#46 are about cold pulling incidents.'The"NRC says these allegations refer to "a well documented licensee-identified cold pull incident" in the main steam feed line.
However, neither allegation referred to that particular cold pulling incident ( Nonconformance Report No.B0749). Although the NRC response to allegations #40 and # 46 seems to indicate tb9te is only one documented case of cold pulling, there is evidence throughout the report to show that cold pulling was a serious problem.
For instance, allegation #46 (see also allegation #55, page 91) refers to cold pulling in the condenser piping (extraction system), not~the main steam feedwater system mentioned by the NRC. Allegation 97, page 28, refers to crackingtin the cement of 4
d 9
the cement-lined service water pipes. In 1984, theLNRC staff le . -reviewed licenceecrecords-(Inspection" Report No.- 50-443/84-12), '
and visually inspected 40 feet of a 42-inch service. water pipe,to
.. determine the conditions and. controls applicable to. pipe cold -
' springing."~The service water-piper"is classified as. safety- "
related ASME' Class 3,-Seismic."
Apparently cold pulling was so serious a problem that the licensee submitted a Construction Deficiency Report (CDR) to-the NRC in 1982_ evaluating seventy piping systems . fore the effer ts of. cold pulling. The CDR also said "procedurer were revised to preclude. recurrence," and the NRC report states the corrective actions were in place by January 1983 (pages 74 and 75).
Although the NRC 1984 report decided "it is unlikely that the- ,
cement lining-would.have been subjected to sufficient forces to
' ' ~
cause signifigant cracking by cold springing during pipe installation," the report said "The lining did contain hairline ,
cracks, although these were of a width much less than'the 1/32 inch acceptance criteria." This implies cold pulling was responsible.for pipe lining cracks in the service water system, a safety-related system.
k The contractor was not aware of prohibitions against cold pulling; the licensee inspected 70 piping systems in relation te
.to.4 cold pulling; and the allegers were referring to different cold
. pulling incidents than the one acknowleged by.the NRC. There are
,. 5
F- < indications-the> problem was vast-ly vmore widespread'than simply one incident.
It is interesting to note that the-licensee's service water acystem report-dealing with cold pulling-was dated 1984,'but- tv -
t procedures-were changed in 1983 so cold pulling.would not recur- >..-
(page 75). .Did cold pulling continue to be a problem after the-procedure was rewritten?
Poor Construction Practices The NRC speaks to allegers' concerns-about the poor relationship -
between~P-H,'the piping contractor, and United Engineers and
, Constructors (UE&C), the construction manager--(allegations #33,-
r s- #34, #47, #59, and #60,...pages 66-68). The NRC says this bad relationship was due to P-H's poor job performance. "In the early 1980s, significant concerns with-P-H's job performance-were identified by the NRC...primarily with design control and a the -use of' construction practices which were' in conflict- with UE&C specifications" (page 67).
According to the.NRC, corrective actions regarding -the-piping - -
contractor's poor job performance resulted in a major "
reorganizational effort, " organizational and procedural changes-which ultimately led to increased licensee and UE&C control of
<F P-H activities" (page 67). Coupled.with the statement-P-H did not r <<know;coldepullingewas~a' prohibited practice, and the inspectionn of the 70 piping systems, this major reorganization indicates the 6
I
possibility of an extensive piping problem.
How extensive was this problem?-It was discovered.after the piping in the plant'was substantially installed. According to'the-
'allegers, there~were' numerous instancesaof cold pulling neither .
'the licensee'nor the NRC knew about, since the NRC says there was,,
only one documented report of cold pulling.
Poor Design Control The NRC report shows an overall design control problem, and cites.such.a problem in relation to Pullman-Higgins' work. Further examples of. design control problems may be found in the NRC response to allegations #51 (page 86) and.#54.(page 90).
Allegation #54 says parts of the air conditioning / refrigerant system of the control Building Air Handling (CBA) system were built without' design drawings. Although the NRC rays this t-. . allegation could not be substantiated, and says design drawings have been issued on the system in question, when were those drawings issued?
According to the alleger, the CBA system as originally designed l called for two identical air conditioning systems.-Because the original system lacked sufficient' capacity, two more supplemental systems had-to be added. The tubing for these, supplemental systems was field run, or put in without design drawings for guidance. Just the fact those supplemental systems had to be added shows there were design problems.
7
1 l
ten >
rAnother-issue pointing-to-either.: design control or construction practice problems is raised in the NRC response to allegation .
154,' the CBA system: steel piping,was , installed- originally, then - .
had to be replaced by copper piping. The code as cited says "all piping' associated-with-the system is rigid-copper piping. Steel-piping is not used in any part of the syst'em." Yet steel was used the first time around. Were design specifications unclear, or was the design not properly followed?
Another instance where the correct specifications were not made known can be found in the NRC response to allegation #51, page
- 86. Although to NRC says, "all piping (in the CBA system) is.
- seismically supported...," the alleger,'an.as-built piping inspector for P-H in 1982, was not told about specifications requiring those pipes to have seismic supports. Did the regulations change,.or did piping inspectors and perhaps even piping installers, receive incorrect or insufficient information?
Training Adequate and appropriate technical training for.craftspeople engaged in nuclear plant construction is essential for making sure the plant is properly inspected and safely built. The NRC response to the allegations that training wastpoor'and not well :
pi
' monitored ("not. substantiated") raises questions of how closely-the NRC actually oversaw the Seabrook plant.
8 i
The NRC response cites a number of reports saying the training
>was fine.and.that the " quality of the. training programs was -
-ultimately reflected in the quality of the equipment installations. The quality.of. equipment installation was
.cxtensively~ examined by,the NRC" (page 35).
Yankee Nuclear Services Division conducted 11 audits between May, 1978 and December 1981; UE&C conducted 10 internal audits on training between July 1974 and October 1985.."No significant F
~ Jde~ficiencies ~were found=. . .The NRC : inspected -training and qualification programsuas a routine part of the inspection program during the construction phase"(page 35).
Allegation #11, page 37, refers to communication and comprehension problems for engineers and other employees whose first language was not English. "If.the communication problem was -a
- . . severe, it would be. reflected in unacceptable work-and be detected by the multiple checks and counterchecks."
l P-H was a contractor with a major role in building the plant:
1 installing the miles of piping which makes up a nuclear power plant. Yet it wasn't until 1983 that the licensee took action because P-H did not know cold pulling was prohibited, and had job performance problems with " design control and use of; construction practices" (page 67). If a major contractor-had major problems which weren't acted on until seven years after construction L
- began, what does that.say of training, quality'of equipment 9
. c."
I e
A installation,.and the NRC's oversight of either?
As far as'being able:to track people's training records, the NRC
-states,on,.page.35.that.qualificat.ionscfor.
contractors, performing br a welding or quality control-work-were-document'e'd and are' x '-
available. And<again,- on:page . 63, -the NRC: states that. during 'the '"
, hiring. process the " individual had-to demonstrate his. '
l qualification. Examples of'these are welders and nondestructive 4-j examiners." And, " Nondestructive; examination personnel were
! tested to assure their qualifications met theicode..., the
- individual's experience record was verified..."
r
- How well did the system work?-James Padavano, 'a weld inspector,
. , falsified his qualifications on.his resume, sthen went on-to '
, falsify documentation on 2,399 weld inspections.,Some-of:those
{' welds were safety related, and'some were~ inaccessible due to 1
i concrete pours.by the time Padavano was caught-(in 1983) and' !
j'- convicted (in ~1985),'and could not be' checked. His 4
" qualifications" may have been documented, but they were certainly never checked. Only after Padavano's case went before a Grand Jury was it was discovered he falsified his- -
4
-resume and references.
Allegations #12 and #27 (pages 38 to 41) refer'to improperly -
1
-s traineduwelders.~The NRC report-cites many inspections?of~
avus. training' programs and welding procedures. But how good'were these 1
programs and procedures? The NRC performed "in excess of 26 t ,
j .10
_ . . - ~ . _ , , . _ _ . . _ _ - _ - , _ _ . - - . - . - _ , _ _ - _ - . - _ . _ _ - - _ . _ _ - . , ~ , . -_ . _ _ - , _ _ _ , , . _ . . _ . -
~
'~ inspections"'and "over 592 indep'endent examinations of welds at Seabrook." Of all the thousands of welds'in the plant, only'"145 ~"r pipe-welds were selected by the'NRC and examined by - e radioagraphic, ultrasonic, magnetic particle, or liquid penetrant testing methods." The rest of the 592 were visually examined, according to the NRC.
' The NRC.is satisfied with welder training and qualification programs,.and is. satisfied that procedures were understood.
.Again, responding to allegation #25, page 60, that. construction procedures were written in ambiguous language, up to <
interpretation by the reader, the NRC says,'"a formal process existed for clarification of procedures or interpretation of i
. technical requirements." How.well did that. formal, process -
actually work?
On page 1-5,the Executive Summary, the report says workers were l trained and qualified to American National Standards Institute !
requirements. However, Doug Richardson, an as-built piping inspector for P-H was not certified to these requirements and never heard of " ANSI N45.2.6." l It seems , at least in the case of P-H, welders were not aware i 1
cold pulling was a prohibited practice.-If training is not truely i adequate, construction work quality suffers.
11
' Quality. Assurance / Quality Control .
The-NRC-explains the; quality assurance-program asra three-tiered"m* =n system,~the-first-level'being inspectionsyby the contractor, the we second and~ third.being audits and surveillances of the contractors' inspections by Yankee Atomic Electric Company. The NRC then audited those audits. It is up to the contractor doing the work to police themselves, then the NRC examines the contractor's inspect-lon reports.
On page 69 allegation #36, the NRC finds no problems with the quality assurance, quality control-program.at the Seabrook> plant.> -
However, the apparent breakdown in other aspec'ts of the-NRC's' oversight procedures raises questions about the NRC's assurances here.
NRC rp'esence at the Seabrook site was not omnipresent. Prior to 1980, there was no on-site NRC inspector, so the NRC performed only flying inspections. In 1982, a second NRC inspector was assigned to Seabrook. Considering the 8,000 to 10,000 people ;
i working onsite at any given time, and that a good part-of an NRC l 1
inspector's job is paperwork,.it--would be-extremely difficult for l NRC inspectors to discover the smallest fraction of violations.
The 20,000 man-hours the NRC puts forward as evidence of the quality of NRC oversight is somewhat misleading in light of the size of-the job site and the number of people who worked tnere:
12
)
one inspector for the entire project over ten years..
.An. example of.. quality assurancesbreakdownsisSfound:onspage 74-(70 >"-"
piping systems -were-evaluated): where the NRC verified that -
supports were " installed on piping systems... assuring that the offects of cold pull...were minimal." But cold pulling should never have occurred. It was apparently determined in the summer of 1982 that P-H did not know about the prohibition against cold 4"~
wpulling.~New* procedures-to reinforce the* cold pulling prohibition
-were produced in 1983. Two years later, the service water system was. tested.and f6und to have cracks in the cement lining, possibly-due to cold pulling. Was. cold. pulling. continuing.despite.
procedures being re, written to prohibit it? (see page 75). -
Pullman Power- Company, P-H's parent company is "N" qualified by.
i _. ... the: NRC to perform. nuclear plant-related work. How reliable is that "N" qualification if P-H didn't even know about an important prohibition? Does this point not only to a generic problem with P-H understanding of quality assurance / control, out to questions on the understanding of the other constractors as well?
i i i
l Although the NRC's inspections, procedures, and-quality assurance / quality control programs are cited extensively to prove allegers' charges are unsubstantiated, they clearly failed in one major case (P-H and cold pulling). Shouldn't procedures and rules-be considered suspect in declaring'the allegations 13
. - ~_-
- unsubstantiated"? Is it possible all piping installations up o- unti'171983 are questionable? -
.The NRC'says all quality assurance / quality--control requirements <"%
were. met, but..is,this accurate? P-H,. piping-contractor for major - '-
work, had its role.severly' curtailed when c"old pulling and construction practice problems were discovered. At that point the plant had been under construction for seven years.
s., .One, issue-not,addressedgin the NRC. report,cbut related to contractors' quality of work and interrelationships, has to do with UEEC. In 1984, Public Service Company of New Hampshire (PSNH), the lead owner of the Seabrook. nuclear power plant, was-
.in severe: financial; straits.-Construction was shut down, and 1 there were massive layoffs: 6,000 people. At that time, there was-mention in-the media.that PSNH was considering suing UE&C..That- -
a suit never came about, so it is unclear why.PSNH was looking into that option. -PSNH owed UEEC money. WhenL the project restarted l (after Merill-Lynch got involved in. restructuring the project 's financing), Pullman-Higgin had been fired, but UE&C was still on the job. UE&C.had changed the debt PSNH owed into a loan.
In a more recent development, a stockholders' suit against both PSNH and UE&C in Federal-District Court for mismanagement, among other things, was settled out of court in November of 1986.. l I
4
- JPSNH's insurance company agreed to pay $19 million to ratepayers to settle.the suits.against both UE&C and PSNH. Why.was.PSNH 14
1 t .s > contemplating.a suit.against UE&C in71984? Why did PSNH* decide not to file. suit, and why was UE&C retained?
. CRITIQUE'OF' SPECIFIC ALLEGATION 1 RESPONSES -
Page 1 of the NRC's Executive Summary states investigators are cuthorized "to expend whatever resources were required to resolve the-issues." Yet the report also says that by the time the NRC made their investigation into the allegations , the specific m'
cont actors referred-to-by the allegers were no longer on site.
Consequently, the NRC gathered only secondhand information from the licensee staff, and made no effort to contact companies responsible for the work on systems examined.
In many cases, the NRC refers,to programs which-were instituted after construction was substantially complete, notably ~the ~
. security,. drug..and alcohol. testing,-and. personnel-programs'.
The NRC also relied almost exclusively on previously generated paperwork.
When Jacque Durr, the engineer heading the NRC inspection, interviewed the allegers, he baldly stated he expected to find !
nothing wrong, demonstrating an unacceptable degree of wishful thinking. He also told the ELP coordinator, in the presence of
,the ELP attorney, he flatly. refused to interview whistleblowers if they wanted the ELP coordinator to be present. In addition, he said the ELP was interfering with the NRC, and that"there was no 15
N Il role for the ELP since whistleblowers should go directly to the NRC. However, people.in contact with the ELP are hesitant to go
- to the NRC believing the agency will whitewash their concerns and
- could-compromise.their confidentiality as.has occurred at.other:.cxu nuclear. plants._The charge of interference was puzzling since the: -
NRC.would never have been' aware of these allegations without the j help of the ELP.
i i
CRACKS IN THE CONTAINMENT CONCRETE (allegations #1,92, #3, #4, 3-me 'and . 91.7,-pagesil5:.to 23) . .Allegers.-refer ;to major cracks, some j leaking water. The NRC reply only addresses reports on surface cracks concerning surface cracks, finding the allegations are "not substantiated." But the NRC.does in passing mention there.
are some cracks which leak; water'(page 22).HIf the cracks leak water, then aren't they more than simply." surface cracks"?-The-
! NRC'says the cracks leaking water are adequately patched, and ,
l cite reports on inspections done in late summer and early fall.
! Since the water table is usually at its lowest then, is it .
- possible the cracks would leak when ground water was higher?
The NRC says minor cracks in the containment are acceptable
- because the reinforcing bars prevent containment failure , and because surface cracks don't affect the rebar, cracks as a problem is "not substantiated." There is no discussion of-the i
J cracks which did leak water (NRC reports in 1982, 1984, and 1986,
- page 23), and the water's effect on the rebar. The NRC discussion j.
.of,the-structurals integrity. test ~ implies the containment will I 16 i
n.,.- , . . , - _ . . , - - - , ,
iflex,*and-that weak spots are> susceptible to pressure.~
Isnit' it- possible -that wheni he t concrete leaks,c the 1 rebar loses' '
its protectionufromicorrosion ,. sonlosing;its tensile:strengthf
~" "
- This .would'c,reate weak e spots." As:-the :rebar weakens with age, the " ;~'
~
- containmentiloses its margin of protection as'it increasingly-
needs it. Also, if water can leak in, can't radiation leak out in
~
a pressurized situation?
Allegation-92, a rejected batch of concrete was poured anyway, ,
'was dismissed by the NRC. Even though that allegation had.been clarifie'd, showing the incident occurred in Unit II, the NRC dismissed the allegation, citing records from Unit.I.
Even though.the rods supporting-the' containment.weresimproperly.
- severed, the
- NRC says;that;was1not a problem because-the rods were reattached using the "cadweld" process..The NRC statement I
g.,:s that:this-process makesethe..rodsrstronger:-than'if:they had-never-been improperly severed is debatable.
THE FIRE PROTECTION SYSTEM'S CLOGGED PIPES addressed in allegations #6, #49,-and 450 (pages 25 to 27) drew an inadequate response from the;NRC. The following~ analysis was provided by Raymond Lavoie, a former. electrician at the Seabrook plant, who saw 12-inch, pipe.so clogged--there was only a 4-inch diameter hole.
On page 25, paragraph 2,1he did'not find it helpful to learn that 17
I 1
the inspector simply' reviewed documents and ensured that procedures were in place for maintenance of the fire protection ,
equipment. Some effort should have been-made to inspect the pipesa -
which'he observed'to contain thick; sedimentation..The; fact that . . -
_curveillance:and. testing programs are in effect is not. evidence _.
-of ability to implement them, even if they'are' adequate. It would also be helpful to know what specific procedures exist.
Page 25, paragraph 3: the NRC inspector reported that "to
% ' *cstablish"the : condition,of- the- fire. protection system," he observed fire hydrant testing, sprinkler system testing, and examined screens. It is not sufficiently clear when this was done, i.e., 1983 or during the-onsite visit-in.1986, whether.it.
was the onsite 1986 inspector who observed the testing, or ,
whether it was a report that the onsite inspector observed of testing done-on some other date. The report also. fails ~to indicate from where the screens were removed. The remainder of paragraph 3 again only refers to review of written documents and procedures that had been provided. The paragraph also refers to
" inspection of fire pump house piping." One assumes the reference i j
is to piping inside the fire pump house and not outside the pump ]
house where the actual piping was observed to contain thick i
sedimentation. Overall, the review appears to be only a paperwork l l
review.
So *
.'Page.26," paragraph 1,;ansinterview with the American Nuclear Insurers representative reportedly took place. Since the nuclear industry backs ANI, any conclusions arrived at by the NRC may 18
lack credibility. Again, paragraph 1 does not provide us with any u dates. At best, it' appears'that~the NRC reviewed a memorandum dated October 22, 1986, prepared by ANI.
Page 26, paragraph 2, the NRC. report. indicates that on November
-4, 1986, (the same. day.Raymond Lavoie was-interviewed, the NRC
-" observed insurance tests for systems "P" and "I," the electrical transformer 2-inch drain tests and the hydrant #1 flow tests and the " expected pressure and water volume flow characteristics were achieved with no evidence of line blockage noted." Again, the NRC-does not indicate whether they were observing written reports of tests done prior to November 4, 1986. While the NRC admits to some blockage and evidence-of sedimentation, the actual. test performed (on some unknown.date).wascinadequate..The_ system should:
have been achieving.several thousand. gallons more of water per minute from the nozzels.
Raymond.Lavoie believes.the NRC should have used at least 20 2-inch nozzels. Also, the fact that " water flowing from the nozzel was clear" is not indicative of anything if the sedimentation in the pipes was hardened and crusty, as Lavoie observed it to be.
Arrangements should also have been made for producing several streams of water.
The NRC does not'specify what activity it was involved in or what it observed that caused the NRC to conclude that the Fire Pump
, .,.... House was always.kept.. locked when not attended. Furthermore, the NRC apparently is indicating in paragraph 2 that the inspector reached his conclusions prior to interviewing Lavoie, such an 19 A-___ - g-% a
interview, therefore, could not be characterized as one conducted in good faith. The paragraph also states "the stream through a 1 3/4-inch nozzel reached beyond 200-feet." In Lavoie s opinionc,.
t -
- this -is: inadequate evidencecofcabi-lity;to put out a:. major fire atexr
.the plant,,i.e.,.there would have to be evidence of the stream reaching far beyond 200 feet.
Page 26, paragraph 3, the NRC inspector noted that " chlorination had been in progress," but the reference is to the word
" initiated" in 1983..The report further. states the purpose of chlorination was to prevent microbiological induced corrosion (MIC). Allegations #6, #49, and #50 do not speak about corrosion, rather they. speak about. sedimentation, a completely.different -
process. Furthermore, the NRC talks.about preventing corrosion-inn
-the " unlined pipes," while the pipes.in question were not-unlinedt s
pipes. The NRC admits this further on in.their-report- where the.- -
inspector indicates that the pipes in question were lined with
~ cement'and therefore could give'the impression of.being clogged with sediment.
Again, the NRC states that the pipes were removed or disassembled inside the fire pump house.to. remove MIC deposits, and not disassembled outside the pump house where workers actually observed the cediment or clogging. Further, the NRC reports that the evidence of success of the chlorination project was verified by the clarity of the water. Again, Lavoie believes clear water could be achieved if a pipe was filled with hardened sediment.
-The'realsquestionsis: would the: amount or-volume of< water be 20
sufficient to put out a major fire?._
Conclusion:
m the NRC's' inspection did.not adequately. address the-allegations-and it is debatable whetherror-not an actual onsite =-
l inspection' occurred. '
' CEMENT' COATING
- BREAKING"OFF INSIDE SERVICE ~ WATER LINES,
'T*
_(allegation #7, page 28)is dealt with asna cement problem, and is severed from the cold pulling problem raised in other. parts of the report, although NRC comments on this allegation imply the-cement. cracking- could have been 'due to cold pulling.
~
TRAINING 1 INADEQUACIES.(allegations #10,.#11, #12, #27, #29, and
- 35, Pages 35,.37,.38, and 63);were dismissed by the NRC which .
relied.on. reports by.-.the licensee;and~ companies it? hired.eThe:NRC-
.also affirmed' procedures were adhered too,J.and,they* met NRC- < ,
. requirements. However, other parts of-the report (pages 28, 66,74,.and 86) show a. major failure of those NRC assurances.
W>c Pullman-Higgins,"thespiping, contractor-is' cited'as notaknowing, seven years into the plant's construction that cold pulling is:a prohibited practice, and.with having-problems with. design control-
..and_ construction practices. If the-procedures. worked so well, why -
weren't these problems discovered much earlier? _
HARASSMENT OF WORKERS REPORTING SAFETY PROBLEMS; DRUG AND ALCOHOL
.s... ABUSE (allegations #13, #16, and #21, pages 42/and-49) are 4
. dismissed asx"not substantiated." The NRC reasoning? The rules do not allow that kind of behavior. Such rationale doesn't account i for the fact that rules get broken. l j
21 1 1
i
DEBRIS IN AN ELECTRIC GENERATOR, FIRE IN AN-ELECTRICAL-CONDUIT, A LFILTHY REACTOR,. PAINT-. THINNER SPILLED-ON ELECTRICAL'., CABLES,,-WORNm '
ELECTRICAL 1 CABLES.WHICH GAVE.OFF(SPARKS:l(allegationsu#18, #19, - #2-
-#38,_f39, #43, pages 50, 51, 71, 73, and 80) refer:to an overall l
housekeeping problem in the Seabrook plant 's construction. They 1 were symptomatic of an ongoing generic problem of poor working conditions and an uncaring attitude toward building a nuclear plant. Looking at'the issue now has no bearing-on the actual 1
- . workingcsituation. .a
.The. fire.in.the electrical conduit caused by a cigarette was dismissed by the'NRC with rather. speculative language, "if a~ fire had occurred..." The alleger reiterates:,a firesvery definately" i
occurred. Is it possible debris or garbage'had also. fallen.into the conduit and burned hotly enough.to-burn the cables?-That' possibility was not considered by.the NRC in addressing this allegation.
CHECK OFFS FOR STARTUP WERE DONE CARELESSLY (allegation #20, page
- 53) was decided to be " unsubstantiated" by the NRC.4The response,. -
"if erroneous information was gathered, it would have,been detected and corrected" does not take into account that information not collected cannot be checked. Inspection work s
which is not.done with first-hand knowlege is-sloppy-work; it is
- not according to procedure. The NRC is willing to concede H erroneous information may have been gathered in the inspection procedure; why then assume the follow up procedures functior, 22 1
correctly if other procedures apparently have failed?
SECURITY problems (allegations #22 and #23,-pages 55.and 56) we're -
dismissed by'the NRC which; cited access contro1~ reports../One c mn:-
elleger' responded that in 1982, security didn't seem as -
interested in controlling access as in searching outgoing personnel to prevent theft from the site.
The NRC report does not address security during construction so
. .much as it analyzes post-construction security. Essentially the NRC accepts the licensee's word that security worked simply because the slicensee's procedure was NRC-approved. Is the presence of an NRC-approved procedure enough, guarantee the procedure worked?
DEFICIENCIES.WITH NONCONFORMANCE REPORTS-(allegation #24, page; _
- 58) was found to be " unsubstantiated" by the NRC because all the
- appropriate reporting,-engineering, and quality assurance procedures were NRC-approved.
SAFETY RELATED CONSTRUCTION PROCEDURES AMBIGUOUS (allegation #25, page 60) was dismissed by the NRC because NRC-approved rules and procedures to prevent such problems were found to be acceptable by the NRC.
"N ETRACKING OF BLUEPRINTS ~AND DRAWING ' REVISION CONTROL WERE INEFFECTIVE (allegations #32 and #57, page 64) were found by the NRC to be true "in isolated cases", but were " unsubstantiated" in 23 t___-
5
- i i
the NRC conclusion. However, the NRC procedures .only actually 4
call for inspections in isolated cases anyway. If--only a small number-of cases were examined by the NRC,.and within.those were-
,,found " isolated; instances" of.this problem,--might thererhave.been ,e-*'
e many more. cases.never discovered? '
Pullman-Higgins, the piping contractor, lost its document control responsibilities to UE&C in 1983 (see page 67). That action shows more of a problem than the NRC acknowleges in the " isolated cases" cited.
BATTLING AND SABOTAGE BETWEEN CONTRACTORS (allegations #33,#34,
- 59, and i 60, page 66, "could not be fully substantiated by the
. NRC, but no safety related equipment deficiencies could be -
identified...",No contractors from P-H, one of the contractors' mentioned in the allegation,. remained on site-at-the time of the -
NRC's investigation, and the NRC made no apparent effort to contact any of the.P-H-employees who-had worked: on'Seabrook. No safety problems were found because the NRC didn't talk to anyone who would know about the problems referred to in the allegations.
PRIMARY AND BACKUP FEEDWATER SYSTEMS SUPPORTED BY A SINGLE STRUCTURE AND NOT ADEQUATLEY SEPARATED (NO FIREWALL BETWEEN THEM)
(allegation #48, page 85) was dismissed as "not substantiated" by
- - the NRC, but the allegation, made by Douglas Richardson, was
- g. misinterpreted. The. alleger-was concerned an accidenti specifically a fire or a seismic event, could destroy both systems at once; the NRC only analyzed a situation where a 24
t.
c
+
<- missile from.the. turbine driven pump wrecking the system "is not 1-
. a credible event.".That was.not the concern raised.by Richardson.
i
- THERE~IS:NO FIRE BARRIER OR OTHER-SEPARATION'BETWEEN" CONTROL' ~1 "
- BUILDING = AIR-CONDITIONING SYSTEM RSFRIGERANT~ LINES (allegation't ~~
. .51, page 86) refers.to no separation of power sources and no-fire
-barriers between primary and backup. systems. The NRC agrees that
'is the case, but says the " design...does not degrade plant safety." But is-the design truely adequate for. protecting public He ssafety? YThe +al-leger;' Douglas Richardson, " wa's' told by' NRC ' staff the lack of separation was based on the proper functioning of'the fire protection system.'But that system has been ca~11ed into l question-(see page 25).
I
=
-CONDENSATE-STORAGEJFOR;THE MAIN' STEAM FEEDWATER~ SYSTEM' ~~~
i
.(allegation #52,-pageJ87) was found to.be " unsubstantiated"'by- ,
< the NRC. However, the rationale assumes a minimum requirement, 4
that the heat removal system will work. Does'this-follow the defense-in-depth requirement?
4 Both the primary and backup system are connected to the.same f
water tank. This tank.is backed up by the concrete enclosure-
, which will catch water from the tank if it ruptures. However, does this rationale-take into account a rupture high upfin the M.,itank, preventing' water from flowing into the concrete containment?
3 Wouldn't water inside the ruptured tank then be. inaccessible?
.25 i
Also,.if the tank ruptures, is potential clogging from debris
- 4 from the rupture, or failure of alarm and level. gauges taken into -
account? .The system is also defended by-citing administrative.
controls. which
- rely . on operators.:.taking correct actions. ' Does in Ir this analysis look.at.the fact that human error'is the cause of .
many nuclear plant accidents?
The tank has six nozzle penetrations; other systems are hooked up to it. Will there always be a full tank? Is design adequate?
Wouldn't.two tanks.in different locations be safer?
The feedwater system is an extremely important part-of the nuclear plant, and its safe design and construction.is crucial to
.the plant's safety. It should be noted-that this system failed-in the Three-Mile Island nuclear plant, and this systems's-failure-caused an accident more recently at the Davis Besse nuclear plant in-Toledo, Ohio.
UNEVEN SUPPORT LOADING UNDER HEAT EXCHANGERS; LINES RUN IN WRONG '
SLOPE; WELD IDENTIFICATION PROBLEMS; COLD PULLING IN THE CONDENSER PIPING, PROBLEMS IN THE TURBINE EXHAUST. SYSTEM AND CONDENSER PIPING (allegation #55, page 91) was found unsubstantiated because the NRC misconstrued the allsger's (Douglas Pichardson) concerns and looked at an entirely different system. The NRC examined the feed water heaters, not the heat exchangers, even though the alleger showed the NRC on their own drawings the exact system to which he was referring. l 26
The NRC says the sloping of the pipes was part of the design, but ethe alleger, a former as-built: piping. inspector, would not confuse a designed slope for a construction error.
The weld identification problems were dismissed because.according-to the NRC, that information was "not a regulatory requirement."
The alleger was told by P-H that weld identification was a 1
requirement, and part of his job. That program was cancelled at the same time there was a major restructuring of P-H's role in
- the Seabrook plant construction..Is there a relationship between the decision to cancel the program and the discovery that P-H was suffering from reports of poor job performance (see page 67)?
The alleger addressed a. problem.of-cold. pulling in the-condenser >
piping. The NRC looked at an entirely different system and : cited a cold pulling incident- which had-already been documented and dismissed as an isolated. incident (see page 74).
The NRC inspected the main steam and feedwater lines instead of the turbine exhaust system and condenser piping, even though the.
alleger was very specific on the location and function of the system he was concerned about. In inspecting the wrong system, the NRC found it had no problems and dismissed the allegation.
Photos numbers 11 and 12 are not-the heat exchangers described by e._,,. Douglas-Richardson to the NRC. There is no question of mistaken i terminology: the NRC examined the wrong system.
i 27
TRAINING WAS OF UNEVEN QUALITY (allegation #58, page 95) was misinterpreted by the NRC,.thus was "not' substantiated." Allegers: '
a referred to specific technical trainingr the NRC sidestepped tIhis" - *-
concern-and addressed.only'.generalrorientation-procedures.- . Na CONCLUSION From random indications that something was not right here and
'r
-there,'the=informationrin'the NRC~ report shows:the feeling on the allegers' parts that something was wrong is justified. Cold pulling was not known to be a prohibited practice by the piping contractor who also had job performance problems. Those problems weren't discovered until long after construction was. begun,-
calling into question.. effectiveness of training, of quality assurance and quality control programs (if the contractor didn't i .s.know about. prohibited practices, neither did'their inspectors),
and of NRC inspection and general oversight of the Seabrook plant construction.
Some NRC decisions are questionable. For instance,.the fire protections system is not classified as safety related. However, the NRC relies on the fire protection system in calculations on how well safety related systems and their backups should be l 1
separated. For that reason, shouldn't fire protection systems be I considered safety related? !
1 28 l
Douglas Richardson, former piping inspector, was told by NRC "cngineer Jacque Durr, and on-site'NRC inspector Anthony Cerne, that.the NRC,was.not, concerned if_non-safety related: systems --
~~
don't-work..However, on page 92, the NRC states it is concerned "
about.the general quality-of all plant systems-to avoid failures -
end challenges to safety systems.
The quality of the report itself is poor. The NRC sidestepped allegations, misconstrued allegations, which had been made very
. clear .The..NRC~ accepted licensee analyses and. reports, and quoted rules and procedures prohibiting certain actions as proof those actions could not have taken place. Yet there are indications, those rules have been broken repeatedly. The NRC arguement that the existence;of certain procedures means those procedures couldn't have been violated seems to be a way for the NRC to insulate itself from questions of how well the agency protects pt blic safety.
4 Even though the NRC inspection team for this report was specifically asked to look at the individual allegations as examples of generic problems, the NRC made every effort to avoid doing so. Larger questions, beyond the allegations and the NRC response to them are raised by this report. How valid is the framework within which the NRC operates? Is it enough for the NRC to say'there are procedures to prevent certain prohibited
> activities? Rules aren't always obeyed. Is it enough for the NRC to approve a nuclear plant's safety hased on audits of a very small percentage of licensee reports on self-inspections?
29
Additional questions to be addressed are how were'similar " - '"
ellegations and problems at other nuclear-plants-around the ~
country treated by the NRC?--It seems-there was a serious'.qua3ity' '~'
essurance breakdown.with.at least one contractor at the Seabrook' nuclear plant. Several companies which worked at the Seabrook plar.t were cited for serious quality assurance breakdowns at other nuclear plants. For example, the Byron nuclear plant was denied an operating license in 1984 because Johnson Controls and Pittsburg Testing Labs (both contractors at the Seabrook plant) had quality assurance breakdowns there.
The NRC response to the allegations in many instances widely missed the issues allegers brought up. First hand information was i not gathered. If this NRC report is an example of how well'that 4:,, agency < carries outaits. responsibilities, it'.is.not encouraging.
" Fail safe" is a concept whose meaning has changed since j Chernobyl and the Challenger accidents. The NRC assurances the Saabrook nuclear plant is fail safe are undercut by-information '"
provided in the very report meant to substantiate them. Shouldn't assurances the Seabrook plant is safe be put in the hands of an independent investigator,,who, with considerable public
-oversight, can comprehensively examine the plant?
l 30
4 , _, s n p pa x, a na <+ . - a r_ _ e +
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3 J- !
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s
+
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l EXHIBIT B
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-NUCLEAR REGULATORY COMMISSION s
i-
.1 nREPORT NO.<-50-443/84-12' -
i- (APPLICABLE SECTIONS) a k
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f,kf;%,:;. x b +n, w. U.S. NUCLEAR REGULATORY COMMISSION REGION I .
$h. .$ da)Np,. ~,. -?g . . . ,
i:50-443/84-12 -
~#
Rcpsrt No. f 50-444/84-06 .
50-443 Docket'No.
- u, 3 50-444 -
' .;.y:
. ,;:.3 , , ', '
CPPR-135 License No. CPPR-136 Priority --
Category B
/
Licensee: Public Service Company o'f New Hampshire .
1000 Elm Street Manchester, New Hampshire 03105 Facility Name: 'Seabro~ok Station,' Unit'1~&nd 2 Inspection At: Seabrook, NH Inspection Conducted: August 13-17 and 27-31, 1984 Inspectors: /o/.5I6 Y H. Gray, Lead Re@r Engineer ' date bLC E. va , c ngineer
/o /r/#
date d A'.
f .?-arela, Lead Reactor Engineer
/6/f/94-
'date U* /c/(/pc/
S. D. Ebneter, Chief, Engineering Programs 'date '
anch -
~
. {. /6/fff
- f. Harris, ROE' Technician / 'da te Appreved by: <&f S. D. EbnEter, Chief, Engineering Programs ek/89-date Branch Inspection Summary:Inspec' tion on August 13-17 and 27-31, 1984 (Inspection Report 50-443/84-12 and 50-444/84-06)
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4: Table of Contents .
- g.. a hNi&S g-l Topic Pal geno.
s .-
a-j '
. v< .
{ '
- 1. Persons Contacted .
'2'
- 2. Background
{,,. 4
.s
- 3. Allegation - Cracks in Concrete Walls of Waste '3
' ~
Processing Butiding
- 4. Allegation - Cold Spring o'f Pipe.(JanlTrm Area) 10
- 5. Allegation - Cold Spring of Ferro-Cement Pipe 14
. 6. s Allegation Low Quality of Reactor Coolant Pipe 19
- 7. Allegation - Violation of Pipe Minimum Wall Oue to 22
' Grinding Out Mismatch During Fitup .
- 8. Allegation - Poor Pipe Welds in Pipe Tunnel 27
- 9. Allegation - Field Weld Defect in Diesel Generator 35 Piping
- 10. Allegation - Pipe Weld Mismatch in Radioactive Tunnel 37
- 11. Allegation - Turbine Butiding Piping - Shop Weld Defect 40
- 12. Allegation - Overheated Teflon Seat Valves 41
- 13. Allegation - Improper Storage of Motor Operated 49 Valves
- 14. Allegation - Unrepaired Defects in Steam Generator 56 -
Nozzles
- 15. Interviews 59
- 16. Falsification of Quality Control Inspector's 60 Signature
- 17. Unresolved Items 62
- 18. Exit Interview 62 SLpplement A - Nondestructive Examination Summary -
- -- ' 2.
,,,,,, '.. . $.C...- - - - ~ t '5Mir,' ..,
?
LIST OF FIGURES
- Figure . TITLE pAGE 3-1 Concrete Wall Cracks 8 4-1 Pipe Lines Connected to RWST 1-CBS-TK-8 12 5-1 Ferro-Cement lines - Service Water Pipe 17 6-l' Butt Welded LongitudinaPSeaIRC-58 21 7-1 Containment Butiding Spray (CBS) Line 26 Valve . .
8-1 Waste Processing Building - Pipe Tunnel 30 8-2 ' Welds Inspected in WPB Pipe Tunnel 34 11-1 --
Line No. EX-4125-01 Rev. 1 - Main Steam ... 42 Extraction Pipe 12-1 Exploded . View of Typical Tufline Valve 45 12-2 Tuf1ine Valves 46-12-3 Close-Up of Tufline Valve Internals 48 ,
13-1 Motor Operated Valves 54 LIST OF TABLES TABLE ' TITLE PAGE -
3-1 Results of Windsor Probe Test 7 8-1 Pipe Specification (WPB) 31 10-1 Pipe Specifications 39 12-1 Tufline Valves - Teardown / Internals 47 Inspection 13-1 MOVs Inspected By NRC Staff 52 l 13-2 Independent Measurements - Limitorque 55 Valves 1
l l
__.._._......_.%,.; -u.m.fic h 4
Photo 1:. ~
WasteProcessingBuilding(WPB)
Elevation: --25.0~- - -
Description:
South ' exterior wall, with cra'ck exte,nding .
approximately 30 feet. Ground water is. evidently percolating - -
through. Crack was superficially repaired by removing concrete the-length of the defect.to 'an approximate depth of one to two 1.nches and a width'of 6 inches, and replacing it with mortar.
Photo 2: .
WPB
Description:
South exterior walfwith crack extending approximately 4 feet. Evidence of ground water percolating through Photo 3&4:
WPB
Description:
' West Exterior wall, with crack ext'ending along embed plate. Evidence of ground water and mineral deposits percolating through.
3.1 Scope of Inspection The inspection effort was directed to the above allegations to a ertain if improper concrete construction placement had been made; determine if the contractor, Perini Corporation, had circumvented standards applying to concrete; and to evaluate the significance of the concrete cracks and of the ground water leakage through the Waste processing Building (WPB) exterior walls. This effort consisted of the followingi visual inspection of cracks in the south and west exterior walls observations of cracks _ to determine if leakage occured during this inspection .
review of engineering specifications, drawings and referenced codes and standards on concrete construction review of implementing construction and quality control procedures discussions with cognizant construction and engineering personnel, -
and performance of independent measurements by the NRC NDE van to check the quality of concrete 3.2 References UE&C Specification Number 13-3, Specification for Concrete Work Other '
than Containment
5 UE&C engineering drawing number 101751 and Perini construction I
drawings and WFB-12 sheets I and 2. -
UE&C and Perint construction and quality control procedures and 2 o
. inspection . verification reporting.on concrete placing, . vibratory ~u l
consol,idation and curing
{
UE&C Specification for Concrete Crack Repair by Capillary I Waterproofing and Perini construction control procedure-for crack repair using the. proprietary method identified as "Vandex" Capillary -
Waterproofing.
Perini Concrete Placing Sch'eme for WPB exterior wall construction, pour #WPB-12-ABC, dated January 23, 1979, approved by UE&C ,
Quality Control records of Pour #WP8-12-ABC involving 230 cubic P '
" yards placed January 24, 1979. The records include formal check lists and reports identifying independent sign off and verification by measurement and/or inspector observation. 1 3.3 Inspection Conduct e-
- a. Rev %iew of Nonconformance Report Relating to Waste Process Building-Concrete Cracks and Water Leakage Inspection Perini Corporation's' Quality. Assurance Department initiated:NCR #551 on November 11, 1979 identifying ground water leakage through the waste process building's 2'6" thick exterior walls. The NCR states _
that a small amount of water is entering the_WP.B_due =to incompleto "
.. construction of the waterproofing membrane on the axter.ioc wal.l.s_
p gila _,silows rain watv to-Ente
- b[qurface of the ennerate wall u,r betWein the NembrT!feYd exterior"-Y ,
.ThQ.ECRwas-tracedthrouahfive l revisions _.during which studies were co6FdiE W ba.twann.Perint, UE&C arrd Yankee Atomic. (NRC inspection reports number 50-443 and '
444/82-03 and 82-07 relate to the above). In August 1982 UE&C ._
issued Specification Number 10-4 for Concrete Crack Repair by Capillary Waterproofing. Details of the specified repairs and the quality controls imposed thereon are addressed in the following ..
paragraph.
- b. Review of WPB Exterior Concrete Wall Crack Repairs and Observation of Their Present Condition Perini's NCR #551 identified that UE&C is responsible for the dis-position of the nonconformance.. The hairline cracks identified in I-the NCR are noted to be due to concrete shrinkage. Extensive crack surveys, detail crack mapping, water leak monitoring and water chemistry analyses were performed when leakage continued after ~
completion of the waterproofing membrane on the WPB exterior walls.
.The waterproofing membrane was found not.to accomplish its intended
6 purpose. The UE&C studies resulted in UE&C Specification 10-4 for repair of the WPB exterior wall concrete cracks- by ca.pillary water-pftofing using Vandex Inc. material. This material is a surface applied waterproofing compound consisting of a combination of chemicals, cement, and special treated quartz which waterproofs by-crystalline growth through the capillary voids in the concrete. The WPB exterior wall crack repair specification provides detail quality control requirements for dimensional control of crack preparation by chipping out of cocerete on the interior surface of the subject walls. Perini implemented these requirements in their Field Civil ,
Construction Procedure No. FCCP-11 Land QC procedure QCP10.9. WPB crack _ repair work was oerforme'd'by Perini during 1983. The NRC
^
staff observed in the review of NCR #551 and QC docTmentation of the repairs that the specified details of repair and quality controls conform to the requirements of Specification 10-4. C Observation was performed during this inspection of the WPB exterior south and west wall cracks to identify, among the numerous hairline cracks that had been repaired, those cracks spectfled in,the allega-tion. See Figure 3-1A. These three cracks were observed _lo_have.
- been repaired and no perceptible leakage was observed during g s inspection. tvidence was found that the wall paint nad blistered and p_eeleo over many of r.ne repatred cracks. This could have bise H aise'd by additional seepage or possTbte chemical rea~ctTo~n Tn the repaTr~1 area. _ This is not of significance, nor does it jeopard ~fze t.heJn_c-tional aspects of the building or the structural integrity of the -
concrete.
As a result of the recent reorganization of the Seabrook project, U E&C h a s t a ke n o v er_the_ ras ponsibili.ty__o f_Eer_i rti '_s_NCR_.#55 L whic h .--
still remains open for final disposition. The NRC staff identified at the exit interview their concerns relating to p_q.SSjhlo firtiira ;
! c%ng,eL1.g_.gng.ymLxMer etteni.itry.
k(gd The present non-saline condition VJNg ' of ground water may change and affect the concrete walls' reinforcing steel bars. This might cause rusting of the steel bars and affect -
O(2 the concrete as well as the steel. This is unresolved item number g Eg 50-443/84-12-01.
- c. Review of Quality Records The WPB walls in question were constructed in January 1979 to the specifications listed in the References section. The following concrete construction and quality control documentary records were reviewed for conformance to requirements and their referenced codes and standards, governing the safety related concrete-construction of the WPB:
Preparations for concrete construction.
In process concrete placement controls of continuous placement from Elev. (-) 31.0' to (-) 5.5'.
7 Consolidation of placed. concrete - controls verified on use of-vibratory equipment to. achieve required homogeneity and density of the concrete mix as required by concrete construction standard ACI-309.
. Concrete Post. Placement Cold Weather Protection and temperature' l control in curing for seven days. l Concrete Form Removal on February 15, 1979 and finishing of formed surfaces.
~
Concrete Records of controTs'in batch plant mixing, truck delivery, pumping into forms and verification testing for concrete slump, temperature, air content, unit weight and compressive strength.
Concrete strength test records of test cylinders for.7 and 28 day compressive strength.
No violations or uncorrected unsatisfactory items were observed in 4-the above records.
- d. Independent Measurements The NRC NDE van crew performed six Windsor-probe measurements.on .two walls in the WPB as shown in Figure 3-18. The NRC measurements were taken at different elevations on the walls in an attempt to determine if.there was any segregation of aggregate during the pouring of the.
walls. A summary of the measurements is shown in Table 3-1. The results of the NRC tests _were compared..with.. data. # ram previously
- conducted. licensee Windsor probe tests.~ All data correlated well.
The concrete strength was greater than 7000 psi which exceeds spect-fication requirements.
TABLE 3-1 -
RESULTS OF WINOSOR PROBE TEST Concrete Test A11eger's Compressive Test Area Wall Reference Strength (PCI)-
1 WPB S. Exterior Photo 1 7200 Wall .
2 WP8 S. Exterior Photo 1 7200 Wall .
3 WPB S. Exterior Photo 2 7400 Wall
1
- g. _
9 TABLE 3-1 (Cont)
Concrete Test Alleger's Compressive Test Area Wall Reference Strength (PSI) 4 WPB S. Exterior Photo 3 7200 Wall 5 WPB West Exterior Photo 3&4 7400 Wall ,_____.--
6 WPB West Exterior Photo 3&4 7400 Wall
3.4 Findings
Perini's construction method for placement of ncrete was verified to conform with requirements. The QC records generated by qualified.
engineering inspectors during the construction of the WPB exterior walls, conformed to American Concrete Institute Standard, ACI-309 for consolida-tion of concrete. UEAC specifications required the use of cal _i.hca_ted i
vjbratory equipment. s The controls applied in the concrete placement, and the vibratory equipment used, were documented to satisfy concrete standards. The staff could find no evidence that industry standards were circumvented. The use of industry standards required to achieve homogen-eity and adequate density of the concrete were substantiated by the concrete strength tests. The concrete was poured in 2' deep layers, and each layer was vibrated to fill the forms to a total depDr6f.15.5',
(Eler (-) JIf.(l' to (-)5.5'). The referenced ACI-301.and.ACI-318 stan- - !
dards do not_ljmit av h-pou 4 epth to In A t.
The WPB south exterior wall was found to have many hairline cracks that l are documented in Perini NCR #551. Leakage through some wall cracks was expected by UE&C. The WPB exterior walls with the exterior waterproof -
membrane applied are designed to prevent excess water inflow caused by hydrostatic pressure of considerable head. Accarent elaforte in the_ l envelope of the waterproofing membrane applied to the exterior wdl1. '
CMd'the_ water ieaKage throuch the h34p.k4ng.gq CK$. - {hes.gracks.in, alleger Photos #1 and #12 were identifed in NCR #551 as cracks #2b and 8b and were noted to show signs of water leakage. These cracks were repaired in mid 1983. The.NRC staff observed that the repairs were effective since no perceptible water leakage could be detected although paint peeling across the repairs was observed.
There was a total of 29 hairline cracks in the WPB walls that required repair to prevent ground water le~akage and these are shown on Perini .
Drawing WPB-12 sheets 1 and 2. T_he controlled methp,qLQf rqp_ air cajlej;I,,f_o.g chipping out of. concrete,to_e.nlarge,the cr ^
depth as specified for application of ~tfie _ac_k..to _the._r.equiyjdt y,idthjndsp (CP) m_ortar, identified as Vandex C:P;- compou'n'd.' This~jiFoyrTetary
s....
10 compound, through crystalline. growth and chemical action when combining with water does more than accomplish; superficial repairs. The NRC staff-inspection conducted one year after repairs, indicated the technique-is' effective and that the grouting material used was acceptable for its >
~
intended purpose.
.The crack identified in alleger Photos #3 and #4 is identified in the
. repair drawings as number 8H, and was repaired as discussed in Section-3.3.b. No evidence of leakage or mineral deposits at this crack location was observed by the NRC staff during this inspection which is approxi-
- mately one year after repairs.
,, j )
3.5 Conclusions ,
The observations identified by the alleger in his letter and in captions '
to the four photographs were valid prior to completion of repairs to'the
+: WPB exterine ells." The walls had natr Ine cracks that admitted groun3 /
water leakage through them. As identified in preceding paragraphs of this report the contractor used approved construction standards, industry practices, and state-of-the-art construction techniques. The alleger's
" belief" that concrete cracks and groundwater leaks were the result 'of circumventing standards applicable to concrete placement was not substan-
. tiated. Es alleaatin_n* hat repMee _+a + ha e ==d - -- " super f.i " and ,
- c. used ." ordinary grouting material" also was not substantiated. The N *"t. -.
Windsor probe measurements verified that the concrete was of high.
quality.
- 4. Allegation - Cold Spring of Pipe (Tank Farm Area) -
The alleger states on page 3 of his written statement:- '
"In May, 1983, the campany issued a memo forbidding any more " cold- :
springing" of pipo and indicating that anyone found to be engaging in the practice would be. disciplined and perhaps terminated. How-ever, following the memo, at least one area supervisor instructed -
workers to " cold spring" a pipe from the Tank Farm near the Pump Auxiliary Building to a valve."
During a telephone interview with the alleger on August 24, 1984 he supplied the following clarification:
l It was a CBS 4" diameter 1.ine off a flange to a valve. They rolled. ,
a piece of pipe to get the proper fit-up. There was also a 14" line '
connected to the tank. Mr. X knew about it.
. l l
)
i
.v. _ .
14 the erection). One joint on'the 14" Itne could not be fit up properly and <
.the NCR disposition by engineering approved a-slight. miter condition.
However, in the final ff tup on the 1-CBS-1222 line <no fitup proble.ms were -
expertenced. He stated that pipe can be rolled to effect a good fitup as long as the pipe is essentially level and that too much roll will' result -
in an out of level condition.
Two welder /fftters were also interviewed. Both worked on the lines during erection. Neither knew of any problems during fitup or welding of these Itnes. Both sai<f the fitups were easy because of the pipe configur-
- atton and loose end of the pipe attached to the opposite side of the valve. '
4.5 Conclusion The staff could not identify any defects in the as-built system to
-substantiate:the. alleger's concern related to improper fitup of 1-CBS-1222, 1-CBS-1217, or 1-CBS-1202. r Independent measurements vertfied
. requirements were not for ovality and wall thickness. No evidence of cold spring was detected.
- 5. Allegation - Cold Spring of Ferro-Cement Pipe The allegation states on pages 2 and 3:
" Concrete linings of several sections of ferro-cement pipe which brings service water into the plant have cracked. When the pipes-failed to meet properly, a 10-ton.Portapower Hydraulic. Jack was ,used -
to " cold spring" the pipe -- that is.to try to bend the pipe to make-it fit. When the ptpes were cold spruno. I could hear concrete cracking some dfs_tance b'ehina the joint in the pipe slot. I am afraid some worker could get hurt if he loosens the phlanges."
g 'During_a._lelephone conference with the alleger on August 24.'1984, the a'TTegir_refecred-to-theappe-slot" acea as the atta be.tNA. eft.the_j{aste Processing Butiding and the Diesel Generator Buf1 ding. 8 5.1 Scope of Inspection y/fhb '
For cement-lined service water (SW) pipe, the staff reviewed records and-drawings, interviewed engineering and supervisory personnel and observed cement lining inside piping. The staff entered the 42" pipe and visually-
. inspected approximately 40 linear feet. The SW pipe is classified as safety-related ASME Class 3 Seismic. .
5.2 References Drawing 9763-F-202499 - Service Water System - Plan "
- 1 ASME Code Section III Subsection ND (Class 3) '
, , : . :-9 15
(
, . 4 -
ANSI B31.1, Power Piping Code -
Piping Data Sheet for ASME III, Class.3, UE&C Class.153. ,
a- -
.NCR punch 11st .for~ Service , Water. Area. dated 8/17/.84. - > .
Procedure .IX - 30, . Application of:Sika-Gel. to cement lined pipe-Joints Procedure IX-31,. Application of X-Pando to cement lined pipe joints -
(including cracks)
Centriline Process Booklet,. page 18 - Deflection Test NRC CAT inspection report 50-443/84-07, page VII-5. ,
+ . ..
< Report.of. March 13, 1984 by UE&C to YAEC on Service Water - Cement Lined Pipe. '
NCR numbers 002, 327, 1810, 3820, 4773, 5065 and 5173 Drawing 9763-0-804998, Pipe End Joint Design for Cement Lined and Non-Ferrous Piping..
Specification 9763-006-248-2, Fabrication of Cement Lined-Pipe and Non-Ferrous Pipe 5.3 Inspection Conduct i The inspection was conducted to determine the conditions and controls
.pplidute- tc ,,ips caid spr'imff ng, to estaD11sn 1r the lining cracked
.during pipe fitup or> welding, and how cracking would be identified such that repair could be initiated. Interviews and records review were e concentrated toward service water piping in the pipe slot area between the i diesel generator butiding and the waste processing building. The staff - l
. visy411y f atpacted_accesMble--interior and exterior portions of the_SW '
pipe in several areas. Cement-lined pipes installed as part of the service water system are shown in Figure 5-1.
5.4 Inspection Findinas The construction supervisor detailed the sequence.of. events from arrival of pipe at the site to final cement installation on the inside of the pipe at welded joints after completion of piping fftup. .Co.1d ,spr.f,ngtng of. pipe was lipigesf _by both procedure and.physicaldistances ;between,_p,1, pes. Movemen,t Me enTof a pipe was: limited to one inch during fitup,' an insignifi-c*ay - --a up , ivr me sengtn-of- pipe secuons (up- T,o 9PJ 'beTng " .
,. . installed. Tae majority.orthe TufvTt9Mretur-tined piping is 24 inch <
diameter or larger (up to 42 inch diameter) which permits internal access l after welding for mortaring of fitup joints and inspection of the inside :
surface of the cement lining. The inspector reviewed records verifying l
l
...m..._
16 that in the pipe slot area fitup joints were mortared after welding such
.that any cracked cement lining could be also identified and repaired The
. construction supervisor and-engineer also.-stated thatethis was true during informal interviews with them. 1 l
1 l
1
. . 4 l
1 l
l em.
9 O l
w=._ . .
18 They also stated that QC . inspectors were. advised to be alert to identify" and report significant cracks in piping,while enroute.to specific internal pipe mortar inspections. The.NRC staff reviewed a sample of NCRs wheree
, service water lining cracks exceeding the 1/32" criteria were identified 9.
and repaired. The justification 'for the '1/32" dimension for the ' maximum,
' width crack is contained in the report- submitted under the-letter of" e March 13, 1984 by United Engineers and Constructors, Inc. (UE&C) to .u Mr. J. .DeVincentis, YAEC Project Manager. This report details the result of a study into the corrosion mechantse and barrier breakdown which could S occur in the cement lined system and provides the basis for the 1/32" '
$ maximum lining crack dimension.
)
N R The Centriline Process Booklet' on cement lining of pipe lines reports the
.h deflectio9 testing of a 72" x 5/.16".. pipe section with a " lining. The -
3 pipe was deflected 13" without impairment to the lining. The site drawing n, 4 %p *" h* and*3/8"^respectively.D-804998, Table test While the deflection 1 details result the is notlining thickness fo y directly applicable to the Seabrook 24" and 42" pipe lining sizes, the test does . indicate an unexpected resistance of cement lining to cracking or breakage on deformation. It is probable that some-"p.a.pp. tag" nat.sa.'
could be heard when the pipe is stressed._ ,
The staff found that it is unlikely that cement lining would have been subkect to sufficient forces tT cause significant crackTHb bv col { spring-ingsthe pipe curina 'attallation. Should cracking by this mechanism have occurred, it would have been identified during work operations includtng QC inspections conducted in the pipe after welding and those cracks exceeding the 1/32" criteria would be repaired.
The_in spector_ en te ret the. 42. i nch . d i ame. tac lia m 1-SW-IR S thru the open g forswvalvev*ounacoservedthecement11ninaandluncti.gns,.qtweld
~
seAis"fo7Tppr.oximately-40--feet. ~ThElinirig.did contaiP~h'alilline eracks altnough these were of widtW~m'ikh less than the ITJ2" acceptance criteria '
in paragraph 3.5.3.10.6 of Specification 248-2. The lining at weld joints was noted to be smooth and merged with the pipe lining. .
5.5 Conclusion The Itcensee had studied the affect of cracks on,the- safety of the' pipeo *.
in service and determined that cracks exceeding 1/32" should be -
repaired.
The staff eaa-W that cracking of the service water otoe cement lining, although unlikely could occur if eveau force was applied to the p.jpr.
~
~
Dr eddttT5n~fCTs')'orstbie.
s tnat cracks coulci occur due to iiiGiiiiIlling during transportation.
c.o.
I 19
. However..the crack criteria, final internal inspections subsequent to
.fitup and welding, and repair criteria provide reasonable assurance that' cracks exceeding the'1/32" criteria, no matter what the source, would be' detected and repaired.
l
- 6. Allegation - Low Quality of Reactor Coolant Pipe ~
+
I c . The.a11eger states, on-page 1.of his. written statement: su i
" Faulty welds and mismatches of round pipe with out-of-round pipe in -
l the auxiliary reactor cooling system. In addition to the potential for a loss-of-coolant accid.ent-such mismatches could -- if the emer-i gency cooling system was activated -- create turbulence in the water l
which could lead to the formation of air pockets."
i *
"The company appeared to be using cheaper pipe as money got tighter '
f s .. , dat-the, plant. . Often the pipe.would be. significantly out-of-round."
He further elaborates on the RC line on page 2:
{
"On the Reactor Coolant Line, it was also a normal practice to grind j down excessive mismatch, center line shrinkage, suck back and unconsumed ring. Look at the RC line from the main steam feed."
1
- In a telephone conference with the alleger on August 24, 1984 the alleger
- stated that there was a 10" schedule 80 RC line in the MSF penetration j
area that was of concern. When questioned about. "use of cheaper pipe" (see above) .he stated.that on the RC system the prints calledifor' .t
. _seamlessapipe but.that seamed - butt.. welded _ pipe was used. Hec. thought u j the seamed pipe was cheaper.
I
'6.1. Scope of-Inspection i
The NRC staffyalked down all the lines in the Main Ste.am_Eud-(MSF) area to Ldent gifRC and other piping in the general area. Two RC lines.were _ l identif f ed, the pipino and__aswhtad walds_wer.e_ visually inspected, radfooraphs were taken, ovality _and ultrasonic wall . thickness-r.easurements
- welre made_and_.the engineering specifications were reviewed. .
l 6.2 References 3
4 Sketch E2936-614 Sketch E2936-598 1
{
Sketch E2936-135 Specification.9763-006-248-1, Shop Fabrication of Piping
- 1 1
l l
l
}
- n a,.
20 '
- . 6.3 Insp ction Conduct -
1 The staff walked.down the MSF penetration area to. identify the RC. lines.r The staff could not identify any 10" RC line but did. identify two 12" RC lines'in-the area, RC-58 and RC-13,.the redundant. residual heat'. removal suction lines. The staff. inspected these lines.. "
~
Both.RC lines !.>ere visually inspected andlovality measurements were made' at numerous points on the lines Wall thickness measur'ments e to detact 1
i excessive grinding anrune miematt h were marfo at several welds and at D e
- spool ph ces. In addition, an_ alloy analyses was performed to provide assurance that the pipe material was ss Ju, as specified in the specifi-cation. .
i l
r .
l 4
~
I b
. - t-22 NRC radiography of welds on the RC-58 and RC-13 lines was performed which provided additional assurance of-proper alignment, wall thickness, -
mismatch and overall pipe weld quality.-
6.4 Findings -
- Visual inspection revealed.the RC-58 and RC-13 line were 12" diameter ---
. lines.and both utilized seamed butt welded pine. The spool pieces and a.
welds on these lines, visually were of high quality and had been inspected and accepted by ASME inspectors. Figure 6-1 shows a typical spool piece -
with both a horizontal seam and circumferential weld. Note the ASME Code acceptance stamp. Seamed pipe-rsfi~r's to the fabrication method of the pipe spool piece in which a longitudinal weld seam joins two edges of a formed plate. -
i Ov_ality measurements with calipers at 6 points each on line RC-53 and i
, e.. . .
. . .. 2RC-13;q16 act_rayeal any deviations from ASME specification requirements.
Wall thickness measurements at 2 field welds, 2 shop welds and at 2 points on the pipe run of RC-58 by NRC staff utilizing ultrasonic techniques did
. nat_ reveal any violation of minimum wall thickness requirements.
I Radiography by the NRC NDE Van staff of weld number F0301 on RC-58 and on .l :
weld number F0302.and F0304 on RC-13 did noteshow any mismatch, signifi- '
cant wall . variations, or .volumet'r ic defects. --
i The staff reviewed the appropriate drawings.and cross checked .the piping !
material specification. The applicable specification, 9763-006-248-1 was l identified on the spool.pfeces. The RC pipe was classified as UE&C. class. l
. , .601,.which:specified.that pipe of 10".through 12". diameter should be SA312-type 304 Schedule 40 we_1ded or seamless pi)e'(emphasis added - welded -
l ida'ns WTYn longitudinaTTseamf. The1NRC NDE van personnel performed an alloy. analysis on both the RC -lines and verified that the material was
, type 304s stainless steel.
6.5 Conclusion ., _
The staff-could not substantiate the allegation of " cheap pipe". lha
. .. gine conformed to < pacification requirements. . .The. welds. met code design .-
requirements as verified by NRC independent measurements. ~~4
. No out af epecification deviations were identified hv av214t u rasonicy
- wal I thickness _ or radioaraohy. mea-owementt The staff confirme
~
there was siamed butt welded pipe in the RC piping spools, but this was acceptable per the design specification.
- 17. Allegation - Violation of Pipe Minimum Wall Due to Grinding of Mismatch During Fitup On page 1 of his written statement, the alleger states:
- + "The grinding-down of' pipes to thicknesses significantly below those mandated by NRC codes. Bombardment '*c; vt41cactive particles could cause the overly-thin pipe sections to beca n k sc.fe.- etit ra 1
e r.-,,.--s.r--,..y,-,-w -
v -
--r---- -- + , . . . . - , , _ _ , , .- --, -- , , - . - _ _ -
. . . . =_- -_. .- ._ -- . - - . -.
. w E
23
.m engineering projections would anticipate their embrittlement. Such grinding down of pipes to make:them fit properly.was one thing. .
everyone at the plant-knew we .were doing. 'Itrwascas: fliegal as hell,
.but everyone did it. See, for example, line E2936-283-1-CB5-1211 --
. . the Containment Butiding Spray line from.the main. steam feed which. -
runs through the Pump.Auxtitary Building _through~the. Radioactive - .
tunnel through the Equipment Vault. -
I worked on the CBS system connecting the main steam feed pipes to.
valve set into the concrete containment hull.- Throughout the plant, -
welding crews frequently found that the pipes didn't match in size or shape the valve or pump they-feed. The company appeared to be using cheaper pipe as money got tighter at the plant. Often the pipe would be significantly out-of round. We would have a %" concentric in a large pipe. Under codes of both the NRC and American Society of Mechanical Engineers, only 1/16th" concentric (or 1/32nd" eccentric)
-- m is* permitted......When-a concentric mismatch greater than 1/16th" was found, a welder was sent squirming (sometimes, myself) inside the pipe to grind out the inside base metal diameter. That would, how-ever, reduce the thickness of the pipe form h" to " concentrically. ;
I am concerned this could affect the metal's ability.to withstand '
radiation. The error is not detectable by X-rays. I understand that-ultrasonic tests must be conducted to determine pip'e thickness.- I know of no. ultrasonic tests done on this specific line, except for {
one weld repair at a different location". i Further, the alleger provided two photographs designated.as Photos 6 -
and 7 with a_ description.of his concerns on.page 6 of.his ._m I statement. l Area: Main Steam Feed, Penetrations Elevation: -20.0
Description:
Containment Vessel for 16" stainless steel Motorized .,
Gate Valve, on Containment Butiding Spray (CBS) Line. Also pipe _
fabrication by Oravo, which extended from the valve through the Radioactive Tunnel and connecting to the Equipment Vault. Upon an
. . attempted " fit-up".of_the valve described above, an. excessive." mis. a match". existed between it and.the Containment. Penetration connection.'
With Quality Assurance acquiescence and awarenesscof a h" mismatch p the joint wu welded out-as is. As an accepted practice by produc-a' tion. Management, Quality Assurance and NDT, I was. told by my area. .
supervisor and foreman to grind down the mismatch.so that the joint.
would pass x-ray criterion, thus diminishing the wall thickness by minimum of % inch. Due to the out-of-roundness of.all of .the Dravo fabricated pipe, from the opposite side of the valve to the Equipment Vault tie in. the practice of grinding the root inside diameter was necessary for it to pass NOT tests becatse of mismatch and excessive ,
suck back.
I f
1,' t e .
24 7.1 Scope of Inspection The staff identified the 1-CBS-1211 line in the Main Steam Feed Penetra-:
tion area. This line, its redundant line 1-CBS-12 12, and associated. .
valves 1-CBS-V-8 and 14 were examined by the staff utilizing independent -
measurements. The licensee records-were also reviewed and compared with-the NRC data.
7.2 References Drawing CBS-1211 Containment Spray System ISO-
./
Drawing C85-1212 Containment Spray System ISO ASME III, Division I, Subsections NB and NC ANSI-B31.1,-Power Piping Code Piping Data Sheet for ASME Class 3, UE&C Class 301 and 151.
Pullman Power Products - NDE Records .
7.3 Inspection Conduct The staff reviewed the ASME Code Section III and ANSI B31.1 requirements for fairing of offsets and alignments when component surfaces are inaccessible, evaluated the effect of radiographic sensitivity on detectability of. excess internal pipe metal removal, ultrasonicallym --
measured the pipe and weld thickness at V14-and V8 anh'twe 'oLiierIpipe. 2 ydganc ract ographed selected 1BS_sys.Lem_ welds.. ...___.. . .. . _ _ _ . . .
7.4 Inspection Findings All of the pipe fabrication codes have provisions to control fitup and alignment tolerance of pipe weld joints. These are discussed for various -
pipe classification in the following paragraphs.
The ASME. Code Section III Subsection N8 for Class I components -is quoted a -
below to provide a. baseline for consideration of weld joint fairing and --
alignment of inside surfaces.
NB-4232.1 Fairing of Offsets.
"Any offset within the allowable tolerance provided above shall be faired to at least a 3 to 1 taper over the width of the finished weld or, if necessary, by adding additional weld metal beyond what would otherwise be the edge of the weld. In addition, offsets greater than ] ,
those stated in Table NB-4232-1 are acceptable provided the require- j ments of NB-3200 are met."
25 NB-4233 Alignment Requirements When Component Inside Surfaces Are' s Inaccessible.
"When the inside surfaces of components are inaccessible for welding-or. fairing in accordance with NB-4232.1, the A side diameters s_hal b match.each other.within 1/16 inch._ When the_cornp.onen.ts._are. aligned.
~.concentMcany,. a. uniform mismatch of 1/U f ach al' around-the-joint, can,. result as shown_in Fig. NB-4233-1(a). However, other variables-not associated with the diameter of the component often result in alignments that are offset rather than concentric. In' these. cases, .
the maximum miulianment at any one point around the joint shall not exceed 3/32 inch, as shown .i.n-Ff~g7NB-4233-1(b). Should connanant-tolerances on diameter, wall thighneM.u_t-of-roundnes_s,,,et,c.,
resGTt'~1n Tnside diameter variations whicCdo..notimeet these f.imits, thii~inside diamFtFrTihil1'b~eToilit'eWoYed, sized or g7olind'tu'
^
~~
~~
p i oduce TblirE Vi thi n th e ~s. .e"I f m i t s~~ ']Em'pha s'i s added)
The ASME Code,Section III Subsection NC for class 2 system components is identical to paragraphs NB 4232.1 and 4233 except for references. ,
The ANSI B31.1 Code.Section 127.3 prefers internal trimming (by grinding or machining) where ID mismatch exceeds 1/16".
,The.CBS-1211 and 1212, lines.spectfied.in the allegation are'ASME-Code Class.2 lines which are governed by.the requirements of.NC-4230. yi.sual, ultrasonir, and radioaraphic examination of specific welds on therCBS-lines
.did not disclose violations of. the NC. alignment requirements. -See -
. Figure 7-1.
In the case of radiography,-th.e . issue is if exc1s_ grinding-was done ort radiographed joints,.would This condition be observable on-the radiograph?
The ASME Code,Section V, Article 2, Tables T262.1 and T262.2 specify the sensitivity of the radiograph to be 3% minimum. In the case of CBS-1211 with a thickness requirement of 3/8 inch, the RT is required to show a local .. material thickness difference of 3% x 3/8 or 0.012 inches or more. -
The reduction of wall thickness by h" by grinding (or other metal removal ritethod) is many times greater than the minimum RT sensitivity requn~dmE t i sUch '~th'aT;ine ta l EdWl~a'mW0nt s-~iff li"'Io'V~wo'lifdl
~ c 1 e a r lTiho7 o n~'ths'~~ . e radio ^gr'a'ph of the'Ee.1didelit'.~~~~'~'" ~~ ~ ^~~~
.Two'CBS welds, F0204 and F0206, on CBS lines 1111-and'1212 respectively" &
were radjqgraphed and interpreted by the NRC inspection team. These -
welds were found to be acceptable and without evidence of. excess local.
pipe mater.jtaL.cemoval . A sample of licens~eFTradiog.r_a:ph's Ef. welds in the CBS-lines was reviewed by the staff.and found to meet requirements.
l l
1 l
l
- - . - - _ _ _ __=_-.- - - , . - . . - - - _ . -
- e ..,
27
- Ultrasonic wall thickness measurements made on the CBS pipe-to-valve weld joints on valves V8 and V14 did not show evidence of excess internal weld joient or pipe metal-removal . Pipe wall thickness exceeded minimum. wall.
requirements and these measurements correlated with.the radiographic ,
interpretations In addition UT wall thickness measurements were made on one weld each and at least one spool piece -for lines 1-CBS-1211 and 1~-CBS-1212. All met' requirements. ,
7.5 Co~nclusion
./
The staff could not substantiate the alleger's concern of "the grinding down of pipes to thicknesses signficantly below those mandated by NRC Codes". NRC performed NDE and applicabl.e_ documentation review _provided
. objective evidence of the acceatability of._the CBS.. lines in.cluding ovality, wall thickness, and welds.
- 8. Allegation - Poor Pipe Welds in Pipe Tunnel On page 2 of the written statement the alleger states (technical parts abstracted from the paragraph):
- * " Working in the pipe tunnel, I saw frequent instances of lack of proper documentation of faulty welds in pipes. Many welds were performed with the use of 2 Diametrics (automatic welding) machines."
- "The Diametrics machine was used to weld beveled pipe ends with.a .~
consumable ring. But the ring. whic_h is at2.q.ut 1/16th"_thirk and the sadi diaireter as the pipes, would shrink by as much as 1/8th". As a result, the inner circle of the ring would shear off or " fingernail."
The crew was ordered to cut out 6 such welds. All were found to have up to 75 percent of their root below accepted standards. All these welds resulted in excessive suck back and lack of fusion, center line _.
shrinkage and unconsumed ring."
During this' telephone conversation, the alleger identified an individual,.
Mr. Y who could verify the above. The alleger felt Mr. Y had been intim1-dated.
During the August 24, 1984 telephone conversation the alleger stated . .
"you could see by looking down the open end of the pipe with a flashlight the unconsumed ring."
The alleger also provided a list of nine (9) specific lines located in the pipe tunnel on page 5 of his statement. These lines are listed _
below.
2B Alleger's List.of Lines in WPB Pipe. Tunnel Line No. 2 - Vent Gas - 1530'ss/40,.1530 Area: Pipe Tunnel (WPB)
Zone: 378, 348 4
Cleanliness: Class B i Line No. 2 Chemical Volume Control ss/40,'522' -
Area: Pipe Tunnel (WPB)
Zone: 378, 348 .
- Cleanliness: Class B
~
Line No. 2 - Spent Fuel Pool Cool 0, 1711 Area: Pipe Tunnel (WPB)
Zone: 378, 348 Cleanliness: . Class B Line No., Steam Blowdown carbon steel /40,1711 Area: Pipe Tunnel (WPB)
Zone: 378,'348 Cleanliness: Class C Line No. 2 Chemica.1 Volume control ss/40, 388 Area: . Pipe Tunnel.(WPB)
Zone: 378, 348 .
Cleanliness: Class B
- Line No. 2 Waste line drain ss/40, 2102 Area: Pipe-Tunnel (WPB)
Zone: 378, 348
.'~~ cleanliness: Class C Line No. 2 resin slutcing ss/40, 2517 Area: Pipe Tunnel (WPB) ;
Zone:. 378, 348 _
Cleanliness: Class B Line .No. 2_ Boron recovery system ss/40, 2020 Area: Pipe Tunnel-(WPB)
Zone: 378, 348 Cleanliness: Class B Line No. 2 vent gas ss/40, 1525 Area: Pipe Tunnel (WPB) '
Zone: 378, 348 Cleanliness: Class B w g h
g 29
., - 8.1' . Scope of Inspection All,_of the lingjd_sntified by the alleger are non . safety _.cala.ted itnav wfi6se requirements are si D ety'reTited lines and
.therefore'~are'sW 6e~t7a.gnificantly less than s l a" i neseMa7h= n safety re1ated_~ lines. .ThIt
~
NRC staff inspected the full length of all of the lines in the pipe tunnel
- tdentified by alleger. . The staff performed _ independent measurements . :,__
includt.ng pipe ovality,: pipe wall thickness, weld penetraat examina- .
tions and vTsual weld fnspectionrvtth-eauges. ~In addition, the staff viewed tha inter 21_renditian of accessible welds from the open end of -
each_ pipe run. Further, the. staff cross-checked the specification
~'
requirements for the pipe and ve.rified Yhe proper alloy by independent alloy analysis on the NRC NDE van.
The NRC staff also examined the pipe storage areas and stored pipe in the
>WPB pipe tunnel including sections of pipe that had been cutout of lines.
u- PThese' cut-out~ piece < ~milowed internal insoection of__the_cooLacea. of typt' cal Wif area welds.
8.2 References Seabrook FSAR - Section 3.11, Appendix 3B and Table.3.2-1 ANSI B31.1, Power Piping Code '
? Specification 9763-00'6-248-43, O'esign Specification for Nuclear. Power Plant Piping Systems
~
.x . = Specification 9763-006-248-51, . Field Assembly and Installation.of.P,iping and Mechanical Equipment . .
8.3 Inspection Conduct ,
The staff identified all but one of the pipe runs listed in the alleger's statement. The pipes were located in the Waste Processing Building (WP8) _
pipe tunnel. Figure 8-1 is a sketch of the relative location of each line in the tunnel. The steam blowdown line listed as ISO 1711 in the allegers
_ list could.not.be. identified as ISO 1711...Apparently this:was listed -~ 2t incorrectly by the alleger. The steam blow'down line identified as MK-2-SB-1362-9A7-4"-22 was. inspected. _ Table 8-1. lists each.line, system; _
and relevant specifications. a l e
LOOKIN WEST O6 O
_*MK-2-RS-2517-1-A7 ! *MK-2-WLO-2102-10-A7-4
%-2-CS-522 A7 n /
- MK-2-CS-388-3-A7- *~
\ -
k-2-BRS-2020-1-A7 -
O O O O *Mx-2-Sr-i7ii-i-A7-3
\
(
- HK-2-VG-1530-1-A7 w
=O .n
\
~
SB-1362-9A7-4
-7 vG-1525-5-A11-3 ' ' ;
'n n -MK-2-SF-1736-1-A7 (not part of allegation) i
. 1 i \
l Cross Section of Tunt 1 Showing Pipe Runs identified by Alleger and Inspected by ilRC ' Staff (ALL PIPES ARE NON SAFETY RELATED)
WASTE PROCESSIttG BUILDillG - PIPE TUliflEL FIGURE 8-1 gi
. 1 - l
4.
32 l
l
.This part of the inspection was concentratied in the Waste Processing -
Butiding (WPB) pipe tunnel, elevation (-) 4. feet. Inspection efforts. -
were expended to verify compliance with code requirements, FSAR . .
- commitments, and document requirements,;as applicable,:inathe following-areas: .
,;a) - Pipe' ovality.(measu'ements r a.t welds and in vicinity of therwelds)' v b) Characteristics:of pipes and welds (visual inspr.ction and-penetrant exams) c) Pipe wall thickness (by ultr>soriinxams) d) Weld Process Co'ntrol' Records review e) Receiving inspection records review f) Inspection records for Dimetrics' welds
~
Isometric drawings (IS0s) were utilized to inspect the installed piping in WPB pipe tunnel to verify the pipe length,-weld configurations and associated detatis (see Table 8-1). .
7 m. . . . # [ The pipes identified with an. asterisk in Figure 8-1 were ; inspected. . The outside pipe diameters were measured by calipers, to. check ovalities at-the welds and 3" on either side of-the welds. Visual examinations.were.
made .of the. piping and welds to check for defects 'oFrioifc6iiformance with
. ANSIl31.1 requiremeritiEWi~d gauges were ~used to measure ortsets, hedghts and
- pipe-alionmentsJfor concentric 1 ties on-tne>weids.- MJ_rrewere-used -to -
L,,_,4 examine..the. . internal se.. face of pina wald%whera thay man-'rera s r MW#roa -
- v. openTae end.h. Confirmatorf ~ calculations to . verify compliance with code ml,nimum wall thickness requirements were made.by the staff and compared with NDE van independent measurements.
Penetrant examinations on 10 welds, which included one weld for each line --
in question, were performed by'the NRC NDE van crew to determine weld quality. The NDE van crew also performed ultrasonic exams of 27. weld.
~ joints and, adjacent pipe walls to determine if minimum wall-thickness: 1-violation had occurred.due4 to grinding.of, pipe mismatch. An alloy --
analyzer was utilized by the.NRC NDE crew.to analyze _the chemical .:2 '
composition of the stainless -steel pipes and verify. compliance with -
material specifications.
The welding records, receipt inspection records and QA records as appli-cable, were reviewed for compliance with the ANSI B31.1. code and other codes and standards as appropriate. The IS0s were reviewed and compared with the installed piping and weld configuration to verify as-built ,
conditions.
~
N 1.
33 l
- y. .
'l - -
The staff informally interviewed. craft persons:in the. plant during the ,
field inspection ~s. The crafts reported no known quality problems. -Mr. Y, j
! an individual the alleger identified = by name in a .telecon with the NRC .on '
, August 24, 1984, was on. site and was interviewed by,the staff. u
~8. 4 Findings The pipes in the-WPB are non-safety related-pipes.- Seabrook 1 & 2 FSAR,-
Volume 6, Section 3.11, Appendix 38, classifies the above lines as non-seismic, non-ASME class, and non-essential lines. Table 3.2-l'--
Seismic Category I structures, systemsand components, lists these pipes as non-nuclear, non-safety, and ANSI ~B31.1 piping. The IS0s identify.
these piping either ANSI B31.1 or upgraded ANSI B31.1 piping. The quality of the upgraded B31.1 lines exceed that required by licensee commitment.
United Engineers & Constructors (UE&C) Specification No. 9763-006-248-51,
?- + e m u Field. Assembly an.d: Installation of. Piping and Mechanical Equipment,-
paragraph.1.1.1~.41 provides additional documentation requirements for the upgraded ANSI B31.1 piping.
The ANSI B31.1 Code, Chapter V, Section 127.3, Paragraph C, specifies the- !
, alignment requirement as quoted below:
" Alignment. The inside diameters of piping components to be joined shall be aligned'as accurately as is practicable within existing commercial tolerances on diameters, wall thicknesses,.and-out-of -
roundness. Alignment shall be preserved during selding. ~Where, ends are to be joined and the internal misalignment exceeds 1/16 in., it 4
~'
-is preferred that the component with the wall extending internally.,be internally trimmed (see Fig. 127.3.1) so that adjoining-internal- '
' surfaces are acoroxima.tely_ flush Howane, this.tr_imains shall not -
!" ' result in a piping component wall thickness less than the minimum ,
design thickness and the change in contour shall not exceed.30 deg '
(See Fig. 127.3.1)."
The staff did not identify any unacceptable pipe conditions. All pipes i met ovality / concentricity requirements ana no violations of minimum wall l
. thickness (less than 12 % of nominal wall) were observed. Alloy analysis confirmed that stainless steel. pipe met specifications. ;, -
l A typical Dimetrics weld .in the WPB is shown;in Figure.8-28. Ihs. ,c _.
Dimetrics machina-= da w!ds were af exeg ttonally high qualftv and uni.-
furHiTT-(See Figure 8-2A for a comparison with 'a typical manual weld).
sua and 11auid oenetrant examinations verified acceptability. Internal ;
examination of welds eccascible from the open oice ande hy mirrors and flashliahts did not reveal any unconsumed roots.. UltrasonJc examination i
at the weld did not show any significant variation across the weld volume.
Normal weld shr1nkage occurred at the weld-to pipe intTrfacii. A few welds
~
exhibited some external discoloration but this was of no significance.
l t i
. . .u.
35 4
One manually made field weld, FW.F0603 in line 2-SB-1362-5-A7-4"-16 ~.--
exhibited excess reinforcement.at_one point on its circumference and was of different surface appearance than. the Dimetricsc. automatic welds.;n -
1 -
m ,
However, the staffs judgement.was that.the weld was .ff t:for service..c .-
Mr. Y was still. employed at Seabrook during this. inspection and he wasm.
>tnformally~1nterviewed by the. staff. Mr..Y stated he had worked-in the.-
.WPB pipe tunnel during welding operations there. .He inspected pipe welds and Tufline valve-to pipe welds and had worked both day and evening , ---
shifts. He knew of no unresolved quality problems and in response to questions about harassment or intimidation he responded he had never been the subject of either. ,'
8.5 Conclusion
.The staff could not substantiate the allegation.
4 - ~~
9.0 Allegation - Diesel Generator Piping Field Weld NCR The allegation states on.page 3 of the written statement:
"Two days later, I was assigned to work on Lina No. 4417-01-R/1 F0101, NCR No. 2166 to grind and remove. block veld stainless metal .-
i from weld area. This, field weld had sugar dep3 sits (oxidation.
caused by atmospheriq contamination when welding stainless steel) i from 10:00 to 2:00.on the interior of..the root. pass. I pointed this-out the welding. foreman, but the field weld was complet.ed regardless j of this defect. _I.believe it involved the diesel generater." -- .
i 9.1 Scope of.Inspec. tion . _ . . _ _ . _ _ _ _ . . _ ..
NCR 2166 was written against weld 2DG-4417-enini whteh_js_ located in
- r, - setbrookJJnit 2. This portion of the inspection was directed toward the Unit 2 01eseT~ Generator Cooling Water System with emphasis on the specific weld 4417-F0101. The staff reviewed design records, performed an ASME _
code calculation to confirm' wall thickness, and reviewed test records.
The inspector also considered the significance of an internal weld oxida-s tion (sugaring) area in the root of weld 4417-F0101. -,a 9.2 References _.
FSAR Section 3.11, and Section 9.5.5.
ASME Section III, Subsection ND Drawing 9763-F-202103, Diesel Generator Cooling Water P&I Diagram Isometric Drawing 20G-4417-01 Rev. 5 ~
.. Isometric Orawing 2DG-4417-02 Rev. 5 i
j
_ _._ _ _ ._ _ _- .~ _ . . . _ _ _ _ . . . - _ . . . - . _ _ _ . . _ . _ _ _
40 710.5 Conclusions i-The examinations, physical. measurements,.and the* observations performed.
. on the radioactive tunnel area piping.do-not substantiate .the identified-.
allegation.
A11egation.6 also discusses Dravo-made pipe in the MSF penetration area.--
oThere are some references to the " tunnel" in.the MSF. area. See- -. -
allegation findings and conclusions in relation. to RC .(Dravo) pipe in-the MSF area. - '
- 11. Allegation - Turbine Building Piping-SfioiWeld Defect The allegat.fon stated on page three:
"While working in Turbine Building No.1,- the crew received many m ...- prefabricated. sections of. welded pipe made by Dravo. Many times the joints did not meet ASME codes.
On May 11, 1982, I was assistins another welder on line EX-4125-01-Rev/1, field weld no.108, a 10" weld outlet (WOL) off a 24" carbon steel line, when I noticed a Dravo shop weld defect.
Informed the Quality Assurance inspector about a one-inch lack of
. a- vfusion zone on the~ interior-of the root: pass.:iHowever,"I-was~ told; -
"A Dravo shop weld 1s not our concern."
11.1 Scope of Inspection
....~.-The staffrvisually examined weld Joint FW 108, and t h otherrnearby welds ~
including Shop Weld B;J erformed an ultrasonic exam on Shop Weld B and
_ reviewed NDE performed by the_ licensee in response to staff concerns.
11.2 References ANSI B31.1, Power Piping Code _l FSAR Section 3.11, Page 220 1 Drawing 9763-F202080, .P&I Diagram for Extraction-Steam ==n SA 524, Table A2 - pipe dimensions. r Sketch E2937-1885 for shop fabrication of=24" diameter extraction l' steam pipe / elbow assembly and preparation incuding shop weld "B" dated May 14, 1979.
Isometric Drawing EX-4125-01 Revision 9.
Field process sheet and weld rod requisitions for field weld FW 108.
l l
41
. Specification 9763-006-248'-1, Shop Fabrication of. Piping.
11.3 Inspection Conduct
'The staff identified'the weld on the steam extraction.line in the' turbine:
butiding. See Figure 11-1. -.The-staff exa~ mined the weld joint FW.108 and-
- ~the.other_ ne.arby welds on the steam extraction line 1-EX-4125-01. Dravo.
' shop weId "B".istadjacent to FW-108 and iszthe only-shop weld <in the Dravo shop fabricated oipe section where the 10" weldolet (WOL).was: field ,
. attached. -
The shop weld in the area of FW 208'6 circle seain joining 24" diameter x 0.375 wall SA106 Gr8 pipe to an elbow with a design pressure of 100 psi.
Visual examination of the shop weld on the outside surface showed this
, weld to be of adequate but not excessive reinforcement with the edges of
. the welded material to be in alignment. No surface defects were observed.
e+., Aw.The weld wassultrasonically examined by the NRC NDE van crew arcund its
. circumference. The licensee responded to an NRC question, raised as a result of the UT exam, by performing radiography on the weld.
11.4 Findings One six (6) inch portion of the shop weld "B" near FW 108 produced a small c
, strMitration. _ This -area was,ra iographically examinea- bune .
' licensee ana or m = e=s yeviewed by the(nRC starr_with the resulting
-conclusi_on o that.the ultrasonic indication was a reflection from the con-tour of the Inside weld Deaa surface but w ndication-of-a weld-
" ing.5r material defect. a The ANSI Co e.and des 'gn . specification, for.
-" 'EX-4125 do- not7 require ' radiography or. ultrasonic examination'of- this v m shop weld. The radiographL.taken..to.. supplement the..ultr.ason.fr evalua.ti.on .-
ex,hi.ht.ted_cnel/16" lono incU. cation which did not correspolfa to the root pass interiorytf. ace.
11.5Conciusion
'The conclusion reached by the staff is that the-visual indication discussed in the allegation could not be confirmed by volumetric examina-tion of the-subject weld area. .However, the 5/16"'long radiographic -~ *
' indication exceeds the ANSI B31.1: standard allowable 1.inear. indication- e length of " that would apply t . radiography was required. Iha disposi g d
tion of the'5/16" licensee radiographic eyaluarysu indication is an unresolved; item,p.e,ntln,
_99#84--12-2). ,
j (g. #
- 12. Allegation - Overheated Teflon Seat Valves The alleger, on page 3 of his written statement, states:
"In the' Waste Processing Building, I observed several instances of improperly welded pipes to valves. Because the valves are made with teflon seating material, a manufacturer's tag warns never to heat
56 the MOVs were found to be in acceptable condition. Two MOVs exhibited very slight oil seepage. The manufacturer's (Limitorque) maintenance _
manual stated this is acceptable .and can be expected.after exten'ded._ -
periods of idleness.
. The staff interviewed several ,QC inspectors involved in the performance-
- :of the MOV inspections (one of these inspectors had written-NCR 1249 and-was very knowledgeable of the storage problem). They acknowledged problems had been experienced but felt the corrective actions were effec-tive and knew of no other quality problems that were not being addressed. -
A Limited Work Authorization (LWAs) is a valid administrative control mechanism which allows work to be performed on a nonconforming item. For example, on MOVs, some LWAs were issued to. allow QC to perform p-M func-
,e, r m m tions on>the.MOVs.thus preventing further deterioration. The staff did not identify any misuse of the LWA nor was any situation identified where the deficient condition on the NCR was bypassed by use of an LWA.
13.5 Conclusion
'TheallegationIhatMOVshadbeeninadequatelystoredinJanuary1982is true.. Howe er. tne iic_e_nsee's quality assurance system idiFntiffTd the' problem and institutad nroper remealai corrective action. the preventive maintenance program further assured that the valves did'not degrade.during the construction phase and a relubrication/ inspection prior to: turnover provides additional . assurance of the quality of the MOVs. The _MOVs will .
also be< subjected to functional and performance tests during the preop ~
test program thus proving the operability of .the MOVs.
- 14.- Allecation-- Unrepaired Defects in Steam Generator Nozzles The allegation stated on page 2: l "The failure to check nozzles on three of the plant's four steam -
generators. In one case, workers found a separation of cladding --
that is,.the stainless steel nozzle kept separating -from the carbon & l steel of the steam generator. After much grinding and rewelding; it- '
was discovered that the nozzle was contaminated by large amounts ofu
. slag. Representatives of General Electric, which manufactured the
- I nozzles, apparently repaired that particular nozzle. But to my knowledge, none of the other nozzles on the plant's other three steam generators were checked for similar problems."
l 14.1 Scope of Inspection Unit 1 and 2 each contain four steam generators (SG) which have two lower head nozzles for a total of sixteen. The staff reviewed records for pre weld examination of all nozzles and the post-weld examination of those nozzles i
.12 .
57 i
that are welded to piping. Visual. inspections and independent penetrant, exams were. performed on SG, nozzles in. Unit I by the..NRC-staff.. .;
14.2 References FSAR Sections 5.4.2 and 5.4.3
- Files'on Unit #1rSteam Generator Nozzle Welds'to RC17 2,' 4, 5,J7, 8l 10 and 11, Field Welds FWO101 and FWO104 including pre-weld PT,- ^
post weld RT, post-weld internal and external inspection. '
~
ASME Code Section III, SubsectTon NB.
ASME Code Section V, Article 2 - Radiography NCR numbers 1107, 1476, 3833, 4490, 4789 and 6069.
Memo-RC Loop Welding - Unit II, dated 8/30/83 file W-1043, from Kountz (UE&C) to Corcoran (P-H).
Westinghouse concurrence of 9/13/83 to program of file W-1043 Ultrasonic Test Records for Unit #2 Nozzle Buildups Status memo of Reactor Coolant Loop Unit #2 dated 4/11/84' including welds to steam generator nozzles.
- Unit #2 Steam Generator Layout.for F420003/4/5/6 ,. ..
F{ eld _ instruction ISO FI-132 Reactne canlant Laan ofping Ins +=11a-4 tion and Inspection Files on Unit #2 Steam Generator Nozzle Welds for Loops RC1, 2, 4, '
5, 7, 8,10 and 11, Field Welds F010 and F011, including pre-weld RT, UT, & PT, Post Weld RT and post-weld internal and external -
inspections.
- NCRs, 2364,.5321, 6697,.and 7035 . _ .
__s NRC Inspection Report-50-443/83-19 -2; 14.3 Inspection Conduct i
10 CFR 50.55a(g) defines compon.ents which are part of the reacter pressure boundary to be classified as ASME Code Class 1.= The steam
- generator bottom head reactor coolant inlet and outlet nozzles which carry reactor coolant are required to be welded to the reactor. coolant loop piping and examined in accordance with ASME Class 1 requirements. The principle construction non-destructive examination (NDE) for these welds
.is. radiography (RT) withmthe primary inservice _ inspection examination
{ being Ultrasonic Examination (UT). The inspector reviewed site records
58 for the.eight steam generator to reactor coolant piping welds for both Unit 1 and Unit 2, observed a.sampleJof welding and-discussed welding and testing practices with cognizant site personnel. Two comp'leted nozzle
. . . welds were penetrant inspected by the- NRC NDE va.n crew. _ The final radio-graphic film for the-steam generator nozzles were reviewed.
14.4 Findings .
The defect referred to by the alleger had been identified'by the' licensee and on Unit 1 the eight nozzle. clad weld preparations were penetrant in-spected (PT) to locate surface indicat. ions prior to welding the nozzles to reactor coolant loop. piping. ,Jgbs'equently, all eight Uni _t_1 nozzles were welded to the reactor _cmoolant lonp_ pip.idg. ine work ~iias performed under the QA program controls and in process inspections were performed. '
Final acceptance inspection consisted of radiography in accordance with the ASME Code. The NRC staff verified that the required radiography W w.v %,v(volumetric-examination) had been done and was complete by review of individual' weld joint records and RT record sheets. The staff reviewed -_._._ 3 ,
objective evidence that weld defects and defects in clad found by PT or RT '
by the licensee during fabrication were repaired and re-examined by the -
.. . required NDE method. Of the two steam generator nozzle to piping welds examined with the -liquid penetrant method by the NRC-NDE van crew,,_both met ASME Code requirements and were acceptabl.e.
On Unit 2, in an effort-to minimize post. weld: repair of clad,4the licensee established a supplemental UT, PTrand.RT program of the steam-generator
. clad lower head nozzle weld joint areas. The inspector reviewed the records of this-supplemental NDE on the clad of the nozzle weld joint -
mcpreparationc: At.the time of this inspection ~..three Unit 2 nozzle-to .;~u v reactor coolant pipes were__ welded _a_ndEep.t.ed _on RT. An additional two_ .
L '
welds are presently-rejected on final RT due to a total indication length I of 6" outtof'approximately 200" of weld-length. One nozzle (2RC-2-1-F011) !
has not been fit-up to the 40* elbow, and the other two > nozzles are fit-up :
and partially welded. .
_l The staff also reviewed Field Instruction ISO FI-132 for Reactor Coolant Loop Piping Installation and Inspection, the documentation of the. ASME Code. required RT, and inprocess records of work.done on the eight
^
lower head. nozzles of. the .four. steam. generators..on . Unit .2. . Based on thea above, the inspector concludes.that- all clad. lower head steam generatore nozzle weld joint preparations were examined to. identify and repair .
defects-including " separation of cladding". Subsequent to welding the.
nozzle clad to reactor coolant loop piping, each weld jcint requires ASME Code Radiography for construction acceptance and ultrasonic examination for inservice inspection purposes.
The NRC Region I staff,as part of the. routine inspection program had L
previously followed the status of the steam generator nozzles. During NRC inspection 443/83-19, the NRC Regional NDE specialist reviewed the final radiographic film packages for seven of the.etght Unit #1 steam generator nozzle welds. ' Of two radiographs questioned, both were reshot i
59 i
.and found to be acceptable. . At that time, radiographs of eight Unit #2 reactor vessel safe end nozzles were also reviewed and-found to be acceptable.
14.5 Conclusion *
-The allegation that the: nozzles on three of the four' plant's steam ~ '
. generators were..not. checked was not substantiated.
"'a
- 15. Interviews -
During the course of the inspect.fon,"the~ staff informally interviewed crafts workers, quality control inspectors, and field supervisors to obtain their views on:
- the quality of work at Seabrook effectiveness of the QC interface with crafts, i.e. availability of QC and observance of hold points, and a
harrassment or intimidation of inspectors.
15.1 Welder / Fitter Interviews Twenty-four (24) welders and , fitters were interviewed in the -fieldi- None -
knew of any unresolved quality problems related to piping or welding.
Most of the welders / fitters had been employed-at Seabrook for-time periods from 6 months to over 3 years.
There were no negative comments about the QC inspection inter' ace. One w,-
.crart worker. stated that newly hired -inspectors have a tendency to over inspect because of, lack of knowledge of> requirements. Hold points are observed by the crafts and QC is fairly responsive to the need for timely inspection of the hold points.
The welder / fitters interviewed were knowledgeable of site conditions and work requirements of their trade and stated the quality of workmanship was good or better than average, several commented that it was excellent. -
15.2 Quality Control Inspector Interviews . ;_ _
The staff. informally interviewed six (6) field quality control inspectors'.
A*i QC personnel stated the quality of work'is good and there is no !
harassment or intimidation of QC. QC inspectors were aware of the limita-tions of welding Tufline valves; one inspector stated the crafts had frequently asked him to check the, valve body temperature with a pyrometer.
i 62 ;
l This is a noncompliance with the requirements of 10.CFR 50, Appendix B, Criterion XVI.
- 17. Unresolved Items Unresolved items are. matters about.which more-.information is required _in.
order to ascertain whether they are acceptable items, violations, or. _.
-deviations. . Unresolved items are discussed in. paragraphs 3.3 and.11.5 __2
- 18. Exit Interview .
A management meeting was held at .the-c6nclusion of the inspection on August 31, 1984 to discuss the inspection scope and findings as detailed in this report. The attendees at this meeting are identified in paragraph I by asterisk. No written information was provided to the licensee at ani time during the inspection.
9 4 = n ame l
)
P J
a
]
EXHIBIT
, C PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE s CORRESPONDENCE WITH ,
i 1
NUCLEAR REGULATORY COMMISSION- . _= ,
. 6/11/84; 2/25/85; 3/29/85 4
I i
, - - - , , - , . - < - . +,--, -+-r-- --,-.,nn ,, ,,w -- , - - - - - , , - ,-e --- - - - - ~ ~ --
~
. l SMM STATION l
U PUBLIC SERVICE Iasia aan om )
Company of New Hampshare 1671 Worcester Road j Framinchom. Massachusetts 01701 - !
(617) - 872 8100 D :",[' - June 11,1984
- pa N b a0*. 7 SBN 666 T.F. Q2.2.2
, e-p@LN " ' ,] I United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention: Mr. Richard W. Starostecki, Director e Diyision of Project and Resident Programs
References:
(a) Construction Permits CPPR 35 and CPPR-36, Docket Nosg 50-443ang50-444 (b) Telecon df' November 10, 1982, A. L. Legendre (YAEC) to Eugene KeIley (NRC Region I)
(c) PSNH Letter, dated December 14, 1982, " Interim 10CFR50.55(e) Report;- Cold Pulling of Pipe", J. DeVincentis to R. W. Starostecki (d).PSNH Letter, dated July 15, 1983, " Interim _10CFR50.55(e)
- Report; Cold Pulling of Pipe", J. DeVincentis to R. W. Starostecki
.,(e).PSNH Letter, dated December 15, 1983, " Interim-10CFR50.55(e) Report; Cold Pulling of Pipe", J.--DeVincentis to R. W. Staros tecki (f) PSNH Letter, dated March 2,1984, " Interim 10CFR50.55(e)
Repo rt ; Cold Pulling of Pipe", J. DeVincentis to R. W. Starostecki
Subject:
Final 10CFR50.55(e) Report; Cold Pulling of Pipe
Dear Sir:
On November 10, 1982, we reported a-potential 10CFR50.55(e) item . - . .
regarding an-isolated incident of violation of UE&C: Specification'for Assembly and Erection of Piping and Mechanical Equipment, No. 9763-006-248-51, i Paragraph. 3.5.8.
A. Description of Deficiency We have found that a misalignment greater than that permitted by the piping erection specification existed prior to the ficup of the Main Steam Piping (Line MS-4007-01-B1-30") field welds F0105 "A" and F0106 "B" of Dravo fabricated spools E2937-1982 and E2937-1981, respectively. This.vas diacovered when the. area superintendent requested that the restraints holding the pipe in place for welding be removed to allow a check of the ficup of the pipe.
(Pullman-Higgins Non-Conformance Report No. B0749)
,un,ntneaa O'3"11 ll
' p McE'os000443 PDR _
h
% p- . , ,
United States Nuclear Regulatory Commission June 11, 1984 !
^
Attention: Mr. Richard W. Starostecki, Director Page 2 !
l l
This item is in violation of the specification for Assembly and.. -
Erection of Piping and Mechanical Equipment, No. 9763-006-248-51, .
Paragraph 3.5.8.
A further investigation of a possible generic problem with the.use
~
of mechanical clamps. that could possibly- pull a pipe more than ,the ,
specified 1/8" was performed.
B. Analysis of Safety Implications If excessive misalignments existed in the ficup of Code piping, safety-related components (piping, valves, supports, etc. ) could possibly be overstressed.
..z . u , .a -. .Co m , Corrective Action In order to preclude the possibility that safety-related piping is j overstressed due to excessive cold pull, the following corrective action was undertaken.
- 1. 1The nonconformance report was dispositioned to " rework" the -
piping following an analysis of the piping and.in.accordance i with-installation procedures.
- 2. In order to assure proper installation in the future, Specification 9763-006-248-51, Revision 10 was issued co-add
. the .following:
- a. Paray'.ph 3.5.8.4 s
4 Installation procedures shall establish a hold point at the installation of the final spool piece. Adjacent piping shall be verified as to being in the design configuration, as shown on the drawings, spool piece shall be fit into position as verification that the requirements of Paragraph 3.5.8 are not violated.
- b. Paragraph 3.5.8.5 When tooling clamps are used, as. permitted by Paragraph ,
3.5.8.1, on the final closure weld of any system, or ,
portion thereof, verification of having met the
, requirements of Paragraph 3.5.8 shall be performed prior j to making the weld.
i In conjunction with Items a and b above, Pullman-Higgins has revised their installation procedure and has conducted retraining of pipe fitters, supervisors, Level I QC and Level.II QC personnel,
, ace'ordingly. . The implementation date for_ thers activities was January 1,1983.
bnited States Nuclear Regulatory Commission June 11, 1984 Attention: Mr. Richard W. Starostecki, Director Page 3 D.- Additional Studies and-Analysis-
.The evaluation of the-piping. proceeded on-the premise that. .. .
installation of- the-supports / restraints af ter- the completion- ofa-y final. closure weld would assure that_the effect of any cold pull __.
that may have been introduce. would be minimal. -It was verified -
that the supports / restraints were installed after the final closure weld, therefore, also permitting the elimination of a review of the support designs with regard to any unaccounted for loads attributable to cold pull. All ASME piping installed prior to January 1,1983, where the final closure weld of a system or subsystem was completed, was considered suspect and reviewed with .
respect to the potential effects of cold pull.
The above review encompassed approximately seventy (70) subsystems, ,
, with a subsystem defined as that portion of the piping connecting two points of relative fixity (i.e. , anchors, branch connections, equipment nozzles, etc.). .
i i
Pumps with flanged connections had the piping disconnected and' misalignments were minimized- to assure that. no operation. problems -
o . -would result from pump / motor coupling misalignments.tiSince no nonconformances were generated + indicating misalignments in cexcess of those : allowed by . Specification . 9763-006-248 (1/8") ,_ ic : can a be .
concluded that for these systems, no cold pull had been introduced, r>Further studies.and investigations were initiated.in. order.co.... ,
- further assure that cold pull overstressing was not introduced into y the subsystems. The sensitivity. study intentionally selected.
5 relatively stiff piping configurations so as to yield conservatively 4
high stresses. ,
From these analyses, a stress per unit of cold pull displacement due to misalignment was developed. Based on the margin left in the Code allowable stresses,.an allowable displacement.for misalignment was calculated -for, each subsystem. , ,_ n I
- The - maximum misalignment due to cold pulliwas taken as . l.1/4".-_This 4
misalignment is the maximum misalignment = accepted by the clamps a which are used to align the pipe for velding. In order to exceed .
this misalignment, application of an external mechanical force would be necessary which would have resulted in a nonconformance report.
i'
~For most of the 70 subsystems, the allowable displacement limit for misalignment was greater than the maximum displacement due to cold i
pull. - Subsystems. which had an allowable displacement . limit below
. I 1/4" were analyzed on a. case-by-case basis. ~ Individual analysis of these subsystems produced an allowable displacement for misalignment of greater-than 1 1/4".
, United States. Nuclear Regulatory Commission' June 11, 1984 At'tention: Mr. Richard W. Starostecki, Director Page 4 In conclusion, the results of our-evaluations, studies,-and - -
investigations indicate that if cold pull had been inadvertently. introduced .
.and left. undetected, it would not be of sufficient magnitude.to cause . ,.....
detrimental effects within the piping. In light of this conclusion, we . . ,
consider this item not to meet .the reportability criteria of .10CFR50.55(e)..
Very truly yours, YANKEE ATOMIC, ELECTRIC COMPANY
& b J. DeVincentis
[x Engineering Manager-h- * - ~ -*cer" Atomic
- Safety and Licensing Board Service List Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 .
4 b
.y.,
l,,l SEABROOK STATION Engineering Office February 25, 1985
..... m m g y m ~3 - - -
3~BN- 769 New Hempshire Yankee Division ** **
s United States Nuclear Regulatory Commission ...J.-
Region I 631 Park Avenue King of Prussia, PA 19406 Attention: Mr. Richard W. Starostecki, Director Division of Project and Resident Programs
References:
(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 504444 g (b) USNE6=detter, dated January 4,1985, R. W. Starostecki to
.R. J. Harrison -
(c) PSNH Letter SBN-750, dated January 14, 1985, J. DeVincentis to R. W. Starostecki (d) PSNH Letter SBN-666, dated June 11, 1984, " Final 10CFRSO.55(e) Report; Cold Pulling of Pipe", J. DeVincentis to R. W. Starostecki
Subject:
Response to Allegation Regarding Pressurizer . Surge- Line Cold Pull
Dear Sir:
.The Allegation Resolution Department has conducted an independent investigation into the facts surrounding the alleged incident referenced'in your letter, dated January 4, 1985 [ Reference (b)]. Within the scope of the
. . Allegation Resolution ~ Program, interviews were conducted and written statements taken from individuals associated with the installation of the 4
, pressurizer surge line. Also, the investigators physically examined the pressurizer surge line and found no evidence of scratches, etc., which may have been caused by some mechanical device other than the Deerman clamps which are normally used for fit-up. .
In summary, our investigation did not substantiate any cold pull used'for' alignment of the pressurizer. surge -line at , Field Weld No. RC-49-F0103, nor. any )
of the other welds on the pressurizer surge line. Furthermore, RC-49-F0102 ' -
was the closure veld for the pressurizer surge line, not RC-49-F0103 as alleged.
As noted in Reference (b), the pressurizer surge line was not covered by our " Final 10CFRSO.55(e) Report" on the subject of Cold Pull [ Reference (d)]. s' Omission of the pressurizer surge line and others from our Final Report is attributable to the fact that the lines covered were only those with completed closure welds prior to January 1, 1983, and not those that were in process.
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" gDR ADOCK 05000443 l PDR 1 P.O. Box 300 Secbrook.NH03874 Telephone (603)474 9521 '
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United States Nuclear Regulatory Commission Attention: Mr. Richard W. Starostecki Page 2 We are currently developing a: schedule--for the evaluation of the-linese.-
which were omitted from our Final Report. We will appraise you of this schedule by-March 31, 1985.
Very trul yours, J. DeVincentis, Director Engineering and Licensing
. cc: Atomic Safety and Licensing Board Service List t'
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l SEABROOK STATION Ingineering Office 1
Putsc Service of New HampsNro New Hampshire Yonkee Division March 29, 1985 .g e n pEC J r'SBN- 784 T.F. Q2.2.2 4 go.05
... . . . - 3.4 United States Nuclear Regulatory Commission P ., ,
Region I k. l 631 Park Avenue '
King of Prussia, PA 19406
, Attention: Mr. Richard W. Starostecki, Director Division of Project and Resident Programs
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References:
(a) Cons,truction' Permits CPPR-135 and CPPR-136, Docket Mos. 50-443 and 50-444 (b) PSNH Letter SBN-666, dated June 11, 1984, " Final 10CFR50.55(e) Report; Cold Pulling of Pipe", J. DeVincentis to R. W. Starostecki (c) PSNH Letter SBN-769.. dated February 25,.1985. " Response to Allegation Regarding Pressurizer Surge Line Cold Pull",
J. DeVincentis to R. W. Starostecki
Subject:
Cold Pulling of Pipe
Dear Sir:
4 We connitted.in Reference (c), to develop a schedule for the evaluation of the impact of inadvertent cold pull of the piping lines which may have been s omitted from our Final Report on Cold Pulling [ Reference (b)].
We are currently determining which piping may have been omitted from our Final Report. Upon completion of this task, we will assess the impact of inadvertent cold pull on these lines, and then revise our Final Report as.
appropriate.
These tasks are presently scheduled to be completed by September 1,_1985. l Very truly ours, .
I~> A John DeVincentis, Director Engineering and Licensing cc: Atomic Safety and Licensing Board Service List i
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P.O. Box 300 . Secticok. NH 03874 . Telephone (603) 474-9521 g wmee#=_ m
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EXHIBIT '
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INSTITUTE OF NUCLEAR POWER OPERATIONS EVALUATION OF SEABROOK STATION 12/84.
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SUMMARY
INTRODUCTION l
The' Institute'of Nuclear. Power Operations (INPC) conducted an evaluation of the Public l Service. Company of New Hampshire (PSNH), New Hampshire Yankee Division '(NHY)
Seabrook Station construction project during the weeks of December 3 and December 10, 1984. The project is located in Seabrook, New Hampshire, approximately 30 miles north of Boston, Massachusetts. The project has two 1,198-Mwe Westinghouse pressurized water reactors. ,
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' I PURPO5'E AND 5 COPE l INPO conduc'.ed an evaluation at the site with follow-up at the principal design office, ,
United Engineers and Constructors in Philadelphia, Pennsylvania to evaluate the. control of design and construction processes and to identify areas needing improvement. Information was assembled from discussions, interviews, observations, and reviews of documentation. -
! The INPO evaluation team examined the areas of organization and administration, design control, construction control, project support, training, quality, test control, maintenance, 1
techrucal support, and industry operationa experience. The. team observed actual wuk perfarmance and test periormance. A' portion of the evaluation focused on a detailed vertical path exami..ation through the design,,constrxtion and qua!ity of tbt prefect, combined with a horizontal examination at several points. The team follo_w-up at the design office reviewed the design control, and the team at the project site examined,'in some l detail, the installed equipment.
INPO's goal is to assist member utilities in achieving the highest standards of, excellence in nuclear plant construction. The recommendations in each area are based on best practices, rather than minimum acceptable standards or requirements. Accordingly, areas where improvements are recommended are not necessarily indicative of unsatisfactory perfor-mance. .
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DETERMINATION Within the scope of this evaluation, the team found, except as indicated by the findings, that.the systems in place to control.the quality.of design and construction are being imple- 1 mented effectively. j The following beneficial practices and accomplishments were noted:
A strong corporate commitment exists to complete the Seabrook Station project.
Personal involvement and commitment of senior managers are reflected in effective meetings, improved communications, and in holding personnel accountable for project goals. -
'The establishment of a site engineering team is resulting in the definition of remaining engineering work, improved communications, and in holding personnel accountable for :
project goals.
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1 The controi room simulator is being effectively used to check out start-up and opera-tions procedures and to develop human factors improvements. .
The early establishment of an experienced plant operations staff.has. enhanced the :
preparation of operating procedures. '
improvements were recommended in a number of areas.- The following are considered to be ameny the mest impactanta 1
in the near term..the project needs to complete a detailed integrated schedule of ali major milestones in sufficient detali to ensure-that needed personnel and material resources are identifled to support schedule dates.
Increase emphasis on training craftsmen and inspectors in site requirements. Include provisions to retrain personnel as requirements change.
Ensure increased involvement of first-line supervisors in the day-to-day direction of work activities.
Strengthen the corrective action program to identify problems, analyze generic . issues, and provide timely resolutions to root causes. -
Strengthen start-up and hydrostatic testing activities throug'h improved staffing and operations involvement and the routine use of procedures, valve lineups, and good testing practices.
Improve the quality of preparation and review and the timely issuance of engineering
} change authorizations. .
Increase emphasis in completion of systems and correction of wahdown deficiencies on 1
-a schedule to support testing.
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PUBLIC SERVICE' COMPANY OF NEW HAMP5 HIRE
- NEW HAMPSHIRE, YANKEE DIVISION . . _
Response Summary Public' Service Company of New Hampshire (P5NH), New Hampshire Yankee Division has reviewed the- findings and recommendations resulting from INPC's December 198t+
Construction Project Evaluation of the Seabrook Project.
. This evaluation identified a number of areas where improvement can be made in l i
project procedures and methodology. Each INPO finding has been evaluated along with its associated recommendation. A description of the appropriate corrective action that has already been implemented or is planned for the future is provided in each attached
- - < response. . A schedule for implementation of outstanding corrective action is provided with '
i each resporue. l
- our review of INPO's findings has indicated a need to enhance training on a project-wide basis. The. Project is presently developing a customized traimng progrcm that will include comprehensive supervisory, techmcal, and procedural traimng for both' manual and i non-manual personnel. We will request INPO's assistance in development of the training course outlines to ensure that the final program will adequately address Seabrook's needs. -
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~ The management of the Seabrook Station project wishes to express their appreciation
' to the evaluation team-for their effort and dedication and.to INPO for,its assistance in i
striving for a high level of excellence in the construction of Seabrook Station. .. . u. .
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Page5 ORGANIZATION AND ADMINISTRATTON .
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THE ROLE OF FIRST-LINE SUPERVISORS AND MIDDLE MANAGERS .a-a PERFORMANCE QSJECTIVE: The project .first-Une supervlaars and middle-managers should perform a significant role in ensuring the quality of the project.
Finding (OA.3-1) . Some first-Une supervisors need to be more involved in the daily , 3 activities of their craftsmen to ensre quality construction. On 1 a number of occasions, quality control inspectors provided work l instructions to craftsmen in lieu of the foremen. Since the foremen were not present, they were unaware of the instructions given. Specific work activities included piping, hanger, and instrumentation and control installations.
i Recommendation Improve supervisory attention to quality by strengthening the l accountability of supervisors for their crew's work perfor- l mance. Ensure supervisors take eifactive corrective. action on '
problems identifled. Consider establishing specific quality. goals and objectives for supervision.
Response .Since the INPO evaluation, the fo!!cwing corrective actions have 4
been implemented for the contractor's -Instrumentation and ,
i Control (!&C) Construction disciplines
- a. In January 1983, all. !&C craft pipetitters, l
tupervi:or:, =ginscrs, and QC Lwocs received ;
intensive training or; the Field Instrumentation Procedures, App. 8 of 10 CFR 50, weld symbol nomenclature, and general Nuclear Quality Assurance Manual (NQAM) requirements.
- b. In January 1985 a Lead !&C Superintendent was added to the Owners Construction Group. to strengthen the management of the instrumentation and control effort. In addition, the contractor appointed a new !&C Superintendent who assumed all of the contractor's managerial responsibility for the .
. !&C Department. This action . released field
. superintendents and supervisors to concentrate _their efforts directly with craft activities. These changes provide for improved supervisory attention to installation quality and direct craft supervision.
- c. Additional field engineers were added in February 1985 to relieve the foremen and supermtendents of paperwork processing, thus a!!owing the supervisors to spend more time with tn.e journeymen in the installation process. .
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controls on. storage areas to : ensure that acceptable ASME i- material. remains segregated .from non-safety 2and non-
. conforming. material. . Increase surveillance activities of mate-
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rial storage conditions to identify . improper storage conditions and to ensure continued effectiveness of the storage program
. controls. .
Response The ASME.111 piping contractor has a surveillance / monitoring program in effect for all ASME-designated storage areas. The January 1985 ASME piping contractor inspection reports (14 total) identified 37 unacceptable conditions, including segregation of ASME and non-ASME ltems, that are being resolved by appropriate construction supervision.
Since the time of the INPO evaluation, the NHY Quality Assurance (QA) Depe.i...e..t has increased the frequency of its surveillances of areas in which the piping contractor is storing ASME materials. A significant improvement in storage conditions in these areas has been noted, as demonstrated by a NHY QA surveillance conducted during the last week of January 1983 in which no deficiencies were found.
In addition to the above activities, covered farm wagons ~are
.being used for storage of materials outdoors to help alleviate ,
the cosmetic rusting problem. Cosmetic rust will be cleaned to '
meet specification requirements prior to finish pairiting.
Surveillance by both the ASME !!! piping contractor QA and YAEC QA will continue on a regularly scheduled basis to ensure
, adequate material control in storage areas is maintained.
CONTROL OF CONSTRUCTION PROCESSES
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PERFORMANCE OBJECTTVE: The construction organization should monitor and control all construction processes to ensure that.the project is completed to design requiremenu and that a high level of quality is achieved. ,
Finding (CC.4-1) The care and protection of electrical cables need to be upgraded to ensure that cables are not d.amaged. Some cables were being mishandled during installation, and others were not property l protected af ter installation.
Recommendation - Initiate action .to ensure that procedural requirements are understood, implemented, and enforced.
. Response .The Field Electrical Procedure. (FEP-50t+) training sessi5ns conducted by NHY and Construction. Management personnet !
placed a great deal of emphasis on the care required during I cable installations. Special consideration was given to mtntmurn
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bending and sidewall pressure limitations. All cable pulling l 1'
) .' foremen.were trained and tested-to FEP-304 with a minimum
! . acceptable score of 80 percent. A survey of cable rework during the months of November and December 1984 revealed that only 1 percent of rework was due to damaged cable. Because some 1
, rework .was . still . occurring. - all foremen received-additional l
< instruction on the aforementioned subjects in March 1983.
grinding (CC.4-2i The monitoring and control of some construction activities need improvement. Specific problems were noted in the following areas I l
- a. hanger erection I
- b. pipe installation *
- c. welding process i
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Recommendation ,
Implement in-process inspections by craft supervision.to ensure that construction is performed in accordance with procedures l and quality requirements. Hold field supervision responsible for '
.the quality of work - produced by. the craftsmen. Monitor construction activities to ensure that qua!!!y and pr: Ject {
objectives are met.
Response Since the INPQ evaluation, the following corrective actions have been implemented for the ASME !!! piping construction disciplines
- a. Additional craft supervisors have been added to the piping contractor's staff to increase the level of craf t supervision during in-process work.
- b. By procedures, the field supervisor is , directly .
.. responsible for the quality of work produced by the craftsmen. The. site is- presently reviewing training l needs for supervisory personnel as well as craf t personnel to clearly establish responsibility for quality and training programs.
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- c. The contractor is now staggerin5 start times of l
. second-shift craft supervisors to allow cohestve turnover of work activities between first and second shift. A one-hour overlap permits :he supervisors to walk down work being turned oser and pass on t'.e.
appropriate paper. work.
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Page 19 DOCUMENTATION MANAGEMENT PERFORMANCE OBJECTIVE: The management of project documentation should support the effective control and coordination of project activities and provide a strong foundation for the documentation /information requirements of the plant's operational phase. -
. . Finding (PS.6-1) .
h control of documents used by start-up personne! needs
. improvement. ..Some drawings and documents used by start-up 1 personnel for performing tests are not controlled and are not the latest revision.
Recommendation Implement improved controls to ensure that drawings and documents used by start-up personnel during the conduct of testing activities are the current revision. Perform follow-up reviews in this area to ensure effective corrective action.
Response
Startup Administration Instructions " Control of Drawings," will be revised to improve controls for the notification and issue of drawing revisions to Startup Test Engineers (STE). STEs will be !
notified of drawing revisions and will be required to j acknowledge that a drawing previously issued to him has been i revised. The latest revision will then be issued if requested.' l These drawing control changes should,be fully implemented by May 1985.
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Page 20 TRAINTNG q GENERAI. TRAINING AND QUAUFICATION PERFORMANCE 083ECTIVE: The training program should ensure -that all employees ~
rgeiw indoctrination and training required to perform effectively and that employees are y as appropriate to ther assagned responsibilities.-
Finding (TN.3-1) ?
2.- -...s.t is needed in the training of craftsman and quality control (QC) inspectors. Some craftsmen and QC inspectors are not effectively trained in installation procedures and acceptance criteria. Craftsmen are allowed to work on site prior to l receiving safety training. i Rmommendation Develop and implement training methods to ensure that craf ts-
- men and QC inspectors are knowledgeable concerning proce-dures and acceptance criteria. Implement a monitoring and feedback mechanism to assure management that requirements are being met. Hold first-line supervision accountable for the !
knowledge level and quality level of work of their subordinates. t Implemertt administrative controls to ensure that craftsmen are . !
not easi training.gned work prior to receiving site-specific safety ' l
, Response The W for procedural and acceptance criteria' training for craftsmen will be addressed in the revised Orientation Program for new employees. The procedural and ' acceptance criteria 3
} training w!!! tc predattrminad p.c craft function via a training '
needs matrix. The training format will be prescribed by the Construction Site Training group. This program is first priority in the development of craft training. Initial implementation is )
planned for April 1983. Retrofitting all present craftsmen to this program should be complete by June 1985. i t
Procedural and acceptance criteria training for QC personnel will be predetermined by job function via a training needs l matrix and will be implemented during April 1985. The training :
!. format will be prescribed by the Construction Site Training ,
group. Required refresher training will-be completed by June i
1985.
The existing training procedure (ASP-8)~will be revised by April 1983, and will include a monitoring and feedback mechanism to 4 ensure that desired results are attained and supervisory accountability is established.
! First-line supervisor accountability for the knowledge level and quality level of subordinates' work will be strongly emphasized i in a general foreman / foreman training program, whic t is ,
1 expected to be developed and imp,lemented by Aprt! 1985.
i Administrative controls. to ensure that the craf tsmen recetve safety training on a timely basis will be included in the revision, l
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of the training procedure (ASP-8). Safety trainin
. _ integral part of the Employee Orientation Program.g will be an
. The Site . Training _ Administrator. has developed the.. scope and
', implementation plans for a completely revised construction site training --program. . -The revised . training program > will be
- implemented by June 1985.
NHY, with outside consulting assistance, will design, develop, and monitor the programs to address the above mentioned actions, as wall as the necessary training.to meet the project schedule milestones.
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l QUALITY INSPECTIONS i
PERFORMANCE OBJECTIVE: Quality inspections should be. performed in a manner that ensures opumum monitoring of project activities. m
.- Finding (QP.3-1) . .~ m _ Quality control. inspection hold-pointa are not a6ered to by a11 craftsmen and inspectors. The hold-point programs are not always understood by all craftsmen and quality control inspec-tors.
i Recommendation Provide a more consistent methodology. for annotating hold points in weld process sheets. Provide clear and consistent procedural guidance as to the meaning and requirements of hold points, and provide training to both QC inspectors and crkitsmen to ensure their understanding of the hold point program requirements. ,
Response The symbol H indicates a QC hold point on the weld process control sheets and is well understood by craftsmen, supervisors, and inspectors. The symbol N (H with a slash) with. initial and date indicates a hold point has been deleted. Deleted hold points were shown on the ASME !!! pipe contractor's process !
' sheets several weeks prior to the INPO evaluation and may not !
have been fully understood by. craftsmen.. QC-inspectors were l Informed of the deleted hold point symbol. l As of January 1985, there is no question as to the meming of a hold point by QC or craft personnel, and the existing procedures )
re cler. In this r:gr.rd.~ O!sciplinary action.is administered against any individual bypassing designated hold points. -
In the event a hold point is inadvertently bypassed, a non-conformance report (NCR) and a Corrective Action Report are generated. Trend analyses are performed monthly to confirm that hold points are being adhered to by the ASME !!! piping ,
craftsmen and inspectors. '
4 Similar misunderstanding of hold point symbols existed in the
, area of the electrical contractors. To clarify any -
- misunderstanding on electrical fieldt procedures, at training t
seminar for quality control and construction persennel is scheduled for. April.1985. . The. training will highlignt attributes to be inspected at hold points and symbols used to identify hold points.
Finding (QP.3-2) Some QC inspectors are not adhering to requirements of the QC procedurew Deficiencies were noted in the inspection of instrumentation and controls (l&C), pipe supports, anc electrical.
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Recommendation Ensure that QC inspectors understand the importance of fo!-
.i lowing all procedural requirements. Conduct traimns of QC l
i personnel- on changes to procedural requirements that affect inspection attributes.
i Response -
'Three memorandums have been issued to-remind QC inspectors of the importance of certain procedural requirements. The j content of the memorandums are highlighted below.
- s. ASME Pipe Supports, " Material identification and Fit-up Inspection for Support
- dated December 20, 1984. This memorandum provided the fo!!owing directiom
!. to ensure that both pieces of material $ning joined at fit-up inspection are identified by proper markings
- 2. actions to be taken if marking is not on one or both pieces in order to resolve the problem
- b. !&C, "!.iquid Penetrant Testing" dated January 15, 1985. This memorandum directed that- the temperature of surfaces to be examined by-liquid penetrant testing must be determined prior to performing the test, utilizing a calibrated surface temperature indicator.
- c. Electricai, "Use of a Sultable Weld Measuring Tool" dated February 11,1983. This memorandum directed that a suitable weld measuring tool (e.g., fillet gauge, six-inch scale, etc.) must be utilized to determine acceptability of fillet welds.
In addition, all I&C, QC, and construction personnel received comprehensive documented training in January 1985. An electrical field procedure training seminar will be conducted in April 1983 to highlight a!! QC notification points and inspection acc.eptance criteria. All QC and construction personnel involved -
in electrical construction were required to attend this seminar.
UEAC Procedure QCP-10-8, "AWS D1.1 Safety-related/ Seismic Weld Inspection," was revised-in February 1985 to clarify that the weld size will be measured utilizing a suitable weld measuring tool (e.g., fillet gauge, six-inch scale, etc.).
Changes to inspection procedures are reviewed by responsible supervisors for inspector training needs. If the supervisor determines that training is necessary, inspectors af f acted by the change either receive formal classroom training or are required to complete reading assignments. The supervisor determines the-type of training, based upon the complexity of the change. The training in either case will be documented.
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l Finding (OP.2 2) Auxiliary operator -(AO) adherence to procedures-.needs I
-improvement. Instances were noted where operatmg procedures were not followed or were not used to guide operating activities.
Recommendation f.mpessize t to Aos the need to use operating procedures and to adhere to procedure requirements. In addition, Operations Department supervisors should periodically monitor AO acti-vities with emphasis on procedure usage and adherence.
Response Auxiliary operators have been verbally reminded, in wIrekly meetings with the Assistant Operations Manager, of the need for e using procedures and for adher e to procedure requirements.
Operations Department supervisors have been instructed, by department memorandum, to periodically monitor the auxiliary operator's use of procedures and to validate procedures during equipment and system testing in conjunction with the Startup
. Test Department. The Plant Manager and the Operations . ,
Manager will monitor the actions taken and -evaluate the l effectiveness by May 1985.
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OPERATOR KNOWLEDGE AND PERFORMANCE PERFORMANCE OEDECTWE: Operator knowledge and performance should support safe j and reliable plant operation. )
1 Finding (OP.4-1) Auxiliary operator (AO) knowledge of some plant systems needs .
to be improved. Several Aos were not familiar with some plant equipment they operate. Format AO qualification requirements for individual systems and equipment have not been developed.
Recommendation Evaluate the current level of AO knowledge and provide.appro-priate remedial training. Develop formal qualification require-ments for individual systems and equipment that Aos operate.
Ensure qualification requirements are met prior to ass:gning j Aos operational responsihitities.
Response
In accordance with the plans being developed prior to the INPO evaluation, the auxiliary operator training program nas been transferred to the Licensed Train ng Department. A task force of Training Center staf f and Operations Department staff has ,
reviewed tne INPO generic job task analysts for appitcac:; tty to Seabrook Station. The task force is revising the tra:n:. g i
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, program for auxiliary operators accordingly. The revised program will include formal qualification require.ments. These qualification. requirements . will ~ take into consideration .both
- . Initial training and recycle training to reduce known ,
weaknesses. Plans are being made to recycle on-shift operators 1
- to training as soon.as.possible. ~The. Operations Department is <
also developing a procedure to matrix and track tasks that an auxiliary operator needs to accomplish. The matrix will be used !
by the shift supervisors to document demonstrated proficiency in specific tasks and to schedule on-the-job training for areas of noted weakness. These program revisions are scheduled to be in 1
. full effect by June 1983.
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OPERATIONS PROC 3DURES AND DOCUMENTATION i PERFORMANCE OBJECTIVE: Operational procedures and documents should provide
! appropriate direction and should be effectively used to. support safe operation of the. plant. .
4 Finding (OP.5-1) Uncontrolled drawings and sketches used as operator aids are l
located at various places throughout the plant. Adminutrative controls have not been established for approving, updating, or verifying these documents.
Recorrer.sdatbn Raylaw all postad y:rator aids !ct c:ntinuad app!! cab!!!ty, and I remov0 those no longer required. Update and authorize those that need to remain posted. Document the' posting of a18 ooera-ter aids so an effecti,ve review for continued applicability can be conducted. Posted operator aids of a procedural nature should be minimized. INPO Good Practice OP-207, " Control of Opera-
. tor Aids,"could be of assistance in this eifort. l Response Operations Department personnel have been notified that only i controlled operator aids are to be used and that uncontrolled information will not be allowed in the performance of. duties at j the station. Many uncontrolled operator aids have been comoved ~
i and others are being reviewed to determine the need.for their-i continued use.. Those aids found.useful will become controlled and the others will be removed by June 1983. The importance of t using controlled documents will be stressed to all individuals in
- weekly Operations Department meetings. A procedure for the
- use and control of operator aids is presently under development
- - and will be issued for use by June 1985. The procedure will
- incorporate the beneficial. aspects of INPO Good Practice OP-l 207," Control of Operator Aids."
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f EXIIIBIT .
E DIRECT. TESTIMONY OF GREGORY.C. MINOR AND LYNN K. PRICE ON BEHALF'OF THE STATE OF' VERMONT' DEPARTMENT'OF PUBLIC '
SERVICE REGARDING SEABROOK 1 COSTS DECEMBER 31, 1986 i
(APPLICABLE SECTIONS)
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STATE OF VERMONT
!. o DEPARTMENT;OF PUBLICmSERVICE -
IN RE: Tariff Filing of )
Central Vermont Public Service } Docket No. 5132 Corporation Requesting A )
12 Percent Increase In Rates )
To Take Effect June 2. 1986 )
1 DIRECT TESTIMONY OF GREGORY C. MINOR AND LYNN K. PRICE ON BEHATJ OF STATE OF VERMONT DEPARTMENT OF PUBLIC SERVICE l t
REGARDING l l
SEABROOK 1 COSTS l J
! December 31, 1986 l
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2 of Seabrook 1. Two significant problems experienced at 3
Seabrook due to inadequate performance by UE&C and 4
ineffective management of UE&C by Yankee and PSNH were 5
the inability of UE&C engineering to' support the design 6 needs.of construction and the inability.of UE&C to 7
control the design change process.
8 g Q: Please describe the inability of UE&C engineering to support the design needs of construction.
10 II A: In 1979, Seabrook management became concerned with the 12 ability of UE&C engineering to adequately support the 13 construction effort. As the project progressed, UE&C I4 engineering experienced.significant problems.in the 15 production of pipe support designs, despite continuing 16 efforts to increase production and adequately support II thd needs of construction. Notes of meetings, reports I0 issued internally by specific Seabrook project 19 organizations, and reports generated by outside 20 organizations indicated concern with the ability of 21 UE&C engineering in the area of pipe supports 22 throughout.the bulk. construction. phase at Seabrooku A 23 summary of relevant remarks from these reports in 24 contained in Exhibit (MHB-6).
25 26 27 28
- l 1
2 contractors-(e.g., electrical) can be completed. Any 3 problems experienced with piping can' create _a ripple-4 effect through'the project ~ schedule-which ultimately..
5 affacts system turnover and start-up. . , -
6 u
Pullman-Higgins' piping work was directly 7
l g supervised by UE&C, and indirectly, by Yankee, the g owners' managing agent.
- _, 10 .Please. explain the inadequacies you found in the
_Q:
II performance of Pullman-Higgins.
12 1
A: 'Our review f-problems with Pullman-Higgins indicates 13 i g that piping installation.was an area of continual 1 -
difficulties throughout the period starting when. piping l 15 16 entered the critical path to the 1984 shutdown.- 31/
I t
I l The major problems experienced by Pullman-Higgins l i I0 were poor performance in meeting schedules and in l I9 keeping the necessary drawings and records up to date.
20 This problem was compounded by an inefficient document 21 control cycle. As early as. December of 1980, the NRC, 22 noted. problems.with piping and.. hangers.. While : c._
23
] acknowledging that external factors may have -
j 24 25 12/ Exhibit _ (MHB-9) provides a review of internal and
- 26 external seabrook reports regarding problems
] experienced with Pullman-Higgins.
27 28 t
i f
1 contributed to an unsatisfactory performance in this area, the report noted:
4 5
licenseecorrecti.veactionsinthisareainthe past have failed to. identify and correct the generi auses to specific problems, as evidenced 6
by the recurrent enforcement items. #_B/
7 g Q: Was the Seabrook management structure monitoring the g performance of Pullman-Higgins?
10 A: Yes. Yankee conducted a series of QA audits of II Pullman-Higgins. Some of the findings of these QA I
audits include the following:
13 g (June, 1981] Eighteen deficiencies identified indicating weaknesses in implementation of the P-H QA program. Weld monitoring was shown as a 15 repetitive deficiency also identified by YAEC 16 surveillance and P-H internal audits. Bjf g7 (November and December, 1981) Fourteen dericiencies were identiried. YAEC letter of gg transmittal recommended that a more comprehensive indoctrination training and assessment program be gg established and that more corporate support to.the field be provided. 1Q/
20 21 22 B.8/ NRC Systematic Assessment of ' Licensee Performance, ,1/1 23 - 12/31/80, provided in response to. Data Request #23, Set #1.
33/ Yankee Audit No. SA508C5158, summarized in NRC 25 Construction Appraisal Team Report, August 24, 1982, provided in response to Data Request #36, Set #1.
1Q/ Ibid., Yankee Audit No. SA565CS184.
28 l
l i
1 2 [ November 1981 to January 1982] Fourteen i deficiencies were. identified.-.The transmittal i 3 letter recommended more corporate involvement by l P-H to' assure more. effective management. control of I the QA program. 11/
5 (April,.1982] -' Twenty. deficiencies were. .;
' identified. This audit -identified two primary 6 areas of-concern:- material. identification and weld monitoring. The letter also stated that P-H 7 Management was less than effective in taking corrective action in the above areas. 22/
g 9 These findings indicate that prior to and during 10 the period that piping was entering the critical path II at Seabrook, Pullman-Higgins was already experiencing 12 difficulties.
13 Q: Was project managment aware.of these problems?.
15 A: Project management seems to:have produced and received 16 ample evidence'of Pullman-Higgins problems duiing this 17 period. As erly as December 17, 1960, eves seabrook 18 meeting notes report that "The YAEC people have found 19 many problems with the piping system being constructed 20 by Pullman-Harris (sic)." 12/ In May 1981, the 21 ,.Seabrook Planning.and. Scheduling. Task Force reported 22 that: .
23 24 11/ Ih.id., Yankee Audit No. SA573CS188.
25 22/ Ihi.4., Yankee Audit No. SA598CS203.
F 26 22/ D.R.'McLeod, CVPS, to M.J. Delphia, "Seabrook Meeting of December 17, 1980," December 23, 1980.
28
_73
1 P.H. is not scheduling properly because of their inability to hire schedulers. They are also 3
behind on their drawings. More' effort must be expended by P.H. RA/
4 Engineering has now stated they require longer 5
detailed schedules from Construction to schedule their work. Construction has responded that they 6
need more engineering information to schedule in more detail.... Contractors are not as oriented 7
toward scheduling as they should be. Pullman-Hiccins and Blouin annear to be the Drime 0 (emphasis added) 25/
offenders.
9 Als , the NRC's Systematic Assessment of Licensee 10 yy Performance and Construction Appraisel Team (CAT) rep rts identified Pullman-Higgins problems throughout 12 1982. For instance, the CAT report performed in June 13 g and July of 1982 noted the following:
15
[YAEC) Audit reports of the piping subcontractor revealed several specific oroblems which, when IO viewed collectivelv. indicated a nrocrammatic 37 weakness. These were identified by the licensee's audit program circa mid-1981. AlLlavuyli effurts to jg resolve these problems have been initiated, they have been ineffective. (emphasis added) 25j 19 20 21 21/ Plannina and Schedulina Task Force Report, May 19, _
22 1981, provided in response *.o Data Request #191, Set
- 1, see Exhibit _ (MHB-7).
93/ Plannina and Schedulina Task _ Force Renort, May 27, 24 1981, provided in response to Data Request #191, Set
- 1, see Exhibit _ (MHB-7).
25/ NRC Construction Annraisal Team Renort, June 21-July 2, 26 1982, issued August 24, 1982, Appendix B, provided in response to Data Request #36, Set #1.
28
_74 i
1 2 Responses by' P-H to these (YAEC) audits provided acceptable corrective action for:the individual 3 deficiencies but did..not acknowledge or respond.to the recommendations for correction of programmatic 4
or repetitive problems. 17/ . -
5
'Q: .What impact'did Pullman-Higgins'~ poor' performance-have 6
on the project during this early time period?
7 8 A: The poor performance of Pullman-Higgins, combined with l
' 0 the ongoing UE&C problems described in the previous j 10 section, adversely affected the progress of the II project. In May of 1982, Project Review Meeting IE Minutes mention a report regarding the status of 13 startup turnovers:
l i
14 15 One problem noted was that P-H has.been.getting bogged down with documentation requirements and -
delaying turnovers unnecessarily. 16/
16 I
A " Status of contractor Milestonas" report, dated June I
18 of.1982, indicated that Pullman-Higgins had made "O of ,
19 4" of their past milestones, and " impacted on 2." of'a ,
20 future lo milestones noted, Pullman-Higgins was !
21
. expected to complete only 4 on schedule. There was.no 22
, indication of the expectedzimpactaof these. delays..on.
E other milestones. Nevertheless,.it.is clear that,-
24 25 1 17/ Ihid , p. 10.
26 l 16/ Proiect Review Meetina Minutes, May 3, 1982, p. 3.
- 27 28 t
I
l 1
2 because piping was.on the critical path, any delays 4
experienced in the area of the-piping:and support.. j 4 / structures also affected.the entire project. 12/_-
5
- Q:- Did the project management- take any. action to rectify 6
these problems?
7 0
A: In early 1982, when progress on the piping structures 0
was reportedly over 5 months late relative to the 10
- . milestone schedule, 1QD/ the contractor project
^
II manager was replaced and changes were instituted in the UE&C organization.
13 j4 Q: Were the changes made in 1982 effective in correcting Pullman-Higgins' inadequacies?
15 IO At No. As with other PSNH/ Yankee attempts to correct.
I
~
problems, no substantive improvements in performance I I0 were evident. As noted above, the June 1982 " Status of IO Contractor Milestones" report indicated continued poor 0
performance after these changes, and also reported that 21 22 93 / Another evaluation ofrtha Seabrook project found that:
23 "After mid-1982, the complex interaction between ,
engineering and construction on piping and supports-24 generally controlled the overall project schedule."
(Pickard, Lowe & Garrick, Seabrook Proiect: Manacement 25 prudence Audit, July 1986, p. 3.1-197), provided in response to Data Request #1, Set #2.
1Q9/ Ibid.
27 ,
28 l
l I l l
2 !
" discussions are underway with Pullman home office ,
1 3 l management in an effort to improve the performance of 1 4
P-H." 191/ Also, an October 1982-internal UE&C memo 1 5
documents some of the diverse and ongoing problems with 6
Pullman-Higgins which persisted after the early 1982 7
management changes:
8 9 Another problem was brought to our attention concerning Pullman-Higgins. We were shown several 10 examples of PH construction aid drawings which did not agree with the UE&C drawings. Piece marks were jj different, revisions were different, and dimensions were incorrect just to name a few.
12 Steve Madaras, a design supervisor in the field, showed us PH construction aid drawings where 13 dimensions were incorrect up to 13" off. Steve indicated that PH was making changes and not j4 informing UE&C, thereby, causing the possiblity of more interferences. We were also told that there 15 is n t a check of PH drawings to see if they agree with our UE&C drawings. Steve also indicated that 16 UE&C changed their NQA manual to indicate that checking PH drawings against UE&C drawings was not 17 required. 1_q2/
18 In November of 1982, an INPO sponsored "Self-19 Initiated Construction Project Evaluation" report 20 identified Pullman-Higgins activities as "the most 21 22 .
23 24 191/ Status of Contractor Milestones, June 3, 1982, Items #2 25 and #18.
20 192/ UE&C Memorandum. J.J. Humma. Jr. to G.E. Sarsten, October 26, 1982, p.1, provided on site.
7 28 I !
2 significant area of weakness identified during the 3 evaluation." 192/ The. report continues: ..
4 The concerns with'the performance of the Piping l 5 contractor had been recognized by the project
- m . . , prior..to this. evaluation.and were.alsor. indicated 6 :in.the NRC Cat Inspection #50-443/82-06 performed in June, 1982. The areas of weakness identified 7 by this evaluation reinforce the need for the nroiact to continue to monitor closely work 0 cerformed by this contractor and to consider other remedial actions that would nrove effective in 9 innrovina work auality and schedule nerformance.
Areas of weakness relate to control of documents, !
10 including. design changes, work planning and supervision, craft training, and quality control.
II (emphasis added) 1Q.4/
12 In late 1982 cygna was hir~ed to evaluate piping. '
13 g and hanger installation.. cygna reported.that: . .
15 ... hangers, narticularly nine hancers. are ;
not beina installed at satisfactory rates, -
16 over 50% of hangers in process have required {
redesign, and 40% of all engineering changes .
17 -are hanger problems. (emphasis added) 10.5/ ;
18 l l
19 j 20 I i
21 1Q2/ ,INPO sconsored self-Initiated construction Proiect; _. I Evaluation, November 5, 1982, p. 3, provided in 22 response to Data' Request #1, Set #2.
23 10.4/ Ibid., p. 3.
24 10.5/ cvana Seabrook Station Hanaer Enaineerina Transfer Procram Interin Renort. Phase it Develonmental 25 Procram - Draft Prenared for UEsc, November 19, 1982,
- p. 2-1, see also Appendix E, notes of the October 22, 26 1982 meeting. Provided in response to Data Request
- 181, Set #1.
28 r__.
' EXHIBIT G
+
NDIRECT. TESTIMONY OF' GREGORY C. MINOR AND LYNN. K. PRICE ON BEHALF OF
- STATE-OF VERMONT DEPARTMENT OF PUBLIC SERVICE REGARDING'SEABROOK 1 COSTS ,
VOLUMES II: ' ATTACHMENTS.
' PULLMAN-HIGGINS' PROBLEMS ,
DECEMBER 31, 1986 1
1 l
l
l i
STATE OF VERMONT
.; DEPARTMENT.OF PUBLIC: SERVICE ... a, IN RE: Tariff Filing of )-
l Central Vermont Public Service ) Docket No. 5132
- i corporation Requesting A )
! 12 Percent Increase In Rates )
To Take Effe.t June 2. 1986 )
I ,
l b
l l
i DIRyCT TESTIMONY OF GREGORY C. MINOR 1
i AND LYNN K. PRICE 3
ON BEHALF OF i
STATE OF VERMONT DEPARTMENT OF PUBLIC SERVICE i
l REGARDING t
SEABROOK 1 COSTS ,
! VOLUME II: ATTACHMENTS i
)
i I
December 31,11986 i \
I l
i i
1 I
\
I' i
l f
i
- .. . - . . . ~. - . -.- . . _ . . . . . - .. -. -
i-1 i
Exhibit (MHB-9)
I PULLMAN-HIGGINS PROBLEMS _
1/1/80- -
12/.31/80, Systematic Assessm'ent-of Licensee Performance:; _,e 2
.. Assessment of. Piping-and Hangers notes that external factors may hva contributed to an
- unsa tis fac tory x pe rformance , -howeve r," " licensee " 2" C
, corrective actions in this area (piping-and hangers) in the past have failed to identify and
- correct the generic causes to specific problems, 4
as evidenced by the recurrent enforcement items."
6/20/80 J.H. Herrin, PSNH Site Manager to J. F. Vought, 1
UE&C Resident Construction Manager, "Seabrook i Station, Pioing Weldir.g Quality," 6/20/80: !
"The quality of pipe welding which we have been '
p , 1
.sgetting at Seabrook Station is cause for serious concern. The rejection rate for radiographed
! safety class welds performend by Pullman-Higgins 1
was 38% as of 6/10/80. The rejection rate for I
weld repairs was 50% for the same period. From I the period 5/1/80.to 6/10/80 the rejection rate j for both,new weld and repairs was 60%... - -
l .
The above examples show an ; unacceptable situation.
4 wherein the' quality of welding is poor and seems-to be worsening. We recognize that the end j product will be top quality. This is our acceptance standard for quality assurance and .-
nothing less will be tolerated. However,' with the-amount of rework required to achieve acceptable quality based on the welding performance we have experienced to date, we'are really facing a major j
cost factor which is forcing the welding costs to 4 1 increase. Furthermore with the limited manpower "
j situation, particularly welders, this will also j have a negative impact on schedule performance."
i
- 5/19/81 -Planning and Scheduling Task Force Report: '-
"The design;and construction.of Seabrook Station..+--
! ise proceeding on a hand-to-mouth, crisis basis." '
{
"P.H. is not scheduling properly:.because of their "C
- inability to hire schedulers. They are also
- behind on their drawingn. More. effort must be j expended by P.H."
i 5/27/81 PSNH Planning and Scheduling Task Force Report:
Discusses breakdown between engineering and j construction, and states "many of the problems i
I identified in the report have been discussed in 1
the past and can no longer be permitted to remain
(
i u-- -
-. _. - - . .. . - -. . ~ . . - - - - _ . . -
s-unresolved. A definitive plan of' action to resolve these. problems is required immediately." ,
~
" Engineering.has now stated,theyirequire longer -
detailed schedules from Construction to schedule.
[ their work. Construction has responded that ,they- !
-need.more engineering ~information tosschedule.in- e
'" <more detail." .The review reveals that . . . . ,
" Contractors are.not..as oriented toward scheduling.
astthey should:.be.' ' Pullman-Higgins:and-Blouin wa appear to be:the prime offenders."
6/81 YAEC site audit:
-: " Eighteen deficiencies identified indicating I
i weaknesses in implementation of the P-H QA
'; J , program. Weld monitoring was shown as a repetitive deficiency also identified by YAEC f surveillance and P-H internal audits.(Audit No. ,
i SA508C5158, summarized in-6/21-7/2/1982 CAT --
i t c +.d.r. 436)..
8/20/81 Project Review Meeting Minutes:
" Pipe support production rate is being maintained
- but is requiring substantially higher manpower
, level than' estimated. Manpower level at 180 l
currently."
P ' -9/15/81 "NRC Caseload ^ Forecast Panel: "
Panel determines that Unit 1 will- not be1 completed i until December 1984, as opposed to November 1983'
! PSNH completion date.
11/81 &
12/81 YAEC site audit:
" Fourteen deficiencies.were identified. YAEC-
' letter of transmittalf recommended that a more i comprehensive indoctrinatio'n training and l i , assessment program be established and that more '
l corporate support to the field be provided."
j (Audit No. SA565CS184, summarized in 6/21-7/2/1992 CAT --d.r. 436).
a 11/81 to '
i 1/82 YAEC site audit:
I
" Fourteen deficiencies were identified. The a.m .
transmittal letter recommended more corporate
! involvement by P-H to assure more effective j management control of the QA program." (Audit No.
l SA573CS188, summarized in 6/21-7/2/1982 CAT'--
j d.r. 436). /
4 i
I p y ;
._m . _ _ . . _ _- . _ , , , , , _ , ._,___,m ,, . , , , , _ _ . _ ____,,, _ ___,.,__,,,___.._..,_,-,_cm- . , _ _ . , , . . . . _ _ _ _ _ . _ _ . , , , , _ , . , , _ _
i 12/81 Monthly Report #114:
"As noted last month, manpower requirements for pipefitters will be the controlling factc in .
-completing the plant-on schedule.--Pullman-Higgins has the responsibility for increasing their. number of pipefitters-and has-indicated they will plan _on.
- achieving the required. level by-April 1, 1982." .
12/11/81;; Project Review Meeting Minutes: -c
-"UE&C and Pullman Higgins are working.to' improve~
the weld rejection rate.. It is cur.rently.ac.the.
- 24-25% level. One reason given fer this high rate i of rejection is that nur fitter
- velder ratio is i approximately 2 to 1 and it shculd be 2.5 to 1.
1 "It was noted that the piping discipline is getting very little Project Controls attention d
considering the importance of this discipline.
r-aUE&C. attributed this to Pullman-Higgins' lack of scheduling. UE&C is requesting P-H to submit the l remainder of their building schedules in January."
3/3/82 Project Review Meeting Minutes:
j
" Pullman-Higgins has-started work on the C Leg of the Cross Under-Pipe using the approved procedure. ,
! The second leg which-has been identified as'having
- an obstructioncis grossly.out.-of line=and..there.;is, more information required to resolve'this . .
problem."
. . _ .3/25/82m;NRC Meeting Summary, L. Wheeler, Project Manager: g PSNH meets with NRC staff to. address.a-13 month _
dif ference between the utility and NRC projections 4
for. construction. completion. !
4/82 Monthly Report 4118: '
"The Immediate Action Letter (IAL) and the three associated items of noncompliance were closed.
These were written against repair welding by Pullman-Higgins."
4/82 YAEC site audit:
- " Twenty deficiencies were identified. LThis audite,.
- identified.two; primary; areas.:of concern: material.
identification..and weld monitoring._ The letter. .
also stated that P-H Management was less than effective in taking corrective action in the above-areas." (Audit No. SA598CS203,-summarized in 6/21-7/2/1982 CAT -- d.r. 436).
4
i 5/3/82 Project Review Meetino Minutes:
"D.C. McLain presented the status of startup I turnovers.. .One problem noted was that P-H has been getting bogged down with documentation requirements -and- delaying turnoverc unnecessarily.
6/3/82 Status of Contractor Milestones:-
i Pullman Higgins: Past, made 0 of,4 (impacted-on 2); Future, 4 on. schedule, 6 behind. "R.P.
.Pizzuti: reported:that discussions ~are-underway ~ -
.with Pullman homeoffice.. management in an effort to improve the performance of P-H."
8/24/82 NRC Construction' Appraisal Team Report: !
" Audit reports of the piping subcontractor revealed several specific problems which, when viewed collectively, indicated a programmatic weakness. These were identified by the licensee's ,
audit program circa mid-1981. Although efforts to p - resolve these problems have been initiated, they have been inef fective. .. . Responses by P-H to these
! audits provided acceptable corrective action for j
the individual deficiencies but did not acknowledge or respond to the recommendations for
- correction of programmatic or repetitive 1 problems."
1 j "* r - -
9/13/82<
~
Systematic' Assessment of-Licensee Performance:-
Piping Systems and. Supports-analysistnotedr"unlike the violations identified during the previous assessment, all but one of the current violations relate.more -directly to the deficiencies in. the guidelines and engineering criteria provided to the piping contractor rather than.to the
- , performance of the-contractor, Pullman-Higgins.
Additional problems were raised by NRC findings that P-H was openly using construction practices in conflict with UE&C specifications."
9/29/82 Project Review Meeting Minutes:
" Pullman-Higgins after much delay has issued their procedure (for use. of : instant ECAs] but have not -
used the instant ECA yet."
l 10/26/82 UE&C Memorandum, J.J. Humma , Jr. 'to G.E. 'Sa rsten , jl 10/26/82:
"Another proteam was brought to our attention concerning Pullman-Higgins. tWe.were shown several examples of PH. construction aid drawings.which did not agree with the UE&C drawings. ' Piece marks were dif fe ren t, revisions were different, and dimensions were incorrect just to name a few.
Steve Madaras, a design supervisor in the field, j showed us PH construction aid drawings where
dimensions were incorrect up to 13" off. Steve indicated that PH was making changes and not informing UE&C,.thereby, causing.the possiblity of more interferences. - We were also told that there is not a check of.PH drawings to see if they agree j - '
with~our UEEC' drawings. Steve 1also' indicated that UE&C changed their NQA manual tocindicate that ,-
. checking PH, drawings,against UE&C drawings was.not requi r ed .' "
111/82 .Stop Work Order:
Due to the f ailure to control piping and support design change down to the point of installation, also to unqualified welding procedures r
) 11/4/82 Project Review Meeting Minutes:
"Use of Construction Aid drawings was addressed by-
., . ~..J.,R.-Slotterback.. It-was noted that P-H
' construction drawings have been found to conflict with UE&C design drawings."
11/5/82 INPO sponsored Self-Initiated Construction Project Evaluation:
"The Piping Contractor's (Pullman-Higgins) ;
activities [as] the most significant. area of weakness-identified-during..the evaluation" "The concerns with the . performance of the . Piping 4
. Contractor had been recognized by the project
. prior to-this evaluaion and were also. indicated .in I
-the NRC Cat Inspection. 450-443/82-06aperformed.in.
June, 1982.. The areas of. weakness identified by i
this evaluation reinforce the need for the project i to continue to monitor closely work performed by this contractor and to' consider other remediatl actions that would prove ef fective in improving work quality and schedule performance. Areas of weakness relate to control of documents, including design changes, work planning and supervision, craft training, and quality control." --
"The supervision of the Piping'. Contractor's worke' l
' should be . strengthened. . . Weaknesses 'in the area of- l schedule awareness and directrsupervision of the:-"
work were noted."
' " Finding OA.3-1: Piping Installation Constractor supervisors are not sufficiently_ involved in the control, performance and direction;of project activities. . Corrective Action : Project i
Managment is currently restructuring all activities being performed by the Piping '
l
O 4
Contractor, to address specific weaknesses ;
- relating to document control, the development of construction aides, craf t supervision an training, work scheduling, productivity and quality Control."
l 11/10/82. A. M. Ebner,'- UEEC. Project-Manager-to P. L. Evans,,
'.P-H, "P-H Drawing and Design Control Procedures, ,
j
_ ._ ,, Quality Assurance Audit Report NH-590, Evaluation ~ )
i of Responses:
" Contrary torthecabove, erection,=in-process:and-final inspection are performed to the P-H Drawings
' and not in accordance with the UE&C Design Drawings" Corrective Action Reply: "The agreement reached in the December 1982 meeting with United i
Engineers and Constructors, Inc. ' stated, ef fective i January 31, 1983, UE&C is responsible for preparation of design drawings to be utilised for i construction." ,
i , . . -
l Audit Finding-Report: "A) Contrary to the'above, l during the Audit numerous discrepancies were observed in translation of information from UE&C Design Drawings to P-H Drawings _(6 out of 40 in 1 piping and 1S out of 67 in hangers), B). Contrary l t
to the above, out of a . sample of 66 hanger l drawings selected from work in progress 16.were.
c - observed to - have a la ter.: revision or;.ECA'.s~ issued - -
1 against them." . Corrective Action Reply: " United i Engineers and Constructors /and-Pullman-Higgins are. l jointly pursuing the reduction of the backlog =of' l
.ECA.'s. Effective January.31, 1983,- United
-Engineers and Constructors will assume -
responsibility for the design and incorporation'of ECA's."
11/18/82 Letter, J.J. Corcoran, P-H Resident Construction
' Manager to R. A Rebel, UE&C:
'As we have previously discussed, the magnitude of 9
the Pullman-Higgins' engineering backlog has created a situation where we cannot guarantee that piping and pipe support erection is being performed in accordance with the latest design -
documents.- Of n significant -importance is that we u cannot_ define 1what. engineering.-changes impact-workr o in' progress, nor can we define what completed or-a !
'~
future work is impacted by the engineering -!
changes. As this situation is untenable, we will issue stop work orders.to cease piping and pipe-support _ erection . activities. ef fective Monday, November 22, 1982... Concurrent with the stop work,
- j. orders, Pullman-Higgins Engineering Department will commence working 24-hour days in order to ascertain engineering change impact.- In pursuit I
l
of this activity, we will relocate field and Quality Assurance personnel. However, this does 1
not constitute .suf ficient personnel to conduct this evaluation in.a expeditious manner. The 16
, hanger engineers from: Philadelphia will be placed on second shift.. In. addition,.we.will. appreciate -
4 , the loan of site personnel as listed below: [ 2 0. ,
names listed]"
ll/19/82,-Cygna Seabrook- Station Hanger Engineering Transfer
+ Program Interim Report. Phase 1: Developmental -
Program - Draft Prepared for UE&C:
In meetings between Cygna, UE&C, and the Owner, problems regarding hanger installation were discussed, and are cited as the reason for the initiation of the Cygna study. Specifically noted was the fact that " hangers, particularly pipe hangers, are not being installed at satisfactory rates, over 50% of hangers in process have
,> required redesign, and 40% of all engineering changes are hanger problems."
12/10/82 Gilbert Associates Interim Report #2:
' "The hanger program is apparently belatedly the cause of much concern at this time. We believe that the prime responsibility.for this problem 4
lies with.the. Engineering. design group. ..It is
- inconceivable to me that.a . policy -was allowed to develop that~ allowed the erection of piping previous to-the erection of hangers. -
4
, . 12/22/82. Project' Review Meeting Minutes:
'~ "P-H As-Built work has been suspen'ed~to-devote d l effort to drawing revisions. Evaluating the use
.of UEEC. drawings for installation in place of Construction Aid Drawings."
"D.E. McGarrigan stated that-Perini, P-H ,
and JCI have been audited for use of Construction Aid Drawings. The only problem noted to date has been with P-H."
"N. Hayes discussed the reorganization of P-H 4
and UE&C. piping. The cost, planning and scheduling,.and cleanliness, responsibilities have.
been restructured. .The production side of.the -
i i
organization 1has been reviewedsandschanges willaben i implemented. December 20, 1982.- I l
2/22/83 Project Review Meeting' Minutes: I "R.B. Cheynes presented the status of the Unit 1 Schedule....The two areas-largely responsible for 3
schedule slippage are concrete and piping, of 1 I i
l which piping is the major concern. Major problems identified in the piping were: 1) .the stop work order, 2) .an interium (sic) . loss of efficiency during the organizational restructuring and 3) -
pipe fitter manpower. levels are.below -
requirements.
"R.A. Rebel . reported-that- the .P-Hereorganization-
.is complete. Engineering is.now starting to :-..
-generate drawings to-be used-by the field." -
1983 UE&C Response to Prudency-Hearing Task-Request No.
100182, 10/08/85:
"UE&C in 1983, in response to the contractors inability to support the efforts of their craf t, removed a large portion of the non-manual scope
- from the contractor" (contractor = P-H) 3/30/83 MAC Diagnostic for Construction Completion and i
7 Start-up.for Seabrook Unit .(:
P-H/UE&C merger explained as follows: P-H engineering and OA plus craft labor remains under P-H direction. All other is merged with UE&C non-manual site capability. The objective is to
" reduce the number of communication interfaces, and give UE&C CM management of the entire group.
MAC report states "Itiis~ recognized.by CM and the contractor _(P-H) that design and -installation of piping hangers is a key and critical issue impinging the construction completion and start-up
-. -schedule. Installation. rates must more than -
double present rates in order to accomplish the current. schedule.. While achievable, these high installation-rates will. require improvements in other areas, notably the handling of Engineering Change Authorizations (ECA) and preplanning of construction work."
Report notes, with regard to use of nonconformance !
l documents: "Some confusion seems to exist at
_ subcontractor levels (e.g.,.P-H) on the status of- i nonconformance document activities..and on actions.
required to accomplish disposition.
4/8/83 YAEC Seabrook Trip Report ST704CS265:
Results: (a) . . .Mr. Giansiracusa provided the ..
auditor with a list of twelve.(12) ECAs which have been sent to Pullman-Higgins; however, a comparison with Pullman Higgins' list of ECAs 4
indicates that only five (5) of the twelve (12) l have been received by P-H. '
-g-
4 (b) UE&C stated that sixty-one (61) drawings will be sent to Pullman Higgins for review...After P-H reviews the. drawings, they are transmitted '
back to UE&C. in order for UEECs.. document control to release the. drawings back to.P-H.
(c) . Pullman-Higgins has received just two4(2).. l weld repair documents-since the merger. P-H records show.that.usually. twenty (20). weld ~. repair- '
orders are sent uto -the field per week. -
.(d)aPullman-Higgins/has received.. nineteen.c-m(19) . drawings from UE&C since the merger; -however,-
twelve -(12) of the nineteen (19) drawings shall be -
rejected..."
'(e) On February 15, 1983, a Corrective-Action Report (No. 069) was sent ... regarding controlled documents that have been removed _from the Pullman Higgins Engineering office. As of March 1, 1983, there was no evidence that UE&C had returned tho documents. E
Conclusions:
It appears that the cooperation between UE&C and Pullman Higgins could be improved. It also appears that UE&C does have a
, -lot of work ahead before a smooth operation can be l instituted."
)
i 4/22/83 Seabrook Joint Owners - Meeting: '
J
" Performance in -.the electrical. area.: remains good, however, because of piping delays,: eventually .
- electrical will also be. held up."
"As.to schedule and cost,--Unit 1 now appears to be.
73 days behind schedule primarily because-of ~the '
piping and mechanical area."
"Wendell Johnson indicated that the high density
', of labor is a real problem and agrees that the schedule is a very optimistic one, however, he would hesitate at this . time to change the schedule
' as they believe that any slippage in schedule will l automatically relieve the contractors to some extent of meeting. a tighter. schedule and they ,will~
. correspondingly _ relax their efforts." -
5/83 Report of the MMWEC Task' Force: - ? "-
"W1at truly dictates the final quantities is the - -
degree of-completion of engineering and design support. For the Seabrook project, this support is lagging, particularly-in the pipe support area."
i 1
. -_ . . - _ .- . . , - - - . - . . . , _ - - . _ - . . - - . _ _ ._ -. - - - <._-. _ .. - _ - - _ , - . . , _ _ - - . _ ~ - - - - _ -
. . . . - = _ . - - - - . .-.
5/11/83 NRC Meeting Summa ry, L. Wheeler, Project Manager:
"NRC and applicant representatives met to review the basis.for. projecting a fuel load date for-Unit
- 1. . . .The meeting consisted of a.. review of detailed information presentedaby thecapplicant to support. !
I' their projection:of; September.:1984 as the daterthe
-plant will be ready for fuel loading.- The --
applicant -stated :that construction was .
~-approximatelym two-months behind, schedule _but.. plans are in place to make up this time and be on -
schedule- byathe spring of -1984. . . .The MAC = report--
projects that the plant will be ready for commercial operation by the end of 1985.- In 4 addition,the applicant, in response to staff
, inquiry, reported that the New Hampshire Public Utility Commission (NHPUC) projected completion dates of.early 1985 to 1986. The applicant indicated that an NRC staff estimate that would be '
4-similar to those of MAC and the NHPUC would not be >
< .-unexpected."
} 6/14/83 Special Seabrook Joint owners Meetinc:
"PSNH reporte on the status of the c.eficient weld inspections where .. . one inspector was doing his i job strictly on paper and in reality never did
! examine 1,978 welds.- Pullman-Higgins, the responsible party, has now re-examined'77.of-these welds and'they have determined that 17ahave_not.
passed the quality assurance standards.- An i
outside contractor has been hired by Pullman-Higgins to examine the balance of..the welds and_
this.. work will be finished around the.first of 1 .-
August."
i ~
6/21/83 _ Project-Review Meeting. Notes:
"B. J. Huselton addressed the piping As-Built
' program. UE&C has qualified several of those doing as-built work as Level II inspectors. This relieves P-H from reinspecting for location and configuration. P-H is now using " marked-up" drawings as input to hydropackages."
"B.'J. Huselton. discussed the status of TP-8. -,-
Rhiladelphia.has. issued revision-4. The s.
contractors'apersonnel are.being: trained in its;=
use and it is'being' implemented.":P-H is the only contractor not implementing the procedure '
- adequately."
, ~6/28/83 Project Review Meeting Minutes:
- "W. Taylor discussed the status of P-H 4
performance. He attributed the recent rise in
- rework to an increased amount of ECAs, written to respond .to emphasis on hanger- installa tion."
l rw * .$ - - + - , . - - , = . - . - - , - - . - , , - - - , , - , , - - ------.y . - --s - - . - - . - - -,y-we w,e-- , c - - - ,+->s-------+ ----aw
7/28/83 YAEC CFQA Stop Work Notifica cion 47:
"P-H_ Procedure.III-4 requires ECA's to be recorded on drawings by the individuals in possession of the controlled = drawings. As -ECA.'. s -can change -the . .
design.and/or QC-requirements itais. essential;that this. function be performed to assure that work- is -
_being. performed _to the latest design-requirements. '
On.numerousLoccasions,tduring-YAEC. audits,-P-H w JCorp., Audits, YAEC. Site Surveillance. and YAEC/UE&C
.Supevisory. Support Group. Activities,c. failure.to=- ,
record ECA's on drawings was identified to P-H.
To date YAEC considers actions taken by P-H to be inef fective in correcting the problem or preventing repetition..." (Work was not stopped under this SWO, but.P-H agreed to a number of corrective actions outlined in YAEC Memorandum, J.
H. Herrin to E.M. Hayes, UE&C, 9/1/83) ,
t-28/83 ' vYNSD-Monthly Report' Notes, 458:
"As a result of repetitive deficiencies identified
' in the Pullman-Higgins design control program, YAEC CQA has taken escalated management action in j
the form of issuing to Pullman-Higgins a selective stop work notification on all safety related work activities. The selective nature of the-notification allows P-H. to continue a specific-work activity only .af ter 'it'.has- been verified that -
i the pertinent design. drawings reflect the-latest-design informantion. Meanwhile, an-intensive corrective action effort:is underway _to. assure 1
.that.1) all controlled.. design drawings.used.for.
)
construction reflect the latest design information, 2) the design change program is )
a 1 evaluated and changes are made, as necessary, and
- 3) that the necessary training for those personnel responsible to assure design control is being i maintained as conducted. Satisfactory accomplishment will be verified by YAEC CQA personnel prior" to removing this stop work j notification.
8/8/83 Systematic Assessment uf' Licensee Performance: ~ ~y"
" Summary of Results:. While.the licensee's a performance in each evaluation area reflects a
- commitment to safety, only marginally acceptable' results were achieved in the Piping Systems and
, Supports area. The number of violations cited in-this areas is less significant. than .the inability of the licensee's corrective action program to achieve satisfactory performance."
l I
"The Piping Systems and Supports functional area has been a continued -area of concern over the
.recent past,-as. evidenced by : (1). Catagory 3 assessment in the 1980.and 1981/82 SALPs; (2)
Significant program ~ weaknesses and. violations identified bysthe.NRC Construction Assessment Teame
- i. inspection (June , 1982); (3) The-identification by the INPO sponsored Self-InitiatedsConstruction
. Project Evaluation-of; the piping-contractor '_s. acc_..
4
- < activities as the most significant area of.
-weakness-(November, 1982)."
- 9/83 "The CDG'for piping had reviewed approximately 12,000 Pullman-Higgins drawings through March 1983, in order to determine what piping work was still outstanding. The piping group determined that 1,730 piping installation isometrics were
- still required as of April, 1983. 'The CDG for pipe supports was working on 1,400 drawing for new elarge bore supports and begain production of 2,266 drawings for new small bore supports during this month...By the end of September, 1983, the CDG
, piping had almost completed revising the 1,290 drawings affected by the November, 1982 stop work order. -The CDG for pipe supports'had cleared the backlog of 1,337 new small bore pipe: support. -
drawings for new small bore-pipe hangers for,_ .
issuance to -Pullman-Higgins- for.efield
- construction."
A.P. Angelopulos,.UE&C to C. Huston,
. Challenge,.Inc.,."Seabrook Prudence. Support Unique RFeatures. Task No.4.b. UE&C.Manhour Expenditures for Assumption of Pullman-Higgins Functions:
644,000 Manhours, TRF Nos. 200,131 and 200,205,"
4/16/86)":
9/23/83 Memo from Tracy to Johnson and Merrill re:
Baseline Schedule - Assumptions:
"As part of the process in developing a Baseline Schedule for Unit il and Common the task group requested that UE&C provide their assumptions applicable to such a schedule....We have no current reason to change UEEC's assumptions on~ <
rework withethezexception.of; Pullman-Higgins and.;2_.
" Pullman Higgins (UE&C 33% - OCMG 40%) P-H rework ,
has tracked at 40 to 50% consistently since May 1 1983. July (34%) was an exception primarily due to a major piping goal which took' people only temporarily from rework. The remaining work which P-H must perform in mainly on the Primary Plant side which is subject to the greatest amount of
.. rework.- . Hanger work (both large and small bore)
represents the largest exposure. To date we have over 4000 equivalent hangers at 90% completion but only 60. completely signed off. exposing us to a potential.of rework for already complete work.
UE&C and P-H have instituted walkdown programs and
. area engineer programs,and they. continue to tyr ta-reduce the amount.of rework.by better planning.
.. Although .these- programs have .been . working for some .
-time, we~see little impact..on the-percent of- ~ c. .
. rework facing P-H. We therefore feel. that a more reasonable rework figure for P-H should be 40%- to complete remaining work. We also feel that UE&C and P-H are going to have to work very hard to improve to that level."
9/29/83 Seabrook Joint Owners Meeting:
" Piping is still the major problem which is holding up progress of Unit #1. Consistently we are not making our target expectations. . ."
'"As stated earlier, piping is the big problem and many piping systems are in the range of 130 to 150 days behind schedule."
11/18/83 Exit Meeting Construction Project- Evaluation of- __
Seabrook Project, INPO:
"Although not required by.the ASME. code,.the _
piping contractors.procedureifor..ECAts_ require a review by Engineering, QA, and the ANI. This_ i review negates the. advantages of on-the-spot ECA's !
which should allow work to. proceed immediately."
(Finding CC.1-1) 12/12/83 Yaec Seabrook Audit Report No. SA784CS319:
" Evaluation: This audit revealed a tendency for-Pullman-Higgins' procedures to (a) state in all inclusive scopes, but have a limited application, ,
and (b) impose time limits, but have no l documentation of enforcement or corrective action when procedural time limits are violated. It is evident that there is .a need for changes in .
Pullman-Higgins ' = training Program to encompass . the ' !
. construction and engineering. personnel and for._a-~-
. system to incorporate YAEC-identified deficiencies--
into P-H's system for nonconformance and corrective action."
"The lack of timely response to open items, the new items revealed during this audit, and the need to issue an-Immediate Action Request indicate a need for Pullman-Higgins ' managemnt to display a proper sence of urgency relative to identified program deficiencies."
. ~ . --
'12/29/84 Seabrook Joint Owners Meeting:
" Piping continues to be the major hold up of the project, installaton. targets are not being made
. ~
' and it appears that we are approximately 9 months behind on piping installation based on the most-recent installation rates."
\ -
1/10/84 YAEC Seabrook Audit Report'No. SA793CS327: '
" Evaluation: This audit revealed an increase in:
awareness of_the needslof the program, but there'-
is.still.a need for more prompt action in solving i
open audit items."
2/2/84 Project Review Meeting Minutes:
"W. J. Taylor discussed the installation of pipe supports....Mr. Taylor stated pipe supports are experiencing an 80% rejection rate at inspection.
Most rejections pertain to " welding conditions." .
...Mr. Taylor discussed problems with final inspection of . welds which are causing rejections.
'He-stated that inspection criteria was being interpreted incorrectly."
In attachment ld this is explained as
' follows: lack of proper inspection judgement and terminology, excessive inspections and interpretations, reject criteria, overcritical' inspection.
. Attachment 3_ notes Pipe. Support Detailing-Problems. Sources: 1) Early H.O. Designs; 2) 3
- Field drawings prepared by Pullman-Higgins;' 3)
ECAs.
I Corrective-Action: 1) CDG review of H.O.
. Designs during preparation of field drawings; .2)
. Preconstruction walkdown; 3) Awareness-training; 4)-Experienced consultants / spot checks."
03/13/84, Seabrook Units No. 1& 2, Revised' Order of Magnitude Project Estimate, 3/13/84:
" Direct manual labor manhours for to go work were adjusted to reflect average industry productivity (Based on UE&C, Stone & Webster, and Maidment Productivity Data.)"
"The reductions-made in direct, indirect and UE&C
Costs assume that proper management -action will b'e 'T taken to increase direct / indirect productivity and" adjust the number of dngineering personnel towards-normal industry standards." (emphasis in original) i
3/30/84 Seabrook Joint Owners Meeting:
"Mr. Derrickson next reported on what will be
. happening.the next 30 days. They will continue to streamline the project with respect to manpower and they will revise a piping program and they have asked -Bechtelsto act as a consultant in, this area."
.. 4/84 Ebasco Schedule Review of the Seabrook Unit 1 ~~~~"
Project - Final Report, Prepared for PSNH:-
Regarding piping, the ~r~epor t contained the following conclusions: . "l) The planned fuel load date of 10/1/85 has a potential to slip approximately 6 to 10 months, due to the current
- status of the installation of small-bore and large-bore pipe hangers. These are of particular i concern in both the containment and primary auxiliary buildings." ,
.Significant areas ofz concern included: "7) The planned revision of the Pipe Supports Installation Program to support systems testing, compounded by the current status condition of the same and small-bore piping, can lead to an increase in 4
physical interferences and craft interface scheduling problems."
'"l) .A backlog'of;P-H. documentation. packages... _
required to support 18 safety' related- mechanical'
, BIPs has accumulated. ( 5.1. 3.1) ; 2) . A backlogrof 1,268~P-H radiographic film--packages was~recently detected.by YAEC QA.".(5.1.3.2) ,
4/5/84 YAEC Seabrook Audit Report No. SA809CS340:
" Evaluation: The audit revealed that; (1) P-H does not fully comprehend the need for clarity and validity in voiding Corrective Action Requests i (CARS) and Nonconformance Reports (NCRs); (2) '
Th 'e is a need to more clearly delineate the us, of the Support Rewor:c Order vs. an NCR; (3)
Pu1 Aman-Higgins, as a whole is showing a more
. cooperative attitude in working with.QA YAEC in .-
correcting- taatters .of concern."
4/23-5/4 and 5/14-25/84 Construction Appraisal Team Executive Summary:
" Weaknesses involving piping support installations have been previously identified by NRC Region I.
' -Many of these weaknesses have existed for some time. The NRC CAT inspectors noted similar
, programmatic-weaknesses with regard to
' installation activities in the mechanical construction area....Although the individual
. q n.,,. .:.r y. , . - _ _. _, , . , ;,_.,._.__...--. .
~ - . , _ , , . . -, -, ..,....--.n..-.. . . . . , , - - - _ . . - ,
deficiencies identified in this report are resolvable from a technical standpoint, the '
' ' program weakness that thay reflect requires-management attention. to assure that they do nor 3
adversely affcs4. future site activities."
6/23/84 _ P-H Potential-Records-Management-Program Problemi
. Summary:
" Owner's-Sample, review of P-H document -
- packages.. . identified -record package sof tware--'-
entry inconsistencies - typically [ include] : a) dates and-signatures missing; b) nonconformance-report No.'s transposed; c) ISO. revision no.'s missing d) conflicting data entries on Process sheet and related inspection reports; e) documents not suitable for microfilming."
'9/24/84 YAEC Seabrook Audit Report:
" Exit Interview: A concern was addressed dealing with he adequacy of corrective actions to close 4
-Pullman-Higgins internal addit findings. It appears that adherence to actions to prevent recurrence are lacking in some cases. The same deficiencies closed in P-H internal audits are recurring and being addressed in YAEC audits. It was suggested that more attention be paid to the-P-H internal audit system-and actions to. prevent
, recurrence."
4
4 i
1 5
EXHIBIT
.H
";SEABROOK-STATION WORKER'S CRITIQUE i OF NUCLEAR REGULATORY COMMISSION REPORT NO. 50-443/84-12 ON HIS
-ALLEGATIONS t
Y j
L 7
f 1
f l
[
3.2 Inspection conduct
- a. Review of Nonconformance Report. Relating to Waste Process Building Concrete Cracks and Water Leakage Inspection 3.3a "The NCR states that a small, amount of. water.is entering the _ I
-WPB due to incomplete construction of the vaterproofing * -
membrane and exterior surface of the concrete. wall."
3.3b Review-of WPB Exterior Concrete. Wall Crack. Repairs and-. ..<-
Observation of Their Present Condition "The vaterproofing membrane was found not to accomplish its intended purpose."
As a rasult of the recent reorganization of the Seabrook project, UFAC has taken over the responsibility of Perini's .
NCR #551 which still remains open for final disposition.
The NRC staff identified at the exit interview their concerns relating to possible future changes in ground water chemistry. '
F
'--The present non-saline condition of ground water may change and affect the concrete walls' reinforcing steel bars. This might cause rusting of the steel bars and affect the concrete as well as the steel. This is unresolved item number 50-443/84-12-01.
3.4 Findings
" Apparent defects-in the-envelope of the waterproofing. membrane. applied to the exterior wzlls caused the water leakage through the~ hairline cracks."
"The contro11ed' method of repair. called for chipping out'of concrete.to.
enlarge the crack to the required width and depth as specified for application of the special Capillary Waterproofing-(CP) mortar, identified:as-Vandex.C.P.
compound.
RESPONSEM) NRC' FINDINGS:
Vandex C.P. compound is a cementious material. It is designed for j static crack repair in concrete. It does not however, address the causation of the cracking. The cementious consistancy does not accomodate additional cracking. Therefore, it cannot be expected to resolve the structural potential for more leaks to occur. Nor can it be determined how far the crystalline growth of the. compound may go.
It is possible then (as comented in Section 3.3b)- to subject the steel .,_
reinforcement bars to continual ground water contamination, resulting in.
swelling and oxidation of the rebar; thus compromising the integrity of the concrete walls.
In Inspection No. 50-443/86-52 4." Superficial patches. vere. applied to major cracks in the containment (resulting from improperly cured cement)."
x
Page 2-17.":nere were cracks in the cement of the equipment vault which were leaking water and cracks in the inside containment dome between the inside and outside domes which were just patched over. It is my understanding that
- patching on hardened cement does not.last very.long."
The conclusion to these allegations were that cracks in.the concrete are ,_ m expected to occur and are permissable if.they do not affect.the integrity ,
of the concrete.- It is important to note that in Inspection 50-443/84-12/01.
the concerns relating to possible future changes in ground water chemistry-and the changes and affects this may cause-on the reinforcing steel' bars--
was still cause for' concern and-considered an unresolved Item Number ._
50-443/84-12-01. % erefore,'the conclusion in Inspection No. . 50-443/86-524 contradicts the findings in Inspection No. 50-443/84-12.
- 5. Allegation - Cold Spring of Ferro-Cement Pipe Inspection No. 50-443/84-12 "During a telephone conference with the alleger on August 24, 1984 r . the. alleger referred to the " Pipe Slot" area as the between the Waste Processing Building the the Diesel Generator Building."
5.4 Inspection Findings
" Movement at the end of a pipe was limited to one inch during fitup, an insignificant dimension for the length of pipe sections (up to 40')
being installed."
2 "It is probable that some " popping" noise could be heard when the pipe-is stressed."
5.5 Conclusion "The staff concluded that cracking of the service water pipe cement lining
, although,unlikely could occur if excess force was applied to the pipe."
- 7. Allegation - Inspection No. 50-443/86-52 "When the service water lines were tested, some of the inside cement coating broke off. This system cools essential parts of the plant and must be debris-free. The only parts of the lines replaced were the elbows where the greatest friction occurs."
2 DETAILS The NRC has received allegations related to this subject in the past. -
The NRC performed a detailed inspection of the service water pipe concrete as detailed in Inspection Report No. 50-443/84-12. The following quota-tions from the NRC inspection outline the scope and findings relative to cement lined Ei piping:
s"For cement-lined service water (SW) pipe, the staff reviewed records and drawings, interviewed engineering and supervisory personnel and observed concrete lining inside piping. The staff entered the 42" i' pipe'and visually inspected approximately.40 linear. feet. The SW
Page 3 pipe is classified as safety-related ASME Class 3, Seismic.
'Ihe inspection was conducted to determine the conditions and controls app'icable to pipe cold springing, -to establish if the lining cracked during pipe fitup or welding, and how cracking would be identified such that repair could be initiated.: Interviews and records review- -
'were concentrated toward service water piping in the area between :_
the diesel.generatcr building and the vaste processing building. The
. staff visually inspected. accessible, interior-and exterior. portions,of..
the SW pipe in several areas...
RESPONSE 'IO NRC FINDINGS:
During my telephone conference with the NRC I referred to the " Pipe Slot". This is an area between WPB and PAB, not between WPB and DGB. Therefore, the inspec-tion was conducted in the wrong location.
In the Pipe Slot, " Cold Spring" was used to achieve fitup. The area had sections of pipe ranging from 24" to 42" diameters, with lengths no longer than 14'. In W -u usome cases thespipes were_ forced several inches to attain fitup.
In Inspection No. 50-443/84-12 the NRC used Centriline Process Booklet on cement-lined pipe. A deflection of a 72" X 5/16" pipe with a 1/4" lining was deviated 13" without impairment to the lining.,They neglected however, to state how long the spool piece was, and over what distance the deflection was absorbed..It is important to note aswell, that the Service Water lining is considerable hicker and less tolerant to deflection.
Inspection No. 50-443/86-52 uses the finding from report No. 50-443/84-12 to dispell any apprehension raised by allegation No. 7. Inspection NO. 84-12 was unfortunately conducted before the hydrostatic Start-up,.in the wrong location,;
- and. preformed- in.only 40. linear feet of pipe. Based on this infomation it would,_.
be incorrect assume the current condition of the pipe as " sound".
e .
+ Inspection No. 84-12; allegation No. 5, concludes that."In addition it is possible that cracks could occur due to mishandling during transportation." It is from the cracks resulting from cold spring and mishandling that failure of the cement lining occurred in portions of the service water line. It is possible to conclude from this data that future problems could occur in the cement lining during the operation of the service water piping.
- 8. Allegation - Poor Pipe Welds in Pipe Tunnel Inspection *No. 50-443/84-12 .
On Page 2 of the written statement the alleger states (technical parts abstracted from the paragraph):
" Working in the pipe tunnel, I saw frequent instances of lack of proper documentation of faulty welds in pipes. Many welds were performed with the use of 2 Diametrics (automatic welding) machines." i "The Diametrics machine was used to weld beveled pipe ends with a )
consumable ring. But the ring, which is about 1/16th" thick and the 1 same diameter as the pipes, would shrink by as much as 1/8th". As a l
. Page 4
. result, the inner circle of the ring would shear off or " fingernail".
The crew was ordered to cut out 6 such welds. All were found to have up to 75 percent of their root below accepted standards. All these
. welds resulted in excessive suck back and lack of fusion, center line shrinkage and unconsumed ring."
All of.the lines identified by the alleger are non-safety related 1'nes-i +
whose requirements are significatnly less-than safety related lines and " --
therefore are subject to less . inspection than safety related lines.
Inspection Conduct
" Mirrors were used to examine the internal surface of pipe welds where they were accessible fran open pipe ends.
RESPONSE 'IO NRC FINDINGS:
In 1981 these lines during fabrication were still classified as safety related systems. It was not until the end of January 1982 that these lines were down-c.. . graded.< Therefore, these. lines were still classified under safety related criterion.
Visual, penetrant and ultrasonic tests were performed on these lines. Very few of these lines remained visually accessible, this would make the area of visual inspection extremely Ibnited. Liquid penetrants are only surface indicators and are not relevant to the root pass defects. The ultrasonic relates to base.
metal thickness. Subsequent the only conclusive test would have been the radiographic.
In Report. Number Q-1-84-020, Douglas Barker, a Pullman Higgins (P-H) Quality Control (QC)_ Inspector was interviewed by telephone by R. K. Christopher on November 6,1984.
approximately threeBarker years. advised that: he-has been at- Seabrook with P-H'for-
" Barker did confirm that'he had sane problem in inspecting welds performed with_the.use of two diametric _ welding machines in the tunnel located between
. waste processing and the Primary Auxiliary Building. He explained that there-nus a problem with the consumable insert in that the welds were not being cumpletely consumed from the inside. He said since they did not realize this was a problem until they had "x-rayed" a large number cf welds, he asked his supervicor " Rick Wise" for x-rays of the earlier welds to ascertain whether or not the concunable inserts had been completely consumed. Barker said his supervisor-told-him that he could not reject what he could not see and that~ -
the piping in .guestion was nonsafety related and did not-justify the expenditure -
of manpower toa x-ray" nonsafety related piping." *~
He did confirm that he felt approximately 100 of these welds.were suspect due '
to his lack of assurance that the consumable insert had been completely consumed ;
from the insiva. l 1
There~ is also no information given on the welds cut out and repaired and their l relevant disposition. There is no mention either of the other Diametric welds l that were fabricated in Turbine 1 building; they also had the same apparent l problems. '
i l
l
Page 5
- 14. Allegation - Unrepaired Defects in Steam Generator' Nozzles Inspection No. 84-12 "The failure to check nozzles on three of the plant's four steam generators.
In one case, workers found a separation of cladding -- that.is, the stainless steel nozzle kept separating from the carbon steel of-the steam generator. After much grinding and rewelding, it was discovered that the. nozzle was ..
contaminated by large amounts of slag.4 Representatives of General Electric ~
t which manufactured the nozzles, apparently repaired that particular nozzle.
But to my knowledge, none of the other nozzles on the plant's other three
. steam generators were checked.for.similar problems." u...,..
14.4 Findings
" Based on the above, the inspector concludes that all clad lower head steam generator nozzle weld joint preparations were examined to identify and repair defects including " separation of cladding".
RESPONSE TO NRC FINDINGS:
r . s. ..In.aiSafety., Evaluation. Report related to the operation of the Seabrook Station Units 1 and 2, a preservice inspection relief request evaluation was submitted May 28, 1986.- The applicant requested relief from ASME Code Section XI requirements which he has determined to be, impractical to perform at Seabrook Station Unit 1. The technical review of this request refers to several of the preservice inspection relief request involved limitations to the examination of the required volume of a specific weld. The inservice inspection (ISI) program is based on the examination.of a representative sample of welds to detect L ' generic service-induced degradation. -In the event that the welds identified-in the PSI relief requests are required to be examined again, the possibility of of> augmented inservice inspection will be evaluated during review of the
-Applicant's initial 10-year ISI program. An augmented program may_ include-increasing-the extent and/or frequency of examination of accessible welds..--
Included in the relief request were the Pressurizer ~and -Steam Generator: Welds, -
Examination Category.B-Bi Pressure Retaining Welds in Vessels, and Examination u . Category,B-D, Full-Penetration Welds on nozzles in vessels.
The staff concludes that the limited Section XI volumetric examinations and the Section III fabrication examinations, along with the hydrostatic test, provide an acceptable level of preservice structural integrity and that compliance with the specific requirements of Section XI would result in hardship or unusual difficulties without a ccxnpensating increase in the level of quality and safety.
It is important to note that the defect which I refer to in Inspection No. 84-12<,
was discovered by accident during the welding of the pipe to. vessel joint. A -
lack of fusicn zone was indicated by the radiograph. Craftspersons began to grind out the defective area where a " slag inclusion" was discovered. This -.
defect was followed by a developing crack in the steam generator nozzle.
Incidences of lack of fusion zones occurred in other steam generator nozzles, which mechanics were never definitively able to locate. 'Ihe questions are, were these defects recorded in the radiographs generated by the " weld out" r : lack of; fusion.. zones or already present as " slag inclusion" left behind by the fabricators? Also, the portable radiographic sources used in x-ray examinations at Seabrook are incapable of giving decisive renderings of base metal with thicknet.ses between 3 and 6 inches.
Page 6
+ 4 Based upon'this data and the history of generic problems in>the steam generator nozzles, it seems inadvisable for the Seabrook Owners to request a waiver with-uncertain ramifications.
4 t
,11. Allegation - Turbine Buildina Pipina' Shop Weld Defect.iInspection No. 84-12.y.-
, "While working in Turbine-Building-No..1, the crew received many - ~-
! -prefabricated sections of welded pipe made by; Dravo. .Many, times the.
joints did not ': net ASME codes.
One May 11, 1982, I was assisting another welder on line EX-4125-01-Rev.1, field weld No. 108, a 10" weld outlet (WOL) off a 24" carbon steel line, when I noticed a Dravo shop weld defect. Informed the Quality Assurance
- Inspector about a one-inch lack of fusion zone on the interior of the root pass. However,'I was told "A Dravo shop weld is not our concern".-
'11.4 Findinas The radiograph taken to supplement the ultrasonic evaluation exhibited _
one 5/16" long indication which did not correspond to the root pass ,
-:-interiorAsurface.
4 0
11.5 Conclusion ~
The disposition of the 5/16" radiographic indication is an unresolved item pending licensee evaluation (50-443/84-12-2).
. . "the ,5/16?'. long radiographic. indication exceeds the ANSI B31.1. standard - . . .
allowable-linearJindication length of 1/4"! that would apply @ radiography- -
was required."
' RESPONSE T0"NRC FINDINGS:
The interpretation of the radiograph is incorrect. 'Ihe defect was' on the interior of the root pass. This inconsistancy with radiograph interpretations j is indicative to the same renderings given on the steam generator nozzles.
Giving support to the theory that most radiographic renderings are a matter of interpretation subject to experience. . 2 i In Report No. Q-1-84-020,- I also mentioned that Brian Kennedy,va Pullman- .= '!
.Higgins QA Inspector, informed me that a Dravo shop weld was not.their concern w ,
1 and I did not have to worry about it. ;
l 1
The NRC has made no mention as to whether an interview was. conducted with I Brian Kennedy in regards to his attitude towards other related material other than Pullman-liiggin's.
A wL also observed a number of improper welds fabricated by Dravo manufacturers, l with excessive mismatch in the radioactive tunnel. I made management aware of these infractions, but the attitude was the same as above "a Dravo wold is not our concern".
L s
2 r
o mw -
' EXHIBIT
~ I
- 1. ' ,
NEW SAFETY-' PROBLEM REGARDING WELDS IN THE SERVICE WATER I PIPE,,AND INSPECTIONS OF.
' THOSE WELDS 4
E i
N-1 4
t
l POOR SERVICE WATER PIPE WEIDS
-In-1980, I was trained at the United Engineering School of Helding. This was -
an off site training center manned by union personnel and funded by UE&C. .
It's purpose was to train and familiarize, welders with certain pipe welding ands
~ fit-up procedures;' from there individuals would go to the Seabrook Station's...,._
welding test shop and be certified for their particular weld procedures.
"At that time UE&C and-Pullman-Higgins had expressed their concerns.over the..~.y
' local union's failure to meet their present personnel quota for production ..
demands. It was necessary then to qualify as many welders as possibJe to meet desired production milsstones.
The standard pipe test was a six inch schedule 80 carbon steel coupon, which ,
was to be fitted with a six inch carbon steel Kellogg insert. The " weld-out" was a shielded tungsten inart gas root-pass followed by a 7018 manual stick filler veld-out. After two attempts at this particular procedure, I was
" -+ -a -certifiedito weld all_ carbon steel standard pipe wall.
I remained on first shift for approximately one week, where I received a vague and rather confusing indoctrination. I was then transferred to second shift where I was assigned to the service water pipe grew;. I was designated a fitter and assigned to my first 24 inch carbon steel standard wall pipe.iThis.
was the first exposure I ever had had~with large diame_te.rspipe.
P -The service water joints were fitted togeth'er with a factory installed carbon steel backing ring. I had never encountered this particular fit-up procedure.
before and therefore had no idea how to weld it,but the apparent difficulties where inmediately obvious. The fitted ends had serious mismatch in both the..
high-low (the outside diameters of.the two fitted spool pieces) and the . _ , .
- - J factory installed backing ring. The. sidewalls oftthe. fitted pipes could;be made to conform by ',he utilization of pipe alignment clamps. These clamps could be fastened around the pipes and the screw-dogs tightened into position. The
' fitter'would then attempt to force the mismatch into symmetry by wrenching pressure to specific screw-dogs.
If this were accomplished, the welder would then be instructed to place his tack-welds over the mismatch of the backing ring. This was in an effort to keep the pipe-joint in fit-up specifications and Quality Assurance parameters.
It was scmetimes necessary to concentrate tack-welds in many. areas in order to achieve this.
If the " fit-up and tack" inspection passed, the next difficulty came in welding-out the excessive gaps created during the fit-up on the backing ring.
" Permit welders" having less experience would always be assigned the worst ;
side of the weld by their foreman while more experienced-union welders always ;
4 knew what side to take first. Attempting to weld gaps like these usually ;
i required a welding technique known as " bridge welding". 'Ihis usually resulted '
in " burn-through" of the backing ring, and slag entrapment between the root-
- 4 pass and the backing ring.
1 i
l
i POOR SERVICE WATER PIPE WELDS - Continued I Another serious problem was condensate in the piping itself. There is a -
deleterious effect on the 7018 filler metal when it comes in contact with moisture. It produces a porosity in the deposited metal which usually penetrates through the entire area of the exposed root. 'Ihe condensation was created by the warm air, caused by welding, coming in contact with the cold surface of-the interior-pipe wall. his temperature differential was created by.one area of the pipe being sheltered while the remaining pipe was exposed
-to the ambient outside air temperature. 'Ihe porosity was usually encountered 2 at~the bottom of the pipe, where the condensate-would generally concentrate.
The porosity would normally present itself through the root and. hot-pass of. - w+
this area but generally the-fill-pass would deposit enough metal to cover it.: >.- .
From these observations, it is my opinion that these welds are extremely-suspect and should be categorically reviewed.
,- 1 7
/
EXHIBIT J
NUCLEAR REGULATORY COMMISSION
' SAFETY.-EVALUATION REPORT JUNE,'1986 (APPLICABLE SECTIONS)-
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PRESERVICE INSPECTION RELIEF REQUEST EVALUATION :?0NflQ{%
~
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'YA I. . INTRODUCTION ";
This section was prepared with the technical assistance of. 00E. contractors-from the Idaho, National Engineering Laboratory.
For nuclear power facilities whose construction permit was -issued on or ^
after July 1,1974,10 CFR 50.55a(g)(3) specifies that components shall meet the preservice examination requirements set forth in editions and addenda of Section XI of the ASME Boiler and Pressure Vessel Code applied to the construction of the particular component. The provisions of 10 CFR 50.55a(g)(3) also state that' components (including supports) may meet the requirements set forth in subsequent editions and addenda of this Code which are incorporated by reference in 10 CFR 50.55a(b) subject
-to the limitations and modifications listed therein.
5 In a submittal dated May 28, 1986, the Applicant requested relief from f
ASME Code Section XI requirements which he has determined to be imprac-tical to perform at Seabrook Station Unit 1. These relief reques:.s were k supported by information pursuant to 10 CFR 50.55a(a)(3). Theref re, the
! staff evaluation consisted of reviewing this submittal to the re'quirements i of the applicable Code edition and addenda and determining if relief from j- the Code requirements were justified. 4 5
{ II. TECHNICAL REVIEW CONSIDERATIONS A. The construction permit for Seabrook Nuclear Power Station,- Unit 1, was-issued-on July 7, 1976. In accordance.with 10 CFR.50.55a(g)(3), .
I components (including supports), which are classified as ASME Code Class 1.and 2,_have been designed and provided with access to enable the performance of required preservice examinations.
B. Verification of as-built structural integrity of the primary pressure boundary is not dependent on the Section XI preservice examination.
- The applicable construction codes to which the primary pressure bound-ary was fabricated contain examination and, testing requirements _which by themselves provide the necessary assuranc~e that the pressure bound- , '
ary components are capable of performing-safely under all operating <-
- r. conditions reviewed in the FSAR and described.in the plant design -
specification. As a part of these examinations, all of the primary . ,,
pressure boundary full penetration welds were volumetrically examined (radiographed) and the system was subjected to hydrostatic pressura tests.
6 --- _ ..C. The intent of a preservice examination is to establish' a reference
! or baseline prior to the initial operation of the facility. The re- ,
l sults of subsequent inservice examination can then be compared with j the original condition to determine whether changes have occurred.
i f If the inservii e inspection results show no change from the original l
l Seabrook SSER 5 1 Appendix H ,
=e -
mag
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?
[ [
condition, no action is required. In the case where baseline data 5 l '
are' riot available, all. flaws must be treated as new flaws and eval- j L uated accordingly.Section XI of the ASME Code contains acceptance .%
!!2n [
standards which may be used as the basis for evaluating the accept- --
ability of such flaws. ~ - - - - -
t D.
Other benefits of the preservice examination include providing redun- 2 dant or alternative volumetric examination of the primary pressure >
boundary using a test method different from that employed during the -
component fabrication. . Successful performance of the preservice ex - !
. amination also demonstrates that the welds so examined are capable -
of subsequent inservice examination using a similar test method. !
In the case'of Seabrook Nuclear Power Station Unit 1, a large portion 4 of the preservice examination required by the ASME Code was performed. '
Failure to perform a 100% preservice examination of the welds identi-
' fied below will not significantly affect the assurance of the initial structural integrity. ;
l i
E. .In some-instances where the required preservice examinations were not~
~ performed to the full extent specified by the applicable ASME Code, '
the staff may require that these examinations or supplemental exami- 1 nations be conducted as a part of the inservice inspection program. .
Requiring supplemental examinations to be performed at this time would result in hardships or unusual difficulties without a.compen-sating increase in the level of quality or safety. The performance of supplemental examinations, such as surface examinations, in areas {
where volumetric examination is difficult will be more meaningful after a period of operation. Acceptable preoperational integrity 3 has already been established by similar ASME Code Section III fabri '
cation examinations.
c In cases where parts of-the required examination areas cannot be f effectively examined because of a combination of component design or ,
current examination technique limitations, the development of new or improved examination techniques will continue to be monitored. As k' improvements in these areas are achieved, the staff will require tha \
these new techniques be made a part of the inservice examination re- .
quirements for the components or welds which. received a limited pre .
service examination. - ,
Several of the preservice inspection relief requests involve limita-tions to the examination of the required volume.of a specific weld..
The inservice inspection (ISI) program is based on the . examination of a representative sample of welds to detect generic service-induced degradation. In the event that the welds identified in the PSI relief requests are required to be examined again, the possibil ity of augmented inservice inspection will be evaluated during revie of the Applicant's initial 10 year ISI program. An augmented progr may include increasing the extent 'and/or frequency of examination o,
, accessible welds. '
Seabrook SSER 5 2 Appendixk, Si
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. III EVALUATION OF RELIEF REOUESTS
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ments in a submittal dated MayThe Applicant requested relief 28, 1986.
, ported by information pursuant .to 10 CFR 50.55a(a)(3).These relief re a Based on the in-formation submitted by the Applicant and the staff's review of'th
. geometry, and materials of construction of the components, certain pres vice inspection requirements of the ASME Boiler and Pressure Vessel Section XI have been determined to be impractical to perform. ,
' cant has demonstrated that either (i) the proposed alternative would pr vide an acceptable level of quality and safety or (ii) compliance with specified requirements of this section would result in hardships or unu
. difficulties without a compensating increase in the level of quality arid safety.
preservice requirements are impractical are justified Unless as 1977 Edition including Addenda through Summer 1978.oth
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.M UR WIOGs!DEination Category B-0, Reactor Pressu p Full Penetration Welds
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E Code Recuirement:
R2 Section XI, Table IWB-2500-1, Examination Cate-ff gory B-A, Items Bl.11, Bl.12, 81.21, B1.22, and Bl.30, .and Examina-y, tion Category B-D, Item 83.90 require a 100% volun.etric examination s.' of the RPV shell, head, shell-to-flange, and nozzle-to-vessel welds'.
y; Code Relief Request:
s :
F Code and/or Regulatory Guide 1.150 re. quired volume g the 4 shell welds, 8 head welds,1 shell-to-flange weld and 8 nozzle-y to-vessel PR-1. welds (21 velds total) listed in Table 1 of Relief Request g Reason for Relief:
9' .the prohibit 100% volumetric examination of the Code requ subject welds.
T._
g i _ Staff Evaluation:
.J submittal including the attached Table and Figures.The 28, 1986 In the attached staf
( Table 1, the Applicant identified the individual welds with respect
- y to the percentage of the ASME Code Section XI. rbquired examination e
F amination completed, and provided a description of t i (i.e., nozzle obstruction, weld geometry
! ence, etc.) encountered during these exam,inations. control rod drivein-The Figures, interfer-1 cluded in Relief Request PR-1, showed the subject welds with respect i to the obstructions encountered. The Applicant reported that all of
! the subject welds received the ASME Code Section III volumetric and 1 surface examinations during fabrication as well as the construction hydrostatic test. -
I On the basis of this review, the staff has concluded that a signifi- -
cant percentage of the Code required examination has b'een performed and that the reactor vessel would have to be redesigned in order to Seabrook SSER 5 3 Appendix M Jk _
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complete..the remainder. Therefore, the staff concludes that the .i.O ;{\'%
limited Section XI and Regulatory Guide 1.150 volumetric examinations I jT $
in conjunction with the Section III fabrication examinations and hy- ' fi f drostatic tests provide an acceptable level of preservice structural 's j l integrity and that compliance with the specific requirements of-Sec- '.$ gy l tion XI would result in hardship or. unusual difficulties without a 4.T $
compensating increase in the level of quality and safety.
3:
, 8. Relief Request PR-2, Pressurizer and Steam Generator Welds, 9
! Examination Category B-8, Pressure Retaining Welds in Vessels, and_.
( -Examination Category 8-0, Full Penetration Welds on Nozzles in (3
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Vessels t
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_ Code Requiremer'it: Section XI, Table IWB-2500-1, Examination Cate- ? l gory B-8, Items 82.11 and B2.40, and Examination Category B-D, ~
1 Items 83.30, B3.40, and 83.50 all require a 100% volumetric exami-nation for PSI. {
.$ I Code Relief Request: Relief is requested from performing 100% of the i i i '
" Code required volumetric examination on the 3 pressurizer circumfer- 3.
ential shell-to-head welds, 4 steam generator tubesheet-to-head welds, f 6 pressurizer nozzle-to-vessel welds,1 pressurizer nozzle inside "
radius section, and 8 steam generator nozzle-to-vessel welds 4 (22 items total) identified in Table 1 of Relief Request PR-2. 5.:
3 Reason for Relief: The Applicant reports that geometric configura- 5- :
tion and' permanent obstructions (i.e. vessel penetrations and steam .i generator supports) prohibit performance of a 100% volumetric exami- i nation of each of the subject welds. ; :
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Staff Evaluation: The staff has reviewed the Applicant's submittal, i. j including Table 1 identifying the items for which relief is being - 4 requested. This Table includes the component or weld identification, .};9 the Code Item Numb:c, the examination angle and technique being used, ;p the configuration of the item, and the percent of the Code-required f volume that was completed. The staff notes that each item received a.t least 74% of the Code-required volumetric examination for PS.I.
In addition, the Aopticant reuorts that all of the sub,1ect welds y$ l received the ASME Code Section III volumetric and surrace examina- 27.
t on auring i4Uh cation as weli as the constructtert-hydrost'a' tic test. .M The inservice system leakage tests will be perrormed per tne TDD Section XI requirements during each refueling outage.
E On the basis of this review, the staff has concluded that a signifi-cant percentage of the Code required-examination has been performed q and that these components would have to be redesigned in order to t
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complete the remainder. Therefore, the staff concludes that the , 42 ;
limited Section XI volumetric examinations and the Section III fab-rication examinations, along with the hydrostatic test, provide an k i acceptable level of preservice structural integrity and that compli- { g l
.ance with the specific requirements of Section XI would resultla . ;
.<- ,. f hardship or unusual difficulties without a 6.wdrensating increasa in '
thelevelofqualityandsIfy. ;
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