ML20096B841

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Testimony of RM Bucci,Ej Pagan & EM Mclean in Response to Eddleman Contention 9E Re Physical Orientation of Equipment. Related Correspondence
ML20096B841
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 08/31/1984
From: Bucci R, Mclean E, Pagan E
CAROLINA POWER & LIGHT CO., EBASCO SERVICES, INC.
To:
Shared Package
ML20096B797 List:
References
OL, NUDOCS 8409040371
Download: ML20096B841 (16)
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August 31, 1984 000KETED. 03'G,C UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSITu SEP -4 A11 :15 Before the Atomic Safety and Licensing Board In the Matter of ) 

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CAROLINA POWER & LIGHT COMPANY ) Docket No. 50-400 OL and NORTH CAROLINA EASTERN ) MUNICIPAL POWER AGENCY ) 

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(Shearon Harris Nuclear Power ) Plant) ) APPLICANTS' TESTIMONY OF RICHARD M. BUCCI, EDWIN J. PAGAN AND EDWARD M. MCLEAN IN RESPONSE TO EDDLEMAN CONTENTION 9E (PHYSICAL ORIENTATION OF EQUIPMENT) 8409040371 840831 - PDR ADOCK 05000 0 _s

4 l Q.1 Please state your names. A.1 Richard M. Bucci, Edwin J. Pagan and Edward M. McLean. Q .~ 2 Mr.:Bucci!-and Mr. Pagan, are your addresses,.occupa-tions,' employers, educational backgroun'ds and professional work experiences described elsewhere in the recor$ of'this proceed-ing? A.2 (RMB, EJP) Yes, the relevant information is provided. in " Applicants' Testimony of Richard M. Bucci and Edwin J. Pagan in Response.to Eddleman Contention 9D (Instrument Ca-bles)." Q.3 Mr. McLean, please state your address, present occu-pation and employer. A.3 (EMcL) I am employed by Carolina Power & Light.Com-pany ("CP&L") as a Project Mechanical Engineer. My business address is the Shearon Harris Nuclear Power Plant, P.O. Box 101, New Hill, North Carolina 27562. Q.4 State your educational background and professicnal work experience. A.4 (EMcL) I graduated from North Carolina State Univer-sity in 1968 with a Bachelor of Science Degree in Mechanical Engineering. .I joined the Navy in March 1969 and served as missile officer aboard the U.S.S. Bainbridge until March 1972. I joined CP&L in April 1972 as a Heating and Cooling Engineer in the Customer Services Department. I transferred to what is now the Harris Plant Construction Section of the Harris Nuclear e b

a Prohect-DepartmentinJune1974. 

                                             'I have been involved in engi-neeringfsupport of construction at the SHNPP, Brunswick Steam
Electric Plant, and the H.B. Robinson Nuclear Plant for the last ten' years, ihr major responsibilities at the SHNPP have included developing and supervising the storage,and maintenance program for_the equipment and materials onsite, designing' tem-porary. mechanical facilities,~and providing engineering support for-the installation of piping, equipment, HVAC duct work, and
       . hangers. My major responsibilities during two assignments at the Brunswick Plsnt included start-up of HVAC equipment and su-pervising the mechanical engineering support group.      This group
       -was responsible for providing engineering support for piping, hangers, and equipment. I also acted as the CP&L night shift representative responsible for all phases of construction.      At the Robinson Plant during an assignment lasting ten months I provided engineering support for the mechanical construction activities. For the past two and one-half years I have been respcnsible for providing engineering support for the installa-tion of equipment at the SHNPP.      I am a registered professional engineer in North Carolina.

Q.5 Please elaborate on your professional experience that is directly relevant to the testimony which you are presenting regarding physical orientation of electrical equipment at SENPP. A.5 (EMcL) The group that I have supervised for the past two and one-half years is responsible for providing engineering

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            - support for the installation of both mechanical and electrical equipment. We develop work packages that provide design infor-mation to field supervision personnel and provide process con--

trol sheets associated with work packages to ensure that quali ' m ty control inspections are made. , Q.6 What is the purpose of this testim'ony? 

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A.6 (RMB, EJP, EMcL) The purpose of this testimony is to respond to Eddleman Contention 9E, which states: There is not sufficient assurance that the physical orientation of equipment in testing is the same as the physical orien-tation of equipment installed. Q.7 Hcw is your testimony organized?. A.7 (RMB, EJP, EMcL) First, we discuss circumstances in which physical orientation of safety-related electrical equip-ment is a potential concern. Second, we describe the process , by which physical orientation of such equipment at SHNPP is controlled, from qualification testing of the equipment, to in-stallation design, to physical installation of the equipment in the plant. Q.8 What is meant by " physical orientation of equipment"? A.8 (RMB, EJP) Physical orientation of equipment refers to the mounting location with respect to a set of rectangular coordinates, its angular position, its location with respect to other items in the plant and installation interfaces. Q.9 When is physical orientation of safety-related elec-trical equipment a concern with respect to environmental qualification of the equipment? l-l S U _c

A.9 (RMB, EJP) -Physical orientation of e .ctrical equip-ment in the SHNPP-generally does not affect environmental qual-ification. For-most electrical equipment, . environmental condi-tions are identical regardless of the orientation. Physical orientation is more likely to be related either to seismic qualification or to' operability of the equip' ment. There are circumstances in which physical orientation of electrical equipment could affect environmental qualifica-tion. For example, if an electro-hydraulic valve operator were installed upside.d'own, hydraulic fluid could potentially leak onto the cable terminations -- possibly causing corrosion of the electrical connections. Another example could be improper orientation of a battery charger, which could result in inade-quate ventilation -- raising the temperature of the components above the expected normal operating temperature and potentially shortening the qualified life of the equipment. Q.10 What information is received from vendors concerning physical orientation of electrical equipment? A.10 (RMB, EJP) The environmental qualification test re-ports, provided by vendors of electrical equipment which is qualified by testing, describe and/or provide sketches or pho-tographs of the test set-up, including physical orientation of the test equipment. A typical photograph of a test set-up for a level transmitter is shown on Attachment A hereto. (Attach-ment A shows test set-up in a thermal aging chamber indicating the vertical orientation of the level transmitter.) I

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Orientation is-addressed in a variety of ways. The vendor may. test the equipmentiin the most limiting orientation, i.e., the orientation determined by engineering analysis that results in the most severe environmental conditions. In that case, the equipment _would be environmentally qualified for any physical orientation. The vendor may instead test in'a single orienta- 

      . tion which is not the most limiting condition, and either qual-ify the equipment by analysis for other orientations or simply specify the test. orientation as the only permissible orienta-tion. Or, finally, the vendor may test the equipment in sever-al orientations.

Vendors also are required to provide-technical manu-als containing installation and maintenance instructions.- Fi-nally, the vendor provides mounting drawings which include spe-cific instructions for orientation. Q.11 Who receives this information? A.ll (RMB, EJP) Vendor supplied information is sent by the vendor to the responsible design organization. Q.12 What does Ebasco, as a design organization, do with the vendor supplied information? A.12 (RMB, EJP) With regard to physical orientation for a particular piece of equipment, Ebasco reviews the test orien-tation or orientations against the design drawings which Ebasco has prepared for installation of the equipment at the SHNPP. Orientation during testing must either be identical to the in-stallation shown on the design drawings, or the equipment must O

m be able to be qualified by analysis for a different orienta- l 1 tion. In addition, Ebasco reviews the vendor mounting drawings and technical manuals to make sure that they are consistent with the qualification test set-up. If there are any discrepancies, inconsistencies or ambiguities concerning physi-cal orientation of the equipment, Ebasco req'uests further information from the vendor as necessary. Q.13 With regard to phycical orientation, please describe Ebasco's procedures for preparation, control and review of in-stallation design drawings and for documentation of corrective actions concerning physical orientation. A.13 (RMB, EJP) Physical installation drawings are pre-pared based on vendor supplied information and the specific physical conditions at the equipment location. During their preparation, the drawings are reviewed by affected engineering disciplines (e.g., civil, mechanical and electrical engi-neering) to ensure adequate consideration of applicable aspects of the plant design. In addition, in some cases the installa . tion drawings are sent to the equipment vendor for his review and concurrence prior to issuance to the field. As a part of the SENPP environmental qualification program, vendor qualification reports are also specifically re-viewed to ensure that physical orientation during testing was consistent with the installation drawings. Any concerns re-sulting from this review are documented in the qualification review package as outstanding items which require resolution 0 O

r prior to considering the equipment environmentally qualified. Should resolution of a concern require a change to the instal-lation drawing, a design change notice ("DCN") must be issued. 

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The DCN is subject to the same review as the original drawing for the area-affected by the DCN. In addition, the DCN is tied 

       . to the drawing by the design change procedur'e so that all af-fected personnel are made aware of the change.      After final ap -

proval, the DCN is issued to the field personnel for imple- 

           . mentation. It is subsequently incorporated on the installation record drawing.

For example, Attachment B -- which is an instrument installation drawing for the safety-related level transmitter depicted in Attachment A -- indicates the original approval and revision status. This example also indicates the DCN's that have been incorporated on the drawing via the above-described procedures. (The required physical orientation of the level transmitter is clearly indicated in Attachment B, consistent with the orientation during the qualification test set-up as shown in Attachment A.) Q.14 How does CP&L assure that safety-related electrical equipment is installed according to the installation drawings? A.14 (EMcL) CP&L assures that safety-related electrical equipment is installed according to the installation drawings through detailed procedures for control of design documents, i preparation of installation work packages based on design docu-mentation, installation performed in accordance with work e I

m _ packages :and work procedures, and quality _ inspection to verify proper install'ation. . Q.15 .How does CP&L control installation drawings-and other design documentation at the SHNPP? A.15 _(EMcL) Installation design drawings,and documents-are transmitted'by Ebasco to CP&L's Document Control I Center ("DCC"). The' construction engineer, following written engi-neering procedures, then obtains the drawing from the DCC. The 

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DCC will automatically issue subsequent revisions, DCN's, and field' change requests ("FCR"), to holders of controlled draw-ings. Q.16 What does the construction engineer do_with this information?

  • A.16 (EMcL) In preparing for the installation of_ equip-ment at the SENPP, the construction engineer prepares a work package that generally includes Ebasco installation design drawings, vendor drawings, vendor manuals, process control sheets, and decign changes in the form of FCR's and DCN's.

Q.17 What is done with the work package? A.17 (EMcL) The work package is given to the field su-perintendent responsible for installing each piece of equip-ment. The field superintendent ensures the equipment is in-stalled according to the design documents and notifies the quality inspector when he reaches inspection points for quality related activities. These inspection points are indicated on the process control sheets. 9 O b

g; p - s  ; , a N' (.: [The quality--inspec' tor prepares inspection documents E 

-a, correspon' ding to thelprocessecontrol-sheets developed by the l-
construction; engineers. The inspectors referito the work pack-
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ages when they make their inspections. Physical orientation'is one of the required 1 inspections. , Q.18 What = happens if the construction ' personnel 'are un - < 

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                     *able to' install the equipment in accordance with the work pack-
                    . age?

A.18. (EMcL) 'If a change.in' install'ation. orientation is-required.which exceeds the design.' tolerances contained in the work package -- e.g.,.if the orientation of'a motor control center needs to be changed in order for it to fit'into'its al-lotted space -- the. construction engineer writes a FCR. .The FCR must be reviewed and approved by the responsible' design en-gineer. The design engineer evaluates the FCR' based on the de-sign drawing and available vendor information. If necessary, the design engineer obtains additional information from the 

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vendor or Ebasco. If the design; engineer approves the-FCR, it is sub-mitted to the DCC, is forwarded to the construction engineer, and becomes part of the-work package. Construction personnel then install the equipment based on the FCR. A design change in the form of a DCN might also come 

                    ~from Ebasco.       This would occur if the equipment were installed prior to Ebasco having received the vendor qualification test
                     . report 1and Ebasco, on reviewing the report, identifies a l'

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           " limiting con'ition d      with respect to installation orientation which is inconsistent with the original design drawing.      In this situation, the'same procedures would be followed as those controlling a .FCR initiated by construction personnel.

Q.19 What corrective actions are taken 1( the'FCR is de-nied? , A.19 (EMcL) A FCR is seldom denied. The cases in which a FCR is denied usually relate to FCR's submitted by the con-struction engineer for economic reasons and disapproved by the design engineer. In such cases, the construction engineer can still complete the work in accordance with the original design documents. If the installation cannot be completed as designed and the design engineer does not agree with the resolution pro-posed by the construction engineer, he should provide an alternate resolution. If the design engineer denies a FCR and the installation cannot be completed as designed, work stops. The quality program will not allow work to be completed and ac-cepted until the installation agrees with design documents. Q.20 Please describe how CP&L's quality in-spection/ verification program for SHNPP helps to assure proper installation orientation of safety-related electrical equip-ment. A.20 (EMcL) Inspection points are specified on the pro-cess control sheets in the work package. These inspection points are for such items as location, elevation, orientation, and anchor tightening. Certain installations require that the b 

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                                                       " construction engineer prepare. process control sheets without-                                                                                                                         i predesignated: inspection points.                                                                                                          The construction engineer re-fers to design documents to prepare theJappropriate inspection points.                                                                            The inspection points are written in the form of a command with spaces for craft and inspector signatures for ac-ceptability of completion of each command.                                                                                                             'hese T       process con-trol ~ sheets are reviewed by the quality inspector and the resi-dent engineer responsible for equipment installation.                                                                                                               An inspection point is designated for those activities.that affect the quality of the installation.                                                                                                         There is an inspection point for almost every, activity performed on the equipment. .Until the inspection points for a piece of equipment are accepted, the installation is not acceptable and the procedural require-ments are not satisfied.

Q.21 Who conducts these inspections? A.21 (EMcL) Construction inspections are generally con-ducted by quality inspectors, who, depending on the equipment,. may be either Construction Inspectors or Quality Control In-spectors. The inspector reviews the installation of the equip-ment according to the design information in the work package. The quality inspector records the inspections on inspection re-ports. If there is a discrepancy a nonconformance report is written and a " hold tag" is placed on the equipment, which may limit the work that can be performed. Each nonconformance re-port requires a specific disposition, i.e. rework, repair, scrap, or accept as-is, which requires design engineering approval. 4 %- _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . . _ _ _ _ . _ _ _ . _ . _ _ _ _ _ _ _ _ _ b 

 'a Q.22   What additional. assurance is there that electrical
              " equipment is correctly installed with respect to physical ori-entation?

A.22 (EMcL) Through industry-wide programs, problems ex-perienced by one utility are reported to'other. utilities and reviewed and evaluated by ~ these other ~ utilit'ies. Problem expe-rienced by equipment suppliers are also reported to the utilities that purchased their product. Engineering, Licensing and Corporate. Nuclear Safety personnel are involved in problem evaluation. The construction personnel both in engineering sup-port and field installation have accumulated years of experi-ence in their work. Reporting potential problems is encouraged by management. Finally, the start-up organization checks the equip-ment in its various modes prior to operation. These programs and the experience of SHNPP construction personnel provide ad-ditional assurance of the quality of installation of electrical equipment. Q.23 In conclusion, do you believe that there is suffi-cient assurance that safety-related electrical equipment is in-stalled so that physical orientation of the equipment does not prevent the equipment from being environmentally qualified?. A.23 (RMB, EJP, EMcL) Yes. Procedures established by CP&L and Ebasco require that installation desi,gn drawings re-flect physical orientation limitations determined from review N _.___m.__ _[

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of-environmental qualification' test reports. Procedures for 

             -preparation of' work packages and quality inspections ensure
             -that instaliation of electrical __ equipment is in accordance with
             -design drawings.

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