ML20133F269
| ML20133F269 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/17/1985 |
| From: | Sanders W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133F075 | List: |
| References | |
| OL, NUDOCS 8508080216 | |
| Download: ML20133F269 (14) | |
Text
.
O b
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00fgE[p.
U BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of GEORGIA POWER COMPANY, et al.
Docket Nos. 50-424mn Or Nt Upl 50-42510CAEg'f (VogtleElectricGenerating Plant Units 1 and 2)
AFFIDAVIT OF WILBERT F. SANDERS I, Wilbert F. Sanders, state under oath that:
1.
I am the Senior Resident Inspector for Construction at the Vogtle Nuclear Station for the Nuclear Regulatory Commission, Region II.
I have held this assignment since November 1981 to the present.
In this assignment, I conduct routine and reactive inspections and investigations in order to evaluate and ensure the licensee's compliance with regulatory requirements and evaluate the adequacy of licensee corrective actions.
I am knowledge-able of the matters set forth herein and the statements made are true and correct to the best of my knowledge.
A statement of my professional qualifications is attached.
The August 22, 1983 meeting regtrding Pullman QC Inspectors:
l 2.
On August 22, 1983, a meeting was held between Georgia Power Company (GPC) and NRC to discuss issues relating to GPC's task force which addressed Pullman's QA/QC organization.
Prior to the meeting, I had conversation with l
8500000216 050005 DR ADOCK O
. f.
Mr. Ehrensberger, the team leader, regarding some of the early findings of the task
- force.
I 3.
I am addressing intervenors' assertion that this meeting was forced by NRC.
4.
The licensee, as part of its corrective action to address concerns raised during their review, committed to reinspect certain spool pieces.
The reinspection of the piping spool pieces (15,611 spools) spanned over a long period of time and I made a number of field observations of this work. All of these items were of great interest to the NRC resident inspector and Regional staff and generated a number of questions.
The meeting was reouested by Georgia Power Company to provide information on the status of the reinspection and respond to questions by the NRC staff.
5.
The intervenor's statement that this meeting was " forced" as a result of poor 0A performance is an incorrect assumption on their part. The technical issue relating to spool pieces is discussed in more detail in a subsequent section of this affidavit.
WELDING ALLEGATIONS Grit Blasting of Closure Head l
l 6.
The Joint Intervenors have stated:
l I
I
.=
]'
3 I
" Repeated violations of NRC regulations and construction methods applied to pipe fittings and welds undermines confidence in the capability of coolant system to perform essential tasks." and
" Applicants construction sheets for examinations of reactor coolant i
pressure boundary welds did not specify penetrant examination required."
l 7.
These statements are understood to be related to the incident where Liquid j
Penetrant Examinations iLPE) were performed on the closure head internal
{
weld metal cladding, after they were received at the site.
l 8.
Although this examination was previously performed at the pressure vessel manufacturer, it was repeated at the site at my request because of question-1 able surface conditions which did not appear to meet the conditions for performing a meaningful L.P.E examination.
9.
This reexamination did reveal surface discontinuities which exceeded the allowance of the ASME code and subsequently a violation of 10 CFR 50, Appendix B, Criterion IX, was issued to the licensee for " failure to I
establish adequate measures to assure that special processes including nondestructive testing are controlled and accomplished in accordance with applicable codes."
- 10. These events are documented in NRC Report 83-18. The licensee acknowledged l
the violation by letter on December 14, 1983, and provided an explanation of events.
J wr-, -
,-e
-,..w.-,--g-
--=n,-~,.
..-,em--.
-n,
-,----,-r----
-,,,,-,~,,-----,m,--
en-,-,nv..--+w-,.--
4 11.
On December 30, 1983, the NRC Regional office acknowledged the licensee responss 'by letter and on August 13, 1984, I closed the item in NRC Report 84-21.
12.
It should be noted that the stainless steel weld metal cladding is used to provide a corrosion resistant surface on the internal surfaces of the closure heads and is not considered part of the cross-section for calcula-tion of vessel strength.
- 13. After the LPE surface examination revealed unacceptable indications, a repair procedure was initiated to remove the indications by grinding which resulted in two of the indications being ground through the cladding to the carbon steel base material surface.
- 14. The resultant cavities were rewelded in accordance with ASME Section III approved procedures.
l
- 15. Although these weld metal defects should have been discovered and repaired by proper procedures at the pressure vessel manufacturer, the nature of the defects was determined to have minor safety significance and was classed as a severity level 5 violation. The corrective actions taken were appropriate and adequate.
Inferior Materials Piping Spool Pieces l
5
- 16. The item related to the approximately 1500 piping spool pieces which were reinspected at the site by the licensee was not identified by an NRC inspec-tion.
My knowledge of this item is based on review of licensee documents and direct observation of the reinspection effort.
The event is briefly described and documented in SALP report 84-01.
The licensee's corrective actions are summarized in the SALP Report as follows:
- 17. A spool piece is a piping weldment that consists of multiple welds joining several pieces of pipe.
The spool pieces were shop fabricated at Pullman Pcwer Products (PPP) in Williamsport, Pennsylvania.
The spool pieces are completely fabricated, welded, radiographed and examined by nondestructive techniques and code stamped prior to shipment.
- 18. Pullman had previously been examined by the ASME code survey team which approved and awarded them a code certification NA and NPT stamp. This does not specifically require a receiving inspection at the construction site other than required documentation and an inspection for shipment damage.
- 19. After certain weld deficiencies were discovered at the site, the licensee reacted promptly by the following actions:
a.
Stopped work at Pullman Power at Williamsport b.
Conductedanauditandtrainingsessionat(PPP) c.
Increased s'jrveillance inspections
)
6 d.
Developed and started a reinspection program for approximately 1500 spool pieces in storage e.
Developed and started a reinspection program for the spool pieces that have been installed f.
Developed and started a statistical sampling program on future spool pieces received
- 20. The extensive reinspection program was handled in a thor ugh manner and resulted in a satisfactory resolution of a quality program.
There were no NRC violations issued because all of the discovery and corrective actions were within the framework of the Licensee Quality Assurance Program which demonstratud that the Quality Assurance Program was effective in identifying and resolving quality problems.
21.
in addition to all of these actions, the licensee engaged an independent radiography contractor to reexamine all of the radiographs for the shop fabricated welds for all of the contractors.
- 22. Corrective actions were adequate and no further problems of this type have occurred.
1 Circuit Breakers 23.
G.E., in a letter of June 15, 1982 to the NRC, identified specific potential defects with the Model AKR 30 and 50 circuit breakers. My knowledge of this
7 item is based on that letter and review of GPC's engineering evaluation and proposed corrective action.
- 24. The first potential defect involved an improperly hardened steel post used within the circuit breaker as a breaker closing spring prop.
l l
- 25. The second potential defect was associated with a switch mechanism molded case that was improperly cured.
I l
l
- 26. The potential defects associated with the improperly hardened steel part and l
l the undersized hole in the switch cases have been reviewed and evaluated by Georgia Power Company, GPC concluded that a reportable condition per the criteriaofPart10CFT50.55(e)couldexist.
- 27. Most of the circuit breakers (safety-related and non-safety related) have been returned to General Electric for modification.
The few remaining circuit breakers will be scheduled for modification in the near future.
- 28. The corrective action will be inspected by NRC to verify compliance.
STORAGE ALLEGATIONS 5torage_of Reinforcing Steel
- 29. This problem was identified as an infraction by a Region-based NRC inspector in NRC Report 79-02 and was related to the storage of cut reinforcing steel which was in a laydown area on the ground,
l l
8
- 30. The licensee responded by providing proper storage off ground, scrapping the bars wilh' deterioration and revising the procedure CD-A-01 to preclude i
future problems.
I l
[
t
- 31. The corrective actions were subsequently reinspected and the matter closed I
out in NRC Report 79-12.
- 32. Although this occurred in 1979, the appropriateness of storage, cleaning, installation and cad welding has been continuously inspected by myself and other NRC inspectors through frequent field observations of material and ongoing activities.
Further, this type of activity and material storage has been included in the licensee selection for audits. Subsequent observations have not shewn this to be a problem.
i i
WELDING ALLEGATIONS Welding In Light Misting Rain
- 33. On November 18. I observed welding being performed on the No. 2 primary containment dome sections after a very light misting rain had commenced.
Although the rain was apparent and could be felt with the open hand, it was
(
not enough at this time to completely cover a flat surface; however, if this l
l condition were to continue, it would have become detrimental to the quality i
of the weld.
34 After I discussed the condition with the welding supervisor and the site CA t
supervisor, work was stopped for the day although they were of the opinion l
i 9
l that this condition was acceptable for welding and that this position could i
be substantiated by the " General Welding Procedure Specification for the i
Shielded Metal Arc Process" CBI-CWPS-SMAW(WPS-800) Rev.10, paragraph 11.1 which states in part:
" Welding shall not be performed when the surfaces of the pieces to be joined are wet from rain, snow, or ice, in the welding l
area."
l 35.
Further discussions with the licensee, architect engineer and contractor l
have emphasized the need for clarification of the requirements to control f
the ambient conditions necessary for quality welds in these structures.
i t
- 36. As stated above, work was stopped before any damage could occur. My concern was related to having clearer procedure guidance since the above procedure a110wed such broad interpretation.
The licensee responded by issuing a i
letter to all of the contractors clarifying the requirements.
l
- 37. The above actions satisfied my concerns and no further similar incidents l
have been observed.
l l
l l
Embed Assemblies i
- 38. This problem was initially reported to the NRC verbally on November 21 f
1978, and formally on December 20, 1978, in accordance with the reporting requirement of 10 CFR 50.55(e) to identify fabrication and installation deficiencies.
My knowledge of this issue is based on a review of the licensee's 50.55(e) report, NRC inspection reports, and observation of licensee corrective actions.
L
0 10
- 39. The deficiencies, for the purpose of inspection and evaluation, were separated' into ten categories by Georgia Power Company.
The site documentation shows that each of the deficient categories were addressed for either rework, pull testing, or engineering evaluations. Some of the embed plates were abandoned if they did not meet the design criteria.
- 40. The program was extensive in determining the thread engagement and ultrasonic inspection to determine bolt straightness and whether there were cracks or voids in the filet welds and a program for load testing actual Installed embed assemblies.
41.
NRC Regional inspectors nonitored the evaluations and corrective actions, found the actions appropriate and adequate, and closed the item in NRC Report 424/80-12.
STORAGE ALLEGATIONS Storage of Electrical Cabinets
- 42. On December 1, 1982, I inspected the electrical control cabinets " stored in place" in the control building for compliance to the requirements of Vogtle Field Project Manual Procedure GD-T-09 Rev. 3 and ANSI 45.2.3.
During the inspection, I observed unacceptable conditions in violation of the applicable requirements.
The results of this inspection and the associated violation are reported in Report 82-29.
^
i.
11
- 43. Upon completion of the inspection and reporting my observation, immediate l
~
actions were taken by the licensee in the form of cleaning the inside of the l
l cabinet bf brushing and vacuuming the dust particles, covering all of the openings with screen for rodent control and restoring the outer plastic wrap.
I i
i 44.
I made several inspections in the electrical storage areas to observe the cleaning and the restoration of the outer package and had discussions related to procedural changes to preclude future problems.
A followup Report 83-14 was issued and a final Report 83-17 written tg close the item based on the corrective actions promptly initiated and the significant l
improvements in the program.
- 45. Throughout my inspections I did not observe any evidence of permanent hardware problems and concluded that the early identification of the problem and the prompt response and corrective actions by licensee management has precluded potential problems with the electrical control cabinets.
s_ W b / d a ' f [ h / d, y Wilbert F. Sanders Subscribed and sworn to before me this July /7,1985 UW My Commission Expires I
%,, r o t c ' * ' ' ' t ' (#88 o e
!.1t*}
1 l
l
r-RESUME Wilbert F. Sanders 2809 Farrar Place Augusta, GA 30909 Age 62 Married--4 children Schools Attended Central High School - Wadsworth, Ohio Akron University - Akron, Ohio Ohio State University - Columbus, Ohio Metals Engineering Institute - Cleveland, Ohio U. S. Navy Steam Engineering - Curtiss Bay, MD Kodak Industriel Radiography.- Atlanta, GA N.D.E. Rockwell International - Santiago, CA Varied Management and Technical Courses 12 years experience with AEC/NRC Present assignment Senior Resident Inspector, Vogtle Nuclear Station Additional NRC experience in the following areas:
Inspection of N.S.S.S equipment manufactured in Europe and Japan for installation in the U.S.A.
Inspection of the programs and the fabrication of nuclear fuel at Exxon, Combustion Engineering, and Gulf Atomics facilities.
Inspection of manufacture of shipment casks for spent fuel.
Inspection of ASME Section XI preservice and inservice inspection in the northeast Region I district.
As part of an Engineering support group in Region I, I performed reactive inspections on material and equipment failures, feedwater hammer problems, intergranular stress corrosion, Eddy Current testing of steam generator tubing and feedwater modifications at Ginna and the Surry steam generator change out.
The submerged demineralizer system at Three mile Island 2 for clean up of contaminated water in the containment.
I also made numerous inspections on welding and nondestructive testing (MT UT RT PT) for both operating and construction plants.
Experience prior to NRC:
Quality Assurance Manager for the Naval Nuclear Program 1969 - 1972 at Babcock Wilcox, Co., Mt. Vernon, Indiana.
Responsible for all facets of the Q.A.,
Q.C. and i
7-2 nondestructive testing in the fabrication of the N.S.S.S. e uipment for the aircraft carriers (Nimitz -
Eisenhower 1967 - 1969 Assistant Manager of Quality Control - Responsible to the manager of Quality Control for the Q.C. Inspection, and N.D.T. activities in the total Comercial Nuclear and Naval Nuclear Programs.
In this position, I was very active in interviewing and selection of personnel to increase the Q.C. organization from 10 to approximately 50 people and the purchasing of equipment to set up a qualified Metrology Lab.
1965 - 1967 General Foreman - Wilmington, N.C. - Responsible for the manufacturing of pre-assembled Fossil Boilers and associated equipment. Directed 8 foremen and 300 hourly personnel.
~
1964 - 1965 Regional Works Inspector - Wilmington, N.C. -
Responsible for all phases of Quality Control and N.D.T. on preassembled boilers and associated equipment.
1961 - 1964 Assistant Chief Inspector - Barberton, Ohio -
Responsible to Chief Inspector for the inspection of Naval Nuclear, Commercial Nuclear, Fossil Fuel Components and associated equipment.
The experience listed has enabled me to obtain a proficient working knowledge of the following Codes and Standards:
Code of Federal Regulations ASME Section II, II, V, VIII, IX, XI ANSI Standbrds - American National Standards Institute MIL STD 25%1500 - Welding & N.D.E. Standard MIL Q 9858 - Quality Assurance Program References and certifications available on request.