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On September 29th, the US NRC reported piping deviations for the Vogtle AP 1000 “two flanges identified with deviations on Passive Core Cooling System pipe spools for the Vogtle Unit 3 AP1000r project had incorrect raised-face dimensions. This appears to have been caused by the two flanges being transposed due to an inadvertent fabrication error that occurred at the pipe spool supplier’s facilities (CB&I Laurens). The error was subsequently discovered after delivery to the fabrication facility (Aecon Industrial).” And, what does this mean? Did they replace it? Or? An expert assures me that this means that they did the equivalent of forcing a door shut, which doesn’t want to go. It should have been replaced rather than corrected: “The flange configuration was corrected and the Q223 Mechanical Module was delivered to the Vogtle Unit 3 site…http://www.nrc.gov/reading-rm/doc-collections/event-status/event/2016/20160929en.html Thus, Aecon is potentially producing defective “modules” in Canada. Greenberry of Vancouver, Washington has also made defective modules: http://www.nrc.gov/reading-rm/doc-collections/event-status/event/2016/20160913en.html http://www.nrc.gov/docs/ML1625/ML16258A454.pdf The Greenberry facility seems to be in Oregon.

The flange deviations are part of long-standing piping defect problems also reported in a supposedly cover-all lump in February of this year: “The basic components being supplied are piping spools to be used for various safety-related systems for the V. C. Summer and Vogtle AP1000® projects… These piping spools are associated with several systems, including Chemical and Volume Control System (CVS), Passive Containment Cooling System (PCS), Passive Core Cooling System (PXS), Reactor Coolant System (RCS), Normal Residual Heat Removal System (RNS), Spent Fuel Pool Cooling System (SFS), Steam Generator System (SGS), Main Control Room Emergency Habitability System (VES), Liquid Radwaste System (WLS), and the Waste Water System (WWS)” (See more below). There was also this: https://miningawareness.wordpress.com/2016/02/05/pipe-sleeve-corrosion-substantial-safety-hazard-for-v-c-summer-vogtle-ap1000-nuclear-power-stations-under-construction/

This appears to be Fordism with a new twist. Henry Ford once famously said that you can have a car of any color as long as it’s black. The nuclear industry appears to be saying that you can have any part you want, as long as it’s defective. Their solution to the inevitable risk of nuclear disaster is to push governments to continually raise the amount of radiation deemed safe, whereas it has been long know that there is no safe dose of ionizing radiation. The Chinese reported based on their experience with the first AP 1000 (still not operable) that small defects in modules add up to large ones – including pipes which could’t be connected. These problems with the AP 1000 provide a glimpse into future problems with the Small Modular Reactors. Even in the past some nuclear power stations didn’t go online because the defects were too great: http://www.agreenroadjournal.com/2012/12/abandoned-nuclear-powerplants-worldwide.html Look at all of the Areva Le Creusot problems, too.

In a June 30, 2016 report to the South Carolina regulator, South Carolina Gas & Electric states that “A number of mechanical modules previously shipped to the site by CB&I contain misalignments and other deviations from final design criteria. These modules are being disassembled and repaired on site.” They also appear to blame, at least in part, Toshiba’s Westinghouse (WEC): “Design changes continue to be communicated by WEC to submodule fabrication vendors on a schedule that disrupts the fabrication process and delays submodule production… Commercial issues between WEC and CB&I related to mechanical modules produced by CB&I-LC remain partially unresolved and are impacting mechanical module production schedule.” (p. 12) “SCE&G has continued its focus on WECTEC surveillance and audit activity at (i) Cives Steel Company (Cives), a supplier of commercial grade steel plate and other steel products used in the project; (ii) CB&I-Laurens, which fabricates the bundles of piping (pipe spools) that are used in the production of submodules and mechanical modules, (iii) Mangiarotti, supplier of major components, (iv) AECON Industrial (AECON) , a supplier of mechanical modules for the project, and (v) SPX-Copes Vulcan (SPX), the supplier of Squib Valves for the project.” (p. 15) They have an inspector “on site at Newport News Industrial (NNI) and a shared inspector for the Vigor Industrial and Greenberry Industrial sites near Portland, Oregon. An inspector remains at Paxton & Vierling where platforms for the interior of the CV are being fabricated.” (pp.11-12) “…submodules required for fabricating the Unit 3 Module CA01 have been received on site from the Toshiba and IHI Corporation facilities in Japan.” (p. 13) On p. 11 they mention that “CB&I’s system was geared to ‘just in time’ delivery which did not allow for sufficient time to process deliveries for documentation review, inspection, stocking and distribution… Fluor is moving to remedy this situation.” Emphasis our own. The entire document, which is probably the best summary of the problems is found here: https://web.archive.org/web/20161019215827/https://dms.psc.sc.gov/Attachments/Matter/8f05100a-b3d7-418a-84ff-7a16724ffb1a Fluor hired the NNSA’s Tom D’Agostino after he agreed to dump German nuclear waste at the Savannah River Nuclear site. Fluor is a Savannah River Nuclear site contractor and is being sued for overcharging the US government: https://miningawareness.wordpress.com/2016/03/19/us-sueing-savannah-river-nuclear-solutions-and-fluor-for-allegedly-overcharging-at-the-savannah-river-nuclear-site-psst-psst-the-nnsa-guy-who-agreed-possible-dumping-of-german-nuclear-waste-there/

Already in 2015 CB&I Laurens had “issued a Stop Work Order (SWO) on all Safety Related (SR) ASME Section III piping on March 17” [2015]. “The issuance of this SWO was during the March NRC inspection… During CB&I Power Surveillance 2015-172, which occurred in August 2015, the surveillance team discovered that issues with CGD and Qualification of Vendors had not been fully addressed by CB&I LaurensJuly 2015, CB&I Site QC inspection of pipe spools not signed off by Laurens ANI resulted in an approximate reject rate of 65%. These were due to minimum wall violations, dimensional issues, and misfabrications. These results have raised questions on inspection methodologies between Summer, Laurens, Vogtle, and Source Inspection./ An additional CBI Laurens self-imposed SWO was put in place on 10/09/15 regarding the incorrect VALVES being place in a pipe spool” (Read more at bottom, SEC gov)

The pipe spools are being supplied by CB&I Laurens, 366 Old Airport Road, Laurens, SC 29360. The procurement of the affected material is being conducted by the firm constructing the facility, which is WECTEC LLC (previously called CB&I Power), 128 South Tryon Street, Charlotte, NC 28202.” [WECTEC is a wholly owned subsidiary of Westinghouse]

The basic components being supplied are piping spools to be used for various safety-related systems for the V. C. Summer and Vogtle AP1000® projects. The pipe spools are classified as ASME Boiler and Pressure Vessel Code Section III. These piping spools are associated with several systems, including Chemical and Volume Control System (CVS), Passive Containment Cooling System (PCS), Passive Core Cooling System (PXS), Reactor Coolant System (RCS), Normal Residual Heat Removal System (RNS), Spent Fuel Pool Cooling System (SFS), Steam Generator System (SGS), Main Control Room Emergency Habitability System (VES), Liquid Radwaste System (WLS), and the Waste Water System (WWS)…..

The specific conditions identified on various piping spools fall into four general categories:

(1) Dimensional Length Deviations – These conditions include center-to-end and center-to-center lengths of straight pipe segments that exceed the minimum or maximum tolerances.

(2) Bend Angle Deviations – These conditions include spool bend angles that exceed the minimum or maximum tolerances.

(3) Minimum Wall Thickness Deviations – These conditions include pipe wall thickness below the applicable tolerance. These conditions typically have been found at some bends in the spools and at some ends of the pipe.

(4) Other Conditions – These conditions include weld related attributes, potential carbon contamination, and tools marks.

Of the categories listed above, the fabrication tolerance deviations involving bend angles and length are considered unlikely to pose a substantial safety hazard.” [Dangerously untrue BS statement.]

[Bend angles and lengths may also pose problems. Some issues would include workers forcing together pipes that don’t fit which results in stress cracking; cockeyed connections, O-rings and seals, issues in welding (weld butt end not aligned, not as strong). Flange function is to seal – tighting and bending to make it look flat adds stress, which would lead to cracking- eventual failure.]

Significant dimensional deviations would not be expected to fit properly during on-site construction activities and would be identified as nonconforming and not able to be used.” [Most deviations will probably be crammed into place, causing stress cracking over time. Will they be fitted onsite or at the module fabrication site in Canada? Both?]

Deviations listed as “other conditions” and minimum wall thickness deviations are considered to be potentially the most significant. The deviations associated with minimum wall thickness that are below the ASME code-required minimum wall thickness have been conservatively judged to have the potential to introduce a substantial safety hazard and are considered defects.

Therefore, if left uncorrected, the described conditions could cause a substantial safety hazard for the V. C. Summer and Vogtle APl000® nuclear projects. This report is also intended to bound any deviations that have not yet been evaluated or that are subsequently discovered during “extent of condition” reviews associated with the piping spools and materials supplied by CB&I Laurens“. http://pbadupws.nrc.gov/docs/ML1607/ML16074A100.pdf https://web.archive.org/web/20161017234155/http://pbadupws.nrc.gov/docs/ML1607/ML16074A100.pdf

CB&I headquarters moved from Chicago to Houston, Texas in 2001 and then to the Hague, Netherlands when Texas enacted a franchise tax.” https://en.wikipedia.org/wiki/Chicago_Bridge_%26_Iron_Company

Not surprisingly, CB&I’s Fabrication Services Group is currently searching for a Fabrication Foreman at its Laurens, SC, along with other related positions: https://web.archive.org/web/20161019005352/http://www.simplyhired.com/search?q=chicago+bridge+and+iron+company&l=laurens%2C+sc

On September 29th, 2016, the US NRC reported:
PART 21 REPORT REGARDING PIPE SPOOL FLANGES FOR VOGTLE UNIT 3
The following was excerpted from an email received from WECTEC LLC:
“Nature of the defect or failure to comply and the safety hazard which is created or could be created by such defect or failure to comply.

“The two flanges identified with deviations on Passive Core Cooling System pipe spools for the Vogtle Unit 3 AP1000r project had incorrect raised-face dimensions. This appears to have been caused by the two flanges being transposed due to an inadvertent fabrication error that occurred at the pipe spool supplier’s facilities (CB&I Laurens). The error was subsequently discovered after delivery to the fabrication facility (Aecon Industrial).

“This error resulted in conditions where the two flanged connections would not have met the design configuration. If the flanged connections had been assembled in the delivered configuration, it is not known if system integrity and operability would have been maintained during operation. The incorrect configuration could have also led to subsequent failure after installation and operation. Hydrostatic testing of these connections is required, but had not yet been performed because the condition was discovered prior to the assembly and testing of these portions of the system.

The condition is being corrected prior to the performance of that hydrostatic testing, therefore it is not known if the flanges in the incorrect configuration would have been able to pass hydrostatic testing.

“Due to the possibility that system integrity and operability could have been impacted by the use of the incorrect flanges, it has been conservatively concluded that this condition should be reported under 10 CFR Part 21. This conservative conclusion is based on the possibility that the Passive Core Cooling System could have been adversely impacted by the identified deviations, if the deviations had been left uncorrected.

“The corrective action which has been, is being, or will be taken; the name of the individual or organization responsible for the action; and the length of time that has been or will be taken to complete the action.

“…The flange configuration was corrected and the Q223 Mechanical Module was delivered to the Vogtle Unit 3 site on September 23, 2016. A corrective action report has been entered into the Westinghouse/WECTEC system to further evaluate the circumstances that led to the identified deviations.
http://www.nrc.gov/reading-rm/doc-collections/event-status/event/2016/20160929en.html https://web.archive.org/web/20160930230508/http://www.nrc.gov/reading-rm/doc-collections/event-status/event/2016/20160929en.html

Apparently the prefab modules are being assembled in Canada (NAFTA at work?), as well as the US, and they’ve apparently had defective or potentially defective modules: http://www.nrc.gov/docs/ML1625/ML16258A454.pdf
https://en.wikipedia.org/wiki/Aecon http://www.nrc.gov/docs/ML1616/ML16167A361.pdf
What a name! Does AECON stand for Atomic Energy Con per chance?

Although the word flange generally refers to the actual raised rim or lip of a fitting, many flanged plumbing fittings are themselves known as ‘flanges’…
There are many different flange standards to be found worldwide. To allow easy functionality and inter-changeability, these are designed to have standardised dimensions. Common world standards include ASA/ANSI/ASME (USA), PN/DIN (European), BS10 (British/Australian), and JIS/KS (Japanese/Korean).
In most cases these are not interchangeable (e.g. an ANSI/ASME flange will not mate against a JIS flange). Further, many of the flanges in each standard are divided into “pressure classes”, allowing flanges to be capable of taking different pressure ratings. Again these are not generally interchangeable (e.g. an ANSI/ASME 150 will not mate with an ANSI/ASME 300).[1]

These pressure classes also have differing pressure and temperature ratings for different materials. Unique pressure classes for piping can also be developed for a process plant or power generating station; these may be specific to the corporation, engineering procurement and construction (EPC) contractor, or the process plant owner. The ANSI/ASME pressure classes for Flat-Face flanges are 125# and 250#. The classes for Ring-Joint, Tongue & Groove, and Raised-Face flanges are 150#, 300#, (400# – unusual), 600#, 900#, 1500#, and 2500#.[2]

The flange faces are also made to standardized dimensions and are typically “flat face”, “raised face”, “tongue and groove”, or “ring joint” styles, although other obscure styles are possible.
Flange designs are available as “weld neck”, “slip-on”, “lap joint”, “socket weld”, “threaded”, and also “blind”.[3]
https://en.wikipedia.org/wiki/Flange

Pipe installation is often more expensive than the material and a variety of specialized tools, techniques, and parts have been developed to assist this. Pipe is usually delivered to a customer or jobsite as either “sticks” or lengths of pipe (typically 20 feet, called single random length) or they are prefabricated with elbows, tees and valves into a prefabricated pipe spool [A pipe spool is a piece of pre-assembled pipe and fittings, usually prepared in a shop so that installation on the construction site can be more efficient.]. Typically, pipe smaller than 2.0 inch are not pre-fabricated. The pipe spools are usually tagged with a bar code and the ends are capped (plastic) for protection. The pipe and pipe spools are delivered to a warehouse on a large commercial/industrial job and they may be held indoors or in a gridded laydown yard. The pipe or pipe spool is retrieved, staged, rigged, and then lifted into place. On large process jobs the lift is made using cranes and hoist and other material lifts. They are typically temporarily supported in the steel structure using beam clamps, straps, and small hoists until the Pipe Supports are attached or otherwise secured.https://en.wikipedia.org/wiki/Pipe_(fluid_conveyance)

Apart from defective piping per se, the Modularization of the AP 1000 poses problems: “the accumulated deviations for module fabrication and installation, the pipe position is difficult to be aligned.
(IAEA workshop: Modularization Construction Experiences of World First AP1000 Unit 2011-12-12 Xiaoliang Deng https://web.archive.org/web/20160913211142/https://www.iaea.org/NuclearPower/Downloads/Technology/meetings/2011-Dec-12-16-WS-Paris/1.12-X.DENG-AP1000.pdf

From the SEC:
EX-10.05 2 a20150930-exhibit1005.htm EXHIBIT 10.05
Confidential Trade Secret Information – Subject to Restricted Procedures
Exhibit 10.05 AGREEMENT

AMENDMENT TO THE ENGINEERING, PROCUREMENT AND CONSTRUCTION AGREEMENT BETWEEN SOUTH CAROLINA ELECTRIC & GAS COMPANY, FOR ITSELF AND AS AGENT FOR THE SOUTH CAROLINA PUBLIC SERVICE AUTHORITY AND A CONSORTIUM CONSISTING OF WESTINGHOUSE ELECTRIC COMPANY LLC AND STONE & WEBSTER, INC., FOR AP1000® NUCLEAR POWER PLANTS

THIS AMENDMENT (“October 2015 Amendment”) to the Engineering, Procurement and Construction Agreement dated May 23, 2008 (“EPC Agreement”) for the AP1000 Power Plants at the Virgil C. Summer Nuclear Generating Station (“Project”) is entered into this 27th day of October 2015, by and between South Carolina Electric & Gas Company (“SCE&G”), for itself and as agent for the South Carolina Public Service Authority (“SCPSA”) (collectively “Owner”) and a consortium consisting of Westinghouse Electric Company LLC (“Westinghouse”) and CB&I Stone & Webster, Inc. (“Stone & Webster”) (collectively “Contractor”). Owner and Contractor may be referred to individually as a “Party” and collectively as the “Parties.”

WHEREAS, Westinghouse has represented to Owner that it intends to acquire the stock of Stone & Webster from Chicago Bridge & Iron (“CB&I”) (the “Transaction”); that CB&I will have no further involvement in the Project except for certain supply agreements; and that Westinghouse intends to hire Fluor Corporation (“Fluor”) or its affiliate(s) as a subcontracted construction manager;…

Laurens Piping Quality Issues

CB&I Laurens issued a self-imposed Stop Ship on March 12 following a CB&I Power Audit (V2015-035), which included two Level 1 findings and three Level 2 findings. Most of the issues were repeat Findings from previous Audits/Surveillances performed by CB&I Power.

CB&I Laurens issued a Stop Work Order (SWO) on all Safety Related (SR) ASME Section III piping on March 17. The issuance of this SWO was during the March NRC inspection which found many similar issues documented in the CB&I Audit (V2015-035). The major issues being addressed by the SWO are CGD and Qualification of Vendors, Internal and External Audit Programs, Document Control, and Corrective Action Program.

During CB&I Power Surveillance 2015-172, which occurred in August 2015, the surveillance team discovered that issues with CGD and Qualification of Vendors had not been fully addressed by CB&I Laurens. This was also noted as an indicator that the corrective actions with the CAP had not been fully effective.

July 2015, CB&I Site QC inspection of pipe spools not signed off by Laurens ANI resulted in an approximate reject rate of 65%. These were due to minimum wall violations, dimensional issues, and misfabrications. These results have raised questions on inspection methodologies between Summer, Laurens, Vogtle, and Source Inspection.

An additional CBI Laurens self-imposed SWO was put in place on 10/09/15 regarding the incorrect VALVES being place in a pipe spool. The preliminary investigation determined that this does not affect Section III Safety Related pipe spools and has only effected a single spool. However, this investigation is only preliminary and a full Extent of Condition has not been performed. In addition to the Laurens SWO CBI Power has issued QRL restrictions for shipping of Laurens ASME SR spools unless they are released (after enhanced inspection) by the CB&I site QA Directors. Currently Pipe Spools have only been released in phases 1-3 of a 4 phase SWO. No spools will be released to phase 4 until completion of First Article Survey(FAS) by CB&I Power. Once all Spools are completed through Phase 4, the SWO will be lifted.

1. Completion of Corrective Actions associated with stop work /stop ship and lifting of restrictions. 2. Agreement on inspection methodologies between Vogtle, Summer, Laurens, and Source Inspection. 3. Completion of Enhanced Inspections on post SWO pipe spools performed by VC Summer QC. 4. Sustainable Improvements in programmatic systems reported from Audit/Surveillance results performed by CB&I Power…
https://www.sec.gov/Archives/edgar/data/91882/000075473715000076/a20150930-exhibit1005.htm

Flange Bolt removal BP Deepwater Horizon: http://youtu.be/XO1SvPVmz5Q
BP Horizon Flange
Flange photo – BP Deepwater Horizon. Actually the only good public domain photo which could be found.

Attachment to Letter Dated February 1, 2016 10 CFR PART 21 REPORT REGARDING DEVIATIONS OF PIPE SPOOLS FOR AP 1000 PROJECTS
Attachment to Letter Dated February 1, 2016 10 CFR PART 21 REPORT REGARDING DEVIATIONS OF PIPE SPOOLS FOR AP 1000 PROJECTS, p. 1
Attachment to Letter Dated February 1, 2016 10 CFR PART 21 REPORT REGARDING DEVIATIONS OF PIPE SPOOLS FOR AP 1000 PROJECTS, p. 2
Attachment to Letter Dated February 1, 2016 10 CFR PART 21 REPORT REGARDING DEVIATIONS OF PIPE SPOOLS FOR AP 1000 PROJECTS, p. 3
WECTEC Letter Dated February 1, 2016 10 CFR PART 21 REPORT REGARDING DEVIATIONS OF PIPE SPOOLS FOR AP 1000 PROJECTS

Regarding Flange “dumping””
FACT SHEET
Commerce Initiates Antidumping Duty Investigations of Imports of Finished Carbon Steel Flanges from India, Italy, and Spain, and Countervailing Duty Investigation of Imports of Finished Carbon Steel Flanges from India

• On July 21, 2016, the Department of Commerce (Commerce) announced the initiation of antidumping duty (AD) investigations of imports of finished carbon steel flanges from India, Italy, and Spain, and a countervailing duty (CVD) investigation of imports of finished carbon steel flanges from India.
http://enforcement.trade.gov/download/factsheets/factsheet-multiple-steel-flanges-ad-cvd-initiation-072116.pdf

http://energy.gov/sites/prod/files/edg/open/documents/6.0_Item_26_Enterprise_Top_Hat_Phases_-_07-04-2010.pdf

https://en.wikipedia.org/wiki/The_Shaw_Group