DCL-84-124, Forwards Response to 840229 Notice of Severity Level IV Violation Noted in IE Insp Repts 50-275/83-37 & 50-323/83-25.Weldments Examined for Acceptability by Qualified Inspectors & Necessary Repairs Will Be Made

Forwards Response to 840229 Notice of Severity Level IV Violation Noted in IE Insp Repts 50-275/83-37 & 50-323/83-25.Weldments Examined for Acceptability by Qualified Inspectors & Necessary Repairs Will Be Made

ML20088A712
Person / Time
Site:	Diablo Canyon
Issue date:	03/29/1984
From:	Schuyler J PACIFIC GAS & ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
DCL-84-124, NUDOCS 8404130003
Download: ML20088A712 (7)

Text

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PACIFIC GAS AND E LE C T RIC C O M PANY hbU43 } 77 BEALE STREET . SAN FRANCISCO, CALIFORNI A 94106 * (415)781-421: . TWX 910 372-6587 J.O.SCHUYLER V>CE PRE $4CE47 March 29, 1984 PGandE Letter No.: DCL-84-124 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Comraission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Docket No. 50-323 Diablo Canyon Units 1 and 2 IE Inspection Report 83-37 and 83-25 -- Notice of Violation

Dear Mr. Martin:

NRC Inspection Reports 50-275/83-37 and 50-323/83-25, dated February 29, 1984, included a notice for a Severity Level IV violation. PGandE's response to this notice is enclosed.

Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincere

1. o. G. Odu, er Enclosure cc: Service List 8404130003 840329

• PDR ADOCM 05000275 _gg.29 a

,j, PDR.

PGandE Letter No.: DCL-84-124

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ENCLOSURE RESPONSE TO NOTICE OF VIOLATION IN NRC INSPECTION REPORT NOS. 50-275/83-37 AND 50-323/83-25 On February 29, 1984, NRC Region V issued a Severity Level IV Notice of Violation as part of NRC Inspection Report Nos. 50-275/83-37 and 50-323/83-25 on Diablo Canyon Units 1 and 2.

The Notice cited:

o Twenty-eight Pullman employees began inspecting and accepting weldments prior to completion of required training and certification as welding inspectors.

DEFICIENCIES IN THE TRAINING AND CERTIFICATION OF PULLMAN WELDING INSPECTORS

["As a result of the inspection conducted on November 14-18 and November 28 -

-December 9,1983, and in accordance with NRC Enforcement Policy,10 CFR Part 2, Appendix C, the following violation was identified:

Section 17.1.5 of the FSAR (dated October 1978) and the Pacific Gas and Electric Company Quality Assurance Manual Section V (dated August 15,1978) states, in part, that, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings...and shall be accomplished

,. in accordance with these instructions, procedures, or drawings...."

Engineering Standard Diablo (ESD) No. 237, " Quality Assurance Inspector Training Program," dated February 26, 1974, states in paragraph 2.3 that, "All personnel engaged as Field QA Inspectors involved in the intpection of weldsents . interpretation of Engineering Specifications and Welding.

Procedures, and documentation work, shall be required to complete an indoctrination period as described in Section 4 of this specification."

Paragraph 4.1 states that, "The indoctrination period for the Field Q.A.

Inspectors described in Section 2.3 shall contain as a minimum, but not necessarily limited to, the following courses:

Visual Inspection Welding Procedures Welding Inspection Welding Processes Basic Q.A.

t Other courses offered as optional are:

Welding Steam Power Plant Fundamentals Basic Power Plan Instruction Introducing Nuclear Power Welding)&

(I.C.S. Piping Engineer. Technology The Visual Inspection and Welding Inspection tests shall be administered and controlled by the N.D.E. Training Officer. All N.D.T. training, qualifications and certifications will be covered by ESD-235."

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Paragraph 4.2 states that, " Tests used for the indoctrination courses for Field Q.A. Inspectors shall be:

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1. For Basic Q.A. Test-ESD's.

! 2. For Weld Procedure Test-Approved Welding Procedures.

l 3. For the Weld Process Test, Welder Qualificatin Card and Pipefitter's Manual.

4. For Welding Inspection Qualifications, General Welding Infomation.

j 5. Visual Inspection Qualifications-General Dynanics NDT Introduction."

1 A' Nuclear Services Corportion (NSC) Audit dated October 27, 1977, identified i in Criterion IX, Finding No. 3 (of the audit) twenty-eight individuals which l were alleged to have begun perfoming their duties without fulfilling the Pullnan Power Products procedural requirenents for certification and

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4 qualification of Quality Assurance (Welding) Inspectors.

Contrary to the above requirenents of the FSAR and Pullnan procedures, the inspector identified on Novenber 15, 1983 that in virtually all cases the

!. individuals hired after Septenber 25, 1973, naned in the NSC audit finding (who were assigned to perfom welding inspections), began inspecting and accepting weldnents, before completing the required training, taking the 4

required exaninations, and before being certified as a welding inspector. It j is noted that the Pullnan Power Products response to this Nuclear Services

Corporation finding states, in part that, "All current inspectors have been

! qualified by test as. outlined in ESD-237. The requirenent for qualification j and certification of field inspector were added in ESD-237 on Septenber 25,

! 1973 to reflect the requirenents of ANSI N45.2.6, just published. Persons hired before this tine were not necessarily tested at tine of hire.

Subsequent to 1973, the records indicate that all inspection personnel received required training and exanination." However, the Pullnan res a se is

silent with regards to inspectors perfoming inspections prior to certification.

l This is a Severity Level IV Violation (Supplenent II)."]

i. EXPLANATION AND CORRECTIVE ACTION TAKEN i

In our investigations,17 of the 28 individuals cited by the NSC Audit werc i welding inspectors. The other eleven were non-destructive test inspectors who ware fully ~ qualified to perfom ND Testing prior to beginning those activities. In responding to the Notice, Pullman Welding Inspectors have been placed into three categories according to their time of hire:

A. . Four individuals were hired to perfom weld inspections from the start of work through August 1973. All inspectors were shown to be qualified to perfom visual weld inspections based on a review of docunentation of

. previous work experience and education. Prior to September 1973, no requirement or guidance existed within the industry directing the docunentation, qualification, or certification of inspectors.

' B.- Documentation of weld inspector qualification and inspector assignnents was reviewed for all inspectors hired during the period from September 1,1973 through December 1980. Seventeen inspectors were found to have perfomed inspections prior to docunentation of conpletion of the training and testing required by ESD-237. These seventeen inspectors

-were hired between September 1,1973 and October 3,1975. After October

- 3,1975 =no inspectors perforned inspections prior to docunentation of qualification per ESD-237.

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A. reinspection program was initiated to determine if walds inspected by these 17 individuals meet the requirements of B31.1, B31.7, or the ,

- current ASHE Section III code. For those inspectors who are considered qualified based upon their education and experience, 20% or more of welds inspected prior to their compliance with the ESD-237 procedure are being reinspected. The inspection is limited to accessible welds only. For those individuals considered unqualified prior to meeting the requirements of ESD-237, all accessible welds inspected prior to qualification are being reinspected.

Based on a review of documented previous work experience and education, all individuals except Mr. Guy and Mr. Cubbage were found to be qualified for weld inspection duties. A listing of the 15 inspectors considered qualified based on previous experience is provided in Attachment A.

The scope of inspections performed by Mr. Guy and Mr. Cubbage prior to documentation of qualificaton and reinspection results are shown on l Attachment B. .

1 C. One hundred and seven individuals were hired to perform weld inspections during the period from January 1, 1981, to the present. A sample of the records for 21 inspectors indicated that all inspectors were documented to be qualified in accordance with ESD-237 prior to performance of inspections, with two exceptions. In both of these cases, documentation occurred one day following the first inspection. This is considered to be an administrative delay and the results provide confidence that the requirements of ESD-237 have been fully implemented from October 3, 1975 i to date. ,

For each individual who performed inspections prior to the training and testing' requirements of ESD-237 the following is or will be identified:

1. No. of inspections - The number.of inspections performed prior to documentation of completion of training and testing requirements.

2. No, to be Reinspected - The number of welds to be reinspected to comply

-with the requirements of.the reinspection. program. All accessible welds accepted by Messrs. Guy and Cubbage will be inspected. If a large percentage ( 5%) of accessible welds originally accepted by any-inspector is rejected and requires repair during the reinspection,'then ,

all welds inspected by that individual will be' examined.

3. Reinspected - The number of accessible welds which have been reinspected.

4._ Suspect - Weld items in this category include such items as minor are strikes,1/32" undersized welds on a small portion of weld circumference, and conditions which require further surface preparation. .

.During the' inspection program, inspectors have examined 1036 welds. Of these, ,

59 fall into the suspect category. The~ suspect welds will be reexamined by supervisory level welding inspectors. If the suspect condition is verified by the supervisors. the condition of those welds will be forwarded to Engineering for evaluation. Presently, 42^weldsents are under consideration by the j supervisors. Seventeen welds,have'been sent to Engineering for evaluation and '

disposition. As of'this'date, no welds have required repair.-

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CORRECTIVE ACTION WHICH WILL BE TAKEN Weldments are being examined for acceptability by qualified inspectors in accordance with the above discussion. Should any welds be found unacceptable, they will be repaired in accordance with the existing approved procedures.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED PGandE has been in full compliance with procedure ESD-237 since October 3, 1975. A high level of confidence in the quality of the work to be reinspected is established by the fact that:

1. All code Class A, B, and C welds were inspected using NDE methods by qualified individuals in addition to the visual inspections performed by Mr. Guy.

2. In some cases, the welding inspection was witnessed by the Authorized Nuclear Inspector.

3. All Design Class 1 piping has been hydro-tested and, in some cases, reinspected for the base line data as a part of the Inservice Inspection Program.

PGandE plans to complete all corrective action within 30 days of the date on this submittal. A final report detailing the results of all inspection activities and the disposition of suspect welds will be submitted at that time.

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1 PGandE Letter No.: DCL-84-124 '

Attachment A REINSPECTION PROGRAM Mininun No. of No. to be No. Already Nane Inspections Reinspected Reinspected Suspect Allmendinger 69 14 29 1 Bloon 2 2 2 0 Bowlby 387 78 117 9 Boyd 192 39 51 1 Finch 289 58 107 4 Jennings 423 85 96 6 Kaz 3 3 3 0 Kincade 84 17 14 0 Page 195 39 35 1 Pennie 294 59 81 2 0'Brien 2 2 2 0 Sarvwatari 31 3 63 72 2 Silver 47 10 11 0 Thonas 17 10 10 0 Willard 367 74 135 16 0680d/0009K W

PGandE Letter No.: DCL-84-124 L

Attachment B REINSPECTION PROGRM1 l

No. of No. to be No. Already Nane Inspections Reinspected Reinspected Suspect Guy 300 300 260 16 Cubbage 23 23 11 1 0

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