DCL-84-141, Forwards Response to 840406 Request for Info Re Allegations 92 & 93 (Sser 22) Concerning Tube Steel Used in Pipe Supports.Related Info Encl
| ML20211J294 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/11/1984 |
| From: | Schuyler J PACIFIC GAS & ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML16341D790 | List:
|
| References | |
| DCL-84-141, NUDOCS 8606260310 | |
| Download: ML20211J294 (30) | |
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PACIFIC OAS AND 2D LE C T RI C C O M P.A.N Y
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April 11, 198i PG'andE Letter No.: DC.-64-141 Mr. John B. Martin, Regional Administrator U. $. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1 SSER 22 Allegation No. 92/93 -- Pipe Support Tube Steel
Dear Mr. Martin:
Enclosed is PGandE's response to the April 6, 1984 request by the Region V staff for information concerning tube steel used in pipe supports at Diablo.
Canyon.
Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.
Sincerel,
>_-.. Y J.
huyler Enclosure ec:
D. G. Eisenhut D. F. Kirsch N. E. Schierling Service List
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8606260310 860611 PDR ADOCK 05000275 U
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PGand Letter No.: DCL-84-141 i
DCLOS M At the staff's request, this letter provides additional infomation on corner radit in the design of pi>e support welds to tube steel (SSER 22 Allegation 92/93).
In a letter to tse NRC dated February 29, Ig64 (DCL-84 d83), pGand provided the Project criterion for the associated weld design. This criterion uses 5/16 R as the effective throat of flare bevel welds, where R is defined as the outside corner radius of the tube steel which is equal to twice the tube wall thickness, 2.0 t.
Thus, the designers use 5/8 t as the effective.
throat of the flare bevel welds.
Durin's the week of April 1,1984, the NRC Staff's contractor, Mr. M. E11, examined the corner radii of pipe support tube steel installations. His measurements apparently indicated that some of the smaller size tubes (those with a perimeter less than 14 inches) had been manufactured with corner radit of 1.5 t.
An exit meeting was held on April 6,1984, and all facts that were known at that time were discussed and several questions were raised.
Subsequently, in a letter dated April 6,1984, the NRC staff ' formally requested PGandE to respond to these questions.
In responding to these questions, PGancE has investigated the nethods used to measure corner radif to determine their validity, and has perfomed weld tests on tube sections with apparent radit less than 2.0 t (measured by the tangent intersection nothod) to demonstrate that the actual weld throat thickness achieved is at least equal to that used in the design calculations.
Neasurenent "of Corner Dinensions The curved portion of the tube corner is not fabricated to be exactly one quarter of a circle, as indicated by the dotted ifne in Figure A.
Instead, it is actually less than a quarter of a circle as indicated by the solid line in the same figure. Therefore, different radii can be measured for the tube i
corner dependent upon the measurenant method used.
If a straight ruler or mechanic's square is used, as shown in Figure B, a corner dimension, D, is naasured. This is considered to be the tangent intersection method. Based on this D dimension, an apparent cotner radius of RO is iglied. As shown in Figure B, this may not be the actual radius of l
curvature. Alternatively, if a concave radius gauge is used, the neasured radius is RA, as shown in Figure C.
RA is the appropriate neasurenent of the actual curvature. Vnly when the tube corner is a quarter circle will the two measurement methods yield the same radius. Examples of tubes with the smallest corner dimension, D, were selected by the site piping contractor's QC personnel (Pullaan QC) for further measurement. The resulting measurements t
are stassarized in Tables 1A and 15. The difference between RD and RA is clearly shown in these tables. For the 3 x 3 x 1/4 tubes, the apparent radius, Rp, is approximately 1.25 t to 1.5 t and the RA is always 2.0 t or s111ttly larger. For the 3 x 3 x 1/2 tubes, RD is ap >roximately 1.0 t and RA ts again 2.0 t.
The NRC staff's contractor used tie tangut intersection method of measurtment.
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Weld Tests The tubes that had been selected by Pu11 nan QC (the "D" dimensten apparently less than 2.0 t) were used for weld tests. The weld tests were perfomed using both 3/32" and 1/8" dianeter electrodes in four welding positions.* The test coupons were cross sectioned and the flare bevel weld effective throtts were neksured. The effective throat was neasured as flus s with the side of the tube. No credit was taken for weld reinfortsment. Tle actual weld effective throat, as shown in Tables 2A and 28, clearly denonstrates that the weld effective throat is at least equal to the 5/8 t dimension used in the
-design calculations.
The above discussion provides the bases for the following responses to the three questions raised in the NRC's letter of April 6,1984.
1.
Consider the effects of a 1.5 't tube steel radius on pipe support a'nd flare bevel weld adequacy.
The use of tube steel with corner dinensions of 1.0 t,1.25 t or 1.5 t, neasured by the tangent intersection method, has no effect on the adequacy of pipe supports or their flare bevel welds. As denonstrated by weld tests corner dimensions less than 2.0 t have no adverse effect on the effective weld throat. The 5/8 t effective throat used in the design calculation is always achieved with margin.
2.
Explain the apparent discrepancy between the Staff's observations (corner radius = 1.5 t) and the statement in PGandE's February 29, 1984 letter relating to the fact that tube steel at Diablo Canyon had an outside corner fr$11 of 2.0 t or greater.
The NRC Staff and Pu11 nan QC have reported corner dimensions, as measured by the tangent intersection method, rather than measured by a curvature gauge. As discussed above and as shown in the attached figures, these measurement techniques lead to different conclusions. Although measurement of corner radit had never been an inspection requirenent, a few jobsite measurements had confimed the radius was 2.0 t or greater.
The recent naasurenents made using a curvature gauge and the weld testing that measured the effective throats of the associated flare bevel welds reconfimed the validity of the 2.0 t or greater radius.
3.
Detemine and explain the full scope of any necessary corrective actions.
Regardless of how the tube corners are measured, the flare bevel welds are more than adequate, and no corrective action is required.
Conclusion This letter has provided the results of PGandE's investigation into the subject of tube steel corner radius and radius effect on the adequacy of flare bevel weld effective throat. The weld test data shows that significant margins exist. No further actions are required.
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Fig. 3 Fig. C Straight Ruler Method Concave Radius Gage Method The implied radius RD The actual radius of the curvature is is taken as the measured D dimension measured I
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TABLE 1A 3 x 3 x 1/4 SQUARI TUBING Mister Sample Corner D'inension (D)*
Radius of curvat.sh (R )**
A
- 1 A
11/32 13/32 1/2 8
7/16 3/8 1/2 i-C 3/8 7/16 1/2
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D 13/32 11/32 1/2
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11/32 13/32 1/2 B
13/32 3/8 17/32 C
3/8 13/32 17/32 D
3/8 11/32 17/32 f3 A
3/8 13/32 17/32 8
13/32 11/32 1/2
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C 15/32 13/32 1/2 D
13/32 3/8 17/32 f4 A
3/8 7/16 17/32 8
7/16 11/32 1/2 C
3/8 3/8 1/2 D
7/16 3/8 17/32
- Corner dinension, D, equair inpited radius, Ro.
(Tangent Intersection phthod)
- Radius of curvature, RA, always equals or exceeds 2.0 t.
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TABLE 18 3 x 3_x 1/2 SQUARE TUBING
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t Minbar Sanple Corner Dinens_fon (D)*
Radius of Curvatu e (R )**
A
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17/32 15/32
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1/2 17/32 1
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C 9/16 17/32 1
D 17/32 9/16 1
f2 A
1/2 1/2 1
8 17/32 9/16 1
- C 15/32 7/16 1
D 7/16 15/32 1
- 3 A
1/2 15/32 1
B 9/16 1/2 1
C 9/16 17/32 1
D 15/32 9/16 1
- Corner dinension. D, equals inplied radius, Ro.
(Tangent Intersection Method)
- Radius of curvature. RA, always equals or exceeds 2.0 t, 0842d/0009K w
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TAR.E 2A TEST RESULTS OF EFFEETIVE THROAT OF FLARE BEVEL ifELD$
3 x 3 x 1/2 TUBE. CORNER DIMENSION = 1/2" (NOMINAL)
Position 1/8 Dia. Electrode 3/32 Dia. Electrode
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31/64. 30/64, 32/64 27/64, 26/64, 26/64 2G 28/64,28/64,29/64 26/64,26/64,27/64 3G 32/64,.31/64,34/64 26/64, 24/64, 26/64 4G 31/64, 28/64, 30/64 26/64, 24/64, 25/64 NOTES:
1.
Effective throat used in design calculations = 20/64".
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2.
Above test results show that the actual weld effective throats exceed the value (20/64") used in the design calculations.
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TABLE 2B TEST RESULTS OF EFFT.CTIVE THROAT OF FLARE BEVEL WELDS _
3 x 3 x 1/4 TUBE, CORMER DIMENSION = 5/16" (NOMINAll 1/8 Dia. Electrode 3/32 Dia. Electrode 14/64, 14/64, 16/64 17/64,18/64,17/64 is 16/64,16/64,17/64 19/64, 18/64, 19/64 2G
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18/64,18/64,17/64 19/64,19/64,14/64 3G 18/64,19/64,19/64 21/64,20/64,19/64 4G MOTES _:
1.
Effective throat used in design calculations = 10/64".
Above test results show that the actual weld effective throats exceed the 2.
value (10/64") used in the design calculations.
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INTEROFFICE CORRESPONDENCE l
l em July 30,1982 I
to H. Karner, QA/QC Manager necu H. Hudson, Internal Auditor I
Exit Conference with PG&E Auditors concerning Program Audit #20705, susjECT
{
" Quality Assurance Program".
The Exit Conference with PGSE Auditors was held on 7-29-82 and audit findings were discussed.
It was stated that the scope of the audit was a Supplier and Program audit.
The main concern was the implementation' of the administration 'of. Quality Assurance.
See the l
attached list for conference attendees.
The following items were discussed:
1.
Previous audit findings were looked at.
Noted that the Internal '
Audit schedule was very effective.
Noted that Management audits
.ht.re okay and that QA interface was okay.
2.
Internal Audits were adequate. Stated that the last two years, a goed audit program was in effect.
Two recommendations:
A.
Cases where Inspectors or others did not follow procedures, the Steps to Prevent Recurrence were to reindoctrinate.but there was no documentation to back this up.
Recommended r
Pullman provide form to document reindoctrination as well as use Internal Auditor letters reminding of procedure requirements. 4:ee m a s-on rw na rH&G- ** " '# # '"
In!V'!'"fuIStor qualification appears to Te @:I d5Sl<?sWo r y,,
1 ternal ff?O?$i$rdrY u?h'o" *""* '
B.
Standard but no statement that it is. Recommends Pullman state Internal ew, Auditor it qualified to ANSI Standard.
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3 Training of NDE Inspectors to SNT-TC-1 A was adequate.
But other I spectors _shoul.d be qua]if.i.ed__to_. ANSI N45.u2._,_6_ standar.ds, 3
There is no evidence that they are. This will be an open item to re-l audit at a 1ater date. f G.6 as ar grpo #
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Cat Organization was okay,y Lf tss fAs
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Discrepancy Reports were okay except Steps to Prevent Recurrence N
I n 4s 4 needs back up documentation when a person has received reindoctrina-
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- f. f4dv tion.
A recom.endation was made about the use of tape over penciled M
in circles which PG&E used to mark the recommended disposition they wanted implemented on a Discrepancy Report.
The tape was used to 1 -
preserve the pencil marks from w' ear.
The auditor called this system
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" hokey".
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To H. Karner. QA/QC Mamnager om July 30,1982 Exist Conference wi ith PG&E Auditors concerning Prograp Audit #20705, I
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5' Continued V7-**ca r+ A e in e sn.s. 76 sff,xy+<ns wowsi'o D#s oJ, A
v He recommended tha a orma zec me be implemented for PG&E to 1.ndicate thetir preference in Discrepancy Report Dispositions.
The auditor alssa made an observation about the number of open Discrepancy Rep orts going back to 1978.
Pullman responded.that these open Disc:repancy Reports were Unit f!I work still in progress.
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den p.A',':.ss too 70 Jeairm '
9 6.
Purchase Orders: were being let before the QA/QC Manager sign off. 4 Need to establiish management control. The receiving of purchased 8/*4 v i
material was urr. der" control. Need to comply with procedure require-ments. This wc:uld remain as an open item to be reaudited at a later date. 'Arr. observation was made about Site Approved Vendor's 4-AWV 1.i st. There wa s no approval by PG&E of the list but approval was A rve f
done on an indUvidual bases by purchase order.
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7.
Design Control was adequately implemented.
- 2
- 8. _Dr_ awing Cgn(ro_' was adequately imp 1_em,en_ted.
9.
Document Corrtr:T had an observatich made about Isometric packages.
Iso packages were complete but documentation not properly arranged into categorie: per-QA Instructions. Stated related documents such as Inspection Check Off Lists were the same way.
Al l information was available but located in different places.
Concerned about only one person knosing where documents are located.
If he dies, control
, may be compromised.
Iso packages audited were 1-14-86A,1-14-85A,1-14-78A and 1-21-38.
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- 10. Monthly Maintenance Surveillance Reports were audited and only two reports available for July. Pullman response was reprts are not o
turned in until the end of' the month.
l
- 11. Control of Measuring and Test Equipment had no problems.
- 15. Control of Inspection and Test Status had an observation concerning piping process sheets.
The last two steps on the process sheet were blank due to NDE findings. Recommended that process steps not used have 's statement exp1aining why. TM.srey s s e*x t c u s a y "* r k W "'k*io na to Fws." S C"fWr~J ot* AdGera wc'-%t 49**rwss sn.'f s w 's' G Special Processes of NDE, Welding, Welder Qual [fication and Welding [# #4' 13.
Material were 2dequate.
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Harold Hudson Internal Auditor l
Diablo Canyon Nuclear Plant HH/dd Att.
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c-My name is Richard D. Parks.
I am submitting this affadavit to document the discrepant conditions identifie'd, and corresponding violatio s n of the applicable codes as a result of the plant tour conducted on April ll 1984 with D. Kirsch and G. Hernandez of Region V, United States N uclear
- Regulatory Commission (NRC) at the Diablo Canyon Nuclear Power P a nt.
I and three witnesses accompanied the NRC to provide " bands on" e a x mples of non-compliance with regulations, specifications an'd codes that form th e
basic cornerstone of a comprehensive Quality Assurance /Ouality C ontr ol p r ograrn.
i Ea ch example identified to the NR Cr, ras s ubs equently " tagged" fo e
ca tion and a " report sheet" was filled out by the NRC.
The " problem description" is a cuote from the report sheet.
The examples identified that violated applicable codes are discussed as follows:
i ITEM #1, Tag #2:
Elevation 116, Unit 1 Reactor Building. Line Designation NO.S2-2 54-13, in the area of Pressurizer and Reactor Coolant Pump 1-2 1
Pr oblem Des cription-Weld attaching Safety Injection A:cumulator line to nozzle cf the cold leg line (NO 52-254-ID).
On the side facing-Reactor Coolant Pump (RCP) is a grinding gouge in the pipe at th e
pipe-weld interface approximately 3/8 inches long,1/8 inch at o
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widest point and 1/16 inch deep (dimensions as visually determined by NRC Inspector - no measurements taken). Additionally, there appears to be a slight amount of undercut at two locations. The undercut is approximately 5/B inches on the weld side facing the RCP and approxi-mately 1 inch at 12D from the side away fro:n the RCP.
Code Violation: American Society of Mechanical Engineers (ASME)
Section III, " Rules for Construction of Nuclear Power Plant Components - 1977 edition, Division I General Requirembets, Subsection NB, " Class 1 Components", para NB-4424 " Surfaces of Welds".
"As-welded surfaces are permitted, and for piping the appropriate stress indices given in Table NB-3683.2-1 shall be applied. However, the surface of welds shall be sufficiently free from coarse rippt'es, grooves, overlaps, and abrupt ridges and valleys to meet (a) through (f) below:
(a)...
(b)...
i (c) Undercuts shall not exceed 1/32 inch (0. 8mm) and shall not l
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(d)...
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(e)...
(f)lf the surface of the weld requires grinding to meet the above criteria, care shall be taken to avoid reducing the weld or base i
rn::tal below the required thickness."
-The discrepant condition identified-by the witness violz.tes the code req:ir'ements with respect to being " free from coarse rippies, grooves, overlaps, and abrupt ridges and valleys to meet (c) and (f)."
1 TEM #2. Tae #4: ' Unit 2 Reactor Building, Elevation 115, Support 97-3R in vicinity of RCP 2-3.
Problem Descriotion: " Excessive overweld has caused excessive shrinkage of SS line. This was supposed to be a full penetration weld with fillet cap and is as specified. The overwelding can damage the pipe because calculations don't account for residual stresses caused by such overwelding."
Code Violation: United States of America Standard (USAS) B31.7-1969
" Code for Pressure Piping - Nuclear Power Piping" (note: this standard now is known as ANSI-B31.7), foreward " FABRIC ATION REQUIREMENTS AND THEIR CORRELATION WITH DESIGN", page XVI paragraph 5.
"Even hanger attachment details are covered. For Class 1 piping, complete penetration welds are required. The designer must consider all stresses in the attachment as well as their effect on the p.ressure CA
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retaining part. "
The welds in question do not conform to the stated intent of the
" Nuclear Power Piping" code with respect to the residual stresses induced by the overweldin g.
It is the concern of this particular anon-ymous witness that these ~ residual stresses should have been but were not a factor in the design calculations.
ITEM #3, Tac f5: Unit 2 Reactor Building, large restraint wall attachment (around surge line), beneath Unit 2 Pressurizer.
Problem Des cription: "Shopwelding is supposed to conform to AWS DI. ) standard s.
The inner welds are excessively rough and of_.s.uch a profile that they would not conform to AWS D1.1.
The welds are ragged."
Code Violation: American Welding Society (AWS) Structural Welding Code - Steel, paragraph 8.15 " Quality of Welds", subparagraph 8.15 "Vis ual Ins pe etion".
"All welds shall be visually inspeeted. A weld shall be acceptable by visual inspection if it shows that B.15.1.1
-The weld has no cracks 8.15.1.2 Thorough fusion exists between adjacent layers of weld metal and between weld metal and base toetal
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5 5.
_ B.15.-l. 3 All craters are filled to the full cross.section of the weld 8.15.1.4 Weld profiles are in accordance with,(para.) 3. 6
[ weld profile] "
The weld in ques tion does not conform to the requirements specified in paragrapli 3.'6 [ weld profile @ or the evident thorough.fesion requirements as stated in 8.15.1.2 l
ITEM 34. Tar #6: Unit 2 Auxiliary Building, area GY, elevation 115, line No. 2-52-265-8 (Containment Spray Discharge Pipe - 4 lug attachments between 5 and T line.)
Item
Description:
" Lug attachments are called out to be 1/2 inch fillet welds on three sides. Actual size is 7/16 inch fillet or les s."
Problem
Description:
" Actual size is alleged to be less than or equal to 7/16 inch which is 1/16 inch less than required. The exce s sive welding used in the design of the lugs attachment welds, when welded to Schedule 10 stainless thin wall pipe, has caused excessive shrinkage.
A ne excesssve shrinkage causes residual stres ses in the pipe which has not been accounted for in the design or stress analysis. The position of the clamp is such that there is a torsional force applied to e
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the lugs, because the clamp enonot contact the wall ci the pipe due to the shrinkage.
This torsional force is not accounted for in the -
design and compr:nmis es the pipe integrity."
Code Violation:
R efer to " Code Violation" discus sion in " ITEM #2, Tag #4".
The welds in question do not conform to the stated intent of the
" Nuclear Power Piping" code with respect to the residual stresses induced by the wel:Eing or.the torsional force applied to the lugs due i
to exces sive shrinkage. It is the concern of this particular anonymous witness that these stresses,should have been but were not a factor in the design calculations.
~
ITEM #5, Tar #7: Unit 2, Auxiliary Building, Area 2H, support 413-131R around CCW line.
Pr oblem Des cription:
"Eight lug attachment welds are required to 6e full penetration welds on three sides. Actual weld is not a full pene-tration weld, but is, instead a fillet weld, contrary to the design."
Code Violation: American Welding Society (AWS) - A2.4 - 79
" Symbols for Welding and Non-Des tructive Tes ting, " paragraph 9. 0
" Groove Welds," subparagraph 9.2.2 " Complete Joint Penetration R e quire d. " "When no depth of groove preparation or effectiv.,
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throat is shown c= the welding symbol for single-groove and symmetrical double-groove welds, complete joint penetration is required. "
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Symbol provided on " Detail" for weld (s) in ques tion.
. :..v PG and E has stated in their lette,r, DCL-84-040, "The weld symbols used at Diablo Canyon are consistent with the standards specified in A WS... " and in an Interoffice Memorandum (file no. 930, 146.20, CA2) dated October 25, 1983 that "all pipe support as-builts issued by General Construction after October 15, 1983 s hould have a_11 1
weld symbols in contorn ce with AWS A2. 4. "
The welds in question were incorrectly performed because of lack of proper interpretation of the weld symbol utilized on the design drawing.
It is the concern of this particular anonymous witness that this discrepancy provided an exarnple of code compliance violation due to a lack of intimate knowledge with AWS A2.4. These particular welds had been inspected and accepted by Pullman Quality Control and PG and E Ouality Control prior to the discrepancy being identified by a Pre-Inspection Engineer.
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I have read the above eight pnge statement. I have based the information contained therein either on personal knowledge or by reviewing the relevant information with the particular witness involved. This statement is true, correct and complete to the best of my knowledge and belief.
I declare under penalty of pe-jtry that the foregoing is true and correct, and that the.same was executed this 17th day of Apyi',1984 at San Iris Obispo, California.
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N. j RIQiGD D. PARKS, pelarant SIATE OF CAI.LWIA
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CDILTl OF SAN IEI.S 031SPO )
On April 17, 1934, before me, the undersigned, a Notary Public in for said State, pe-sonally appeared RIORRD D. PARKS, personally k:nm to me and proved to me on the basis of satisfactory evidence to be the person dese rae is subscribed to the within instncent, and that he emcuted the same.
WITESS rry hand and official seal.
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1:50 MARIA LANE,sulTE 210 4[
CALNLTT C;:EEK,CALIFCI.NI A 945a6 Goooo JUN 121984
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Docket Nos.
0-275 and 50-323
~
1 Pacific Gas and Electric Company 77 Beale Street, Room 1435 San Francisco, California 94106 Attention:
Mr. J. O. Schuyler, Vice President Nuclear Power Generation Gentlemen:
Subject:
NRC Inspection of Diablo Canyon Units Nos. I and 2 This refers to the special inspection conducted by Mr. G. H. Hernandez of this office on May 14-23, 1984, of activities authorized by NRC License No. DPR-76 and Construction Permit No. CPPR-69.
Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
No items of noncompliance with NRC requirements were identified within the scope of this inspection.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written applic'ation to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).
k (/rG-M b u
hb Martin Exhibit 16
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JUN 14 im Pacific G3s cod Elsetric i Shruld y:u h,v2 cny qu;stiens c:ncarning this ine,pectica, w2 eill br gled to discuss them with you.
Sincerely,
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T. W. Bishop, Director Division of Reactor Safety and Projects
Enclosure:
~
Inspection Report Nos. 50-275/84-20 50-323/84-09 cc w/ enclosure:
P. A. Crane, PG&E W. A. Rayond, PG&E S. M. Skidmore, PG&E R. C. Thornberry, PG&E cc w/o encl:
Sandra Silver bec: RSB/Docunent Control Desk (RIDS)
Distributed by RV:
JBM State of California Resident Inspector G Her ez:dh P.J son D.Ki ch T.Bi op 6/ ff /84 6// / /84 6/// /84 6//f/84 e
e ep am e@eeup 44 4 ee e e e emee ee e
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U.. S. NUCLEAR REGULATORY COMMISSION REGION V Report Nos.
50-275/8:4-20 and 50-323/84-Of Docket Nos.
50-275 amd 50-323 License No.
- DPR-76 Construction Permit No.
CPPR-69 Licensee:
Pacific Cas and Electric Company 77 Beale Street, Room 1435 San Francisco, California 94106 Facility Name:
Diablo Canyon Units 1 and 2
- Inspection at:
Diablo Canyon Site, San Luis Obispo County, California Inspection conducted:
May 14-23, 1984 Inspectors:
W /4:<
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. Hernandez, Proj@ Inspector Date Signed Approved By:
6/
M. Kirs W Chief IIat( Signed Reactor Projects Branch Summary:
Inspection During the Period of May 14-23, 1984 Areas Inspected: A special, unannounced inspection by a regional-based inspector to assess alleged deficiencies identified by three allegers.
Three anonymous allegers had identified seven alleged hardware deficiencies during a NRC conducted plant tour on April 11, 1984.
The inspection involved 59 inspection-hours by one NRC inspector.
Results: No items of noncompliance or deviations were identified.
1 7 d tw / #D D MvDI D -
l DETAILS 1.
Individuals Contacted a.
Pacific Gas and Electric Company (PG&E)
J. B. Boch, Project Manager M. R. Tressler, Assistant Project Engineer R. R. Lieber, Field Construction Manager D. A. Rockwell, Project Field Engineer M. E. Leppke, Mechanical Engineer J. Arnold, Resident Mechanical Engineer b.
Bechtel Power Corporation (Bechtel)
P. F. Mason, Special Project Engineer c.
Pullman Power Products Corporation (PPP)
H. W. Karner, Quality Assurance / Quality Control Manager d.
Others Anonymous Allegers A, B and C R. Parks, Volunteer Investigator for the Government Accountability Project (GAP)
===2.
Background===
~
As a result of NRC: Region V participation in interviews with anonymous allegers during April 1984, in San Luis Obispo, California, three allegers offered to identify specific hardware deficiencies in the plant.
A plant tour was arranged to allow these allegers the opportunity to point out deficiencies which they believed existed at the Diablo Canyon site. The seven items identified during the plant tour of April 11, 1984, and the NRC findings are addressed in paragraph 3.
Additionally, the inspector reviewed the licensee's response to these items as documented in their letters to the NRC dated May 2, 1984 (PG&E letter No. DCL-84-170) and June 1, 1984 (PG&E letter No. DCL-84-200).
3.
Details a.
NRC Tag No.1/ Allegation No. 344:
The concern was expressed that the catwalk support channel and associated fishplates in Unit 1, Platform No. 77G, Elevation 163',
located adjacent to Steam Generator No. 1-4 is in the wrong place and is not in accordance with the design drawings.
NRC Finding:
The inspector examined the catwalk support and the asso'ciated fishplates and found the support is installed in accordance with the i
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design drcwings (Drcwics Ns. 6181-C1-13380, Rsvisica5,D2 tail 380A$
dated 11/5/83).
No violations or deviations were identified.
b.
NRC Tag No.2/A11egation No. 345:
s The concern was expressed that the area adjacent to weld No. 157 on the Unit 1 Safety Injection Accumulator line (PG&E Designation No. 1-S6-254-10) to the cold leg line contained a grinding gouge and two areas of undercut on the weld.
~
NRC Finding:
The staff examined licensee documentation generated both prior to the plant tour and subsequent to the tour. This documentation included: the results of design minimum wall thickness calculations, the results of depth measurements performed on the alleged grinding gouge, inspector certifications and surface visual examination records. These records appeared to be in order and acceptable.
Subsequent to the tour, the subject veld was inspected by two licensee Welding Engineers, who are Certified Welding Inspectors, and who measured the depth of the grinding mark.
The results of the licensee's evaluations are contained in letter No. DCL-84-170, dated i
May 2, 1984. Subtraction of the measured grinding mark depth from the worst case wall thickness results in a remaining wall thickness in excess The rationale for the licensee',of minimum wall requirements.
s calculations and conclusions was examined by the staff.
Based.upon these examinations, the staff concludes that the alleged discrepancy does not represent a violation of the code or licensee procedures.
Additionally, the licensee's Certified Weld Inspectors found that the alleged undercut was an area wherein the weld crown and the base material had not been fully blended when the weld was prepared for j
Preservice Inspection. Thus, the alleged undercut was not really undercut at all and does not violate any code or regulatory requirements. The inspectors observations during the tour are consistent with the licensee's findings.
No violations or deviations were identified.
c.
NRC Tag No.3/A11egation No.346:
The concern was erpressed that a support in Unit No.1, Platform No. 65F, elevation 125', near Reactor Coolant Pump No.1-1 was welded to a wide flange beam with an obtuse angle that is in excess of that allowed for fillet welds and the welding procedur(..
NRC Finding:
~~
The inspector examined the applicable drawings (Drawing Nos. 6181-CI-1337, Detail 2, Revision 3 and 6181-CI-1338, Detail 2,
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Ravioica 3, bsth dated 6/23/83) cod datermined that th2 w Id in questicn is o groova wald eith a backing bar, as fcund during the
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April"11, 1984, plcat teur c d es it exists ted:y. Therefera, fillet veld angle restrictions are not applicable because the wel,d in question is a groove weld. Additionally, the weld was found to conform to the H. P. Foley welding procedure and the applicable code.
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'.s No violations or deviations were identified.
d.
NRC Tag No.4/A11egation No. 347:
The concern was expressed that the stainless steel line on pipe i
support No. 97-3R (Unit No.2) has such excessive overvelding that j
. shrinkage or deformation has occurred at the weld areas. This j
overwelding was alleged to cause damage to the pipe due to a failure i
of the stress calculations to consider the residual effects of overwelding.
NRC Finding:
The inspector found that the licensee had already censidered this issue on a generic basis and had provided acceptance criteria to 4
their engineering staff.
The licensee's acceptance criteria are based on NUREG/CR-0371 entitled, " Stress Indices for Girth Welded Joints, including Radial Weld Shrinkage, Mismatch and Tapered Wall Transitions," by E. C. Radabaugh, S. E. Moore, dated September 1978.
These criteria are provided to their engineering staff for resolving identified cases of pipe concavity which appear excessive.
The licensee evaluated this particular support and found it met their acceptance criteria. On May 22, 1984, the inspector observed and verified licensee measurements and determined that the pipe (on pipe support No. 97-3R) met the aforementioned acceptance criteria.
l The staff concludes that the licensee does consider the effect of overwelding, does perform calculations to assure that the pipe can
~
perform as intended, and that the existing pipe concavity (deformation) does not violate code requirements.
No violations or deviations were identified.
e.
NRC Tag No. 5/ Allegation No. 348 The concern was erpressed that the Bostrom-Bergen fabricated rupture restraint beneath the Unit 2 Pressurizer contains welds that are
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excessively rough and of such a profile that the welds would not conform to AVS D1.1.
NRC Finding:
The staff found that the licensee had previously considered these types of welds on a generic basis and provided for a revised acceptance criteria, as allowed by the AWS D1.1 Structural Welding i
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Cada (paragraph 3.7.4).
Th2 licensee determined that these walds w2uld parform tha dzsign functisn.
i The extent of the licensee's examinations of Bostroe-Bergen shop
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welds, are detailed in letters DCL-84-114,- DCL-84-119, and i
DCL-84-200, dated March 23, 1984, March 27, 1984,,and June 1, 1984,
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respectively.
The inspector examined the results of the licensee's
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considerations and concluded that the licensee's analysis of these types of welds appears to be reasonable and responsible. The
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inspector reviewed the calculations performed on these typical 1
supports and found them acceptable.
1 No violations or deviations were identified.
i f.
NRC Tag No. 6/A11egation No. 349 The concern was erpressed that overwelding on pipe support lugs (Unit No. 2 pipe support No.50-26V) has caused excessive shrinkage l
(deformation) to the pipe. This excessive shrinkage, the accompanying residual stresses, and the eccentric loads were alleged not to be considered in the stress calculations.
NRC Finding:
The inspector found that the licensee had already considered this issue on a generic basis. Refer to the NRC finding of paragraph 3.d, above.
For pipe support No.50-26V, the licensee determined that their acceptance criteria, as based upon NUREG/CR-0371, had not been exceeded.
On May 22, 1984, the staff verified the licensee's measurements, reviewed the stress analysis calculations, and determined that the pipe (on pipe support No.50-26V) met the licensee acceptance criteria.
The staff concludes that the licensee does consider the effect of 4
l overvelding, does perform calculations to assure that the pipe can i
perform as intended by the designer, and that the existing pipe concavity (deformation) does not violate code requirements.
l No violations or deviations were identified.
g.
NRC Tag No. 7/A11egation No.350:
Je, The concern was erpressed that the eight lug attachment welds for two Unit No. 2 pipe supports Nos. 413-131R and 24-1)R, were required to be full penetration welds on three sides by the design drawings.
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H cw2 var, the octual walds ecra cat full pacetratien walds but isnstecd cre fillst walds, centrary to design requirements.
NIRC Finding:
M e inspector concurs with the alleger that the eight logs are actached by fillet welds instead of the design specified full prenetration welds (from three sides). However, during the tour w~ith tihe allegers on April 11, 1984, the allegers were asked to make note
- t. hat a " hold tag" was in place on both of the referenced pipe stupports describing the exact situation noted above. The existence o>f the hold tag indicates that the licensee's quality program was flunctioning and had detected this discrepancy.
Nio violations or deviations were identified.
4.
Concluzzion The inspector concludes that none of the seven items identified by the allegers, described above, constituted a violation of a code or regulatory requirements.
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j Supplement No. 22 Safety Evaluation Report jl.j related to the operation of 1,i Diablo Canyon Nuclear Power Plant, N1 Units 1 and 2
.I F, '-
Docket Nos. 50-275 and 50-323
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Pacific Gas and Electric Company GC!
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U.S. Nuclear Regulatory
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Commission s
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Office of Nuclear Reactor Regulation z.+ -'
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March 1984 s-gi
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Task:
Allegation or Concern Nos. 103, 104, 105, 106, 107, 108, 109, 110,
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111, 112, 113, 114, 115, 116, 117, 118, 119, 214, 215, 216, and 217 ATS No:
RV-83-A-0074 BN No:
84-009(1/16/84)
Characterization Multiple allegations associated with a failure of the licensee and Pullman Power Products to meet required codes and standards for welding pipe supports and pipe whip restraints.
Implied Sionificance to Design, Construction or Operation The failure to meet stated codes and standards in the fabrication of pipe supports and pipe whip restraints may result in components which would not perform their intended safety function.
Assessment of Safety Significance The allegations or concerns discussed in this section were received in the form of a 35 page letter from the alleger to a NRC Commissioner.
Attached to the letter were numerous documents provided to support the allegers concerns.
The staff's general approach to address these concerns was to interview the alleger, examine the contractors ana licensee's written requirements, examine pertinentprocedures, documentation,andtoconductinterviewsw[thpersonnel, as appropriate.
A.4-103.1 m
The alleger's written submittal and interview included multiple cross
~
referencing of issues.
The staff did not examine every example of each type of issue individually, but instead focused on the substantive technical and quality concerns by grouped topics. Many of the issues were topics which had been formally documented and addressed by the licensees and contractor's
~
~
control programs.
Th'e staff directed special attention to where the licensee and contractors addressed these items in a responsible manner. The staff has placed the issues into 21 topics. These are discussed individually below.
1.
Allegations 103, 104 and 105:
Pullman Welding Procedure Specification (WPS) 7/8 was inappropriately applied in that deviations from'WPS 7/8 existed in the following areas:
(a) structural shapes, (b) weld joint geometry, (c) materials Staff Position (a) The alleger is correct that WPS 7/8 was used to weld structural shapes in addition to piping and plate as specified in the WPS.
However, the structural shape of the member is not required to be included in the WPS.
All structural shapes, such as W, H beams and angle iron, shall have the connecting sections prepared to conform to the weld joint configuration of the qualified WPS. The structural shapes are identified on the design drawings.
A.4-103.2
procedures that ware not qualified and/or did not provide weldina
~
i specifications for the base metals, structural steel shapes, and c
a joint configuration was used.
These deviations have spanned the whole construction program for both pipe supports and pipe rupture restraints and includes what I call the current design modification program which I believe is the result of the i
redesign engineering program on pipe supports.
I do not believe i
that there is any' authorization from PG&E to deviate from these weld procedure specifications.
Also, weld procedure specifications have been prepared and used by Pullman and approved by PG&E that were not properly cualified for the AWS code as required, by Contract Specification 8833XR.
This issue deals mainly with pipe rupture restraints., Additional welding has been performed which did not comply with the we'ld procedure codes, processes specified on process sheets, and approved by the proper authorities.
It is my feeling, my allegation, that Pullman QC management has attempted to justify and/or coverup this breach of quality assurance by implying that production had the authority to disregard these process sheet instructions.
The last issue is there have been deviations from PG&E's contract specification 8711 and 8833XR, welding requirements for which there are no PG&E contract specification change notices and/or proper management authorization.
Now the term ' contract specification change notice' is my term.
I am not sure what terminology PG&E would use to indicate revisions to their contract specifications.
The most immediate and most pressing problem I feel is Weld Procedure Code 7-8.
That is Pullman's
~
Hudson /1~6 4 Kirsch Exhibit 4
t ASME quality cssurance program recuirements were virtually identical to those c'ontained in 10 CFR 50 Apoendix B.
HUDSON:
So the distinction would be almost linguistic.
KIRSCH:
That was my impression.
My feeling is Pullman has violated 5 or 6 sections of auality assurance recuirements in the contract specifications and probably as many of 10 CFR 50 Appendix B.
These violations that I feel have been pertinent are referenced in the report.
Any cuestions over this point or shall we move on to the next areas?
If this KIRSCH:
I might ask you a general Question.
fabrication was in accor' dance with NF instead of specifications that they used, would you feel all of these guestions would be the same?
HUDSON:
You say NF, are you ref erring to the ASME Code?,
Well, ASME has no bearing here, in my opinion.
Pipe rupture restraints have to conform to the AWS code.
It is also my contention that strucural steel pine supports have to comply with the AWS code.
That is one of the allegations in this report.
That is the base of this problem.
They are using an ASME welding procedure, deviating from that welding procedure to weld structural steel items other than plate and these items should be i
welded to the AWS code.
The next item as far as report goes is I'd like to make some comments about the welding techniaue specification No. AWS 11, which is supposed to clarify the use of Code 7-8.
In my opinion it has a number of deficiciencies as listed in the report.
Hudson /1-6 18 l
HUDSON :
Well, these wolders'were all ASME cualified.
They waro qualified to Code 92-93.
They were ASME aualified.
??:
To an open butt?
HUDSON:
The Code 92-93 is an open butt procedure.
If they were qualified to 92-93 they should have been qualified f,or open 4
butt welding.
N ow, the problem here with rupture restraints using this Code 7-8 require a backing bar.
What they' ve done is they've brought in welders qualified for one procedure to weld supposedly to another procedure, but they're using Code 92-93 in lieu of the required Code 7-8.
Now, what concerns me is that these guys are probably qualified for open butt, cualified for GTA pr'ocess, but those items are not. rupture restraint welding processes'.
So, we have a break down in the cuality assurance, quality control item here.
Now, the difficulty in this particular identification, if you look at the process sheets, the process sheets are going to say everything is welded to Code 7-8.
Now, I have not identified any particular rupture restraints or welds for this problem takes place because I did not have access to the rod requisition.
The rod' requisition is i
going to be the only way to identify where this Code 92-93 was used in the pipe rupture restraints.
The paperwork, all the 1
other paperwork says Code 7-8 was used.
The rod recuisitions, per this memo by the consistent OAOC Manager, identified the work being done as Code 92-93.
I'd like to make an allegation here I
that this letter by the Assistant QAQC Manager is an attempt to justify, I'll add coverup, a serious breach in the cuality assurance program for this welding procedure.
Again;- that's an Hudson /1-6 54 1
Nuclear Regulatory Commission
, April 12, 1984 Page 5 until after the March 19, 1984 Commission meeting:
inaccurate Operation Valve Identification Diagrams (OVID) for use by the reactor operators, which include such serious discrepancies as valves on the wrong side of other components.
(March I petition,
- p. 42).
This problem is particularly significant, since there is no
. dissent within the Commission that reactor operators should "know the plant cold."
(March 27 transcript at 213, statement of Chairman Palladino).
a generic breakdown in design control through the quick fix program, in which major design changes were approved on-the-spot to accommodate construction plans, without normal engineering review and supporting analysis.
(March I petition, pp. 19-21).
pressure by the Bechtel Corporation that employees who resigned should sign a statement that they were not aware of any design, pro-fessional code, or quality assurance violations -- despite common knowledge to the contrary.
This left honest employees in an illegal
" Catch-22" at a critical period: either they could lie to the Govern-ment or risk industry blacklisting.
(March I petition, p. 41).
knowingly false statements in licensee responses to previous employee allegations, illustrated by PG&E's February 7 assertion to the NRC that the lack of consistent weld symbols to guide personnel had no safety significance.
(March I petition, p. 28).
Instead of investiga-ting this new " wrinkle," the staff accepted at face value the licensee's
. alleged false statement as a basis to " resolve" the original weld symbols issue.
- December 28, 1983 procedural changes that denied inspectors the ability to reject welding on pipe supports, even when a weld that was required by the design did not even exist.
(March I petition, p, 6).
The March 23 disclosure also contained more than mere " wrinkles."
For example, one affidavit revealed a continuing " mirror image" problem with electrical installations by the Foley Corporation.
In January 1983, super-visors called an employees meeting to try to resolve the issue.
Unfortunately, the meeting broke up when the supervisors could not agree among themselves what was forward and what was backward.
(March 23 disclosure, - Attachment 12, p. 4).
~
4 Follow-up interviews.
. The staff has made a mockery of its written policy and verbal commitments that allegations would no.t be closed out without follow-up interviews to insure accurate resolution of the issues.
The staff also misled the Commission on this issue.
To illustrate, on March 27 Mr. Martin said that it was "just not a true statement" that Region V had failed to schedule follow-up interviews.
He referred to Region V's communications with Mr. Hudson, Pullman's former internai auditor:
Kirsch Dchibit 5 j
intimidation cnd harcssment type thing.
The came plan out there
~
seems to be to keep the inspector overworked.
We work 60 to 70 4
hours a week.
Up until recently, when we renegotiated our contract, and we still aren't being paid this yet, but we were j
being paid very low compared to the other craf ts out there, and compared to our level of responsibility, you' ve got, you' re I
signing ~ permanent plant-lif e documentation out there, and there's the guy sweeping the floor making more money than you are.
Which is, you know, just kind of hard to swallow.
In some cases, it's justified.
i l
KIRSH: 'Well, there's not a lot that I can do about that.
i O' NE ILL :
Well, we already took care of that, somewhat.
You know, overworked, you get f atigued, you' re always told, I' ve been told I don' t know how many weekends now, you' re going to work i
Saturday and Sunday.
I told them well, I don' t really want~ to work Sunday.
Well, if you don' t, you could be subject to termination.
That's routine out there.
The inspector is always, under Connor's program, is generally not encouraged to find out what specs and codes he's supposed to be working to.
You' ve got supervisors that are telling you that if it's not addressed in the ESDs which are our specs, that you are not to look any further.
You are to just buy it because it's not addressed in the ESD.
S teve's addressed that, one certain individual is more blatant about that anyone else.
LOCKE RT :
He told me specifically that I could not look in the AISC Construction Manual, the ANSE' ASTM Standards' or the ASME code.
I was not to look at anything beyond the ESD.
Let's see if I can find that for you.
October 17th incident pretty much...
NRC-1 / l-5 3 3 Kirsch Exhibit 6 l
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KI RSH:
That's cn understctement.
I still haven' t digested
~
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~
all of this.
O ' NE ILL :
It's tough.
Especially f rom a non-technical standpoint, it's hard to really latch on to...
??:
The immense transf er of information, you can' t really digest it all in a short amount of time.
O' NE ILL :
What we were mostly concerned with were the events leading up to Steve's, you know, mostly I'm substantiate what he's here to tell you.
KIRSH:
Why don' t you kill it because I just want to read here for a minute and make sure that I understand what's in the letter.
CLEWETT :
I got plenty of tape, unless...
'~~~
KIRSH:
October 4th, you say, you reauested the spec penetration while attaching the stanchions of a pipe, you found a cover plate was on the clean end of the stanchion and you asked them to move it, and they didn' t remove it.
Where was this at, what stanchion, roughly?
LOCKE FT :
It was in Unit 2, I believe, probably the 91 level.
KIRSH:
Is this in your log also?
LOCKE FC:
Yeah, there's a note in there, saying, Russ Nolte i
l prevented me for taking the cover plate of f.
KI RSH :
And it tells what stanchion was?
LOCKE RT :
Yeah, it would be in my daily log.
KIRSH:
Daily log, I should be able to pick thatup.
NRC-1 / l-5 -8 4 - 5 8
LOCKERT :
Yeah, tharo will be a little note saying Ruse Nolte prev.ented me f rom taking the cover plate of f.
Well, Tim, before we go, we probably ought to fill them in on each one, or have you already?
I'm not saying we should leave right now, but before we come to a conclusion.
CLEWETT:
We' re not quite half done with the available tape so if you have as much again as you' ve talked about already...
1 LOCKE RT :
Tim here is a pretty deep well when it comes to welding.
We' ve spent many a night talking about our jobs.
O'NEILL:
The nuts and bolts out there on the things that work, the containment liner studs.
J have another package here, this is a snubber on a f eedwater line and it's a design class 1,,
code class E line, it's out on the pipe rack.
The way I got involved with this was it was reissued because they had to swap the snubbers, they took a snubber off of one location where they needed a matched set and they took the snubber that was at this location and moved it over there and moved that snubber over here.
And they had to go back out and read ' as built' on the drawing, the pin to pin dimension of the snubber and the snubber serial number.
Well, when the as builder went out there, you know what an as builder is and all that, when he walked out there, he looked at it and conceded the welding on the plate was obviously deficient.
So it got to me throuch our department through my lead at the time, and he said go out and write a DCN on this because they didn't as built this BR4678 right here, which only addresses the oversize wells / it doesn' t ad' dress the undersize wells on this thing.
Okay, this is all disoositioned N RC-1 / l-5 -8 4 - 5 9
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