IR 05000341/1980013

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IE Investigation Rept 50-341/80-13 on 800728-31.No Noncompliance Noted.Major Areas Inspected:Allegations Re Improper Pipe & Structural Steel Welding QC
ML19340D639
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 10/14/1980
From: Danielson D, Foster J, Norelius C, Ward K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19340D637 List:
References
50-341-80-13, NUDOCS 8012310518
Download: ML19340D639 (25)


Text

o U.S. NUCLEAR REGULATORY COMMISSION

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OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-341/80-13 Docket No. 50-341 License No. CPPR-87 Licensee: Detroit Edison Company 200 Second Avenue Detroit, MI 48266 Facility Name:

Enrico Fermi Nuclear Station Unit 2 Investigation At: Fermi Site, Monroe, MI Investigation Conducted: July 28-31, 1980 Investigator:

J. E. Foster k

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MAM j _/ gQ K. D. k'ard (d ej f 8.'[)(tde Reviewed By:

C. E. Norelius f e//([Fc Assistant to the Director (date)

D. H. Danielson, Chie %

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Engineering Support Section II (date)

Investigation Summary Investigation on July 28-31, 1980 (Report No. 50-341/80-13)

Areas Investigated:

Unannounced investigation of allegations concerning improper pipe and structural steel welding quality control, improper disposition of identified nonconformances; review of pertinent records, interviews of personnel and inspections of installed equipment. The investigation involved 40 investigation-hours by two NRC personnel.

Results: No items of noucompliance or deviations were identified.

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REASON FOR INVESTIGATION

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On June 27, 1980, two former workers from the Fermi Unit 2 site contacted an NRC Inspector performint sonstruction inspection <. at another nuclear power plant site.

These irc".viduals expressed concerns regarding the Quality Control program at the Fermi 2 site. On the basis of the expressed concerns, an NRC investigation was initiated.

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j SUMMARY OF FACTS Following initial contact with the two individuals on June 27, 1980, addi-l tional contacts were made on June 30, 1980 and the two individuals were interviewed on July 11, 1980. Both individuals indicated they had been

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j employed as Quality Control Inspectors by the firm of Daniels International l

at Fermi 2 and had left that site in approximately February, 1980. Each j

individual expressed concerns regarding the Quality Control Program being

exercised at the Fermi 2 site, regarding areas within their purview as j

Quality Control Inspectors.

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Based upon discussions with the two individuals, their concerns were identi-fied to be the following:

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1.

Pipe weld surface grinding is not controlled and surface examinations do not meet Code requirements.

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2.

Design Change Notice and Design Change Request tracking is deficient.

3.

Vendor shop welds on structural steel are seriously deficient.

4.

Submerged arc welding was utilized on structural steel, although drawings did not call for this type of weld.

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Some structural steel welds were performed without a required backing bar.

6.

Inspections of structural steel weldments were performed without removing paint covering the welds.

7.

Many identified nonconformances have been improperly dispositioned as

" accept-as-is".

8.

Defects in flued head anchors were improperly dispositioned as " repair

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what you can see".

9.

Some structural steel plates contain laminations.

10.

Temporary attachments in the torus are poorly controlled.

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The investigation conducted at the Fermi Unit 2 site during July 28 thru 31, l

1980, consisted of a review of drawings, nonconformance reports and other

documents related to the allegations, interviews of contractor and utility

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personnel, and inspections of components installed in the Fermi 2 plant.

This investigation revealed that all of the problems described by the two individuals had,been identified and documented as nonconformances. The

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individuals themselves had been the primary inspectors performing the

inspections and writing the nonconformance reports involved. Their primary

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concern was evidently the disposition of the nonconforming items which they had documented on their reports.

i The dispositions contained on the nonconformance reports pertaining to the i

allegations were reviewed and in all cases the dispositions of these non-conformances were considered to be appropriate.

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A review of previous NRC inspection reports indicated that the majority of

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the nonconformances had been identified or reinspection work had been initi-

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ated based on items observed during NRC inspections.

No items of noncompliance with NRC requirements were identified during this

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DETAILS

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1.

Personnel Contacted Detroit Edison Company

  • E. Hines;. Assistant Vice President and Manager, Qaulity Assurance
  • T.

A. Alessi, Director Quality Assurance

  • W.

M. Everett, Project Superintendent

  • H. A. Walker, Site Project QA Engineer
  • W. J. Fahrner, Project Manager J. R. Mullens, QA Engineer G. Carter, QA Engineer R. A. Bryer, Principal Engineer, Architectural-Civil Daniel International Corporation
  • R. E. McCraney, QC Supervirn!
  • J. Rotundo, Project Quality Engineer E. Thompson, Lead QA Engineer
  • D. Ferguson, Project Manager, Fermi 2 Walbridge-Aldinger Company D. Webber Wismer and Becker T. Bruno B. Abbott J. Flaherty
  • Denotes those present at exit interview.

2.

Introduction The Fermi Unit 2 Nuclear Power Station, licensed to Detroit Edison Company, is under construction at a location near Monroe, Michigan.

The facility, a Boiling Water Reactor with a nuclear steam system provide by General Electric, is designed to provide 1150 megawatts l

of electricity. The architect-engineer end constructor is Daniel

International Corporation.

The allegers, Individuals A and B, indicated that they had been employed as Quality Control inspectors for the firm of Daniel International Corporation (Daniel) at the Fermi 2 site.

Individual A indicated he had worked on site from August 1979 to February 1980, and Individual B indicated that he had been an inspector at the plant for approximately 3 years and had left the site in approximately February 1980.

Both individuals stated they were welding nondestructive examination inspectors with a level 2 rating in several inspection fields.

Both had reported to Daniel personnel in the Quality Control program.

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3.

Background Information

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A number of the items discussed in the Findings Section of this report

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were identified during KRC inspections performed previous to the receipt j

of the concerns of the two individuals.

Included among those items noted j

as being in NRC inspection reports are the following:

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a.

Structural steel welding deficiencies were reported in IE Inspection No. 78-11.

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b.

Pipe whip restraint welding problems were reported in IE Report

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No. 79-03.

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c.

Welding problems with flued head anchors were reported in IE l

Inspection Report No. 79-03.

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d.

Vendor welding deficiencies were reported in IE Inspection Report

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No. 79-14.

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e.

Plate lamination problems were reported in IE Inspection Report No. 79-14.

f.

Tracking of Design Change Requests and Design Change Notices (DCN)

were reported in IE Inspection Report No. 79-17.

g.

Steam tunnel pipe whip restraints problems were reported in IE

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Inspection Report No. 79-18.

h.

Tracking of DCRs and DCNs were reported in IE Inspection Report

No. 80-01.

j As a result of a review of the site quality control organization, a new

organization was implemented by the licensee at the Fermi 2 site in early l

1980. This new organization took over many of the responsibilities and j

inspections formerly assigned to Daniel Personnel. This new quality con-i trol organization was described in IE Inspection Reports No. 80-04, 80-06.

4.

Allegations and Findings

Allegation 1:

Pipe weld surface grinding is not controlled, and

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i surface examinations do not meet code requirements.

Individual A stated that grinding was being performed on pipe weld

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crowns, without benefit of weId traveler or QC inspection, and that i

j these welds were not being nondestructively examined upon completion.

He stated that in some cases clamp-on attachments would be placed over some of these welds, making them inaccessible during inservice

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or preservice inspection.

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j Finding;

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l Individuals A and B provided a number of copies of site documents

which related to their concerns, including that of grinding on weld crowns. These documents were compared with documents in the site

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, files and found to be identical.

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Site proce'dures were reviewed for final weld grinding finishing, non-

destructive examination, and control of clamp-on hanger attachments.

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It was found that weld finish grinding was performed under standard

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procedures for welding and documented on veld travelers. By instruc-tion from Daniel, inspections were being performed to ascertain that weld configuration was that necessary for the preservice inspection.

i In those cases where welds did not meet the preservice configuration, additional grinding was indicated and the procedure called for addi-I tional surface nondestructive examination to assure that such grinding had not produced any nonconforming conditions.

Procedures for grinding of welds to allow clamp-on attachments were i

also reviewed. Weismer and Becker General Procedure, WB-C-131, Revision 1, dated July 10, 1980, which is the present procedure being

utilized at the site, was reviewed. This procedure pertains only to j

carbon steel welds and is not applicable to welds requiring in-service inspection or to General Electric supplied items.

(see Exhibit 1).

The review of the procedure indicated that it was acceptable. Also reviewed during this effort was DCN No. 1756, dated March 19, 1979, a copy of which had been provided by Individual A.

Individual A had

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expressed concern that although liquid penetrant or magnetic particle

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inspection was required by this DCN, it was not being performed in the field.

It was noted that DCN 1756 has a note which indicates that this weld grinding is not to be performed on stainless steel welds or dissimilar welds as noted in the Wismer and Becker procedure previously described.

t DCR P1967 was found to relate to DCN 1756. DCR P1967 provides for

ultrasonic testing of the weld after grinding is complete to verify its integrity and that minimum wall thicknesses have not been violated.

The grinding was to be done in accordance with General Electric pro-cedure GWP-1000.

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No items of noncompliance with NRC requirements were identified.

Allegation 2: Design Change Notice and Design Change Request tracking is deficient.

Individual A stated that while researching document control he had observed a computer printout of open and closed DCRs and DCNs. During his review he noted that there were descrepancies in the tracking of many of these documents and some DCRs and DCNs contained on a computer sheet were not identified on a written tracking system.

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Finding: Deficiencies in the tracking of Design Change Requests and

i Design Change Notices was observed during an NRC inspection reported in

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j IE Inspection Report No. 79-17, with additional followup in IE Inspection

Report No. 80-01.

NRC personnel have been tracking the licensee's efforts to rectify the nonconformances observed.

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As this deficiency had been previously identified, no additional in-

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vestigative effort was undertaken in regard to this concern.

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Allegation 3: Vendor Shop Welds on structural steel are seriously deficient.

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Individual B stated that there are many deficiencies in the welding of

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j structural steel located in the plant drywell.

He stated that these j

deficiencies were nonconformances with the American Welding Society structural welding code (AWS D1.1) and had been identified by visual

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inspection. He indicated that an inspection of structural steel located between the reactor sacrificial shield and the drywell would reveal numerous deficiencies in structural steel welding.

l Finding: Deficiencies in structural steel, and other vendor supplied components, were identified in IE Inspection Report No. 79-14.

On the basis of these findings, the licensee had initiated a program to re-

inspect all vendor supplied structural steel welding.

A review of site nonconformance reports indicated a large number of j

nonconformances had been documented on structural steel welding on the i

basis of the reinspection effort. A large number of the reinspections

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had been performed and documented by individual B.

Site DDRs, the majority generated by Individual B, were reviewed by P.III personnel.

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Among those documents reviewed were the following:

i DDR W4317 dated 3/3/80

DDR W3445 dated 10/14/79

DDR W4094 dated 1/17/80 DDR W4165 dated 1/31/80

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l DDR W4212 dated 2/14/80

DDR W3760 dated 11/13/79.

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Disposition of these nonconformance reports was reviewed and, as detailed in Allegation No. 7, they were found to be acceptable.

i No items of noncompliance with NRC requirements were identified.

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l Allegation 4:

Submerged are welding was utilized on structural steel,

although drawings dia not call for this type of weld.

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Individual B stated that he had identified occasions where the draw-l ings would call for one type of weld and another type of weld would l

be visually observed in the field. He stated that on these occasions

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it was apparent that submerged are welding had been utilized. He

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indicated he had discussed this concern with a Detroit Edison Quality

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Assurance Engineer.

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Finding:

This information was discussed with Daniel International

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representatives, and with the Detroit Edison Quality Assurance Engineer

with whom Individual B had indicated he had discussed his concern.

i The Detroit Edison Quality Assurance Engineer verified that this concern had been discussed with Individual B.

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A review of site documentation indicated that a request for Clarifica-tion of Information, (RCI) Request No. D-001, dated in January 24, 1980, pertained to this concern.

RCI D-001 indicates that on some of the t

j drawing blueprints the welding symbols shown on the drywell framing

prints indicate the shop should be SMAW (Shicided metal arc welding).

The Inland Ryerson shop fabricated parts received on site and installed

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appeared to be fabricated by the SAW (submerged are welding) process.

(see Exhibit II).

The request for clarification indicates that use of submerged arc welding is acceptable and that, since the applicable specification

permits the use of submerged are welding, there was no need to write

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a DCN to document the use of the submerged are welding procedure.

I No items of noncompliance with NRC requirements were identified.

I Allegation 5:

Some structural steel welds were performed without required backing bar.

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Individual B indicated that en some occasions he had identified that

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i a backing bar required for the welding procedure utilized was not j

present, and this could be identified in the field by visual inspection.

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Finding:

NRC discussed this concern with Detroit Edison Quality Assurance personnel, and found that this concern had been discussed

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with Individual B.

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l A review of the welding procedure utilized indicated that a backing bar would be required to perform the weld. The procedure could not be utilized to perform the initial weld unless this backing bar was present

because of the type of welding procedure utilized. However, af ter the initial weld was performed it would be permissible to remove the backing

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bar for repair of the weld, if indicated (possibly by backgouging). The removal of the backing bar would not constitute a nonconformance with the welding procedure.

No specific locations of welds lacking backing bars could be identified

during tours of the site.

No items of noncomplaince with NRC requirments were identified.

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Allegation 6:

Inspections of structural steel welds were perfromed

without removing paint covering the welds.

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Finding: A review of site documents indicated that a concern regarding the removal of paint and other coatings had been expressed by In!ividual A and forwarded to Detroit Edison through the Daniel Lead Welding /NDE Inspector during August 1979.

Detroit Edison provided a response to this conc 6rn on September 5, 1979, indicating that in the majority of cases the referenced structural steel could be visually inspected without removing the various coatings.

It was indicated that defects such as cracks and undercuts might require the removal of coatings in the specific area noted to determine if those defects were acceptable or rejectable.

A review of connection control sheets for the firm of Wallbridge-Aldinger, I

showed that in many cases grinding had been performed to remove paint j

from structural steel welds for the purpose of inspecting those welds.

Based upon a review of the technical significance of this position, and following inspection of structural steel welds on structural steel components in the Fermi Unit 2 plant, this procedure is acceptable.

No items of noncompliance with NRC requirements were identified.

i Allegation 7: Many identifed nonconformances have been improperly

dispositioned " accept-as-is".

Individual B indicated that in many instances welding defects, which

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were unacceptable to AWS DI.1 Code, had been dispositioned as accept-as-is.

He stated that in some instances observed defects involving lack of fusion of up to one inch in length had been accepted.

Finding: A review of site DDRs pertaining to structural steel welding inspections, performed by Individual B, indicated several instances where welding inspections had noted defects identified as " incomplete fusion", or " lack of fusion". For the majority of those conditions identified as nonconforming, the disposition had been to repair.

In a number of instances welds, which had a defect in an area of up to

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one inch, had been accepted on a use-as-is basis, based on the con-clusion that the defect did not significantly affect the strength of the welded connection.

DDRs on which such acceptances were found included Nos. W4165, W4904, ana W4212.

The disposition of these defects was discussed with site personnel.

They indicated that they had reviewed each nonconformance in the field with design engineer, and based their disposition upon this review and reinspection of the welds. One of the welds indicated as having lack of fusion and having been accepted, was selected and inspected in the field.

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l From the inspection of the weld noted as having incomplete fusion, it

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was concluded that the nomenclature used to identify the defect was

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incorrect. The noted defect in the field appeared to be more of a

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start of a new weld with the appearance of a fingernail buildup than

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lack of fusion.

The noted weld was on a beam and the configuration

, of the weld was such that the corners of the beam would be open in a

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any case.. The noted 'Mfect was considered as inconsequential, and

would have au) structural impact upon the structural steel.

Following a review and discussion with site inspection personnel, it I

was concluded that, in those instances where lack of fusion had been noted as a nonconforming condition, the use-as-is disposition was j

acceptable.

No items of noncompliance with Nhc requirements were identified.

Allegation 8: Defects in flued head anchors were improperly disposi-

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tianed as " repair what you can see".

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Individual B indicated that defects in the referenced anchors had been dispositioned on the above basis..

Finding:

Discussion with Daniel personnel indicated that there may at one time have been some discussion about dispositioning noncon-formances observed in flued head anchors on the above basis.

It was

stated that no documentation as to this proposed disposition had been generated, and no documentation that such a disposition was utilized

was found during the investigation.

Site documentation review showed that DDR No. 3152, dated July 23, 1979, consisting of 27 pages, indicated deviations noted on the flued head anchor structures had been reinspected per Detroit Edison request on Design Change Notice 2069.

This inspection had been performed by

Individual B.

i Review of DDR W3152 indicates that the disposition was to remove all

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defects by grinding or gouging as required.

Liquid penetrant examina-

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tion was to be perfor.ned after the defect had been removed.

The non-

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conforming area was then to be rewelded to meet the specifications of AWS DI.l.

All defects were to be reworked in accordance AWS DI.1.

i (Exhibit III).

Discussion with Daniel personnel indicated that some 26 flued head anchor bolts had been returned to vendor, and others had been repaired l

by Monroe welding.

  • l Reworked flued head anchors installed in the Fermi 2 plant were inspected during this investigation and no nonconformances were observed.

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No items of noncompliance with NRC requirements were identified.

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Allegation 9:

Some structural steel plates are laminated.

Finding: Discussion with site personnel indicated that during magnetic particle examination of other welding defects, apparent laminations cf plates, flange edges and box beams had been indicated by the testing.

Such indications were documented on DDRs W4611 and W3970-A, both of which were generated by Individual B.

The disposition shown on DDR 3970-A was to remove the indications by grinding to a depth not greater than 1 inch below the surface of the plate; inspect the resulting cavity; weld the cavity; and, inspect the repaired area. Disposition of DDR 4611 had been to weld repair the existing excavation and not excavate any further.

It was indicated that the slight lamination observed was in the column flange and did not adversely affect the member's performance.

Laminations observed on the plates were discussed with Daniel and Detroit Edison personnel.

Discussion indicated that laminations of the type observed are characteristic of the material supplied and are not an unusual occurrence. Magnetic particle examination is not specified in the procurement specifications for such plates, as it is known that these " defects" will be observed. The licensee's actions regarding these laminations are considered to be acceptable.

No items of nonconpliance with NRC requirements were identified.

Allegation 10: Temporary attachments in the torus are poorly controlled.

Individual A indicated that a number of temporary attachments had been placed in the drywell torus and, in at least one case, the attachment had been placed and then removed and no documentation had been generated to control the work.

Finding: Review of site documents indicated that DDRs 3396 and W3398 indicated temporary attachments had been placed on the sacrificial shield plate. These two DDRs had been generated by Individual B and indicates that the installing contractor was unknown.

Part of the disposition for these DDRs was that all contractors in drywell were to be advised of documentation, removal, and NDE requirements appearable to welded temporary attachments.

Repair of the two deficient areas were noted as being documented on connection control sheet (ces) packages No. 441 and No. 443.

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Discussion with site personnel indicated that on at least one occasion a temporary attachment had been placed, documented on a DDR, and removed before the DDR could be acted upon. The contractor who had removed the

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temporary installation was unknown.

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It was indicated that such occasions were rare, and that site procedures had been instituted to control temporary attachments.

Site procedures presently in force for controlling the attachments of temporary welds to support work ongoing in the torus and other areas of the plant were reveiwed and are considered acceptable.

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No items of noncompliance with NRC requirements were identified.

5.

Exit Interview An exit interview was held with representative of Detroit Edison and Daniels International Corporation on July 31, 1980. The allegations

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and the findings of the investigation were discussed.

Daniel representatives advised that they had deduced the identities of the two allegers and stated that they had been aware that these two individuals had concerns relative to inspections of welding at the plant site. They stated that they had discussed the concerns with these individuals and held a meeting with them to explain and clarify their concerns and the dispositions which had been enacted.

Licensee personnel indicated that they felt they had been forthright in dealing with the expressed concerns and were not aware of any other avenues that they could have pursued to alleviate them.

Licensee personnel indicated that a formal program had been initiated on the Fermi 2 site to provide a mechanism for inspectors to express concerns on an identified or anonymous basis and they were guaranteed a response in writing from cognizant personnel.

Attachments:

Exhibits I, II, III

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.4111 NUCLE AR PR OJECT

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CONST RUCTt GN :/. AN AGET.".ENT l

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P. O. BOX 109; MON ROE, MICHIG AN 4: 10-TO.

charles r.eller.

DAT~. Janucry 2, c;

Wismer & Eecker QC Manager OlC9-179

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Blixt Welding /Muchanical CC Eng;r.ccr

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Inservice Inspection Per CLCC Spec. 3171 'JE & 1;i.

In the next few weeks there w;.1 Le a suct.tcntial in case _:

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surface pre,raration and subscqucnt ul t ra s cr.; c ex;.r.i n a t ;,. cf ;r.;2rv;c inspectica ty_c welds pcr A5.

Sect;cn 11 and Edison pec. 3071-15 &

115 The.ccid surface ccr.c;;;cnc nay require ada; tion;.. grina;n,, alth; :

the welcs have had a "f;r.al' licuid,ncr.e: rant and reaic.,7r_phic ex: ;r.;t.::

that have been acccpted c;.,i sr.cr :. L cher,

t..c authcr;.:ed ins cctor :. r.c Dlc CC.

chould the weld t. rface Oc ground at cil, the 1 ; q ;; d _ _ r.c t r :...

exar.inaticn trevicusly acccpted ws.lc r.c; he c valid ex;r;na:;;r.

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not reprcsent the final total raterial t:.;c:.ess.

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re-examine the welds af cr the " int.crvice in;p cticn grincing" It has also ccr.e to cur attentier tha..;;rer & Decker ;;pu-fitter crinders are grinding the welds to a finie':- that ic sr.oc.c.cr :.r.mn rec _uire d by Edisor. Spec. 3071-9E & 115.

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Page 1 of 5 WNkoC W SWAZi f $$5n5$n$$

R ' sio. 1 GENERAL PROCEDURE

'

TITLE:

GRINDING OF CARBON STEEL WELDS TO ALLCW J

PIPE SUPPORT FIT-UP (Not applicable to

,

welds requiring in-service inspection

~

or G.E.

scope of supply items.)

NUMBER:

WB-C-131 RWISION:

(

,

,

,

DATE:

July 10, 1980 4,,,

COMMENTS :

Revision 1 incorporates comments from DIC80-2968, dated 6/5/80 and an addition to Section 5.0 Prereq-uisites.

Revisions noted.

SPECIFICATION NUMBER:

DECO. No. 3071-29, 30 and 31 CUSTCMER:

DANIEL INTERNATIONAL CORPORATION OWNER:

DETROIT EDISON COMPANY PROJECT NAME:

ENRICO FERMI ATOMIC POWER PLANT, UNIT II PROJECT / CONTRACT NUMBER: 261-7100/lA-84001 APPROVAL S

.ATUREC:

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PROJE92 I.,N R.'

DATE

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PROJECT W IT CONTRM PGNAGER DATE d

/ // /8d Accepted Bv

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AUTHORIZED NUCLEAR INSPECTOR DATE

/

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CUSTOMER REPRESENTATIVE DATE

.

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W & 3 SUBMITTAL No'

/5.7 A azo rxe-.s.i ae sa es* co, ecn.a 9 9:e n:.m.xatz e : e r n6s. 2: a * c :.. u c,wis

[t F &a0M aa( A t*,X 9 4 381 J930 L; CENSE 40. 141691

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Page 2 WB-C-131 WNMM WSW17 f Sku5nYu$n$n'

Revision 1 w

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GRINDING OF CARBON STEEL WELDS TO ALLOW PIPE SUPPORT FIT-UP (Not applicable to welds requiring in-service inspection G.E.

scope of supply items. )

I

.

PROCEDURE APPLICATION MATRIX OWNER Q.A.

LEVEL I

II III A

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OWNER B

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CODE C

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This procedure is applicable to all appropriate work within the Owner Code Class and Q. A.

Level indicated.

Work outside ASME III and ANSI B31.1

  • =

1.0 PURPOSE:

To provide requirements for the grinding of carbon steel welds to allow pipe support fit-up at the Enrico Fermi Atomic Power Plant, Unit II.

2.0 SCOPE:

This procedure defines the permitted amount of grinding and final configuration of carbon steel welds requiring grinding to allow pipe support fit-up.

3.0 RESPONSIBILITIES:

l Unless otherwise noted, all titles refer to Wismer and Becker personnel or their authorized designee.

3.1 Project Manager - it is the responsibility of the Project Manager to insure that all construction personnel have been made aware and comply within the boundaries of this procedure.

3.2 Project Quality Manager - the Project Quality Manager is responsible for recording, documenting, non-conformance reporting and the general inspection

_

of the weld grinding operation through completion, we rate-ass ac. waas ec. airce%: A 93sce W & 3 SUBMITTAL N0. /f7 A utLi%c AE;atts P_ C 0: 1168. W3 A4 %?L. A IF00%; A T[L f pac *.t. an( A (;0C 91f. 381 3930 LICENSE %C. 18169I Exhibit I - Page 3 of 6

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Page 3 WB-C-131

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I Revision 1 WMart? QA W'Sf.W.b l comuries assissif5 suciexn ea noemxu w

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3.3 Project Engineer - the Project Engineer is responsible for developing process traveler for the grinding operation.

I

3.4 Project Superintendent - the Project Superintendent

- is responsible for the general supervision of the weld grinding in accordance with the criteria outlined in this procedure.

4.0 APPLICABLE CODES AND SPECIFICATIONS:

4.1 American Society of Mechanical Engineers ( ASME)

-

Boller and Pressure Vessel Code, Nuclear Power Plant Components,Section III 1971, with Addenda through Winter, 1971.

4.2 Wismer and Becker (W&B) Procedures:

4.2.1 WB-C-110, " Repair of Base Metal and Completed Weld Metal".

4.2.2 WB-Q-105, " Ultrasonic Material Thickness Measurement".

4.3 Detroit Edison Company (DECO) Specification 3071-31, " Pipe Erection".

4.4 Daniel International Corporation (DIC) Letter, DIC9-4928, dated July 17, 1979.

5.0 PREREQUISITES:

5.1 All carbon steel welds which require grinding to j{\\

allow pipe support fit-up require a process traveler from the Project Engineer and an Edison Field Engi-neer approved DCR.

Requirements for DCR is per EF2-46740 and DCN 1756.

5.2 A DECO approved Design Change Request (DCR) is required before the grinding of weld crowns begin.

6.0 PROCEDURE:

6.1

"A DECO approved DCR is required before grinding of weld crown begins.

The location of the weld to be ground shall be listed in the DCR.

Location infor-mation shall include:

spool #, field weld #, hanger

  1. ,

if it is a shop weld or field weld, locating

,

dimension and direction referenced from a valve or

.

W & B SUBMITTAL No. /6 7 A nn e x s.,

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.t na; su=>w ec.cA;rcas:a 99c'

MA..thc A naC2; 8 0 b0n 4163. 'aACaAg e;,.Aitr;esis T[Lf 8acM Aa(& C000 916 341-M30 LIC(%st 40.14;691

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Exhibit I-Page 4 of 6

Page 4 WB-C-131 g

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[ gGl88 Mi,8g3 Revision 1 w

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6.1 (Continued)

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field weld, etc..

Additionally, a low spress stamp-f ed symbol (an arrow pointing to the weld) will be

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put on both sides of the weld.

The markls) will be

'

.

4" from the center of the weld on both sides of the weld.

In the case of a component to pipe weld, the

" arrow" shall be put on the pipe side only.

6.2 Final non-destructive examinations (NDE) as determined from the applicable Weld Process Control Sheet (WPCS), and Postweld Heat Treatment (if applicable), must be verified as complete and acceptable prior to grinding. Welds which exhibit acceptable concavity on the final RT shall be evaluated prior to grinding by the Engineer to determine if the resulting operation will reduce the wall thickness.

The operation process traveler shall provide for documentation of the Engineer's evaluation.

6.3 Grind the face of the weld around the entire pipe circumference until the weld reinforcement

/fh has been reduced to approximately 1/16 inch.

CAUTION:

DO NOT GRIND INTO BASE METAL.

To comp]ete removal of the weld reinforcement, sand the face of the weld until it is flush with the outside diameter of the pipes being joined.

The surf ace condition of the finished weld shall be suitable for the proper interpretation of the required NDE.

6.4 Verify with a straight edge that the weld face is flush with the adjacent base material being

/$\\

joined.

When the contour of the weld face is concave, repair in accordance with reference 4.2.1, including all required operations for the original weld which have been nulified by the weld repair (i.e., PWHT).

When the contour of the weld face is flush and there is no evidence of root concavity on the final RT, the weld is complete.

For all other instances where the weld face is flush, continue to 6.5.

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Exhibit I - Page 5 of 6

Page 5 WB-C-131 ffg g g g g g y

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6.5 Perform an Ultrasonic examination on the ent4fe ground weld face in accordance with reference 4.2.2, to determine if the weld thickness isi nqual (

to or greater than 87.5% of the nominal wall ;

thickness of the thinner of the sections join'ed.

-

I When the entire weld thickness is equal to or greater than 87.5% of the nominal wall thickness

'

of the thinner of the sections joined, the weld preparation is complete.

6.6 Perform surf ace examination of the ground weld using A

LPT or MPT methods.

NDE acceptance report shall O'

become part of the weld data package.

Any section of the weld that does not meet the criteria above shall have the concavity of the root repaired in accordance with reference 4.2.1 and repeat paragraph 6.2.

However, a design evaluation by Edison may be made to either reposition the pipe support should the repair be impr actical, or to specify the design minimum wall thickness if such information would permit acceptance of the weld.

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W & 3 SUBMITTAL No*

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Exhibit I - Page 6 of 6 l

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[f U l ( d 4 RCUEsT'FO,R CLARIFICATION OF INFORMATION

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REQUEST for CLARIFIC AT'ON of INFORMATION (RCI)

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Page 1 of 5

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Nw*ba':

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., j Charlie Bacon Enrico Fermi II II

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~ /r' i DECO Engineer

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AKS D1.1-72, DEC0 3071-129, and related drywell framing prints-

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erection & fabrication; DECO Letter F259-1434

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,?,i. INQUIRY:

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On DECO and S&L prints, the welding symbols shown on the drywell framing prints

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indicate the shop welding should be S.M.A.W.

The Inland Ryerson shop fabricated

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parts received on site by R.M. Parsons and installed by R.M. Parsons and NISCO.

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appear to be fabricated by the S.A.W. process. The prints do not indicate an t c

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"S" after the joint designation as required by A.W.S. D1.1-72, which would

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designate S.A.W. process. Request your review for acceptance or rejection.

If

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your review concludes " Accept As Is", DCN's will be required for all related

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drywell documentation.

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Se reply by RESPONSE:

Specification 3071-129 permits the use of the Submerged

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Arc Welding (SAW) process.

The fabricator has approved

,

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procedurers for SAW and therefore the fabricator is free to use SAW for the drywell structural steel shop welds,

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Since the specification permits SAW there is no ME need (ej

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to write a DCN to MEEREME document the use of SAW,

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DISTRIBUTION

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Exhibit II - Page 1 of 5

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NAME R O O' ' -

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Dear Mr. Larson,

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One of 'the bidders for the drywell structural steel erection has pro-f,(.

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.cosed changing the weld process and the prime !DE r.ethod.

We ask that G

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you consider and ce=ent on the followinn proposed. changes:

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Substitute the flux cored arc welding process for the rianual

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shielded metal-arc.

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Use ultrasonic testino withour macnetic particle or lir.uid pene-2.

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trant testing in lieu or raciographic testino fer all full ocne.

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i tration velds. The bidder feels that ultras 5nic testina vill

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detect both internal defects and surface de4 cts and therefore

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magnetic particle testing and liquid penetrant testing are not

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required.

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Please revieu these requests and advise Mr. C. P.. Bacon (313-237-9621),.2 y

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and Mr. Gene Irwin of illSCO (516-929-S411)]by August 2,1976.

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and Project Engineer

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Written.by:

P.. A. Bryer

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C. R. Bacon Ys. J. Fus'(5 & L)

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Detroit Edi :n Ccn>anY

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regcrding t';2 arywell s tracturr1 stcel crection cad our corrents'

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arc as iollova:

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It ir. nico our recoinendat$on thc.t

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is quectionable.

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i quircrents of the Specification 3071-163, paragraph.2-2.2.5.E fi ]2:..

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