IR 05000458/1979008
| ML19294B217 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 02/06/1980 |
| From: | Crossman W, Randy Hall, Oberg C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19294B209 | List: |
| References | |
| 50-458-79-08, 50-458-79-8, NUDOCS 8002270576 | |
| Download: ML19294B217 (16) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT RF.GION IV Report No. 50-458/Rpt. 79-08 Docket No. 50-458 Category A2 Licensee:
Gulf States Utilities Company Post Office Box 2951 Beaumont, Texas 77704 Facility Name:
River Bend Station, Unit No. 1 Investigation at:
River Bend Station, St. Francisville, Louisiana Investigation conducted: December 20, 1979, and January 9-16, 1980
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Inspectors:
O d
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/gD. P. Tomlinson, Reactor Inspector, Engineering
/Date
't Support Section d#$Aus-W ro C. R. Oberg, Reactor (Jaspector, Projects Section Da'te W. W. Crossman, Chief, Projects Section2/co/so A
Date Approved:
_
7./(,!Bd W. A. Crossman, Chief, Projects Section Date M
d R'. E. Hall, Chief, Engineering Support Section
/ D4te Investigation Summary:
Investigation on December 20, 1979, and January 9-16, 1980 (Report 50-458/79-08)
Areas Investigated:
Special investigation of allegations received regarding the Graver Energy Syrtems Quality Assurance Manual, qualification of personnel, improper welding, improper acceptance of radiographs, equipment calibration and falsification of records.
The investigation involved forty inspector-hours by three NRC inspectors.
Results: Through actual inspection, review of records and interviews, it was determined that all twelve allegations were without merit or could not be substantiated.
80 02270 M C
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INTRODUCTION River Bend Nuclear Power Plant, Unit 1, is under construction in West Feliciana Parish, Louisiana, near the town of St. Francisville, Louisiana.
Gulf States Utilities Company is the Construction Permit holder with Stone and Webster as the Constructor and Architect / Engineer.
REASON FOR THE INVESTIGATION Region IV was notified by the IE:HQ Duty Officer that an individual had contacted him alleging violations at the River Bend Nuclear Power Station.
SUMMARY OF FACTS On Decen.ber 17, 1979, the Region IV Reactor Construction and Engineering Support Branch Chief was informed by the IE:HQ Duty Officer of a phone call from a former employee at the River Bend site.
Two Region IV inspectors interviewed the alleger on December 20, 1979.
The following information was gained from that interview:
Allegation No. 1:
The alleger stated that the Graver Energy Systems Nuclear Quality Assurance Manual does not meet Code Requirements.
He stated that the manual is vague and incomplete in that several areas (not defined)
are not addressed.
He felt that a thorough review of the QA manual by qualified people was required.
Allegation No. 2:
The alleger stated that certain shear bars welded to base mat embeds were gouged greater than 3/16", were not repaired and were " accepted-as-is."
He said these gouges were not reported on a Nonconformance and Dispo-sition Report (N&D). He further stated that welded repairs on the embeds were re-examined by a different NDE method than that used to locate the defects.
Individual B is alleged to have been a QC inspector on this job.
Allegation No. 3:
TheallegerstatedthathalfoftheverticalweldsV1thruV12feitheroddor even numbers) on the containment vessel were welded in 40 - 45 F weather with inadequate or no preheat.
One welding torch on the inside of the vessel plates tried to pre-heat metal for six welders on the outside. No post-weld heat treatment was given, and no interpass temperature was maintained.
The plates are 1 " thick carbon steel.
Allegation No. 4:
The alleger stated that the welder qualification program is deficient. Under-size bend test coupons between 5 and 6 inches were used; the coupons were not cut from tne test plate in the correct order; and coupons were " reworked" after initial failure.
Individual C told Individual A not to say anything
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about the lack of proper size for test plates (coupons) until after coupons were cut.
Individual A was called in to assist and to pass on coupons which were less than 6 inches. He refused.
Individual D also refused to pass on welder qualifications.
Welder qualifications are run by construction.
QA/QC is called in as courtesy only.
Individuals E, F, and G were aware of coupon problem.
Allegation No. 5:
The alleger stated that radiography performed by Peabody Testing and by Graver was being accepted with a film density of 1.3 instead of the required 2.0.
Allegation No. 6:
The alleger stated that a semi-automatic welding machine for use on the containment vessel was qualified without a written procedure.
" Wagon Trackc" (lack of fusion) could be visually detected on welds produced by this process. The qualification was made after five welders worked on the machine and was based on a weld which was made without proper fit-up.
Individual D is said to be aware of this situation.
Allegation No. 7:
The alleger stated that personnel are not being qualified properly in NDE.
Tests given for qualification have no bearing on work to be done and there is a lack of experience in personnel " qualified."
Individual H is involved / aware of the problem.
Individual I was qualified as Level III inspector, but has very limited experience.
He is now a Senior QA engineer with no experience in QA.
Allegation No. 8:
The alleger stated that stainless steel plating for the drywell liner was welded by an unqualified welder.
The welder is said to have been qualified after the fact by welding a test plate instead of by exami-nation of the production weld he produced. He added that an unqualified welder should not be able to draw welding rod from the issue station and that the weld rod control system should be examined.
Allegation Nc. 9:
The alleger stated that Graver is calibrating magnetic particle inspection equipment once per year instead of every six months as required by the Code.
He further said that Graver equipment is now or soon will be included in the Stone and Webster calibration system.
Allegation No. 10:
The alleger stated that " Erection Control Sheets" are being changed in the QA office after work is done in order to make the NDE/QA requirements fit the situation.
The sheets were retyped or additions made after work was done.
Individual I may have some knowledge of the situation.
Allegation No. 11:
The alleger stated that inspection was being performed by qualified trainees and the inspection sheets were signed by Individual H who did not make the inspection. This pertains to visual inspections made by Individual J.
Allegation No. 12:
The alleger stated that Graver has produced approximately 300 radio-graphs, but "only about five have been sold to Stone and Webster". The alleger does not know what happened to the remainder of the radiographs but says all were produced during or following the welding of t): six joints in allegation No. 3.
CONCLUSIONS The following conclusions are based on known conditions at the River Bend site, a review of indicated records, visual inspection of hardware in question and interviews with individuals B through L between January 9 and January 16, 1980.
Allegation No. 1:
This allegation was determined to be without merit.
Individual A was employed as a QC inspector in a field activity of Graver Energy Systems ano, therefore, only had access to Division 2 of the two part Quality Assurance manual. Division 2 is concerned only with parts of the eighteen criteria of 10 CFR 50, Appendix B, which apply to field activ-ities.
It is a very broad QA manual written to cover the requirements imposed by more than one construction site and each section of the man-ual must be supported by various procedures or procedure revisions that are unique to each site.
To reduce the bulk of paper, all the procedures and necessary revisions are not a part of the manual but are available as supplementary documents at each work location.
Both parts of the Graver Nuclear QA Manual were reviewed and approved on August 23, 1978, by an ASME audit team.
Allegation No. 2:
This 211egation was determined to be without merit.
A routine, planned Stone and Webster inspection of all embeds prior to the placement of concrete for the Reactor Building base mat revealed nine gouges in eight of the embed plates and shear bars. These were repaired and inspected by Graver before this investigation began. All work was accomplished in accordance with approved procedures and was properly documented.
Allegation No. 3:
This allegation could not be substantiated.
During the time the alleger was employed at River Bend, the only containment liner plate welding being
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performed was on Ring No. 4.
He claimed that one oxy-acetylene welding /
cutting torch was used to pre-heat and maintain interpass temperatures on six vertical butt joints at the same time.
The Erection Control Sheets (ECS) for these joints do not include spaces for the recording of pre-heat or interpass temperatures but interviews with three craftsmen involved in these operations (one inspector and two welders) indicate the work was accomplished in accordance with the approved welding pro-cedure. All three stated to the investigator that as many as four
" Rosebud" torches were used simultaneously on each joint to achieve and maintain the proper heat.
The cognizant inspector added that this was monitored by the use of temperature-indicating crayons. According to the present construction schedule no stress relief of the welds is planned until all structural welding is completed on the containment liner plating.
Allegation No. 4:
This allegation was not substantiated. As described in Section IX of the ASME B&PV Code, coupons taken from a welder's qualification test plates are subjected to a series of bend tests to verify the quality of the welds.
At the option of the qualifying organization, the Code also allows acceptance or rejection of these tests utilizing radiographic examination as an alternative.
The plates manufactured for this purpose were found, after fitting them together, to be less than the Code mini-mum width of six inches for bend testing.
When the error was discovered, immediate steps were taken to radiograph the plates instead.
One set of undersized test plates was destroyed by using them as set-up parts for a cutting machine.
The welder, whose plates were destroyed, was subsequently qualified by bend testing another set of test plates.
The remainder of the undersized plates were radiographed and qualifications were based on the results of this alternate examination.
Allegation No. 5:
This allegation was refuted.
The River Bend Nuclear Station is, by commitment, to be constructed in accordance with the ASME Boiler and Pressure Vessel Code (B&PV Code) 1974 edition, no addenda.
Section III, Ap;sadix X, of the 1974 Code, paragraph X-3334.3, states "The H&D density through the acceptable weld metal shall be 1.3 minimum for single viewing and 1.8 minimum for composite viewing of double film exposures." Graver's Radiographic Procedure, RE-9 Revision 2, paragraph 7.0 also states that 1.3 for single film viewing and 1.8 for composite viewing shall be the minimum film densities acceptable.
There is, therefore, no discrepancy.
Allegation No. 6:
This allegation was refuted. The 1974 edition of the ASME B&PV Code does not require qualification of welding machines.
Qualifications, however, are required for each welding procedure and each welder.
At
the time the alleger was employed at River Bend, the procedure for electro-slag welding the vertical joints on the containment liner was in the development stage. No procedure, machine or personnel qualifications existed at this time.
The welding he witnessed, or heard about, was that being performed to establish the parameters of the weld procedure. Many of these parameters, including root opening, were varied during this period to find out which produced optimum results. The alleger never was assigned to work in this area and it is doubtful he had first-hand knowledge of the events that occurred there.
Allegation No. 7:
This allegation could not be substantiated.
Section V of the ASME B&PV Code requires that personnel involved in NDE be certified to the proper level in accordance with SNT-TC-1A. A review of personnel records for all on-site NDE inspectors revealed that each has taken and passed the required written and practical tests, has had the required vision test within the last twelve months and has spent the required amount of time at the previously held level of expertise.
Allegation No. 8:
This allegation was refuted.
The alleger stated that an unqualified welder welded on the stainless steel drywell liner plating and that the weld was deemed acceptable based on the welders passing of the appropriate performance test at a later date.
Graver inspection has issued a Nonconformance Report (NCR), however, which indicates that this is not true.
An unqualified welder did partially weld two verti-cal joints on the inner drywell. This situation was noted by a Graver inspector and documented.
Both welds were removed, reprepared and rewelded by a qualified welder. The welder in question was not quali-fied on the basis of the drywell liner welds but did, at a later date, qualify in accordance with ASME B&PV Code,Section IX.
He has since terminated his employment at River Bend and could not be contacted for an interview.
Allegation No. 9:
This allegation was without merit.
The alleger stated that Graver's magnetic particle examination equipment was being calibrated yearly instead of every six months as required by ASME B&PV Code,Section V, 1974 edition, no addenda.
Graver's calibration frequency is, at the present time, annually for this equipment although the 1974 Code does not make mention of any calibration nor does it establish a frequency.
The 1977 ASME Code does not establish an annual calibration cycle for magnetic particle instuments, but this edition of the Code is not the governing document at the River Bend site. Neither edition cites the six-month requirement as mentione,d by the alleger.
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Allegation No. 10:
This allegation was refuted.
A review of all records for the contain-ment liner generated during the alleger's term of employment did not disclose evidence of any record changes. During this period, work was performed only on Ring No. 4 and Ring No. 5 of the liner plating. All erection control sheets for these two assemblies were examined.
In some cases, the ECS forms used on the job site were dirty, had scratch-outs, tears and showed other signs of handling abuse.
These have been recopied and all information, including dates and signatures, was properly transferred to a clean file copy.
In all cases, the working versions of the ECS we re retained and these were checked against the file copies for validity.
No discrepancies were found.
Allegation No. 11:
This allegation could not be substantiated.
Records were reviewed of all inspections performcd on containment liner Rings No. 4 and 5 along with those for the Reactor Buildin8 base mat embeds.
During the alleger's term of..iployment at River Bend, these were the only jobs on which visual
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inspection was being performed.
The alleger stated that inspections per-formed by Individual J (reported to be a trainee) were signed-off by Individual H.
Individual J was certified as a Level II inspector for more than nine years prior to his employment at River Bend.
Since his arrival, he has been, by virtue of written and practical examinations, a Level II inspector and not a " Trainee." Several Erection Control Sheets (ECS) were signed by Individual J as having performed inspections but all were dated following his successful completion of the qualification examinations.
No records of inspections signed by Individual H were located as his present assignment involves work other than hands-on inspection.
Allegation No. 12:
This allegation could not be substantiated. To date, the only on-site radiography shot for acceptance has been that performed on the six vertical weld joints mentioned in Allegation 3.
Ten shots were taken on each of the welds producing a total of sixty radiographs. Each shot, however, utilized the double-film technique resulting in a total of one hundred-twenty exposed pieces of film.
All sixty radiographs have been developed, sorted and examined only for the quality of the film and not for evaluation of the welded joints. At the time this investigation was concluded, none of the production radiographs had been interpreted for acceptance by Graver and none, therefore, had been presented to Stone and Webster for final evaluation.
During the interview with the alleger on December 20, 1979, he indicated that his prior position with Graver Industries was in a supervisory capacity.
The subsequent investigation of the above allegations revealed that he had been, in fact, a Quality Control inspector (Level II).
DETAILS 1.
Persons Contacted Alleger The alleger, hereafter referred to as the alleger or Individual A, stated he is a former employee of Graver Energy Systems who worked as a QC inspector at the River Bend Nuclear Station.
Principal Licensee Employees Site Quality Assurance Director Quality Engineering Supervisor Stone and Webster Employees Individual E Individual F Individual G Graver Energy Systems Employees Individual B Individual C Individual D Individual H Individual I Individual J Individual K Individual L 2.
Background Information On December 17, 1979, the Region IV Reactor Construction and Engineering Support Branch Chief was notified by IE:HQ Duty Officer of a telephone call from Individual A alleging numerous ASME B&PV Code violations at the River Bend Nuclear Power Station.
Individual A identified himself as a former employee of Graver Energy Systems, one of the sub-constractors involved in construction operations at the site.
The first follow-up call was made to this individual during the evening of December 17, 1979, and a second call on December 19, 1979, to arrange a time and place for the alleger to meet with representatives of the NRC.
Indi-vidual A did meet with two NRC inspectors in Houston, Texas, on December 20, 1979, to discuss his allegations.
After the interview, the NRC determined that there were actually twelve allegations.
In summary they were as follows:
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(a) The Graver QA Manual is incomplete and vague and does not meet ASME B&PV Code requirements.
(b) Shear bars and embed plates were badly gouged and not reported.
some repairs were made and inspected by tests other than those used to locate the defects.
(c) Welding on the containment liner plating was accomplished with in-adequate or no pre-heat.
No monitoring of interpass temperature was done.
(d)
Improprieties existed in the welder qualification program.
(e) Radiography was being performed to the wrong film density.
(f)
Improper qualification of an electro-slag welding machine.
(g)
Improper qualification of NDE inspection personnel.
(h) Welding was performed by an unqualified welder and accepted based on a later-date qualification.
(i) Frequency for calibration of magnetic particle equipment was not in accordance with Code requirements.
(j) Erection Control Sheets (ECS) information was being changed.
Records were altered to suit the situation.
(k)
Inspection records were signed-off by person other than the inspector.
(1) Rejection of radiographs.
3.
Investigation Allegation No. 1:
The Graver Energy Systems Nuclear Quality Assurance Manual is, by necessity, a two-part manual.
Division I was written to cover all corporate and shop activities concerned with Quality Assurance.
Division 2, a much more concise version, was written to cover the quality functions of field activities only.
Each manual division is comprised of sections numbered and titled to be in accord with the eighteen criteria of 10 CFR 50, Appendix B.
Section 1 of both Division 1 and Divisien 2 addresses itself solely to Criterion I; Section 2 of each Division addresses Criterion II, etc.
Division 1, being the manual for corporate activities, includes the requirements for each of the eighteen criteria. Division 2, however, as it is written for field activities, includes only those sections dealing with selected criteria which apply to field activitics.
Division 1, for
example, includes Section 3 which cites the requirements of Criterion III for design control. Division 2 contains only a blank section divider to indicate this section does not apply directly to field activities and to keep all subsequent section numbers in agreement with the manual format and the eighteen criteria.
This omission of sections in Division 2 of the manual includes Criteria and Sections III, IV, V, XI, XVI and XVIII.
The alleger, acting as a QC inspector in a field activity, was concerned only with Division 2 and took this to be the complete QA manual.
As it does not contain the specific requirements of each of the eighteen criteria, this manual could easily be referred to as " incomplete" while in fact it does contain all that for which it was designed.
The complete two part Graver Quality Assurance Manual is a very broad, non-specific document to be applied as guidance for the quality function at any of the nuclear sites at which Graver may be involved.
Each site, however, will have different specific requirements, as act all are committed to the same edition of the ASME B&PV Code and Addenco.
Individual procedur _ or procedure revisions are issued to cover the requirements of each area at each site. The inclusion of these procedures as an integral part of the manual would not only produce a document of extreme bulk but would also create problems in the distribution of revisions as this does fall under the Graver document control system. Distribution of all revisions to all manual holders would then become mandatory.
Graver has opted to distribute to each site only the procedures and revisions needed at that site to support the QA manual. Each work area, then, has only the supporting documents needed in that area. The alleger, familiar only with the field activities manual and with the procedural revisions available in his work area, presumed that portions of this manual were self-supporting ac he did not have access to the attendant procedures.
This presumption leads easily to the claim that the QA manual is " vague" and has several " areas that are not addressed."
Both divisions of this manual were reviewed and approved by an ASME audit team on August 23, 1978.
Allegation No. 2:
As an integral part of their over-check system of inspection, Stone and Webster QC personnel performed a routine visual inspection of all embeds for the Reactor Building base mat on December 31, 1979. Nine areas requiring repair were noted on eight of the embed plates.
Stone and Webster Quality Assurance Inspection Report M9000271 locates each of these areas and lists the pre-repair dimensions of each.
It is further documented that all repairs were accomplished in accordance with approved procedures TA-4 (Revision 5) and RP-1 (Revision 9).
The repairs were made on January 5-6, 1980, with the final inspection and acceptance being on January 7,1980.
All nine areas were repaired
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by welders III and LLL (welder idertification), both of whom were qualified to welding procedure 305N/8 prior to making the welds. A qualified Level II inspector performed a magnetic particle examination on each repair and entered his acceptance on Erection Control Sheets (ECS) No. 047, 052, 082, 083, 084, 085, 086 and 087.
Inspection and repair of conditions like these are routinely delayed until shortly before the concrete placement is made so that all damage, including that due to last-minute nandling, can be rectified at one time.
The IE inspector toured the Reactor Building construction site and visu-ally inspected approximately 70% of all the embeds to be covered by the concrete placement.
This included embeds in the areas of the containment liner, drywell liner and the weir wall.
Of particular interest were the shear bars and connecting welds under the corner junction embeds for the containment liner plating attachment.
A review of drawing NL-10388A (Revision 7) indicated that the shear bars were procerly installed and were in accordance with the drawing. All welds on the inspected embeds were complete, of the proper contour and were of adequate size.
Each of the previously mentioned repairs was located and visually inspected by the IE inspector with no unusual conditions noted.
Numerous excavations were observed in the Tee Weld of the corner junction embed plating.
These are all located on the top side of the plating and will not be covered by placement of the base mat concrete.
Graver Energy Systems fabricated the corner junction embeds in East Lansing, Michigan, and shipped them to the River Bend site.
These were welded using the submerged arc process and were found to have exces-sive defects in the area of the weld root. The ASME B&PV Code requires only that a magnetic particle examination be performed on these tee welds, but, because the defects were known to exist, Graver performed an ultra-sonic examination to aid in determining their location and extent.
An engineering decision was made by Graver to ship the hardware with the defects removed but not rewelded.
The excavations are to be repaired after installation of the first two containment liner rings to minimize the possibility of distortion caused by the welding.
This was previously reported to the NRC under the provisions of 10 CFR 50, 50.55(e).
The alleger, seeing either of the conditions noted above and not knowing the circumstances surrounding them, presumed that one or both would be accepted-as-is and that embeds of questionable quality would be incorporated into the base mate concrete placement.
It is unlikely that he would have known of the NRC notification at his level of employment and repairs to the nine gouged areas commenced two months after his termination. The alleger's concern over these items at that time was valid, but unknown to him, steps were provided to preclude their going undetected.
Allegation No. 3:
A review of all Erection Control Sheets (ECS) generated for the welding of containment liner plating during the time of the alleger's employment were reviewed.
No provisions were made on the ECS forms for the recording of actual pre-heat or interpass temperatures but interviews with craft personnel involved in the welding of vertical butt joints 4V2, 4V4, 4V6, 4V8, 4V10 and 4V12 for Ring No. 4 of the containment liner plating indicate the procedural requirements were observed. These vertical butts were welded in accordance with procedure 305N/7 by welders C, J, N, P, DD and EE, all of whom were qualified to this procedure prior to the initiation of welding.
Welding began on all six joints on October 24, 1979, and was completed November 7, 1979.
Two of the above welders and one QC inspector involved on this job all state that the procedural pre-heat requirement of 200 F minimum and a maximum interpass temperature of 350 F were maintained during the actual welding of each joint. Temperatures were monitored by the use of temperature indicating crayons. No attempt was made to maintain the 200 F pre-heat temperature during work shifts when no welding was being performed. The procedure clearly states that proper pre-heat must be attained before welding is begun but need not be maintaineo during the entire sequence. At first an attempt was made to pre-heat the areas of weld preparation with a single oxy-acetylene cutting / welding torch but the results were less than satisfactory.
Interviews with the individuals above and a tour of the fabrication area indicate that as many as four " Rosebud" torches were used simultaneously to achieve the proper pre-heat on a single joint before moving to the next one.
The alleger either saw or heard of the single torch attempt and concluded this was the method used throughout the welding operation.
If he had reviewed the welding procedure 305N/7, he would also have found that pre-heat maintenance at all times was not required.
The alleger also stated in his interview with the NRC that no post-weld heat treatment of these six weldments had been performed.
This is true.
No stress relief of the welds is planned until all welding is completed.
At present only six of the twelve vertical welds on this coutainment liner ring have been completed and any post-weld heat treating done at this stage would be negated by future welding.
Allegation No. 4:
The ASME B&CV Code,Section IX, offers two acceptable methods of evaluating a welder's performance qualification test plates:
the plates may be radiographed or subjected to the series of bend tests described in Section IX.
The organization seeking to qualify welders may, at their option, select either of these methods for evaluation of the test plates. When Graver began its program of welder's qualification, it was decided that the bend test method would be used and a large quantity of prepared test assemblies were produced and stored. A special machine was also purchased
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to be used in cutting the test coupons from the completed test plates.
Section IX of the Code is specific as to where these coupons shall be removed from the plate. Also specific is the requirement that the completed test plate assemblies be a minimum of 6 inches wide if they are to be used for bend tests.
The first set of completed test assemblies was measured and found to be less than the 6 inch minimum.
Further measurements showed that all of the pre-cut plates were undersize due to the addition of a bevel on the unwelded side of each plate.
Individual A was assigned as a QC inspector in the welder qualification area and is reportedly the one who first discovered the dimensional error.
Interviews with Individuals C, D and E indicate that the alleger knew of this discrepancy but told no one and took no action until after one set of plates had been cut into bend test coupons.
This reported intentional delay in informing Individuals C and/or E resulted in a lengthy discussion about the passing of information along the chain-of-command and further discussion as to the duties and responsibilities of an inspector assigned to a specific area.
Individuals F and G were both mentioned by the alleger as having full knowledge and additional information concernino this matter.
When interviewed, Individuals F and G denied this and both stated that their jobs had nothing to do with the qualificction of welders.
Individual G claimed to have been in the building housing the welder test facility only once and that occasion was part of a site familiarization tour.
This was substantiated in an interview with Individual E who is the immediate supervisor of Individuals F and G.
The welder whose test plates were destroyed later welded another set.
Plans were immediately changed and all undersize test plates were radiographed.
New test assemblies have since been fabricated to the correct dimensions and welder qualifications are now being evaluated by bend testing. At no time were the discrepant coupons used for the qualification of a welder by the bend test method.
Allegation No. 5:
The allegation that radiographs are being accepted with a minimum density of 1.3 when a minimum density of 2.0 is required is false.
ASME B&PV Code, 1974 edition, no addenda,Section III, Appendix X, paragraph X-3334.3 states in part, "The H&D density through the acceptable weld metal shall be 1.3 minimum for single viewing and 1.8 minimum for composite viewing of double film exposures." Radiographic procedure RE-9 (Revision 2) paragraph 7.0, approved for use, also states the 1.3 and 1.8 minimum densities.
A review of the radiographs shot on joints 4V4, 4V8, 4V10 and 4V12 indicated that in actual practice no radiograph is considered to be of acceptable quality unless its density in the area of interest is a minimum of 2.0.
The IE inspector checked all ten radiographs on each of these four welds (total-forty radiographs) and found none to be below the self-imposed 2.0 minimum.
The forty radio-graphs examined represent 66% of all production radiographs taken to
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date.
The alleger cited erroneous requirements with this allegation and obviously had no first-hand knowledge of the quality of the radio-graphs on file.
Allegation No. 6:
The alleger stated that the electro-slag welding rachine to be used on the containment liner plating was qualified for use prior to the issuance of an approved procedure.
The 1974 ASME B&PV Code does not require qualification of this equipment.
At the time Individual A was employed at River Bend, the machine was indeed in use and there was not an approved written procedure.
All welding performed with the electro-slag machine and by the various operators was of an experimental nature to establish the parameters of the procedure and to determine the optimum operating conditions for the equipment.
No welder's qualifications were approved to procedure 307N/2 (electro-slag process) until December 2, 1979, or approximately one month after the alleger's termination date. No production welds using this process were initiated until after the procedure was approved, parameters established and operators qualified.
The alleger further stated that visible lack-of-fusion was apparent in the welds produced by this process.
By altering or varying one or more of the welding parameters, certain inherent weld anomolies, most notably porosity and lack-of-fusion, can be minimized.
The sole purpose of conducting tests for both the process and the operators is to control or eliminate these detrimental conditions in the test stages to later assure production welds of acceptable quality.
As can be noted from the above dates, the alleger could only have seen the defective experimental welds and not production welds.
Allegation No. 7:
The alleger stated that inspectors are not being properly qualified in NDE.
The 1974 edition of ASME B&PV Code,Section V, paragraph T-170 requires that personnel performing nondestructive examination be qualified in accordance with the provisions of SNT-TC-1A.
Qualification records of all on-site NDE personnel were reviewed by the IE inspector.
These indicate that each inspector had successfully completed the three part examination which includes a written general examination, a written examination covering specific requirements and a practical examination for the particular NDE method.
Each inspector is also required to show evidence of an annual vision test as specified in SNT-TC-1A.
The IE inspector reviewed both the general and specific examinations for certification of Level I and Level II magnetic particle, liquid penetrant and radiographic inspectors and found the questions on all six tests were taken directly from the ASNT
" Recommended Practices" booklets listing questions deemed acceptance for each Level and each discipline.
The records of vision tests for each employee were properly documented and each was current.
Personnel records also indicated that each inspector met at least the minimum time requirements for the certification Level held.
No discrepancies were noted in the NDE personnel qualifications,
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Individual I is not now, nor has he ever been, a Level III.
He is a Level II who has been delegated the authority to administer qualification tests to other inspectors by a duly certified Level III inspector.
This is permissible according to the provisions of SNT-TC-1A.
Allegation No. 8:
The alleger stated that an unqualified welder was used in the welding of stainless steel plating that will form a portion of the drywell liner.
He added that when this was discovered, the welder was taken off the job and then qualified to procedure 47N (SMAW stainless).
The alleger contends that the welds were accepted based on this after-the-fact welder qualification. Nonconformance Report (NCR) No. F-29, dated October 24, 1979, however, identified this problem and the affected welds.
These were removed totally and rewelded by a qualified welder.
NCR F-29 also states that, as corrective action, the welding foreman and all welding material distributors (rod issue station attendants) were re-instructed to utilize the qualified welder's list in making work assignments and in the issuing of weld filler material. Welder T, who originally made the welds, has since terminated and was not available for interview.
Allegation No. 9:
The alleger claimed that Graver's magnetic particle inspection equipment is being calibrated annually as opposed to the six-month calibration interval required by the Code.
ASME B&PV Code, 1974 edition, which is the governing document for inspection at the River Bend site, does not mention calibration of magnetic particle equipment at all as a requirement.
Graver is committed to an annual calibration cycle, since this is a part of their QA program.
The current edition (1977) of the Code does stipulate nual calibration but this is not applicable at River Bend.
Neithei dition mentions the six-month frequency quoted by the alleger.
A review of Graver's calibration records indicate that all three on-site magnetic particle machines were calibrated on October 19 or October 26, 1979.
Graver did not begin performing inspection with this equipment until after Peabody Testing Labs was relieved of inspec-tion responsibilities on October 18, 1979.
Allegation No. 10:
The alleger stated that records of inspections performed on the containment liner plating were altered in the QC office to "make the requirements fit the situation." During the alleger's term of employment, the only work performed on the containment liner was on Ring No. 4 and Ring No. 5.
Interviews with Individuals H, I and L revealed that several of the ECS forms generated during this construc-tion were recopied prior to being entered into the record file.
All stated this was done not to alter the information but to assure
" clean records" by eliminating the rough work copies, some of which
.
had gotten wet, stepped on, crumpled or soiled by some means.
The original work sheets were retained in another file as verification of the data on the " clean records." The IE inspector reviewed all old and new records for Rings 4 and 5.
Comparisons were made of data, dates, signatures and all other entries.
No changing of data was identified and it appeared that all signatures and initials had been properly transferred.
Allegation No. 11:
The alleger stated that inspections were being performed by Individual J, reportedly a trainee, and the inspection records were signed as being per-formed by Individual H.
The IE inspector reviewed all records generated for inspections performed during the alleger's term of employment.
A through examination found no records of visual inspections signed by Individual H as his work assignment during this period involved other than hands-on inspection.
Some inspection records were located, however, that had been signed by Individual J.
A check of inspection dates and the inspector's certification dates did not reveal any discrepancy.
Since his arrival at River Bend, Individual J had been certified as a Level II inspector and not as a " trainee." Personnel records indicate that he successfully passed the required written and practical examinations before he actually performed any inspections.
Prior to his arrival at River Bend, Individual J was certified as a Level II inspector for a period in excess of nine years.
Allegation No. 12:
The alleger stated that approximately 300 radiographs have been shot but only five " sold" to Stone and Webster.
The fact is that none of the production radiographs shot to date had been presented to Stone and Webster at the time of this investigation. A total of ten radiographs on each of six welds (total 60 radiographs) are all that have been produced and they have not yet been reviewed by Graver's film interpreter.
All of these have been accepted for film quality, sorted and filed pending a review to determine the quality of the welds.
During the alleger's term of employment, there were short periods when extensive radiography was performed but this was of an experimental nature.
Graver, by trial and error, was trying to develop an acceptable shooting technique for the 1 " thick material and still adhere to the requirements of their radiographic procedure RE-9 (Revision 2).
To be established were such items as exposure time, placement of location markers, film identification and thickness of penetrameter shims.
Along with these, the radiation safety distances was defined as required by 10 CFR 20.
None of the radiographs produced during this experimental phase were used for acceptance, rejection or evaluation of any hardware and all have since been discarded.
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