ML040510073

CTF Weld Documentation Requirements

ML040510073
Person / Time
Site:	Dresden
Issue date:	02/12/2002
From:	Narbut P Office of Nuclear Material Safety and Safeguards
To:
References
FOIA/PA-2003-0395
Download: ML040510073 (8)

Text

P:\\DPVs\\Dresden welds.wpd February 12, 2002 Revision A: Added Late Note Dresden CTF Weld Documentation Requirements On February 11, 2002, John Grobe of Region IlIl requested that SFPO provide a clarifying Email describing the requirements for weld inspection documentation for work done for Part 72.

The request was made during a Region III/NRR/SFPO telephone discussion concerning a DPV filed in regards to the welding records for the Core Transfer Facility (CTF) fabricated for Dresden. The request asked that we send the Email by COB 2/12/02.

The Certificate of Compliance (CoC) No. 1014 dated 5/31/00 for the HI-STORM cask system describes the requirements for the CTF In Section 3.5 of Appendix B, "Approved Contents and Design Features." The requirements of Section 3.5 were clarified by E. William Brach memorandum to John A. Grobe dated February 4, 2002 "Response to Differing Professional View Structural Issues Regarding the Dresden Spent Fuel Cask Transfer Facility," which stated the metal weldment, including the lift platform should comply with ASME Section 1II, Subsection NF, Class 3. The CoC, Appendix B Section 3.3 invokes the 1995 Edition with Addenda through 1997as the governing Code. Article NCA 4000, Quality Assurance, includes NCA 4134.10, Inspection. The requirements include the preparation of process sheets, travelers, or checklists, with space provided for recording results of examinations or tests. The requirements state the document shall include space for a signature, initials, or stamp: the date that the activity was performed by the Certificate Holders representative, and the date on which those activities were witnessed.

The Code description of inspection record requirements as applied to CTF welds does not comport with the description of the CTF weld inspection records described in NRC Inspection Report 07200037/2001-002, page2O. The report describes records consisting of weld data and inspection data signed by the vendor's Quality Assurance manager, assembled cumulatively in weld groups, according to size and dated with the date the last welding activity was performed.

The CoC Section 3.3.2, allows for exceptions to the ASME Code requirements when authorized by the Director of the Office of Nuclear Material and Safeguards when the Certificate holder demonstrates that the proposed alternates provide an acceptable level of quality and safety or result in hardship without a compensating increase in the level of quality and safety. The current CoC, Table 3-1 of Appendix B, does not include a Code exception for CTF weld records.

In addition to the CoC, NRC Part 72 requirements for inspections and records are provided in Part 72.160, Licensee and certificate holder inspection, and 72.174, Quality assurance records, The regulations are in accord with the ASME Code requirements for weld inspection records, but are not as specific as the Code regarding signatures and dates.

Late Note: 72.242(b) states that records required by the CoC be maintained.

-Paul P. Narbut A

Q2.

ARTICLE NCA-4000 QUALITY ASSURANCE NCA-4100 REQUIREMENTS NCA-4110 SCOPE AND APPLICABILITY (a) This Article sets forth the requirements for plan-ning, managing, and conducting Quality Assurance Pro-grams for controlling the quality of activities performed under this Section and the rules governing the evaluation of such Programs prior to the issuance of Certificates for the construction, fabrication, manufacture, and instal-lation of Class 1, 2, 3, CS, MC, CB, and CC items.

The Quality Assurance requirements for Material Orga-,

nizations for all Classes of construction are provided in NCA-3800. The Quality Assurance requirements for Nonmetallic Material Organizations and Constituent Suppliers for all Classes of construction are provided in NCA-3900. Certificate Holders are advised to consult other regulations for Quality Assurance requirements governing activities beyond the scope of this Section.

(b) N-Type Certificate Holders shall comply with the Basic Requirements and Supplements of ASME NQA-1-1989 Edition with la-1989, lb-1991, and Ic-1992 Addenda, Quality Assurance'Program Require-ments for Nuclear Facilities, as modified and supple-mented in NCA-4120(b) and NCA-4134.

NCA-4120 DEFINITIONS (a) The definitions in NCA-9000 shall 'apply.

(b) The terms and definitions of NQA-1,'Supplement S-1 shall apply except for those listed in (1) through (7) below. For the following terms, the definitions in NCA-9000 shall apply:

(1) item (2) Owiner (3) quality assurance (4) repair (5) rework.

(6) service (7) use-as-is NCA-4130 ESTABLISHMENT AND IMPLEMENTATION NCA-4131 Material Organizations, Division The requirements of NCA-3800 apply.

NCA-4132 Material Organizations for Division 2 NCA-4132.1 Material Organizations. The require-ments of NCA-3800 apply.

NCA-4132.2 Nonmetallic Material Organizations for Division 2. The requirements of NCA-3900 apply.

NCA-4132.3 Constituent Suppliers, Division 2. The requirements of NCA-3900 apply.

NCA-4133 Material Organizations, Division I The requirements of NCA-3800 apply.

NCA-4134 N, NV, NPT, and NA Certificate Holders for Class 1, 2, 3, IC, CS, CB, and CC Coristruction

- NCA-4134.1 Organization. The provisions of NQA-1, Basic Requirement I and Supplement S-l shall apply.

NCA-4134.2 Quality Assurance Program (a) The provisions of NQA-1, Basic Requirement 2 and Supplements 2S-Iand 2S-3, shall apply and the system used to meet these requirements shall be de-scribed in the Quality Assurance Manual. The Quality

' Assurance Manual shall 'alsoinclude a statement of

olicy and authority indicating management support.

The specific responsibilities of the quality assurance organization of the Certificate Holder shall also include the review of written procedures and monitoring of the activities concerned with the Quality Assurance Program as covered in this Article.

43

'CA4134.2 1998 SECTION 111, DIVISION I -

NCA NCA4134.9 (b) In lieu of Supplement 2S-2, the qualification of nondestructive examination personnel shall be as re-quired by NX-5520.

(c) The controls used in the Quality Assurance Pro-gram shall be documented in the Quality Assurance Manual. The Program need not be in the same format or sequential arrangement as the requirements in this Article, as long as all applicable requirements of this Article have been covered. A copy, including all changes that are made, shall be made available to the Inspector.

The Certificate Holder shall make available to the Inspector such drawings and process sheets as are necessary to make the Quality Assurance Program intelligible.

(d) The Certificate Holder shall be responsible for advising its Authorized Inspection, Agency of any sig-nificant changes which are proposed to be made to the Quality Assurance Manual, and shall have acceptance of the Authorized Inspection Agency's Authorized Nuclear Inspector Supervisor before putting such changes into effect. The Certificate Holder shall be responsible for promptly notifying the Inspector of such accepted changes, including evidence of acceptance by the Au-thorized Inspection Agency, and for simultaneously reconciling copies of the Quality Assurance Manual.

NCA4134.3 Design Control (a) The provisions of NQA-1, Basic Requirement 3 and Supplement 3S-I, shall apply.

(b) Measures shall be established to ensure that appli-cable requirements of the Design Specifications and of this Section for items are correctly translated into specifications, drawings, procedures, and instructions.

(c) Design documents shall be verified for adequacy and compliance with the Design Specification and this Section.

NCA-4134.4 Procurement Document Control. The provisions of NQA-1, Basic Requirement 4 and Supple-ment 4S-1, shall apply, except that procurement docu-ments shall require Suppliers to provide a Quality Assurance Program consistent with the applicable re-quirements of this Section.

NCA-4134.5 Instructions, Procedures, and Draw-ings. The provisions of NQA-1, Basic Requirement 5, shall apply.

NCA-4134.6 Document Control. The provisions of NQA-1, Basic Requirement 6 and Supplement 6S-I, shall apply.

NCA-4134.7 Control of Purchased Items and Ser-vices. The provisions of NQA-1, Basic Requirement 7 and Supplement 7S-I, shall apply, except that:

(a) Supplement 7S-1, 8.3 is not applicable to the procurement of Authorized Inspection Agency services as required in NCA-8130; (b) the decision to perform bid evaluation for materi-als to confirm conformance to procurement documents, required in 7S-1, 4.0, shall remain the responsibility of the Certificate Holder; (c) changes, waivers, or deviations permitted by 7S-1, 8.2.1(b) shall not be acceptable if they do not meet the requirements of this Section; (d) resolution of nonconformances identified in 7S-1, 8.2.1 (c) shall be in conformance with the requirements of this Section; and (e) documentary evidence that items conform to the requirements of this Section shall be. available at the construction or installation site before use or installation.

Requirements for, documentary evidence are satisfied for material when the applicable rules of NCA-3800 and NCA-3900 for material certification are met. For stamped items, the requirements are satisfied by a Data Report.

NCA-4134.8 Identification and Control of Items (a) The provisions of NQA-1, Basic Requirement 8 and Supplement 8-I, shall apply.

(b) Welding and brazing materials for all Classes of construction shall be controlled.

(c) All characteristics required to be reported by the material specifications and by this Section shall appear on checklists, and each such characteristic shall be examined by accepted procedures as required and the results recorded. Characteristics included on Certified Material Test Reports or Certificates of Compliance need not be duplicated in the checklists. Checklists shall provide for a record that the Certified Material Test Reports and Certificates of Compliance have been received, reviewed, and found acceptable. When the results of the examination or test procedure conducted by the Certificate Holder are necessary to show compli-ance with material specification or other requirements, the checklists shall show the required range of values.

The checklists shall include spaces for inclusion of document number and revision to which examination or tests were made; a signature, initials, or stamp; the date of the examination performed by the Certificate Holder's representative; an Authorized Nuclear Inspec-tor's signature, initials, or stamp; and the date on which those activities were witnessed.

NCA4134.9 Control of Processes (a) The provisions of NQA-I, Basic Requirement 9 and Supplement 9S-I, shall apply.

(b) The Certificate Holder shall prepare instructions, procedures, drawings, checklists, travelers, or other 44

NCA4134.9 NCA4000 -

QUALITY ASSURANCE NCA-4134.17 appropriate documents, including the document numbers and revisions to hich the process conforms, with space provided for reporting results of completion of' specific operations at checkpoints of fabrication, manu-facture, or installation. The documents shall include space for a signature, initials, or stamp; the date that the activity was performed by the Certificate Holder's representative; the Authorized Nuclear Inspector's signa-ture, initials, or stamp; and the date on which those activities were witnessed.

NCA-4134.10 Inspection (a) The provisions of NQA-1, Basic Requirement 10 and Supplement 10S-I, shall apply, except for para.

3.1 and the requirements of Inservice Inspection.

(b) The Certificate Holder shall prepare process

-sheets, travelers, or checklists, including the document numbers and revision to which the examination or test is to be performed, with space provided for recording results of examinations and tests. The documents shall include space for a signature,' initials, or stamp; he date that the activity was performed by the Certificate Holder's representative; the Authorized Nuclear Inspec-tor's signature, initials, or stamp; and the 'date on which those activities were witnessed. The examination checklist for construction of items shall be filled in and completed by the Certificate Holder who applies the appropriate Code Symbol Stamp to the item.

(c) Mandatory hold points at which witnessing is required by the Certificate Holder's representative or the Authorized Nuclear Inspector shall be indicated in the controlling documents (NCA-4134.9). Work shall not proceed beyond mandatory hold points without the consent of the Certificate Holder's representative or the Authorized Nuclear Inspector, as appropriate.

NCA-4134.11 Test Control. The provisions of NQA-1, Basic Requirement 11 and Supplement IIS-I, shall apply.

NCA-4134.12 Control of Measuring and Test Equipment (a) The provisions of NQA-1, Basic Requirement 12 and Supplement 12S-1, shall apply.

(b) The Certificate Holder may perform periodic checks on equipment to determine that calibration is maintained. Wohen periodic checking is used, discrepan-cies need only be resolved to the prior check, provided the discrepancy is discovered by the periodic check.

The methods and frequency of periodic checking, when-used. shall be included in the Certificate Holder's Quality Assurance Program.

NCA-4134.13 Handling, Storage, and Shipping.

The provisions of NQA-1, Basic Requirement 13 and Supplement 13S-1, shall apply.

NCA-4134.14 Inspection and Test Status. The pro-visions of NQA-1. Basic Requirement 14, shall apply for inspections and tests, but not for operating status.

NCA-4134.15 Control of Nonconforming Items.

The provisions of NQA-I, Basic Requirement 15 and Supplement 15S-I, shall apply, except that the definition of repair given in this Section shall apply in lieu of repair and rework given in NQA-1.

NCA-4134.16 Corrective Action (a) The provisions of NQA-1, Basic Requirement 16, shall apply.

(b) The requirements shall also extend to the perform-

-ance of the subcontractor's corrective action measures.

NCA-4134.17 Quality Assurance Records (a) General. The provisions of NQA-I, Basic Re-

• quirement 17 and Supplement 17S-1, shall apply, except that the requirements for classification in 17S-1, 2.7, retention of records in 17S-1, 2.8, and facility in 17S-1, 4.4 are not applicable. Such records shall be classified and maintained as required by this Section.

(b) Records Index. The records shall be indexed.

The records and the indices thereto shall be accessible to the Owner, Owner's designee, and Authorized Nuclear Inspector.

(c) Reproduction of Radiographs. Radiographs may be reproduced provided the following requirements are met:

(1) the reproduction process shall be subject to the Owner's approval; (2) when radiographs are reproduced for either an Owner or Certificate Holder, the Quality Assurance Program of the Certificate Holder responsible for the reproduction process shall include a system for control-ling and monitoring the accuracy of the process so that the image, when reproduced to its original size, will provide the same information retrieval capability as the original radiograph; (3) procedures shall contain applicable require-ments pertaining to exposure, scanning, focusing, con-trast, resolution, and distinguishing film artifacts that might appear as material discontinuities in the repro-duced image.

(d) Lifetime Records. For Classes 1, 2, CS, MC, CC, and CB, the records listed in Table NCA-4134.17-1 shall be classified as lifetime records. For Class 3, only records 1, 2, 3, 4, 8, 9, 15, and 16 in Table NCA-4134.17-1 shall apply. The Certificate Holder shall be responsible for the retention and maintenance of these 45

Table NCA-4134.17.1 1998 SECTION III, DIVISION I -

NCA Table NCA4134.17-2 TABLE NCA-4134.17-1 1 LIFETIME QUALITY ASSURANCE RECORDS Record

1. Index to lifetime records NCA-4134.17)

2. Code Data Reports (NCA-8400)

3. Design Specification (NCA-3250) [Note (3)]

4. Design Output Documents, Division 1 (NCA-3350 and NCA-3550) Note (3)]

5. Design Report, Division 2

6. Overpressure Protection Report NB-7200, NC-7200, or ND-7200)

7. Construction Specification (NCA-3340)

8. As-built drawings (NCA-3454)

9. Certified Material Test Reports (CMTR) and documentation providing traceability to location used, if required NX-4122)

Record

10. Records of post-tensioning sequence, procedure, and loads

11. Heat treatment records Note (2)]

12. Qualification test reports such as for concrete design mixes (CB-2460 and CC-2460) and safety valves (NB-7700)

13. Structural integrity test reports (CB-6260 and CC-6260)

14. Final hydrostatic and pneumatic test results (NCA-5280)

15. Final nondestructive examination reports; final radiographs as specified by the Owner for Section Xl applications

16. Repair records when required by Code (NX-4130)

17. Weld procedures

18. Construction Report (NCA-3454)

NOTES:

(1) Nonconformance reports that affect those records listed shall be incorporated into the record or be retained with the records.

(2) Either heat treatment charts or certified summaries of time and temperature data may be provided. These data may be included as part of the CMTR.

(3) For supports designed by Load rating the Load Capacity Data Sheet is the Design Output Document to be maintained as a lifetime quality assurance record. For standard supports designed by analysis and supplied with a Certified Design Report Summary the Certified Design Report Summary is the Design Output Document to be maintained as a Lifetime quality assurance record.

TABLE NCA-4134.17-21 NONPERMANENT QUALITY ASSURANCE RECORDS Record Retention Period

1. QA Program Manual

2. Design procurement and QA procedures (NCA-4134.5)

3. Installation and NDE procedures (NX-5112)

4. Personnel qualification records (NX-5520 and NX-4322)

5.

Purchase orders

6. Audit and survey reports (NCA-4121 and NCA-4134.18)

7. Final radiographs not covered in Table NCA-4134.17-1, Record 15

8. Calibration records (NCA-4134.12)

9.

Process sheets, travelers, or checklists (NCA-4134.10)

10.

Rebar splice test reports (CB-4330 and CC-4330)

11. Joint-welder identification records when such records are used in lieu of physical marking of welds (NX-4322) 3 years after superseded or invalidated 3 years after superseded or invalidated 10 years after superseded or invalidated 3 years after superseded or invalidated 10 years after superseded or invalidated 3 years after completion of report 10 years after completion Until recalibrated 10 years after completion 10 years after completion of report 10 years after completion of report NOTE:

(1) Nonconformance reports, which affect those records listed and are not incorporated into the record, shall be retained for the retention period applicable to the record the nonconformance report affects.

46

I NCA 4134.17 NCA4000 -

QUALITY ASSURANCE NCA4134.18 records while they are under his control. The Owner shall be responsible for retention and maintenance of those records which are transferred to him.

(e) Nonpermanent Records. For Classes 1, 2, CS, MC, CC, and CB, the records listed in Table NCA-4134.17-2 shall be classified as nonpermanent records.

For Class 3, only records 3, 7, and 8 in Table NCA-4134.17-2 shall apply. The Certificate Holder shall be responsible for their retention for the period specified in Table NCA-4134.17-2. In no case need nonpermanent records be retained for longer than 10 years after completion of applicable Code Data Report.

NCA-4134.18 Audits (a) The provisions of NQA-I, Basic Requirement 18 and Supplement 18S-1, shall apply.

(b) Results of audits shall be made available to the Authorized Nuclear Inspector.

(c) The audit frequency shall be specified in the Certificate Holder's Quality Assurance Manual. The Certificate Holder's audit frequency shall be commensu-rate with his schedule of activities and shall be such that each ongoing Code activity is audited at least once annually.

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NF-4322.1 1998 SECTION HI. DIVISION I -

NF NFZ4334.2 (1) the Certificate Holder maintains a system that conform to the requirements of Section IX, except that will identify the welders or welding operators who the removal of impact test coupons and the dimensions made such welds on each item so that'the Inspector of impact test specimens shall be in accordance with can verify that the welders or welding operators were (b) below.

all properly qualified:'

(b) Weld deposit of each process in a multiple process (2) the welds in each category are'all of the same' weld shall, where possible, be included in the impact type and configuration and are welded with the same test specimens. When each process cannot be included Welding Procedure Specification.

in the full-size impact test specimen at the /4t'location NF-4322.2 Identification of Other Joints. For all types of Class 2, 3, and MC component supports and for all classes of piping supports and Standard Supports, the Certificate Holder shall certify that only welders and welding operators qualified in accordance with NF-4321 were used in making all welds.

NF-4322.3 Identification of Tack Welds. The identi--

fication of welder or welding operator is not required for tack welds.

NF-4323 Welding Por to Qualification No welding shall be undertaken until after the welding procedures which are to be used have been qualified.

Only welders and welding operators who are qualified in accordance with NF-4320 and Section IX shall be used.

NF-4324 Transferring Qualifications The welding procedure qualifications and the perform-ance qualification tests for welders and welding opera-tors conducted by one Certificate Holder shall not qualify welding procedures and shall not qualify welders or welding operators to weld for any other Certificate Holder, except as provided in Section X, QW-201 and QW-300.2.

NF-4330, GENERAL REQUIREMENTS FOR WELDING PROCEDURE QUALIFICATION TESTS.

NF-4331 Conformance to Section IX Requirements All welding procedure qualification tests shall be in accordance with the requirements of Section X as supplemented by the requirements of this Article.

NF-4334 Preparation of Test Coupons and Specimens (a) Removal of test coupons from the test weld and the dimensions of specimens made from them shall required by this Section, additional full-size specimens shall be obtained from locations in the'test weld that will ensure that at -least a portion of each process has been included in full-size -test specimens. As an alternative, 'additional test welds can be made with each process so that full-size specimens can be tested for each process.

NF-4334.1 Coupons Representing the Weld Depos-its. Impact test specimen and testing methods shall conform to NF-2321. The impact specimen' shall be located so that the longitudinal axis of the specimen is at least 1/4t, and where the thickness of the test assembly permits, not less than 3 in. (10 m) from the weld surface of the test assembly. In addition, when the postweld heat treatment temperature exceeds the maximum temperature specified in NF4620, and the test assembly is cooled at an accelerated rate, the longitudinal axis of the specimen shall be a minimum of from the edge of the test assembly. The specimen shall be transverse to the longitudinal axis of the weld with the area of the notch located in the weld. The length of the notch of the Charpy V-notch specimen shall be normal to the surface of the weld.

NF4334.2 Coupons Representing the Heat Af-rected Zone. Where impact 'tests of the heat affected zone are required by NF4335.2, specimens shall be taken from the welding procedure qualification test assemblies in accordance with (a) through (c) below.

(a) If. the qualification test material is in the formn of a plate or a frging,.the axis of the weld shall be oriented either parallel to or perpendicular to the princi-pal direction of rolling or forging.

(b) The heat affected zone impact test specimens and testing methods shall conform to NF-2321. The specimens shall be removed from a location as near as practical to a depth midway between the surface and center thickness. The coupons for heat affected zone impact specimens shall be taken transverse to the axis of the weld and etched to define the heat affected tone. The notch of the Charpy V-notch specimen shall be cut approximately normal to the material surface in such a manner as to include as much heat affected zone as possible in the resulting fracture. Where the material thickness permits, the axis of a specimen may 114

NFw4311 ARTICLE NF4000 -

FABRICATION AND INSTALLATION tF-4322.1 dure qualification requirements of Section IX and this Subsection shall be used for welding support material or attachments thereto. Any process used shall be such that the records required by NF-4320 can be prepared except that records for stud welds shall be traceable to the welders and welding operators, and not necessarily to each specific weld.

NF-4311.1 Stud Welding Restrictions. Stud welding is acceptable for insulation supports, nameplates, and locating lugs. Studs shall be limited to I in. (25 mm) maximum diameter for round studs or an equivalent cross-sectional area for studs of other shapes when welding in the flat position and 3/4 in. (19 mm) diameter for all other welding positions. When studs are 1/2 in.

(13 mm) in diameter or less, postweld heat treatment, qualified welding procedures, and certified welding ma-terials are not required.

NF-4311.2 Capacitor Discharge Welding. Capacitor discharge welding may be used for welding temporary attachments and permanent nonstructural attachments provided:

(a) temporary attachments are removed in accordance with the provisions of NF-4435(b); and (b) the energy output for permanent nonstructural attachments such as strain gages and thermocouples is limited to 125 W-sec and the minimum thickness of the material to which the attachment is made is greater than 0.09 in.; and (c) a Welding Procedure Specification is prepared describing the capacitor discharge equipment, the combi-nation of materials to be joined, and the technique of application; qualification of the welding procedure is not required.

NF-4311.4 Inertia and Continuous Drive Friction Welding (a) Inertia and continuous drive friction welding shall not be used for fabrication of Class I Plate-and Shell-Type Component Supports.

(b) The weld between the two members shall be a full penetration weld.

NF-4320 WELDING QUALIFICATION AND RECORDS NF-4321 Required Qualifications (a) Each Certificate Holder is responsible for the welding done by his organization and shall establish the procedure and conduct the tests required by this Article and Section IX in order to qualify both the welding procedures and the performance of welders and welding operators who apply these procedures.

(b) Procedures, welders, and welding operators used to join permanent or temporary attachments to support elements and to make permanent or temporary tack welds used in such welding shall also meet the qualifica-tion requirements of this Article.

(c) When making procedure test plates for butt welds, consideration shall be given to the effect of angular, lateral, and end restraint on the weldmnent. This applies particularly to material and weld metal of 80.0 ksi (552 MPa) tensile strength or higher and heavy sections of both low and high tensile strength material. The addition of restraint during welding may result in cracking difficulties that otherwise might not occur.

(d) NCA-3131 provides specific additional require-ments when welding services are subcontracted to or through organizations not holding an appropriate Cer-tificate of Accreditation.

NF-4322 Maintenance and Certification of Records The Certificate Holder shall maintain a record of his qualified welding procedures and of the welders and welding operators qualified by him, showing the date and results of tests and the identification mark assigned to each welder. These records shall be reviewed, verified, and signed by any authorized individual assigned by the Certificate Holder, and they shall be accessible to the Owner and to the Inspector.

NF-4322.1 Identification of Joints for Class 1 Com-ponent Supports (a) For Class 1 Plate-and Shell-Type, and Linear-Type Component Supports, the welder or welding opera-tor shall apply the identification mark assigned to him by the Certificate Holder on or adjacent to all permanent welds, including fillet welds, at 3 ft (0.9 m) intervals or less, except as noted in (b) below. The marking shall be done with either blunt nose continuous or blunt nose interrupted dot die stamps. As an alternative, the Certificate Holder shall keep a record of permanent welded joints in a component support, and of the welders and welding operators used in making each of the joints.

(b) For partial penetration welds with a depth less than I in. and fillet welds with a throat dimension less than I in. in primary members, and for all welds in secondary members, the Certificate Holder need not identify the welder or welding operator who welded each joint provided:

113