ML16340E228

Safety Evaluation Report Related to the Operation of Diablo Canyon Nuclear Power Plant,Units 1 and 2.Docket Nos. 50-275 and 50-323. (Pacific Gas and Electric Company)

ML16340E228
Person / Time
Site:	Diablo Canyon
Issue date:	03/31/1984
From:	Office of Nuclear Reactor Regulation
To:
References
NUREG-0675, NUREG-0675-S22, NUREG-675, NUREG-675-S22, NUDOCS 8403300300
Download: ML16340E228 (26)

Text

NUREG4675 Supplement No. 22 SaFety Eval!@ation IReport related to the operation of Diablo Canyon Nuclear Power Plant, Units 'l and 2 Docket Nos. 50-275 and 50-323 Pacific Gas and Electric Company U.S. Nuclear Regulatory C.ommission Office of Nuclear Reactor Regulation March 1984 Kirsch Exhibit 3

Task:

Allegation or Concern Nos.

103, 104,

105, 106,

107, 108,

109, 110,

111, 112,

113, 114,

115, 116,

117, 118,

119, 214,

215, 216, and 217 ATS No:

RV-83-A-0074 BN No:

84-009 (1/16/84)

Characterization Multiple all~nations associated with a failure of the licensee and Pullman

'I Power Products to meet required codes and standards for welding pipe supports and pipe wh'g restraints.

Im lied Si nificance to Desi n

Construction or 0 eration The failure to meet stated codes and standards in the fabrication of pipe supports and pipe whip restraints may result in components which would not perform their intended safety function.

Assessment of Safet Si nificance The allegations or concerns discussed in this section were received in the form of a 35, page letter from the alleger to a

NRC Commissioner.

Attached to t

the letter were numerous documents provided to support the allegers concerns.

The staff's general approach to address these concerns was to interview the

alleger, examine the contractors and licensee's written requirements, examine pertinent procedures, documentation, and to conduct interviews with personnel, as appropriate.

A. 4"103. 1

tp

The alleger's written submittal and interview included multiple cross referencing of issues.

The staff did not examine every example of each type of issue individually, but.instead focused on the substantive technical and quality concerns by grouped topics.

Many of the issues were topics which had been formally documented and addressed by the licensees and contractor's control programs.

The staff directed special attention to where the licensee and contractors addressed these items in a responsible manner.

The staff has placed the issues into 21 topics.

These are discussed individually below.

1.

Alle ations 103 104 and 105:

Pullman Welding Procedure Specification (WPS) 7/8 was inappropriately applied in that deviations from WPS 7/8 existed in the following areas:

(a) structural

shapes, (b) weld joint geometry, (c) materials Staff Position (a)

The alleger is correct that WPS 7/8 was used to weld structural shapes in addition to piping and plate as specified in the WPS.

However, the structural shape of the member is not required to be included in the WPS.

All structural

shapes, such as W,

H beams and angle iron, shall have the connecting sections prepared to conform to the weld joint configuration of the qualified WPS.

The structural shapes are identified on the design drawings.

A.4-103.2

h

procedures that were not qualified and/or did not provide welding specifications for the base metals, structural.steel

shapes, and a point configuration was used.

These deviations have spanned the whole construction program for both pipe supports and nd includes what I call the current design modification program which I believe is the result of the redesign engineering program on pipe supports.

I do not believe that ther'e is any authorization from PG&E, to deviate from these weld procedure specifications.

Also, weld procedure specifications have been prepared and used by Pullman and approved by PG&E that were not properly qualified for the AWS code as reauired by Contract Specification 8833XR.

This issue i

deals mainly with Additional welding has been performed which did not comply with the weld procedure

codes, processes specified on process

sheets, and approved by the proper authorities.

It is my feeling, my allegation, that Pullman QC management has attempted to justify and/or coverup this breach of quality assurance by implyinq that production had the authority to disregard these process sheet instructions.

The last issue is there have been deviations from PG&E's contract specification 8711 and 8833XR, welding requirements for which there are no PG&E contract specification change notices and/or proper management authorization.

Now the term 'contract specification change notice's my term.

I am not sure what terminology PG&E would use to indicate revisions to their contract specifications.

The most immediate and most pressing problem I feel is Weld Procedure Code 7-8.

That is Pullman's Hudson/1-6-84 4

Kirsch Exhibit 4

p 1~V

ASME quality assurance program requirements were virtuallv

~ identical to those contained in 10 CFR 50 Apoendix B.

HUDSON:

So the distinction would be almost linguistic.

KIRSCH:

That was my impression.

My feeling is Pullman has violated 5 or '6 sections of auality assurance reauirements in the contract specifications and probably as many of 10 CFR 50 Appendix B.

These violations that I feel have been pertinent are referenced in the report.

Any questions over this point or shall we move on to the next areas' KIRSCH:

I might ask you a general gu~.-tion.

If this r

fabrication was in accordance with NF in~Lead of specifications that they used, would you feel all of these questions would be the same'?

HUDSON:

You say NF, are you referring to the ASME Code~

Well, ASME has no bearing here, in my opinion.

ve to conform to the AWS code.

It is also my contention that strucural steel pipe supports have to comply with the AWS code.

That is one of the allegations in this report.

That is the base of this problem.

They are using an ASME welding procedure, deviating from that welding procedure to weld structural steel items other than plate and these items should be welded to the AWS code.

The next item as far as resort goes is I'd like to make some comments about the welding techniaue specification No.

AWS ll, which is supposed to clarify the use of Code 7-8.

In my opinion it has a number of deficiciencies as listed in the report.

Hudson/1-6-84 18

HUDSON:

Well, these welders were all ASME aualif ied.

They were qualified to Code 92-93.

They were ASME aualified.

To an open butt'P HUDSON:

The Code 92-93 is an open butt procedure.

If they were qualified to 92-93 they should have been qualified for open butt welding.

Now, the problem here with using this Code 7-8 require a backing bar.

What they'e done is they'e brought in welders qualified for one procedure to weld supposedly to another procedure, but they'e using Code 92-93 in lieu of the required Code 7-8.

Now, what concerns m ~ is that these guys are probably qualified for open butt, crualified for GTA process, but those items are not.rupture restraint welding processes.

So, we have a break down in the quality assurance, quality control item here.

Now the difficulty in this particular identification, if you look at the process

sheets, the process sheets are going to say everything is welded to Code 7-8.

Now, I have not identified any particular rupture restraints or welds for this problem takes place because I did not have access to the rod requisition.

The rod requisition is going to be the only way to identify where this Code 92-93 was used in the pipe rupture restraints.

The paperwork, all the other paperwork says Code 7-8 was used.

The rod reauisitions, per this memo by the consistent QAQC Manager, identified the work being done as Code 92-93.

I'd like to make an allegation here that this letter by the Assistant QAQC Manager is an attempt to justify, I'l add coverup, a serious breach in the quality assurance program for this welding procedure.

Again, that's an Hudson/1-6-84 54

< sP

+"

"~

Nuclear Regulatory Commission April 12, 1984 Page 5

until after the March 19, 1984 Commission meeting:

inaccurate Operation Valve Identification Diagrams (OVID) for use by the reactor operators, which include such serious discrepancies as valves on the wrong side of other components.

(March 1 petition,

p. 42).

This problem is particularly significant, since there is no

. dissent within the Commission that reactor operators should "know the plant cold."

(March 27 transcript at 213, statement of Chairman Palladino).

a generic breakdown in design control through the quick fix program.,P in which major design changes were approved on-the-spot to accommod'i~<

construction plans, without normal engineering review and supportinq analysis.

(March 1 petition, pp. 19-21).

pressure by the Bechtel Corporation that employees who resigned should sign a statement that they were not aware of any design, pro-fessional code, or quality assurance violations -- despite common knowledge to the contrary.

This left honest employees in an illegal "Catch-22" at a critical period: either they could Iie to the Govern-ment or risk industry blacklisting.

(March 1 petition, p. 41).

knowingly false statements in licensee responses to previous employee allegations, illustrated by PG&E's February 7 assertion to the NRC that the lack of consistent weld symbols to guide personnel had no safety significance.

(March 1 petition, p. 28).

Instead of investiga-ting this new "wrinkle," the staff accepted at face value the licensee's alleged false statement as a basis to "resolve" the original weld symbols issue.

December 28, l983 procedural changes that denied inspectors the ability to reject welding on pipe supports, even when a weld that was required by the design did not even exist.

(March 1 petition, p, 6).

The March 23 disclosure also contained more than mere "wrinkles."

For

example, one affidavit revealed a continuing "mirror image" problem with electrical installations by the Foley Corporation.

In January

1983, super-visors called an employees meeting to try to resolve the issue.

Unfortunately.

the meeting broke up when the supervisors could not agree among themselves what was forward and what was backward.

(Harch 23 disclosure, Attachment 12, p. 4).

Follow-u interviews.

. The. staff has made a mockery of its written policy and verbal commitments that allegations would not be closed out without follow-up interviews to insur e accurate resolution of the issues.

The staff also misled the Commission on this issue.

To illustrate, on Harch 27 Hr. Martin said that it was "just not a true statement" that Region V had failed to schedule follow-up interviews.

He referred to Region V's communications with Mr. Hudson, Pullman's former internal auditor:

Kirsch Ex!obit 5

The aame Dian out th re intimidation and harassment type thing.

seems to be to keep the inspector overworked.

We work 60 to 70

~ 'v hours a week.

Up until recently, when we renegotiated our

contract, and we still aren't being paid this yet, but we were being paid very low compared to the other craf ts out there, and compared to our level of responsibility, you'e got, you'e signing permanent plant-life oocumentation out there, and there' the. guy-s~eeping the floor making more money than you are.

Which is, you know, just kind of hard to swallow.

In some cases, it' just,if ied.

v KIRSH:

Well, there' not a lot that I can Bo about that.

Well, we already took care of that, somewhat.

You know,=,overwor ked, you get fatigued, you'e always told, I'e been told I don'.t know how many weekends now, you'e going to work Saturday and Sunday.

I told them well, I don' really. want to work Sunday.

Well, if you don',

you could be subject to terminatiogq That' routine out there.

The inspector is always, under Connor's

program, is generally not encouraged to find out

.what specs and codes he' supposed to be working to.

You'e got supervisors that are telling you that if 7t's not addressed in the ESDs 'which are our specs, that you are riot to look anv further.

You are to just buy it because it's not addressed in the ESD.

Steve' addressed thatone certain incLividual is more blatant about that anyone else.

LOCKERI':

He told me specif ically that I could not look in the AISC Construction 1ianual, the ANSI ASTl> Standards or the ASi~

code.

I was not to look at anythinq bevond the KSD.

Let' see if I can find that for you.

October 17th incident pretty much. --

NBC-1 / 1-5-84 -'3 CuJ.

e 7~rcrb 7Mb'lblt

S'

KlRSH:

That' an understatemen".

I still-haven' dioested all of thi s.

It' tough.

Esp cially from a non-technical standpoint, it's hard to reallv latch on to...

??:

The immense transf er of information, you can' rea' digest it all in a short amount of time.

What we were mos tlv concerned wi th wer e the ev=nts

~ r leadina up to Steve',

you know, mostly I'm substantiate what he' here to tell you.

KIRSH:

- Why donou kill it because I just want to read here for a minute and.make sure that I understand what' in the-letter.

CLEWETT:

I got plenty of "ape, unless...

KIRSH:

October'th, you say, vou reauesteo the spec penetration while attaching the stanchions of a pipe, you found a

cover plate was on the clean end of the stanchion and you a=-kec them to move it, and they'didn' remove it.

Where was this at, what stanchion, roughly?

LOCKERT: It was -in Unit 2, I believe, probably the 91

-1'e ve1.

'.KIRSH Is this in your'og also?

LOCKERT:

Yeah, there' a -note in there,

saying, prevented me for taking the cover plate off.

KIRSH:

And it tells what stanchion was?

LOCKERT:

Yeah, it would be in my daily log.

KIRSH:

Daily log,, I should be ab"e to pick that up.

NRC-1 /

., 1-5-S 4 58

S

LOCKZR7:

Yeah, there will be a little note savin revented me from taking the cover plate off.

Well, Tim, before we go, we pr oba bly ought to fill them in on each

one, or have you already?

l'm not saying we should leave riaht

now, bu" be ore we come to a conclusion.

CLEH=TT.:

Ne'e not aui te ha" f done with the available tape so if you have as much again as you'e talked about already...

LOQERr:

Tim here is a pretty deep well when it comes to

\\

fielding.

We'e spent many a night talking about our jobs.

The nuts'and hol ts out ther'e on the thinas that wor k, the containment -liner studs.

I have another packaae her

~

~ C this is a snubber.

on a feedwater line and it' a desian class 1,

coae class E line, it's out on the pipe rack.

The way I aot t

involved with this the snubbers, they was 'it was reissued because they had to swap took a snubber off of one location where t.hev needed a matched set and they took the snubber that was at this location and-moved it over there and movea that snubber over here.

And they had to go back out and read 's built'n the

drawing, the pin to pin" dimension of the snubber and the snubbe

', seri al number. - Well, when

. the" as builder, went out there,'ou know what an as builder's'nd all that, when he walked out

. ther e, halooked at it and conceded the welaina on the plate was" o'bviously deficient.

So it got to pe throuah our department through my lead at the time, and he said ao out and write a D~

on this because they didn' as built this BH4678 right here, which only addresses the oversize wells,'t Boesn' address the undersize wells on this thing.

Okay, this is all disaosi tioned NRC-1 / 1-5-84 59

I 0

intimidation and harassment type thing.

The aame plan out there seems to be to keep the inspector overworked.

We work 60 to 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> a week.

Up until recently, when we renegotiated our

contract, and we still aren't being paid this yet, but we were being paid very low compared to the other craf ts out there, and compared to our level of responsibility, you'e got, you'e signing permanent plant-life documentation out there, and there' the guy sweeping the floor making more money than you are.

Which is, you know, just kind of hard to swallow.

In some cases, it' jus tified.

I KIRSH:

Well, there' not a lot that I can do about that.

O'EILL:

Well, we already took care of that, somewhat.

You know, overworked, you get fatigued, you'e always told, I'e been told I don' know how many weekends now, you'e going to wor k Saturday and Sunday.

I told them well, I don' really want'o work Sunday.

Well, if you don',

you could be subject to termination.

That' routine out there.

The inspector is alwaysg under Connor's

program, is generally not encouraged to find out what specs and codes he' supposed to be working to.

You'e got supervisors that are telling you that if it's not addressed in the ESDs which are our specs, that you are not to look any further.

You are to just buy it because it's not addressed in the ESD.

S teve' addressed

that, one certain individual is more blatant about that anyone else.

LOCKERP:

He told me specif ically that I could not look in the AISC Construction Manual, the ANSE ASTM Standards or the ASME code.

I was not to look at anything beyond the ESD.

Let' see if I can find that for you.

October 17th incident pretty much...

NRC-1 / 1-5-84 -'3 Kirsch Exhibit 6

KIRSH:

That' an understatement.

I still haven' diqes ted all of thi s.

O'EILL: It' tough.

Especially from a non-technical standpoint, it's hard to really latch on to...

??:

The immense transf er of information, you can' reallv digest it all in a short amount of time.

O'EILL:" What we were mostly concerned with were the events

'I leading up to Steve',s, you know, mostly I'm substantiate what he's here to tell you.

KIBSH-Why don' you kill it because I just want to read here for a minute and make sure that I understand what' in the letter.

CLEWETT:,I got plenty of Rape, unless...

KIRSH-October 4th, you say, you reauested the spec penetration while attaching the s tanch ions of a pipe, you found a

cover plate was on the clean end.of the stanchion and you asked them to move it, and 'they didn' remove it.

Where was this at, what stanchion, roughly?

LOCKERT: It was in Unit 2, I believe, probably the 91 le ve 1.

KIRSH:

Is this in your log also?

LOCKERT:

Yeah, there's a note in there,

saying, prevented me for taking the cover plate off.

KIRSH:

And it tells what stanchion was?

LOCKERT:

Yeah, it would be in my daily log.

KIRSH:

Daily log, 'I should be able to pick that up.

NRC-1 / 1-5-S4 58

LOCKERT:

Yeah, there will be a little note aayino~

prevented me from taking the cover plate off.

Well, Tim>

before we go, we probably ought to fill them in on each

one, or have you already?

I'm not saying we should leave riqht now, but before we come to a conclusion.

CLEWETT:

We'e not auite half done with the available tape so if you have as much again as you'e talked about already...

LOCKERT:

Tim here is a pretty deep well when it comes to welshing.

We'e spent many a night talkinq about our jobs.

O'EILL:

The nuts and bolts out there on the things that wcirla, the containment liner studs.

I have another packaqe

here, this is a snubber on a feedwater line and it's a design class 1,

code class E line, it's out on the pipe rack.

The way I got involved with this was it was reissued because they had to swap the snubbers, they took a snubber off of one location where they needed a matched set and they took the snubber that was at this location and moved it over there and moved that snubber over here.

And they had to go back out and read 's built'n the

drawing, the pin to pin dimension of the snubber and the snubber serial number.

Well, when the as builder went out there, you know what an-as builder is and all that, when he walked out

there, he looked at it and conceded the welding on the plate was obviously deficient.

So it got to me through our department through my lead at the time, and he said go out and write a DCN on this because they didn' as built this BR4678 riqht here, which only addresses the oversize wells; it doesn' address the undersize wells on this thing.

Okay, this is all dispositioned NRC-1 / 1-5-84 59