ML16341B738
| ML16341B738 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/18/1981 |
| From: | GILBERT/COMMONWEALTH, INC. (FORMERLY GILBERT ASSOCIAT |
| To: | CLEVELAND ELECTRIC ILLUMINATING CO. |
| Shared Package | |
| ML16341B739 | List:
|
| References | |
| CON-044549-000, CON-44549 D-215-445, NUDOCS 8112040106 | |
| Download: ML16341B738 (18) | |
Text
Attachment to GAP ¹314.08.01
Reference:
NRC Inspection Report Nos. 50-275/84-36 and 50-323/84-23 November 21, 1984 U. S.
NUCLEAR REGULATORY COMMISSION Dated REGION V Page 2 of 5 Report Nos. 50-275/84-36 and 50-323/84-23 Docket Nos. 50-275 and 50-323 License No:
DPR-76 Construction Permit No.:
CPPR-69 Licensee:
Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, California 94106 Facility Name:
Diablo Canyon Units 1 and 2
Inspection at:
Diablo Canyon Site, San Luis Obispo California I
7 Inspectors ---4---- ------ -+
M. M. Mendonca, Sr. Resident Inspector
- County, jar>joe Date Signed M. L. Padovan, Resident Inspector Da'te Signed T.
M. Ross, Resident Inspector Date Signed
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~ wow T. J. Polich, Residen nspector wwww w
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A. Hon, Reactor Inspector Approved ~>>--
W&W R. T. Dodds, Section Chief r/ /3 Date Signed l~ ~y Date Signed Summary:
Inspection from August 27, through October 26,1984, (Report Nos.
50-275/84-36 and 50-323/84-23).
involved 301 inspection hours by five inspectors.
Results:
No violations or deviations were identified.
Attachment to GAP b'314.08.01 4
Reference:
NRC Inspection Report Nos.
50-275/84-36
& 50-323/84-23 Dated:
November 21, 1984 Page 3 of 5 The staff finds that the alleger's concern was previously identified during a Pullman audit, and was addressed and resolved in a responsible and satisfactory manner.
The staff did not find any evidence to indicate that the alleged condition was anything other than an isolated. instance.
e.
Action.Re uired None.
No violations or deviations were identified.
4.
Task:
Alle ation or Concern No.
262 ATS No. RV"84-A-052 a
~
Characterization r
Pullman management instructs inspectors to violate contract specifications by stamping on the weld because it was not prohibited.
b.
Im lied Si nificance to Plant Desi n Construction or eration Weld stamping on the weldment may inhibit visual examination and form sites for crack initiation.
c.
.Assessment of Safet Si nificance During a routine QC walkdown, a contractor inspector observed one field weld with identification stamping on the weldment surface.
Subsequently, a memo dated July 15, 1982 was sent to the Pullman QA/QC manager requesting clarification of weld stamping requirements.
In a written response dated July 19, 1982 the QA/QC manager stated the weld was acceptable because stamping on the weld surface was not prohibited by the applicable Engineering Specification Diablo (ESD).
The inspector reviewed the American Welding Society (AWS) Code Dl.l, applicable ESD's and PGK specifications, the July 15 memo to the QA/QC manager, and the written response of July 19 to the QC inspector.
Furthermore, interviews were conducted of several QC inspectors, the QA/QC manager, and the Pullman QA auditor.
The staff considers that the Pullman QA/QC manager's response did not instruct inspectors to violate contract specifications;
- further, that it was not the intent, of the memo, to instruct inspectors to violate contract specifications.
PGSE contract specification 8833XR was the applicable controlling document for QC work referenced in the memo.
ESD-243 "Pipe Rupture Restraints,"
had been derived from this specification to provide necessary amplifying instructions for implementation in the field.
Neither the PG&E specification 8833XR nor ESD-243 mention any requirements for stamping adjacent to the weldment.
Though the QC inspector states within the memo that
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Attachment to GAP f314.08.01
Reference:
NRC Ins'pection Report Nos.
50-275/84-36 8 50-323/84-23 Dated:
November 21, 1984 ESD-203/204 (Welding Stamping, Reinforcement, and undercutting)
Page 4 of 5 prescribes stampihg adjacent to the weld, this ESD was related to PG&E contract specification 8711 (the piping and pipe support specification),
not to the applicable specification 8833XR.
Weld work related to EDS-243 and PG&E specification 8833XR did not prohibit identification stamping upon the weldment.
In the non-mandatory commentary of AWS Dl.l Section 6.5, "Die stamping of welds is not recommended since die stamp marks may form sites for crack initiation."
The NRC inspector was not able to locate the weldment which may have originally precipitated'he contractor inspector's memo because the memo did not provide such specifics; nor did the allegation provide weldment specifics.
Within the memo of July 15, the QC inspector states stamping upon the weldment was assumed in the past to be an unacceptable practice.
In truth, the practice of stamping upon the weldment is extremely rare at the Diablo Canyon site for the following basic reasons:
1) stamping on the weldment is generally understood, by welders and inspectors, to be an undesirable practice based upon their knowledge of specification 8711 (the piping and pipe support specification);
- 2) the base metal is much more accessible for stamping; and 3) recognition by welders and inspectors that weldment stamping may interfere with non-destructive examination.
Interviews by the inspector with Pullman QC inspectors and QA personnel corraborated the aforementioned statements, and did not identify or indicate any other examples of stamping on the weldment surface.
Furthermore, Lawrence Liv rmore Laboratory inspectors, who have performed independent onsite examinations of several thousand field welds, have not identified any instances of die stamp marks on weldment surface.
In conclusion, the inspector found no evidence of any pervasive problem associated with Pullman welds being stamped upon the weldment.
The instance appears to be an extremely unusual occurrence which was not specifically prohibited by the applicable procedure and industry code.
Staff Position Pullman's management response was appropriate and did not violate contract specifications.
The staff concludes that the concern implied by the inspecotr's memo certainly does not represent a
situation which occurred on any wide-spread basis; in fact the alleger, in his memo, did not identify any weld on which stamping occurred.
The staff recognizes that stamping on structural steel weldments is discouraged but not prohibited by the Structural Welding Code; therefore, this does not represent a Code violation.
This allegation is considered closed.
Action Re uired
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Attachment to GAP ¹314.08.01
Reference:
NRC Inspection Report Nos.
50-275/84-36 5 50-323/84-23 Dated:
November 21, 1984 Page 5 of 5 None.
No violations or deviations were identified.
5.
Task:
Alle ation or Concern No. 475 ATS No:
RV-84-A-062 a.
Characterization Magnetic particle exams for a NDE Supervisor do not show his grade.
b.
Im lied Si ificance to Plant Desi n Construction or eration The NDE supervisor may not be adequately qualified to perform NDE inspections or his assigned job functions.
Co Assessment of Safet Si nificance This item was addressed by examining the NDE Supervisor's qualification
- record, answer keys for magnetic particle test (MT) examination, and applicable procedures and standards pertaining to the examination.
Contrary to the alleger's concern,, only a composite score is required by American Society for Nondestructive Testing (ASNT) No. SNT-TC-lA. Additionally, SNT-TC-lA requires qualification records to contain current copies of examinations, descriptions of practical test objects, and the specified'ercentile weight of each examination or practical test, all of which were contained in the NDE supervisor's qualification record.
The NDE Supervisor had examination individual scores of 100'/ general, 86.68/
- specific, and 100'/. practical, for an overall composite score of 96/.
d.
Staff Position Although individual test scores were not listed in the NDE supervisor's qualification record, as stated by the alleger, these were not required and only a composite score was required. All other required information was available in the NDE supervisor's qualification record and a satisfactory composite score was obtained.
No violations or deviations were identified.
e.,
Action Re uired None.
No violations or deviations were identified.
6.
Task:
Alle ation or Concern No. 482 ATS No:
RV-84"A-065 a.
Characterization-
0
GAP Allegation f314.08. 02 It is alleged that:
I protest that the staff failed to discuss either in its inspection report or our closeout interview a significant portion of allegation 5'262 whether Pullman's management acted properly by vetoing my challenge of.
procedural inconsistencies as to weld stamping, which is contrary to well-known practices of sound construction, merely because the Pullman procedures do not discuss the subject.
(1/21/85 NcDermott Aff. at 2.)
There was no veto of the alleger's "challenge of procedural inconsistencies."
A question was asked and answered pursuant to procedure.
See the preceding response to 314.08. 01.
0362S/0034K
GAP Allegation f314.08.03 It is alleged that:
1 The NRC staff improperly failed to examine a major portion
'f my allegation on tool control why Pullman waited over a year to act on the Deficient Condition Notice that I authored on the misconduct I had observed.
(1/21/85 HcDermott Aff. at 3.)
Review of the previous response to this allegation (JI 197 8 198, NRC Allegation $278 and 279, see attachments) acknowledged the lengthy time interval for closure of DCN 777-013 (attached),
but determined that this delay was in part due to the alleger's refusal to accept the findings of the investigation conducted by his leadman and modify or cancel the DCN in accordance with these findings.
As a result, after the alleger was terminated, a review of his DCN log revealed that the DCN was still listed as open.
The DCN was then closed on January 23, 1983 by the
()A/l}C Manager per procedure.
This allegation was resolved by the NRC in NRC Inspection Report Nos.
50-275/84-11 and 50-323/84-11, dated July 13, 1984, at pp 13-15 (attached),
and SSER 26, at pp A.3-1, A.4-278.1, and A.4-279.1.
0362S/0034K 0
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e PULLMAN POWER. PRODUCT Atta~h~~~t to GAP ¹314.08.03
Reference:
DCN 777-013 ICIllNTACONDI'PION, NOT E
ated November 12, 1981 UNIT ¹ AR V
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Attachment to GAP 8314.08.03
Reference:
DCN 777-013 Dated:
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Attachment to GAP b'314.08.03
Reference:
DCN 777-013
. Dated:
November ld, 1981 Page 3 of 9