ML17083B634
| ML17083B634 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/19/1985 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| Shared Package | |
| ML17083B635 | List: |
| References | |
| NUDOCS 8508080584 | |
| Download: ML17083B634 (26) | |
See also: IR 05000211/2007017
Text
Docket Nos. 50-275
and 50-323;,'i,':"> fan&.",
Pacific Gas
and Electric Company
77 Beale Street,
Room 1451
San Francisco,
California 94106
Attention:
Hr. J.
D. Shiffer, Vice President
Nuclear Power Generation
Gentlemen:
Subject:
NRC Inspection of Diablo Canyon Units
1 and 2
This refers to the special inspecti'ons
conducted
by ILAIL inspectors
under
contract to this office during the period of February ll through July 17,
1985, of activities authorized
by NRC I,icense Nos.
Areas
examined during this inspection are described in the enclosed
inspection
report.
Within these
areas,
the inspection consisted of selective
examinations of procedures
and representative
records,
interviews with
personnel,
and observations
by the inspectors.
No violations of NRC requirements
were identified within the scope of this
inspection.
In accordance
with 10 CFR 2.790(a),
a copy of this letter and the enclosure
will be placed in the
NRC Public Document
Room.
E
Should you have any questions
concerning this inspection,
we will be glad to
discuss
them with you.
Sincerely,
.
>.'.
~ t~(;1
c>r s1C8 Ef
D. $'e Ci.'rsih, Acting Director
Divisio'n of Reactor Safety
S Projects
Enclosure:
Inspection Report Nos. 50-275/85-27
and 50-323/85-24
CC;
Jim Knight, NRR
S. D. Skidmore,
R.
C. Thornberry,
(Diablo Canyon)
P. A. Crane, Jr.,
PGEZ
D. Taggart,
(Diablo Canyon)
R. Weinberg,
(Diablo Canyon)
Sandra Silver (report only)
State of CA
bcc:
RSB/Document Control Desk
(RIDS)
Hr. J. Hartin
Resident Inspector
RV
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Diablo Canyon
SSER-33
8508080584
8507f9
hDQCK 05000275
Q
B. 5-1
Appendix
B
U. S.
NUCLEAR REGULATORY COMMISSION
REGION U
Report Nos.
50-275/85-27
and 50-323/85-24
Docket Nos.
50-275
and 50-323
License
Nos.
DPR-76 and
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 County, California
Inspection
conducted:
February
11 - July 17,
1985
Inspectors:
LLNL Contract Inspectors
Approved By:
R. T.
Do ds, Chief
Reactor Projects Section
1
7z
Pr-
ate Signed
Summary:
Ins ection from Februar
11 throu h Jul
17
1985
(Re ort Nos. 50-275/85-27
and 50-323 85-2
Areas Ins ected:
Followup of various allegations pertaining to plant
construction.
Results:
No violations or deviations
were identified.
Diablo Canyon
SSER-33
B.5-2
Appendix B
DETAILS
1.
Persons
Contacted
M. Tressler,
Project Engineer
D. Rockwell, Unit 2 Construction Superintendent
J. Bratton,
PGSZ Allegation Coordinator
D. Dunham,
PGSE
QC Engineer
T. Pierce,
QC Engineer
S. Pascal,
PTGC Electrical Department Engineer
W. Cadwell,
PTGC Electrical Inspector
R. Ortega,
PTGC Electrical Department Engineer
C. Warne,
PTGC Instrument
and Control Department Supervisor
J. Gisclon,
PGSE Assistant Plant Manager
K. Doss,
PGGE Onsite Safety Review Group Mer,'r
H. Karner, Pullman,
QA/QC Site Manager
J. Guyler, Pullman, Internal Auditor
C. Neary, Pullman,
QC Supervisor
C. Gunderson,
PGSZ Allegation Coordinator
C. Dougherty,
PTGC, Pipe Support Group, Engineer
D. McGrew,
PPP, Engineering,
Engineer
G. Thomas,
PTGC, Pipe Support
Group, Supervisor
G. Vincent,
QC Hotline
G. Morrison,
PTGC Electrical Department Engineer
R. Cook,
PGSZ Allegation and Rate-Case
Supervisor
M. Lepke,
PGSE Onsite Engineering Supervisor
G. Klemm,
PTGC Mechanical Department Piping Engineer
R. Seewald,
PTGC Mechanical Engineer
G. Johnson,
PGSZ,
PTGC Special Projects
Engineer
R. McBay, BCI,
PTGC QA/QC Records
Supervisor
D. Delfino, Pullman Power Products,
Mechanical Engineer
NOTE:
The allegation characterization
statements
contained in this
report are either
a paraphrasing
of the staff's understanding
of the
allegers
concern or statements
taken from the allegation source
document.
The characterization
statements
do not represent
a staff assessment,
conclusion or position.
2.
Task:
Alle ation or Concern Nos.
200 and
201
ATS No:
RV-84-A"030
a.
Characterization
The
PGSE nondestructive
examination
are inconsistent with Foley inspection reports and/or the
reports
were changed
by Foley without the approval of the
PGEZ
inspection
team.
b.
Im lied Si nificance to Desi
n
Construction or
O eration
The allegation implies that the
NDE inspection results
maybe
compromised
due to record falsification which may allow uninspected
or defective welds to exist in a safety-related
structure.
Diablo Canyon
SSER-33
B.5-3
Appendix
B
c ~
Assessment
of Safet
Si nificance
The staff reviewed the original NDE reports related to this
allegation referenced
by PG&E response
Changes
in the
weld NDE identification numbers
were noted by a single line
cross-out with the initials of the person performing the change.
No
changes
were
made that totally obliterated the original.
The
changes
were for identification only because
each
NDE report
identifies the weld joint by connection
number, detail drawing
number
and reference
drawing, eliminating the possibility that the
wrong joint was inspected
and/or repaired.
For example,
a full penetration
V-groove butt joint is identified by
Foley by two separate
weld numbers.
One number is, for the face
and
one is for the root.
In certain instances
on vertical or horizontal
these
weld numbers
were inadvertently reversed
due to the
inspectors orientation while inspecting the weld. If the inspector
was on the outside looking into the fuel handling building he may
call the face of the weld No.
1 and the root No. 2. If he was
oriented from the "inside looking out" these
numbers
were reversed.
This situation
was rare
due to Foley's
QCP-6 requirement that the
inspectors participate in a continuing training program at least
once every three months.
This training, emphasized
orientation of
prints and weld inspection sheets.
d.
-Conclusion
and Staff Position
The allegation that
PG&E inspection reports
are inconsistent with
Foley's inspection reports is substantiated
in rare instances,
but
the inconsistencies
are of weld identification number only and
present
no adverse
safety significance.
The staff, upon review of
the
NDE REPORTS found no evidence of unauthorized alterations of the
reports.
e.
None.
3.
Task: Alle ation or Concern
No.
0219
ATS No:
RV-84-A"045
a
~
Characterization
Construction work on the
PAM-2 panel in Unit 2 was transferred
from
HP Foley to PGGE.
It is alleged that this action was contrary to
procedures
and was
done to bypass Quality Control inspections.
b.
Im lied Si nificance to Desi
n
Construction
and
eration
Bypass of procedures
in this case
could result in inoperability of
this portion of the Post-Accident Monitoring System
when called upon
to operate
and could indicate the possibility of a more general
failure 'to fully implement the Diablo Canyon
QC program.
Diablo Canyon
SSER-33
B. 5-4
Appendix
B
c ~
Assessment
of Safet
Si nificance
The process for PG&E modifications to equipment during construction
was reviewed.
Modifications of this nature are controlled by QC
procedures
DCP-10 and DCP-19.
Both procedures
are applicable to
work on safety-related
equipment
and require
QC review of the work
plans
and
QC inspection
and sign off of modifications to
safety-related
equipment.
Documentation of activities conducted
under these
procedures
is maintained via form E-72 for DCP-10 and
E-53 for DCP-19.
In order to determine if these
procedures
were correctly applied to
the
PAM-2 panel in Unit 2, the E-72 and E-53 logs were examined to
identify modifications
made by PG&E.
This examination
looked for
log entries identified as being associated
with PAM or with Design
Change Notices that affected
PAM-2, as determined
from the revision
description for the
PAM-2 wiring diagrams
435796
Rev.
2 and 435797
Rev. 2.
This process identified
a number of E-53's
and E-72's that
may have been related to the Unit 2 PAM-2 panel.
Each of these
candidate
records
were reviewed;
E-72 number
642 and E-53 number
2082 were identified as the only PG&E conducted modifications
on the
Unit 2 PAM-2 panel during construction.
In both cases,
the work was
identified as Class
1 and the required
QC approvals
were obtained.
d.
Position
Modifications to the Unit 2 PAM-2 panel that were done during
construction by the
PG&E Project
Team General Construction
and the
Dry Run Test Group were performed in accordance
with approved
and
applicable
PG&E procedures.
Documentation
generated
by these
modifications provide evidence that the
QC inspections
and reviews
required by the procedures
were conducted.
e.
None.
4.
Task:
Alle ation or Concern No. 0378
ATS No: RV-84-A-062
a ~
Characterization:
A QC inspector alleges that he was never provided with support to
perform his duties,
nor was he provided with proper training.
b.
Assessment
of Safet
Si nificance
Staff reviewed the affidavit to determine
when the alleger
was
employed by the H. P. Foley Company
as
a
QC inspector.
The staff
subsequently
examined
copies of QC inspector training records
encompassing
the indicated time period.
Diablo Canyon
SSER-33
B.5-5
Appendix
B
The staff review of the documented training records
shows that
H. P. Foley Company conducted
over 750 quality related training
sessions
from January
1981 to December
1983.
The number of people
attending
each session
ranged
from one to twenty.
A review of specific training records indicate that the individual
involved received
classroom training in at least twelve different
gA/QC Procedures,
as
documented
on H. P. Foley "equality
Indoctrination and Training Records"
dated
March 25,
1981, April 1,
1981, February
16,
1983 and March 8,
1983.
The training records
are
all signed by the alleger.
In addition to classroom training, the
alleger also received
over 90 days of on-the-job training.
C.
Conclusions
and Staff Position
The allegation that
a
QC inspector
was not provided with adequate
training cannot
be substantiated.
Staff review of H. P. Foley
training records provide evidence that extensive
gA/(}C training was
indeed conducted.
The portion of the allegation that implies the
inspector
was "not provided with support" lacks specificity, and
cannot
be substantiated.
The allegation
has
no safety significance.
d.
Actions Re uired
None.
5.
Task:
Alle ation or Concern
No.
0624
ATS No:
RV-84-A-052
a
~
Characterization
PG&E officials failed to correct
a false statement
to the
NRC that
the
Company
was ignorant of inaccuracies
in the plant manual for
operators.
b.
Assessment
of Safet
Si nificance
Staff review of the allegers affidavit indicates that,
an inaccuracy
in Volume 16 of the Plant Manual is the source of the allegation.
The necessary
correction involved a hi-lo level alarm on the reactor
coolant
pump lube oil system which was incorrectly identified as
a
lo-level alarm only.
Volume 16 of the Plant Manual is discussed
on
three separate
occasions
in the affidavit, specifically:
1)
Page
13: "...I had repeatedly notified PG&E management
(including a
memo to Mr. Thornberry,
the Plant Manager,
which
is enclosed
as exhibit 8) of an error in Plant Manual
Volume 16...."
2)
Page
14: "...PG&E claimed ignorance of any errors in Plant
Manual,
Volume 16,
even though I had written memo's
on the
subject to both John Gisclon and Mr. Thornberry,
the Plant
Diablo Canyon
SSER-33
B.5-6
AppendixB
Manager,
and given copies of these
memos to the
NRC the
previous August."
3)
Page
31: "...I had complained to the
NRC that an error which I
discovered in the Plant Manual,
Volume 16,
Response'as
still uncorrected
eight months after I had
reported it.
NOTE: this problem was ultimately not corrected
until January of 1983, over 20 months after I identified the
problem...."
GAP letter dated February 2,
1984,
page
49, paragraph
170 states
that "at a 1982 meeting,
PGSE failed to correct
a false statement
to
the
NRC staff that the
company
was ignorant of inaccuracies
in its
Plant Manual for Operators."
PGSZ's
response
to this allegation dated
March 29,
1984,
substantiates
that the subject of inaccuracies
in the Plant Manual
were not discussed
at the exit interview on January
7,
1984,
and
that Mr. Gisclon and Mr. Thornberry did not have the opportunity to
correct this impression.
The
PGSE response
further stated, "...in
fact, however, corrective action was already underway."
The "Corrective Action that was already underway" consisted
of:
Response
to the alleger's
memo dated
June 9,
1981 acknowledging
the problem and indicating that it would be corrected.
Copies of the proposed
changes
were sent to the alleger by
Rob Fisher
on January ll, 1982.
"An on-the-spot
change" to Volume
16 of the Plant Manual was
issued
on January 5,
1983, at the request of NRC.
Permanent
revisions to Volume 16 of the Plant Manual, including
correction of the annunciator
response
problem were
incorporated in Revision 3, dated July 15,
1983.
c
Conclusions
and Staff Position
The allegation that inaccuracies
in the Plant Manual were not
discussed
at
a 1982 meeting
can be substantiated.
However,
PG&E has
taken the appropriate
action to correct the Manual (Ref:
Rob Fisher
letter dated January
11,
1982).
The manual
was corrected in
September
1983 prior to loading fuel in Unit
1 in November of 1983.
The staff concludes that this allegation
has
no safety significance.
d.
Action Re uired
None.
Diablo Canyon
SSER-33
B.5-7
Appendix
B
6.
Task:
Alle ation or Concern
No.
0789
ATS No:
RV-84-A-064
a
~
Characterization
Welded extension bars at the
119 level in Unit 2 were inspected
and
bought off, but did not meet specifications
or drawing requirements.
b.
Im lied Si nificance to Desi
n
Construction or 0 eration
Welded extension for decking supports not meeting specifications
or
drawings
may present
a safety hazard
due to failure upon loading.
c ~
Assessment'of
Safet
Si'ificance
The staff on another allegation (reference
allegation
995,
ATS:
RV-84-A-064) conducted
an investigation to establish its validity
and as
a consequence,
examined inspection records for the
119
foot level.
Several inspection discrepancies
were found.
One of
the three corrective actions
taken by Guy F. Atkinson,
Co.
(GFA) was
to reinspect all related field work at the
119 level.
Of the 900
items to be reinspected,
42 were found inaccessible
due to status of
the construction work.
The remainder
were either found acceptable
or minor repairs
were made.
The inaccessible
items were accepted
without reinspection
by PG&E following an evaluation by the
engineering staff.
d.
Staff Position
Based
on the significance of identified discrepancies,
the staff
concludes that there is reasonable
assurance
that the welded
extensions
meet the specifications
and drawings.
e.
Action Re uired
None.
7.
Task:
Alle ation or Concern
No. 0833
ATS No:
RV-84-A-064
a ~
Characterization
A welder disregarded
the
ISO drawing, field installation
instructions,
process
sheet instructions,
weld rod requisition
instructions
and then incorporated his
own welding procedure.
b.
Im lied Si nificance to Desi
n
Construction or
eration
The failure of a welder to weld in accordance
with the qualified
weld procedure
could result in a defective pipe weld and the
inability of a safety-related
pipe system to perform its intended
function.
Diablo Canyon
SSER-33
8.5-8
Appendix
B
c.
Assessment
of Safet
Si nificance
The staff reviewed the Pullman Power Products
(PPP) internal audit
number
85 for 1981, which was the basis for the allegation.
Audit
number
85 was performed
on 10 CFR 50'Appendix B, Criterion XVI,
Corrective Action.
Audit action request
No. 4-4 was the specific
finding in the audit report.
The original documentation
was retrieved
and reviewed from the
records vault and all procedures
or specifications in effect at the
time of the audit were obtained.
The field work was
shown
on
PPP
isometric drawing No. 23-21 Revision "F".
Field welds
477 and 478
attach
a stainless
steel valve FCV 658 to a 4-inch, schedule
40
carbon steel pipe.
These welds were
made
on February
10 and ll,
1981.
The first of the three-part audit finding stated that the welder
disregarded
the
GTAW/SMAW weld procedure
(WP 149). and continued to
use
GTAW for the weld-out
(WP 150).
This statement is incorrect.
It misrepresents
the requirements
of weld procedure
149, which
permits
1 to 3 passes
of GTAW after the root pass.
In this case,
a
consumable insert was used to weld the 0.237 inch wall thickness
pipe to the valve.
In a weld of this configuration,
no more than
three
GTAW cover passes
would be required to complete the weld.
Hence,
the complete
GTAW geld-out per procedure
WP 149 is identical
to
WP 150.
The weld procedure
change to the process
sheet
was
made
by the field engineer
on February
10,
1981, which means
the
change
was prior to or at the time of the welding.
There
was
no attempt
made by the welder 'to use "his own" procedure.
In this case,
the design of the pipe is not affected by use of
either
WP 149 or
WP 150.
The weld procedure specifications,
procedure qualification records,
and welder 'qualification records
for both procedures
were found acceptable.
The, second part of the audit finding was that according to the weld
rod requisition sheets,
welding occurred
on February ll, 1981, while
the process
sheet
noted welding was completed
on February
10,
1981.
ESD-264 requires
the
PPP inspector to fillall the blocks
on the
field process
sheets
and not the individual performing the operation
(the preferred method).
The method used required the welder to
notify the inspector
when welding was complete
and to enter it on
the process
sheet.'SD-202
required the weld foreman to fillout
the weld rod requisition sheets
the dsy ~rior" to the weld heing
made.
A detailed review of the field process
and weld rod
requisition sheets
for both
FW 477 and 478 showed that the
inspector,
not the welder, filled in the completion date
as
February
10,
1981,
a day earlier than the filler requisition date.
The process
sheet indicated that no welding was performed after the
final inspection by the
PPP inspector.
All welds were subsequently
visually inspected
and radiographed
before acceptance.
The third part of the finding states
that the field engineer did not
initial, date
and explain changes
made
on the process
sheets.
After
Diablo Canyon
SSER-33
B.5-9
Appendix B
reviewing the
FW 477 and 478 process
sheets, it was found that the
field engineer did sign and date the weld procedure
change
on both
process
sheets.
The field engineer did not initial and date where
the
same
change
occurred redundantly
on the
same form.
There
was
no
written explanation of the
change but it was clearly evident the
change
was from WP 149 to
WP 150.
ESD-264 paragraph
7.2 only
requires explanation of changes
and not the reason for the change.
Again, from the foregoing evaluation,
there
was no need to make this
change to the process
sheet.
The staff reviewed several
subsequent
audits for the follow-up
actions to this audit.
1982 Internal Audit Number
31 dated July 6,
1982,
on 10 CFR 50 Appendix B, Criterion XVI, Corrective Action and
1982 Internal Audit Number 35 dated
December
1,
1982
on Criterion
IX, Special
Processes
were reviewed to see if similar problems noted
in 1981 Audit Number
85 were still detected.
Audit 31 was
an
"unscheduled" audit. It was never completed
and
was voided by the
internal auditor on approximately July 6,
1982.
The checklist for
Audit 35 has
an item No.
4 which was to verify that there were no
deviations
from the required weld procedures.
However, the audit
results did not indicate whether the status of work performed
was
acceptable
or not.
Subsequent
audits
examined,
such as Audit 118
dated
May 27,
1983 on Criterion X, Inspection
and Audit 131 dated
April 24-30,
1984 on Criterion IX, Special Processes,
were complete,
accurate
and had
a checklist of reported results.
For example,
the
response
to Audit Action Request
No.
5 of Audit 118 showed the
corrective action and steps
taken to prevent reoccurrence
were
appropriate
and consistent with the finding.
d.
Conclusions
and Staff Position
The allegation that
a welder disregarded
the weld procedure
and
process
sheet
cannot
be substantiated.
The staff has
concluded that
Audit Action Request
No. 4-4 of PPP Internal Audit Number
85
appeared
to misrepresent
the situation
as evidenced
by the original
documentation.
-The weld procedure
was correctly implemented.
It
appears
that the inspector errored in his entry of the weld
completion date,
not the welder.
The changes
made to the process
sheet
were not necessary
but,
even having been
made,
they still met
the intent of the requirements.
There is no apparent
safety
significance to this allegation.
e.
Actions Re uired
None.
Diablo Canyon
SSER-33
B.5-10
Appendix B
8.
Task:
Alle ation or Concern
No.
0995
ATS No:
RV-84-A-064
a
~
Characterization
Inspection work performed under Atkinson's control in 1978 in the
northwest corner roof area of turbine building was performed by a
questionable
inspector.
b.
Im lied Si nificance to Desi
n
Construction or
eration
An unqualified inspector
could permit unsatisfactory
construe'tion
work to go unrepaired resulting in structural failure.
c ~
Assessment
of Safet
Si nificance
Upon disclosure of the identity of the alleged unqualified
inspector,
the staff proceeded
to investigate
the individual's
qualifications
and the extent of his participation in the inspection
of the construction of the Turbine Building roof.
In accordance
with the
Guy F. Atkinson Company
(GFA) Diablo Canyon
Project Specification No. 5442, Quality Assurance
- Personnel
Q.8-9,
the inspector
was indoctrinated,
trained
and certified (effective
August 2,
1978)
as
a Structural Steel Welding and Erection Inspector
by GFA's Quality Assurance
Manager consistent with GFA's Quality
Control Procedure
13.
The supporting documentation
(references
2,
3,
and 4) was reviewed
and found acceptable.
Contrary to the allegation,
the inspector did not perform any work
of record in the turbine building roof area.
Inspection records for
the roof structure
generated
by GFA during the period of the
inspectors
employment at Diablo Canyon were examined
and his
signature
did not appear.
Although the foregoing clearly resolves
the specific allegation,
further investigation
was conducted to establish
the validity of the
allegation with respect
to the work actually performed by the
inspector.
As
a consequence,
inspection records for the
119 foot
level (location derived from reference
1) were examined for the
period of the inspector's
employment.
Several inspection
discrepancies
were identified that had also been found and
documented
by NCR 293 dated April 17,
1979, during an audit of
inspection records
performed by GFA.
The audit was conducted in
accordance
with GFA - QCP-15 (reference 5).
Virtually all of the
discrepancies
described
by the
NCR were attributed to the inspector
in question.
The corrective actions taken by GFA were to:
1)
conduct
a thorough review of all of this inspector's
documentation,
2) reinspect all related field work and,
3) not rehire the
individual who had already terminated to return to college.
The inspector
was found to have been involved with 900 items
and
750
(83@ of these
were reinspected
and found acceptable
(reference
7).
Diablo Canyon
SSER-33
B.5-11
Appendix
B
10
Of the remainder
108 (12$ ) were found to have minor deficiencies
that were quickly repaired
and 42 (5'j) 'were inaccessible
due to the
advanced
state of construction at the time of the
GFA audit.
Half
of the inaccessible
items had been ultrasonically tested
and
accepted
by another inspector
and, therefore,
also accepted
by PG&E
based
upon the availability of test records.
The remaining
21 items
were accepted
by the
PGGE engineering staff on the basis that "welds
were either not critical to resist loads, or margins between weld
size
shown on design drawings
and weld size required to resist
design loads were more than adequate
considering limited
deficiencies that might exist."
d.
Conclusions
and Staff Position
The allegation
as stated
could not be substantiated
to the extent
that the inspector
met all of the requirements
established
for the
job and that no evidence
could be found that he had performed
inspection work in the northwest roof area.
However, further
investigation did validate significant deficiencies in the
inspector's
performance in another location which had been
identified by the licensee's
gA program
and properly dispositioned,
including the evaluation of inaccessible
e.
Actions Re uired
None.
9.
Task:
Alle ation or Concern
No.
1062
ATS No:
RV-84-A-064
a ~
Characterization
Missized or improperly installed
beam
clamps
have been
used to
fasten
raceway support struts to structural
beams.
b.
Im lied Si nificance to Desi
n
Construction
and 0 eration
Inadequately
supported safety-related, raceway could result in
degradation
or failure of critical power, control or instrumentation
circuits during events (e.g.,
that cause
abnormal
loading of the raceway supports.
C ~
Assessment
of Safet
Si nificance
The sketches
provided
as part- of the allegation indicate that the
Unistrut F2785
and P2786 style beam
clamps are the items of concern.
This is the predominate
beam
clamp style in use at Diablo Canyon.
This type of clamp is
a angled piece of plate steel that captures
the foot of a beam between it and the framing channel.
The plate is
held in place
and tightened against
the beam by a U bolt which is
installed around the framing channel
and through the plate
(see
Diablo Canyon
SSER-33
8.5-12
Appendix 8
Sketch)-.
Vendor catalogs
and
PGSE drawing 50030 Revision
30 require
that these
clamps always
be used in
pairs'eview
of the Unistrut, Power Strut and Super Strut catalogs
shows
that Unistrut produces
two clamp sizes in this style,
Super Strut
three sizes
and Power Strut two sizes.
In all cases,
the only
difference between the different size
clamps of each vendor is the
U-bolt length. If a clamp with too short of a U-bolt is selected,
the clamp will not fit in the application because
U-bolt threads
will not extend sufficiently beyond the clamping plate to allow
installation of the U-bolt nuts. If a clamp with too long of a
U-bolt's selected,
then it is possible that the U-bolt nuts would
reach the end of the threads
before the clamp was completely tight.
The selection of the wrong size clamp will not, in and of itself,
result in a loose attachment of strut to beam.
Loose
clamps will
only occur if the U-bolt nuts are not properly tightened.
The results of previous
NRC raceway support inspections
were
reviewed
and additional inspection 'of beam
clamp installation was
conducted.
As
a part of the
NRC inspection of the seismic
reverification program,
300 raceway supports
were inspected
including 24 supports
whose design allowed for the use of beam
clamps.
No loose
beam clamps
were identified during these
inspections.
d.
In response
to this allegation
an additional
200 beam
clamps
on
raceway supports in both Unit
1 and Unit 2 were inspected for
tightness.
During this inspection
one loose
beam
clamp was
identified.
In this case,
the proper size U-bolt was employed,
however,
the nuts were simply not sufficiently tightened.
PGSE
issued Minor Variation Report No.
3281
on April 2,
1985, to tighten
the clamp.
H
Conclusions
and Staff Position
The review of vendor information establishes
that the size of beam
clamp used
does not directly affect the tightness of the clamp. It
is further concluded
from the results of 'raceway support inspections
that loose
beam
clamps
has not been
a generic problem at Diablo
Canyon.
e.
None.
10.
Task:
Alle ation or Concern
No.
1270
ATS No:
RV-84-A-071
a ~
Characterization
PGGE response
that an individual was not aware of orders to stop
working on hangers is misleading.
Another individual" gave the stop
Diablo Canyon
SSER-33
/
B.5-13
Appendix B
work order, but the individual who claims to be unaware of the order
should have
known about it.
b.
Im lied Si nificance to Desi
n
Construction
and
eration
The allegation is not sufficiently detailed to allow an assessment
of its significance to design,
construction
and operation.
Generally,
stop work orders
are issued to hold construction while
problems with design, materials or procedures
are resolved
so the
amount of rework required is minimized.
In this regard, failure to
be aware of or to comply with a stop work order would be more likely
to have economic significance
than safety significance.
c.
Assessment
of Safet
Si nificance
The portion of the allegation provided to the investigation
team did
not specifically identify the subject or time period of the order to
stop work that is in question.
It is assumed
that the order in
question
was
a formal stop work order
on pipe support installation
and that the order could have occurred
between
March 1983 and April
1984.
The general
subject of stop work orders
on pipe supports
was
discussed
with a pipe support supervisor
and
a group engineer of
PTGC.
They stated that one significant stop work order issued
during this interval involved supports that were being evaluated
by
engineering
as part of the seismic reverification program.
Pullman
Power Products
(PPP)
was instructed to stop construction
on these
supports
by a
memo from G. A. Thomas to H.
W. Karner dated August 8,
1983.
The intent of this order was to stop work on supports that
might be subject to
a design
change
as
a result of the
reverification program.
It was stated that
PPP issued
stop work
orders
on the supports in question
and hung hold tags
on each
support.
Failure to stop work on any support in this case
would
have
no safety significance,
as
any design
change to a support would
be implemented whether or not construction
on the support
was
continued.
The
PPP Pipe Support stop work orders
were reviewed for the interval
in question to audit Pullman's
performance in response
to stopping
work on the supports
discussed
above
and to determine if other
irregularities exist that might be the source of the allegation.
A
sample of the supports identified in the August 8,
1983
memo
was
selected
and it was verified that for each
sample
case,
a
corresponding
PPP stop work order
was issued.
During the review of
the stop work orders it was noted that one
PTGC
memo dated
September
15,
1983,
was referenced
by stop work orders
through March
1984.
This apparent
discrepancy in dates
was investigated
and it
was determined that the September
15,
1983
memo instructed
PPP of a
policy change that could also be the source .of the allegation
as
discussed
below.
Pullman Power Products
procedures
require that construction
work on
a support
be stopped
when
a new revision of the drawing for that
Diablo Canyon
SSER-33
B.5-14
Appendix
B
13
support is received.
When
a new revision is received
a stop work
order is issued,
the old construction
package is pulled back from
the field, a new construction
package is issued
and the construction
hold is removed.
As
a result of problems
encountered
in
construction,
PTGC instituted
a pipe support preinspection
program
that evaluated
new designs for constructibility before they were
turned over to PPP.
During the time new drawing revisions
were
under review by the preinspect
group,
PPP
was not formally aware of
the new revisions
thus construction work on the affected supports
continued
even though
new drawing revisions
were onsite.
This
apparent violation of PPP procedures
was noted by preinspect
group
inspectors.
However, since
PPP had not received
the
new revision,
their actions
were in accordance
with written procedures.
Initially, no action was taken
on this problem because
PG&E judged
that
a minimal amount of rework would be required
as
a result of
construction continuing while the new design revisions
were under
consideration
by the preinspect
group.
After an instance
was
identified where significant rework would have been required
had
construction continued during preinspection,
PPP
was instructed to
stop work on any support
when the
PTGC preinspect
group received
a
new revision of drawings for that support.
This policy change
was
transmitted
by the September
15,
1983
memo from G. A. Thomas to
H.
W. Karner.
Review of the
PPP stop work orders
from the time of
the
memo forward indicated that
PPP consistently
implemented this
policy.
Even if this were not the case,
failure on the part of PPP
to stop work on
a support would have
no safety significance since
the support would eventually have to be reworked to comply with the
latest drawing revision.
d.
Conclusions
and Staff Position
No irregularities were noted in the
PPP pipe support stop work
orders during the interval of March 1983 through April 1984.
The
two issues
that resulted in the majority of stop work orders during
this interval were investigated
and appear to have been handled
properly by PGSZ and
PPP.
Therefore,
an allegation that stop work
orders during this were not properly implemented or that key
individuals were not aware of stop work orders
cannot
be supported.
Furthermore, failure to take proper action on the stop work orders
reviewed would have
had economic impact, but no safety impact.
e.
None.
ll.
Task:
Allegation or Concern
No.
1381
ATS No:
RV-84-A-073
a
~
Characterization
A nut could not be properly installed
on an embedded
stud that
attaches
a main feedwater pipe support to the containment wall.
The
Diablo Canyon
SSER-33
B.5-15
Appendix
B
14
nut was cut in half and tack welded to the base plate.
This problem
is described in Diablo Canyon Problem Report 1-2335-P.
b.
Im lied Si nificance to Desi
n
Construction
and
eration
An improperly supported
feedwater pipe could result in a loss of
feedwater, during
a transient that places
abnormal. loads
on the
support.
The pipe support in question is upstream of the main
so that problems with this support would not
impair the ability to provide auxiliary feedwater.
Nevertheless,
the support in question is classified
as safety-related
by PG&E.
c ~
Assessment
of Safet
Si nificance
Diablo Canyon Problem Report DP-1-2335-P contains
a detailed
description of the condition that is the source of this allegation.
The embedded
mounting studs for support
1048/8SL were too short to
allow complete thread
engagement
for the base plate nuts.
As
a
field fix, the nuts were cut in half longitudinally, installed
on
the studs
and tack welded to the base plate.
Engineering approval
of this configuration was provided
on February
14,
1979, in response
to the problem report.
.Approval was based
upon
a determination that
enough threads
were engaged
to allow the full bolt strength to be
developed.
The unusual configuration of the base plate attachment
was again
noted during final gC inspection of the support.
The discrepancy
report generated
as
a result of this inspection
(PPP
DR 5734)
questions
the suitability of the nut tack welds since neither the
nut material or the welding procedure
used could be established.
This item was resolved by memo from J.
A. Longworth to J. Arnold and
R. Tinkle dated January
20,
1984, which recommended
that the nut
welds be accepted
as is, since the welds serve only to prevent the
nuts from backing off and are not assumed
to add any structural
strength to the support.
The partial engagement
of the base plate nuts is documented
on the
as-built drawing for the support
and the as-built configuration was
accepted
by PG&E engineering.
Some confusion about
PG&E's ultimate acceptance
of the nut tack
may have resulted
from the fact that
DR 5734 also identified a
number of undersized structural welds
on the support.
Pipe Support
Design Tolerance Clarification Form No. TC-1-14461 indicated that
some of these
welds were unacceptable
as is and should be reworked.
The rework required by TC-1-14461
was completed
and the resulting
support configuration was incorporated into the as-built drawings.
TC-1-14461
does not address
the nut tack welds.
d.
Conclusions
and Staff Position
The condiiion described in the allegation exists in the field.
This
condition was documented
as
a discrepancy
on two separate
occasions
and was properly dispositioned
on both occasions.
Diablo Canyon
SSER-33
B. 5-16
Appendix
B
e.
Action Re uired
None.
12.
Task:
Alle ation or Concern
No.
1264
ATS No:
RV-84-A-071
a
~
Characterization
PG&E response
to
GAP allegation No.
259
on walkdown by personnel
who
marked-up
drawings
used by equality Control is misleading.
The
people were not qualified.
b.
Assessment
of Safet
Si nificance
The implied safety significance of this allegation is that the
quality of safety-related
systems
may be compromised if they were
analyzed
and constructed
using improper drawings.
C.
Assessment
of Safet
Si nificance
The source of this allegation
was
GAP submittal No.
120 dated
June
21,
1984, attachment
10, page
12, which states
that PGSE's
response
to
GAP allegation
No. 259 is misleading regarding
qualification of personnel
performing walkdowns.
The alleger is concerned
that unqualified personnel
worked on the
drawings
and that "those drawings were used for gC inspection work
throughout the plant and for engineers
to make decisions
on the
acceptability of design changes."
It is not apparent that the alleger understands
the use of drawings
that are marked-up
as
a result of walkdowns
~
Marked drawings that
result from walkdowns are used for updating as-built drawings which
are later analyzed
and used for gC inspection.
The
NRC staff examined
the concern regarding qualification of
walkdown personnel
by: reviewing PG8Z instructions
and procedures
for walkdown inspections;
reviewing
a sample of ISO drawings
used
for the walkdowns;
and verification of training of individuals who
signed the drawings
used for walkdowns.
PGSE instruction entitled "Field Reverification Procedure for Piping
Isometrics"
was prepared
in response
to
on
March 10,
1982,
and was revised
on April 12,
1982.
On May 6,
1982,
PG&E engineering
assumed
control of the procedure,
and re-issued it
as instruction numbers I-17 for large bore pipe and I-18 for small
bore pipe.
The
NRC staff randomly selected
seven isometric drawings that were
marked-up during walk-downs,
and recorded
the
names of individuals
who signed the drawings.
Diablo Canyon
SSER-33
B. 5-17
Appendix
16
Training records
were later reviewed,
and, in all cases,
personnel
who performed the walk-downs
and signed the drawings
had been
previously trained in the walkdown procedure.
Review of PGSZ's
79-14 Training File indicates that over 50 people
have been trained
in the walkdown procedures.
No violations were identified.
d.
Staff Position
The staff concludes that personnel
who performed walk-downs were
adequately
trained
and qualified to do the work.
None.
13.
Task:
Alle ation or Concern
No.
1397
ATS No:
RV-84-A"073
a
~
Characterization
On diesel generator fuel oil transfer
system pipe support (support
number 20/85R),
a nut is bearing
on a weld and half of a shim plate.
This condition is not shown on the as-built drawings, but is shown
on pipe support tolerance clarification form TC-1-11497.
b.
Im lied Si nificance to Desi
n
Construction
and
0 eration
A improperly supported
pipe in the diesel fuel oil transfer
system
could result in eventual failure of one diesel generator
following
conditions
(such as
a seismic event) that imposed
abnormal
loads
on
the piping system.
c ~
Assessment
of Safet
Si nificance
A copy of the drawings for support
20/85R was obtained
and the
support
was inspected
against
the drawing.
The inspection
confirmed
that the condition described
by the allegation exists.
Specifically:
Line 1-2-J-2599-2" rests
on
a shim plate that is welded to one
of the support cross
members.
A U-bolt is installed around the
line and through holes that were drilled partially through the
shim plate
and partially through the weld material.
U-bolt
nuts are installed
on the top side of the ship plate to provide
for the design spacing between the pipe and the U-bolt.
The
U-bolt is secured
from underneath
by a nut and
a lock nut on
each side.
The top nuts rest partially on the shim plate
and
partially on the weld.
These nuts are the source of the
allegation.
Contrary to the allegation,
the correct version of the hanger
drawing for this support details this configuration
(Drawing 049318
sheet
110B Section
D-D in conjunction with section
E-E on sheet
Diablo Canyon
SSER-33
B.5-18
Appendix
B
17
llOH).
These details
were added
by either revision
3 or revision
4
of the drawing.
In both cases,
the Field Correction Transmittal
form documents that the as-built configuration has either been
factored into the support calculations
or that the calculations
have
been reviewed to verify that the condition does not affect the
adequacy of the support.
d.
Conclusions
and Staff Position
The condition described
by the allegation exists in the field,
however,
PG&E has
documented,
assessed
and accepted
the
configuration described.
More than enough weld material remains after drilling holes for the
U-bolt to insure secure
attachment
of the shim plate to the support.
The incomplete seating provided for the top U-bolt nuts is of no
consequence
since the nuts are only used to support the U-bolt in
order to provide the designed
gap between the U-bolt and the pipe.
Therefore,
the staff agrees
that the condition observed
does not
adversely affect the adequacy of the support.
e.
None.
14.
Task:
Alle ation or Concern
No.
1486
ATS No:
RV-84-A-113
a
~
Characterization
An individual questions
the acceptability of capped'ff lines coming
from the reactor vessel
support pads.
b.
Im lied Si nificance to Desi
n
Construction
and 0 eration
C.
Capped lines could be indicative of incomplete construction work.
Assessment
of Safet
Si nificance
The piping and Mechanical Drawing (Drawing 50152
Change
3) of the
rea'ctor vessel
support block was examined to identify pipes
coming
from the support pads.
Twenty four pipes were identified.
Inspection of this piping in the Units 2 containment
confirmed that
lines 2K1696,
2K3003,
2K391,
2K1,702,
2K2947,
2K400, 2K1700,
2K2254,
2K395,
2K1698,
2K3008 and 2K393 are capped.
The piping and instrument diagram for the Component Cooling Water
System
(Drawing 108014 sheet
7) shows these lines as Cooling Water
lines to spare Reactor Vessel support coolers
and that they are
capped per design.
Diablo Canyon
SSER-33
B. 5-19
Appendix B
18
d.
Conclusions
and Staff Position
The capped lines coming from the reactor vessel
support, pads
are for
spare
equipment
and are
capped per design.
e.
None.
15.
Task:
Alle ation or Concern
Nos.
1566 and
1567
ATS No:
RV-84-A-115
a
~
Characterization
Welders worked without shielding
gas flow meters
and incompatible
meters.
b.
Im lied Si nificance to Desi
n
Construction "or 0 eration
made without shielding
gas flow rate information or inaccurate
information could possibly result in oxidized weldments, with lower
mechanical
and physical properties of the base material,
thus not
meeting the original design criteria.
C.
Assessment
of Safet
Si nificance
During an audit of welder performance
by Pullman Power Products
equality Assurance
on June 4,
1984, it was discovered that
a welder
was using
a flowmeter that
was not identified as
an acceptable
flowmeter in weld procedures
ESD-213 and ESD-219.
Further
investigation by Pullman revealed that improper and uncalibrated
pressure
regulators
were also in use.
These deficiencies
were
documented
by Pullman Power Products
on Deficient Condition Notice
(DCN) Number 96-058,
dated
June
7,
1984.
Pullman Power then
prepared Deficiency Reports
(DR's)
8657
and 5946,
and submitted
them
to PGRE for disposition.
PG&E's investigation resulted in a revision to PPP Procedures
ESD-213 and ESD-219.
The revisions included
a description of and
instructions for the use of additional types of flowmeters,
including those
found during the audit.
Supplementary
instructions
were issued to all welders
and
(}C personnel
were indoctrinated in
proper flowmeter and regulator use.
PGScE investigated'egulator
calibration requirements
with the
manufacturer,
and reviewed the
ASME code,
Sectio'n IX.
The
ASME code
addresses
the shielding
gas flow rate
as
a "non-essential" variable.
Because
of this,
changes in gas-flow were deleted
from the
PPP
ESD's,
and the existing welds were accepted.
Diablo Canyon
SSER-33
B.5-20
Appendix B
19
d.
Conclusions
and Staff Position
'The allegation that welders
were using improper flowmeters
and
uncalibrated
regulators is substantiated.
However, the staff
further concludes that
PG&E acted properly in the .corrective action
taken to resolve the situation of the use of uncalibrated
shielding
gas pressure
regulators
and incorrectly matched
flowmeters
to regulators
by revising PPP's
welding procedures
ESD-213
and
ESD-219 to reflect conformance to ASME code Section IX which
considers
the shielding
gas flow rate for manual
gas tungsten
arc
welding as
a non-essential
variable.
All welds performed required
NDE assuring
weld soundness.
This allegation, therefore,
has
no
safety significance.
e.
Actions
Re uired
None.
16.
Task:
Alle ation or Concern
No.
416
ATS No:
RV-84-A-062
a
~
Characterization
Inconsistent
weld acceptance
standards
were used by day and night
shift inspectors
inspecting structural steel welds for the
Guy F. Atkinson Company.
b.
Im lied Si nificance to Desi
n
Construction
and
eration
Inconsistent
standards
could have resulted in unacceptable
being accepted.
This could cause structural steel welds to fail
under abnormal
loads if weld strength is less
than
assumed
by the
design.
c ~
Assessment
of Safet
Si nificance
Exhibit
1 of Attachment
10 to the
GAP letter indicates that one
example of the night shift requiring rework on welds accepted
by day
shift inspectors is excess
reinforcement
on stiffener plates
3 and
5
on column 14.
Review of weld inspection
records indicated that
column 14-A was inspected
on the date in question by the inspector
identified in Exhibit 1.
Stiffener plates
1 through
16 on
column 14-A and" stiffener plates
7, 8,
15 and
16 on column 12.1-A
were inspected
as part of the investigation into this allegation,
No evidence of excess
reinforcement
was" noted,
Thus, the example
cited does not support the allegation.
To address
the question of inconsistent
inspection standards,
two thousand
two hundred
and fifty (2250) structural steel weld
inspection
records
were reviewed for 1855 welds reflecting the work
of 22 different weld inspectors
to determine if any groups of
'nspectors
had significantly different weld reject rates
than other
groups.
The records
reviewed were from two groups.
One group was
Diablo Canyon
SSER-33
B.5-21
Appendix
B
20
randomly selected
from the structural steel welding records for the
turbine building.
The second
group was selected
to include the
records for the stiffener plate welding referred to in exhibit
1 of
the allegation.
The records
encompassed
the time period June
1978
through August 1979, thus spanning several
months before
and several
months after the date of exhibit l.
Of the 2250 inspection records
reviewed,
126 (5Q were rejects.
Five inspectors
accounted for all
of the rejects.
The bases
for these rejections
were reviewed to
determine if they were attributable to different inspection
standards.
Of the
126 rejects
found in the sample, ill resulted
from
reinspection of 395 welds that had been originally accepted
but
which subsequently
cracked at the ends
as
documented
by NCR's 243
and 313.
The resolution of these
NCR's required grinding out the
weld cracks, visually inspecting the welds
and conducting liquid
penetrant testing to insure
no cracked weld material
remained to
serve
as
a starting point for further crack growth.
All welds that
were reinspected
were visually acceptable.
The rejects resulted
from the liquid penetrant testing.
Since the circumstances
surrounding
these rejections
are significantly different from the
other weld inspections
reviewed,
the high reject rate in these
cases
clearly result from circumstances
other than acceptance
criteria.
The reject rates for the two inspectors
who conducted
the
reinspection
were roughly the
same.
'The remaining
1855 weld inspections
reviewed resulted in 15 rejects
((1'j) by three inspectors.
Seven of the rejections
were by a single
inspector
who conducted
906 of the inspections
in the sample.
This
represents
a rejection rate of less
than one percent,
which is not
clearly inconsistent with the other inspectors
rejecting
no welds
out of a much smaller number of inspections.
The eight remaining
rejects
were by two inspectors
who inspected
a total of 52 welds.
It could not be determined if both of these
inspectors
were on the
night shift.
The eight rejects
occurred
on three joints, therefore,
it appears
that the relatively large percentage
of rejects for these
two inspectors
resulted
from the
same welder making more than one
reject weld on
a joint.
To verify that different acceptance
criteria did not result in welds
being more readily accepted
by one group than another,
the
productivity rate for two of the inspectors
that inspected
a large
percentage
of the welds in the sample,
were examined to verify that
no more than
a credible number of welds per day had been inspected
by these individuals. It was determined that one inspector
had
accepted
a very large number of welds in one day.
Review of these
however, indicated that all of the welds were grouped
together
so that it was possible to inspect the number of welds
indicated.
d.
Conclusions
and Staff Position
The specific column referred to in the allegation
as
an example of
unaccept'able
work being accepted
by day shift showed
no indication
Diablo Canyon
SSER-33
B.5-22
Appendix B
21
of excess
weld reinforcement
as alleged.
Review of a large
sample
of weld inspection records did show differing weld rejection rates
by different inspectors,
but in all cases
the higher rejection rates
noted could be attributed to factors other than different acceptance
standards.
No evidence
was noted that different standards
resulted
in inspection of more than
a credible number of welds per day by an
inspectors
Therefore, it was not clear that there
was any group of
inspectors
(day or night shift) that had higher rejection rates
due
to differing acceptance
criteria.
Thus, the allegation of differing
acceptance
criteria between
day and night shifts cannot
be
substantiated.
e.
None.
17.
Task:
Alle ation or Concern No.
1543
ATS No:
RV-84-A-114
a
~
Characterization
An individual feels that
PGEZ made false statements
that led to the
resolution of previous allegations
regarding welder qualification
test surveillance.
Specifically, the existence
of., welder
'qualification records
referenced
by a J.
P.
Watson affidavit
presented
before the Atomic Safety
and Licensing Appeal Board is
questioned.
b.
Im lied Si nificance to Desi
n
Construction
and 0 eration
Lack of adequate
welder qualification test records
would impair the
traceability of weld quality for any welds
made by welders lacking
adequate
qualification records, invalidating the acceptance
of these
As a result
some of the accepted
welds might fail under
abnormal loading conditions because
they lack the structural
strength
assumed
by the design.
c ~
Assessment
of Safet
Si nificance
The allegation
stems
from apparently conflicting testimony regarding
welder qualification records that was given by J.
P. Watson
on two
different occasions.
In the ASLB affidavit, it was indicated that
records of fitup, root pass, filler pass, final visual and bend test
had been
reviewed for a group of welders.
In subsequent
testimony
during
a Department of Labor hearing Mr. Watson indicated that there
were no permanent
records of examinations
conducted at qualification
weld hold points.
The process
used by -Pullman Power Products
(PPP) to conduct
and
document welder qualification tests
was reviewed to determine
what
documentation of qualification tests
was generated
and maintained.
Welder performance qualification is controlled by PPP procedure
ESD 216.
This procedure
requires
the
gC Welding Supervisor to
Diablo Canyon
SSER-33
B.5-23
Appendix
B
22
supervise
welder performance qualification testing
and document the
results of>the guided bend tests or radiography
used to determine
the acceptability of the qualification weld.
These
requirements
and
the documentation
generated
and maintained
by PG&E fulfillthe
welder qualification requirements
of ASME Code Section IX
Article III, gW 301.4.
Discussions
with a
PPP mechanical
engineer indicate that it was also
standard practice for PPP
QC Welding Supervisors
to inspect the
qualification weld progression at selected
hold points, usually fit
up, root pass
and final visual inspection.
The results of these
inspections
were maintained in informal notes
by the Welding
Supervisor,
but were not maintained
as permanent
formal Diablo
Canyon
gC documents.
d.
Conclusions
and Staff Position
The apparent conflict in testimony
seems
to result from Mr. Watson
referring on one hand to records consisting of informal notes
and
on
the other hand to formal permanent
records.
Therefore,
no real
inconsistency
between the statement
that (informal) records of gC
inspection for fitup, root pass, filler pass, final visual and bend
test were reviewed
and the statement that (formal) permanent
records
of these
inspections
do not exist.
Therefore,
the allegation that
PG&E made false statements
regarding welder qualification test
documentation
cannot
be substantiated.
Furthermore,
the welder qualification records maintained
by PG&E
fully comply with the
ASME requirements for such records.
Therefore, failure to maintain records of inspections
conducted at
hold points during the qualification testing
has
no safety
significance.
The specific questions
raised in the alleger's affidavit are
addressed
as follows:
Are inspection
records of welder qualification testing required at
nuclear power facilities?
Yes, however,
the
ASME code only requires that the essential
variables,
test results
and background
data
be maintained
as
'ecords of welder qualification.
The welder qualification
records maintained
by PG&E satisfy these
requirements.
Does the welder qualification test have hold points that must be
inspected
before the test
can be allowed to proceed?
Ão, although inspection at hold points
was standard practice
by
the
PPP
gC Welding Supervisors, it is not requir'ed by either
the
ASME Code or by the written PPP procedures;
If a gC inspector performed
an inspection of a mandatory hold point,
would that inspector
be required to document
the results of such
an
inspection?
Diablo Canyon
SSER-33
B.5-24
Appendix B.
No, as discussed
above neither the inspection hold points nor
documentation of the results of hold point inspections is
mandatory.
e.
None.
18.
Task
Alle ation or Concern
No.
169
ATS No:
RV-84"A-022
a ~
Characterization:
Pullman failed to conduct support welds
as required by procedure
and
QA wrongfully approved
the technique.
b.
Im lied Si nificance to Desi
n
Construction
or 0 eration
made without the proper procedure
could result in improperly
made welds in critical areas.
Ci
Assessment
of Safet
Si nificance
The alleger stated that two W14x90 wide flange beams
were welded
together
on support nos.
2/45R and 2/49R by use of an unqualified
welding technique.
It was stated that Pullman welding procedure
specification
(WPS) 7/8 was used to join steel
shapes
without the
required backing bar in place of which back-gouging
was performed
and the Pullman
QA/QC Manager wrongly approved
the technique
utilized.
The staff reviewed packages
from support nos.
2/45R and 2/49R and
Pullman's
WPS 7/8 to evaluate
welds in question.
The joint type is
a groove butt in which a backing bar is placed to ensure full
when welding.
Pullman's
General Field Support Process
Sheets for these
supports indicate
a hold point after back-gouging
to verify sound weld metal was attained
from the back side before
welding the back side.
Both techniques
are approved
by the
AWS and
ASME codes.
Both techniques
achieve
the
same purpose:
to obtain
full penetration at the root.
The
AWS Code has both of these
particular weld joint types
as prequalified in their Structural
Welding Code Dl.l, but the omission or inclusion of a backing bar is
an essential
variable in which a
WPS has to be requalified if the
weld joint was not prequalified.
ASME Section IX addresses
backing
bars
as nonessential
variables requiring no requalification of a
WPS.
Pullman's
WPS 7/8 closely resembles
ASME Section IX but does not
state that Section IX is to be used
as
a supporting
document
when
a
interpretation is required.
Therefore, technically the alleger
was
correct in stating that the support welds
made without a backing bar
was performed without a properly qualified procedure
because
back
Diablo Canyon
SSER-33
B.5-25
Appendix
B
24
gouging was not addressed
on
WPS 7/8.
On March 12,
1984,
WPS 7/8
was revised to allow for back grinding and back welding.
Pullman's
gA/gC Manager has
no recollection in approving the use of
backgouging
as
an alternative to the use of a backing bar for welds
in question.
d.
Staff Position
The staff concludes that
no structural deficiencies
resulted
from
the change of welding technique
because. full penetration of the root
was achieved in both cases.
None.
19.
Exit Interview
Mr. M. Tressler,
was informed of the results of these inspections
by
telephone
on July 17,
1985.
Diablo Canyon
SSER-33
B.5-26
Appendix B