ML19280B557

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Forwards IE Comments Re Ofc of Inspector & Auditor Investigative Findings Re Weld Chronologies in IE Insp Rept 50-358/80-09.Welds Had Been Identified & Placed in Corrective Action Sys Prior to Applegate Involvement
ML19280B557
Person / Time
Site: Zimmer
Issue date: 09/17/1981
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Palladino N
NRC COMMISSION (OCM)
Shared Package
ML19280B555 List:
References
NUDOCS 8112080190
Download: ML19280B557 (10)


See also: IR 05000358/1980009

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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WASHINGTON D. C. 20555

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September 17, 1081

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NEMORANDUM FOR: Chairman Palladino

.

FROM:

William J. Dircks

Executive Director for Operations

SUBJECT:

JULY 30, 1981 OIA REPORT, *SPECIAL INQUIRY RE: ADEQUACY

OF IE INVESTIGATION 50-358/80-9 AT THE WILLI AM a. ZIMMER

NUCLEAR POO R STATION"

Enciesed are the DIE comments relat've to the OIA investigative findings.

I

would like to specifically direct your attention to the enclosed weld chron-

ologies.

Clearly, these welds had been identified and placed in a corrective

action system prior to Applegate's involvement.

I believe the OIA report summary (page 2) best characterizes the safety issue.

"One of Arplegate's main allegations was that defective welds in

safety-related systems have been accepted, ' * * . By virtue of

prior IE inspections " ' ', it is clear that Region III was well

aware of the chronic and long history of welding problems at

Zimmer: specifically, that unacceptable welds in safety-related

systemt had for all intents and purposes been accepted by both

the contractor and, in some cases, the licensee. Based upon

these inspections, Region III required the licensee to rereview

radiographs and reports of all welds which had been accepted for

turnover prior to operation; this review started in October 1979

and portions of this review are still being studied by Region III."

It appears to be irrelevant to debate whether or not the welds had been

accepted; the pertinent fact is that the welds were in a system to obtain

corrective actio".

I am cot Gdent that the aggregate of licensee and NRC actions would have

-2 :'I' C.resalted in edestate welds prior to the operation of this plant, irrespective

of Applegate's involvement.

'7 O :: 2. P.

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Williaa J. Dircks

Executive Director for

Operations

Enclosures:

1.

Office of Inspection and Enforcement Comments

2.

Held Chronologies

cc: See Page 2

8112090190 811116

ADOCK05000g8

IE

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Chaint.an Palladino

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cc: Comissioner Gilinsky

Commissioner Bradford

Comissioner Ahearne

Com ssioner Roberts

SECY

OPE

OGC

OIA

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Enclosure 2

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CY 606

CY 6CE is a weld in the Cycled Ccndensate System. located in the tank area.

The

line'is sixteen inches in dianeter (weld is 5D.26 inches of weld metal).

Design conditions for this line are 35 psig and 140 degrees F.

Maximum

operating conditions are also 35 psig and 140 degrees F.

This line is S&L

piping Class B.

CHRONOLOGY

07/ /76

Weld fit-up.

07/ /76

Weld performed.

07/15/76

RT of weld - reject.

.

07/16/76

RT read, reject 0-13, 13-26, unconsumed insert.

07/16/76

Approvals on WED No. 1.

07/19/76

R1 readed, FT of grinding - accept, weld performed.

07/21/76

Approvals for WRD No. 2.

07/23/76

Ground area, PT accept, weld pe-formed.

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07/26/76

RT performed.

07/26/76

RT read, reject 0-12, 12-24, incomplete fusion.

07/27/76

Approvals for WRD labeled No. 2. ',

07/29/76

PT - accept.

08/02/76

RT for information only

reject.

08/04/76

PT reject

grind through & adjacent area, crack in weld edge.

08/09/76

RT performed.

08/03,'76

RT read, 0-12 rejected.

08/10/76

KEI approval of above RT report.

08/10/76

Approvals for WR0 labeled No. 3.

08/10/76

PT test of area - accepted.

08/11/76

RT of weld.

08/11/76

RT read - rejection areas 0-12 (Peabody-Magnaflux Personnel).

08/12/76

P-M rejection overriden by M. Low - accept weld.

08/13/76

Gamma plugs CY606GP, 606 CPS, 606GP welded, PT accept.

  • 01/13/77

S&L audit of radiography, areas 8-12 rejected for surface

indications and linear indications.

  • 01/21/77

NR-E-633, documents above finding, grind out defect and reweld.

  • 02/11/77

Approvals on disposition of NR-E-633

04/14/77

ANI approval of 08/11/76 RT.

04/15/77

Approvals on WRD labeled 3A.

06/08/77

RT of area in 3A 0-13, 13-26 accept.

06/08/77

RT read and approved.

06/20/77

ANI review and approval of above RT.

  • 06/24/77

NR-E-633 closed.

07/19/77

Gamma plug re-welded, PT accept.

  • 10/10/79

NES Review Begins

  • 10/12/79

NES review - technique and documentation deficiencies.

  • Significant information not in 01A Chronology.

Received RIII 9/15/81 THOMP15(C)

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  • 01/02/80

Applegate told acceptance of CY 606 improper.

(Daily Report)

  • 03/03/80

Applegate interviewed by Phillip.

0 /07-r9/80

Phillip onsite.

"10/03/80

NR-E-5172 based on NES findings for CY-606 and several adjacent

welds.

  • 10/27/80

Disposition of NR-E-5172, accept as is, A. Lanham.

"11/07-12/80

Approvals on NR-E-5172.

  • 11/12/S0

NR-E-5172 closed.

  • 12/17/SO

Re< Oaker notation on NES documentation review checklist form

(closecut).

  • 5ignificant information not in OIA Chronology.

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WR- K- 511

WR- K- 516

(WR-K-E27)

(WR- K-916 )

(WR-K-917)

WR-K-511 and WR-K-827 were welds on the Auxiliary Building Closed Cooling

Water System.

Weld WR-K-516, on the same line, is still in existence.

Welds

WR-K-916, WR-K-917 are replacement welds.

Weld WR-K-S11 was located in the

Auxiliary Building at elevation 572'

The line is 4 inches in diameter (weld

was 12.56 inches of weld metal).

Design conditions for this line are 120 psig and 105 degrees F.

Maximum

operating conditions are 150 psig and 125 degrees F.

The line is S&L

piping Class C (final visual inspection only, not normally radiographed).

CHRONOLOGY

08/ /77

Approvals for production of WR-K-516

11/08/77

Consumable insert placement and tack weld WR-K-516.

11/09/77

WR-K-516 welded, ANI waiver an hold point.

01/29/79

WR-K-811 weld fit up.

01/30/79

WR-K-811 visual inspection of t ?nal pass-accept.

KEl-1

misplaced.

"10/ /79

Inspector Setlock assisting with documentation location and

correction.

10/11/79

NR-E-2138(RO) WR-K-811 and WR-K-516, aelieve missed ANI

holdpoint.

Disposition:

RT, accept if RT acceptable.

  • 11/06/79

RT of weld WR-K-516 per. NR-E-2138RO.

  • 11/06/79

Probable date of RT of WR-K-811, radiography not retained.

R e j ec+..

(RT done twice).

  • 11/08/79

RT of WR-K-516 rejected for unconsumed insert, other defects.

  • 12/03/79

NR-E-2260, RT of WR-K-811 shows adjacent weld WR-K-827 un-

.

acceptable, unconsumed insert.

Disposition:

Replace pup piece, 'see related NR-2138."

12/14/79

NR-E-2238 " Voided" (actually supe, seded), .

"see Revision 1."

  • 12/27/79

" Steve" tells Applegate K-811, "MSR pipe" has " insert f ault."

  • 01/07/80

Speed memo, Ruiz to Pallon:

WR-K-516 no KEl-1, RT reject.

  • 01/ /80

NR-E-2138 Revision 1, (see related NR-E-2260).

Dispostion:

Cut out and reweld.

01/14/80

Approvals on NR-E-2138, Revision 1 (weld WR-K-516 not mentioned).

01/16/80

Approval on KEl-1 for welds WR-K-916, WR-K-917.

01/18/80

WR-K-916 fitup and weld.

01/21/80

NR-E-2138R1 closed.

01/24/80

WR-K-916 visual inspection and acceptance.

  • 01/24/80

NR-E-2260 closed.

03/03/80

Applegate interviewed by Phillip.

04/07-09/80

Phillip onsite.

  • 08/ /81

RT for WR-K-516 found.

  • 08/ /81

WR-K-516 Re-radiographed.

  • Significant information not in OIA Chronology.

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RH-42

_ -2 zas a veld cn line lam 01CIS in the

Ec_.m_c.

e s t Removal systea.

-ne rela was located in t.'e reactor build:ne at eleva. tion 497'

The line

is

'.S inches in diameter (weld was 56.54 :ncnes of weld metal).

Design conditions for this line are 220 psig and 389 degrees F.

Maximum

eperating conditions are 240 psig and 358 degrees T.

The line is S&L piping

' lass B.

CHRONOLOGY

08/06/76

Weld fit-up.

08/06/76

Weld performed.

08/09/76

RT of weld.

08/09/76

RT read by P-M, reject markers 36-48 (Notation:

re-shoot 100*;

following repair).

08/10/76

KE approval of above RT interpretation.

08/10/76

Approvals on WRD form.

08/10/76

RT of repair area.

08/10/76

RT read by P-M.

08/11/76

RT accepted by KEI.

08/11/76

Approval of repair.

09/16/76

ANI review of 8/9/76, 8/10/76 RT reports, approval.

  • 10/10/79

NES review begins.

  • 01/25/80

NES review, porosity at film markers 53-55.

  • 02/12/80

NR-E-5056 based on NES review findings.

  • 02/15/80

NR-E-5056 dispositioned to grind out and repair defect.

03/03/80

Applegate interviewed by Phillip.

03/21/80

WRD form approvals.

  • 04/07-09/80

Phil-lip onsite , initistion of Applegate investigation.

04/14/80

PT of re prepped pipe ends, acceptance.

04/21/80

Approvals fer WRD for new elbow.

04/23/80

PT of c' bow end prep. accepted.

.

04/30/80

' Weld fit-up breaks loose (Ref: KEIA No. 1008).

05/01/80

Re-fit-up epproved and weld started.

05/02/80

Root pass made.

05/05/80

Root pass approval.

05/06/80

RT of new weld.

05/07/80

RT approved by KII.

  • 05/07/80

ANI review and approval.

  • 06/16/80

NR-E-5056 closed out.

  • Significant information not in OIA Chronology.

COMMENTS

The NES documentation checklist dated January 25, 1980, by R. A. Zieler,

LII RT, on page 3 notes "NR issued to repair rejectable indication" ant

" corrective action prepared by T. McCall, February 12, 1960".

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It appears that tne .decisien t o grind out and repair the defects at film

markers 53-55 was :isinterpreted to mean cut-out the entire veld.

Weld

c u r.- o u t ther: necess::.:r; a net- elbow, as fit-up could not be accomplished

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witnin spec :: cat:cns.

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Enclosure 1

REPLIES TO OIA FINDINGS

1.

DIA Findino

OIA review of investigative file disclosed inadequate documentation.

Discussion

The OIA comment on documentation (page 2) refers to the RIII investi-

cative file, rather than the investigation report itself. They noted

that no "results of interview" or copies of weld documentation reviewed

were in the file.

On page 13, it is pointed out that no identification

key was generated for the investigative file.

Neither NRC, IE, nor RIII procedures require a "results of interview"

to be generated for each interview, and all interviews are not required

to be portrayed in detail in an investigation report.

Investigation

reports should contain all pertinent information, whether obtained

through observations, records or interviews, concerning the matter in-

vestigated.

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There is no need for retention of copies of all documentation obtained

during an investigation.

If a document appears to be relevant to the

case, it is often reviewed onsite,_and no copy is obtained.

If a docu-

ment appears central to an allegation, it is then copied, and may be

made an attachment to the report, if warranted by the issue involved.

2.

OIA Findino

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IE investigative report did not identify the dates on which the welding

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rework was conducted on weld K-811.

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Discussion

Although the IE investigation report did not identify the date when weld

K-811 was removed (approximately January 16,1980), the report did

correctly identify that the weld had been removed as provided by the

disposition of NR No. E-2138R1. Thus, the weld alleged to be improper

was nonexistent, having been removed eighty-two days prior to the

investigation team's arrival at Zimmer.

Determination of the date of

rework was not necessary in our view.

3.

CIA Findino

The IE investigation report did not identify that a nonconformance report

(NR) on weld K-811 had initially been closed with the notation " accept as

is," and was later voided and reopened to order the weld cut out.

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Discussion

The finding as stated is incorrect.

The " accept as is" statement on the

NR was conditional in that it only applieti if a radiograph showed the

weld to be acceptable. Apparently the OIA investigator misunderstood

the NR.

4.

OIA Findina

The investigation did not determine that weld RH-42 had been cut out and

replaced after initiation of the investigetion.

Discussion

The finding is correct. The investigation did, nowever, properly deter-

mine that weld defects had been identified and corrective action was

pl anned .

The actual date of corrective action is not significant.

5.

OIA Findinc

_

None of the welds alleged to have been deficient were inspected by the

investigation team nor was all pertinent weld documentation reviewed.

_

Discussion

The finding is correct but conside.-ed irrelevant. The investigators

did not inspect the welds but did review the radiographs, which was

the correct method of evaluation. Visual examination of the weld would

not identify internal defects. The investigators did not review all

weld documentation but did review the pertinent documentation to

establish proper Weld disposition.

6.

OIA Finding

The IE investigators did not fully investigate or accurately report on

the alteration of a noncomforance report (NR) related to spool piece:

containing defective welds.

The IE report only identified an individual

as a "CG&E official" vice "QA Manager," thus obscuring that this was the

licensee's senior person responsible for the site QA program who ordered

improper voiding of a NR.

Discussion

Investigator Phillip indicates that the matter was discussed with his

supervisor, and the pursuit of who directed the lining-out was seen as

having little significance. This wat because a separate NR had been

opened, providing tracing of the nonconformance. Finally, neither OIE

nor DI A could substantiate the allegation.

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7.

01A Findina

The IE report found Applegate's allecations on defective welds was

"not substantiated" because welds had not been finally accepted.

This is a question of semantics and not consistent with the facts.

Discussion

The use of the term "not substantiated" was linked with the RIII view

of the status of the acceptance of welds.

RIII ,,as, through previous

inspection findings, well aware that nondestructive examination tech-

niques had been found to be deficient. based on the NRC findings and

related concerns, a consultant had been hired by the licensee to review

weld radiographs. That action negated any previous "acr.eptance" of

plant weld radiography. The previous inspection findings and status of

-the welds in question are correctly stated in the IE report. As such,

it should be clear that the licensee had not given final acceptance to

the welds in question and a system was in place to assure that defective

welds would be identified and corrected prior to final acceptance. As

,

shown in the chronologies, decisions to grind out and replace two of the

welds in question (WR-K-811 and RH.42) had been made prior to initiation

of the RIII investigation.

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