ML19347A653

Testimony of CC Williams (AEC) Re Facility Const QA Program

ML19347A653
Person / Time
Site:	Midland
Issue date:	06/28/1974
From:	Williams C US ATOMIC ENERGY COMMISSION (AEC)
To:
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ML19347A649	List: ML19347A648 ML19347A651 ML19347A653 ML19347A654 ML19347A655
References
NUDOCS 8007310557
Download: ML19347A653 (10)

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J estimony on Facility Construction - Ouality Assurance Procrams T

111dland Units 1 and 2 By

-Cordell.C.' Williams I.'

INTRODUCTION

-My'present position is.that of' Reactor Inspector.in the Reactor Construction' Branch, Directorate o'f Regulatory Operations, Region

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III.. In this position,-I assist in the inspection of-nuclear

. facilities that-are b'eing constructed under an AEC construction permit or authorization, to ascertain whether the facility, as built, conforms to the provisions of the construction permit or I

authorization and application and whether it can be operated safely.

Within the Region III geographical arca, I have (among other. duties) principal responsibility for in-service inspection and nondestructive examination.

I have been in my present position since 1970. From 1968 to 1970,,I was e= ployed by the State of

. California Department of Water Resourcet., Equipment, and Materials Departmentasa. Quality. Assurance /!jondestructiveExamination

• Specialist. My dutics included providing technical assistance to field' inspection (civil-mechanical) methods for the construction of large hydroelectric projects, provide assistance in the produc-

. tion.of quality assurance / quality control 'and' nondestructive

- examination requirements, and perforising' vendor inspections.

From 11960~toJ1968,-ILwas employed by the San Francisco Bay Naval Shipyard t;

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-(Hunters; Point,(MareIsland)whereinmyworkinvolvedthe=construc-

tion;and repair of. nuclear and conventional-naval vessels.

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.'in:variods capacities (in,the Quality [Assuranec/ Quality Control-Mj{%S10

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l Department as a Quality Control / Nondestructive Examination Inspector, t

Quality Assurance: Inspector ' Training Supervisor' (quality. control /

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nondestructive examination) ~ and my.last position, prior to resigna-tion, was Nondestructive ~ Examination Supervisor.

.With~ respect.to the~ Midland' facility, I.have participated in~four

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' inspections at the construction site. This testimony will describe the' scope.of my participation ~and the results of these regulatory l>

linspections of.the Midland Nuclear Power Plant authoriaed by the A omic. Energy Commission under Construetion-Permits No. CPPR-81 and No. CPPR-82.

-II.

MIDLAND INSPECTION-ACTIVITIES During.a routine inspection at the Midland construction site on November 6 - 8', 1973, I observed ~significant deficiences in' Cadweld-ing activitiies.

In the course of a routine site tour, I noted that Cadwelds purported.to be finished and' acceptable showed remnants of I

j; slag and asbestos at the Cadweld ends to an extent which appeared to preclude adequate visual inspection ofijoint ends. Further observa-t_

tion of several Cadwelds indicated that. excessive void areas existed, L-and some recently completed Cadwelds did not appear to. meet clean 11-ness requirements for"rebar ends._. Discussion at this-time, with site field engineers and licensee representatives.regarding the above

~ concerns, indicated-that they.were se fully familiar with Cadwelding

. -requirements in' that they indicated - that the observed deficiencies.

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and questionable items vere considered by themLto be adequate.

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r sequently, I identified at.leastifour finished and-'ihstalled Cadwelds-R-

t which:' displayed what? appeared to-be marginally. acceptable voiding. At'my W

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request,.those Cadwelds were reinspected by Bechtcl Corporation Field Engineers-(who had principal' inspection-responsibility) and this i'nspection established the' observed voiding to be acceptable.

-Two days'1ater, I: request'ed that these same'Cadwelds be reevaluated by Bechtel Corporation Quality. Control Engineers.(who examined th'e-work of ' the Field Engineers).! This inspection resulted'in the rejection of the same, previou' sly accepted' Cadwelds. 'One of enese Cadwelds~was in pla'ce'in.the Cadwels makeup area, and the other was installed'in Unit 2.

On'the basis of the above observations'and findings, a thorough review of all quality assurance /qualtiy can' trol and technical requirements of site-Cadwelding was initiated. The results of this

. effort were as follows:

1.- Procedurcs' cover.f rig CAdwelding activities did not provide adequate instructions for performing Cadwelding splicing, nor for inspection of completed splices.-

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1s.structions and procedures were, not being implemented ' to assure that Cadweld' preheating requirements were properly

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accomplished.

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The current l inspection procedures, nor instructions,-could not be made available toidemonstrate that measures had been

-established to. adequately'. control handling and issuance ofi 1Cadwelding splicing material.

14. :An u'nwrapp3d and spot-rusted Cadweld. sleeve was noted-to be.

stored Uith a supply of wrapped Cadweld sleeves.

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f5.;:Aprocedureto:adequatelyprovide'for-identificationandcontrol

- of J Cadwelding material was not' made available~ f or. review.

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, 6. - Procedures,fproviding for; segregation of nonconforming Cadweld) materials,,wasnotavailabicforreview..

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Procedures, to. adequar -ly, assure that ' unused Cadwelding material l

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. issuance' locations, were not availabid for review.

8h Records wdre not maintained to furnish evidence that Cadwelding-splicing in-process production control activities were actually.

performed as required, and records to provide evidence that issuance control measures for Cadwelding material were properly accomplished were notLmaintained.

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Inconsistencies between'the Midlan'd PSAR,-Bechtel Corporation

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Specificat. ion No. C-231, Bechtel Corporation Master Inspection Plan for Cadwelding, and.the manufacturer's recommendation

.. wcre noted in' re;:ard to cadweld preheat reqiiirenents.

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10.. The Cadweld personnel qualification. requirements in Specifica-tion No. 231 appeared incomplete in that it did not provide for L

circumstances under which Cadwelders will be disqualified for inadequate performance or requalified when performance indicates

.a need~for'such action.-

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. ll. ~ A Field Engineer making void area inspections did not demonstrate lI

} knowledge'of acceptance criteria when, questioned.

12. 1The Field Eng'incer's measuring tools ~. appeared to compromise void

. determination.':Asfa result of'the above findings, the licensee-i4 f-took(theifo11'owir.g ' action prior to and/or. at - this end of this

' inspection:-

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The l'censee acknowledged the inspector's findings and.

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indicated.that corrective action f or some of the above

- matters'has been initiated as follows:

. a.~. : Retraining of inspection personnel has starte'd in that

. inspection'personneltexamined a previously accepted and

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.' subsequently rejected Cadweld which had been cut:out and

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used for this purpo'se.

b.

Cadweld inspection requirements have been rereviewed.-

c. ~ Additional quality control personnel are to be made d

. available for this work.

d.

The Erico Products Company representative (Cadweld

. manufacturer) has been requested to come to the site for-t further training.-

e.

A representative of the licensee stated that all-Cadwelding

. operations at the site were temporarily stopped.

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In 'regaid to.the. total finding, the licensee stated-that additional review would be necessary. prior to further

' corrective action.

Subsequently.-1'n a telephone conversation with RO:III, the licensee agreed to reinspect all' site Cadwelds.

I participated in -a subsequent inspection on November 20 'and 21,1973,

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' for. the' purpose of determining. the adequacy of the licensee's corrective

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~ action relative to: ((l)'.Cadwelding -and ' Cadwelding inspection violations

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.- and deficiencies, and-(2).an apparent lack of management involvement in=

Ithe / implementation -of the Midlandf Quality Assurance Program.

' s I was directlyLinvolved-with the following areas-of this inspection:

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Review of Bechtel Corporation. procedures, including draft forms R

for quality. activity performance accounting covering the per-

. formance of and inspection of Cadwelds, t

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Review and discussion ~ relative to the need for Consumers Power

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Company to provide procedures designed to specifically provide assurance-that specifications covering Class I-work' properly

' reference ~and deal with all applicable criteria (PSAR, manufac-turer's specifications, regulatory guides, etc.).

3.

Review of' Bechtel Corporation nonconformance report covering the 4

rejected Cadwelds found by the inspection performed by quality control engineers.

4. ' Review of new instructions and procedures, written.to cover both Cadwelding'and Cadweld inspection, and new forms, designed to dc=en:trate conformance to quality requirements (checklist, etc.).

Some of.these forms were. in' rough ikaf t, unapproved and/or lacking in one or more respects at the cime of this inspection.

On December-6 and 7,1973, I. participated in a special, announced inspection at the site in the company of W. E. Vetter, R. A.

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Rohrbacher, and D. E. Whitesell. This effort involved a special inspection to determine the-status of the licensee's corrective-action, relative'to quality assurance / quality control program deficiencies and specific,f apparent violations -identified in conjunction with s'ite' Cadwelding. activities.

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'Th'e results'of this inspection Idd:to a' conclusion, by RO:III:

inspection personnel,.thaticorrective action has been taken such-a y

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ithat continued!Cadwelding'at the cons'ruction site.could now be t

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-accomplished twith properaattention.coDquality' erit.cria.

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I was directly:.; involved,31n part, with Ehe followihg dreas.of. review:

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il.. Cadweld personnel qualification = relative.to the provisions L

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,establishedoin the governing Bechtel Corporation specification l

'(No. 231).

f2. Review of corrective action relative to identified inconsistencies between design documents and.the PSAR.

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Review of tho' status of corrective action.on the part of Censumers Power Company management to identify'and deal with generic quality L

assurance program deficiencies (participated in first management.

l interview discussion).

4.

Participated in the second management interview wherein each Linspector identified areas of inspection coverage and'co=mented, i

in detail, with respect-to the. scope. of inspection coverage. At this time. the licansee was informed. by Mr. Vetter, that the results.of the inspection would'be thoroughly reviewed and made ll

.available to the Director of Regulatory Operations and that an '

authorization col continue. Cadwalding activit.ies can only be initiated by the Director of.Rugulation.

'5. ' Review of corrective action, relative. to specific violations and deficiencies, -as-reported in R0' Inspection Reports No. 050-329/73-10

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'and'No. 050-330/73-10, as follows:

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Procedures for Cadwelding and Cadweld inspection.

b.1 LInstructionsf ahd procedures for: preiicating (I partic'ipated, i

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in-parthin'this. review).

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c. ; Inspection personnel ~did'not demonstrate knowledge and proper m

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limplementation of Cadweld accerrance criteria (I participated,

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. in parth in review of; this matter). -

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Measures to control handling and issuance of Cadweld splicing

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e. ' Procedures to cor. trol nonconforming Cadweld Material.

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Review of records to furnish evidence of conformance to quality ' requirements.-

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Participated in evaluation of Consumers Power Company P

reinspection of Unit 1 Cadwelds.

h. - Participated in evaluation of provisions for Cadwelder qualifications and provisions to preclude inconsistencies

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between design-documents (Bechtel Corporation Specifications, manufacturer's instructions, and the PSAR) relative to

.Cadwelding activities.

I participated in the inspection performed on January 10 and 11, 1974, with Messrs. Vetter, Rohrbacher and Whitcsc11.

This inspection report,

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in-addition to other matters, covered a'special inspection to determine

.the adequacy of implementation of the corrective astion previously committed to by:the licensee relative to quality assurance / quality control program deficiencies.

Relative'to matters concerning Cadwelding corrective action, I partici-pated.in'the'following areas.z

?l.. Completion of-(Bechtel Corporatiion)-procedure revisions for y

'CadweldingLand records--(Cadweld Inspection Form).

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Provide'further clarificatior r arding-Cadwelder ;,ersonnel~

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' retraining'and maintenance.offqualific. ion.

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7.. Provide-visibility.'of-Cadweld inspection.results.

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14. :: Provide adequatelinstructions -and. procedures for storage and handling offCadweld materials.-

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5. _ Provide adequate procedures and records' relative to the control'

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of nonconforming Cadweld 'atcrial.

c 6.-iProvide instructions and procedures regarding Cadwelding-preheat requirements and provide verification that the requirements have ibeen met.

7.. Adequate. procedures for.Cadwelding.

8. ' Procedures'for Cadweld splice-inspection.

L Ca'dweld inspection records to provide evidence that Cadwelds

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conform to quality' requirements.

I conducted a special, announced inspection on January 29, 1974, at the Midland site. The purpose of this inspection was to review the scope ofsa problem, and the Consumers Power Company /Bechtel Corpora-Ltion' corrective action relasive to errors in Cadweld void area I.

computations. These errors were found in previously submitted and accepted Cadweld reinspection data. The results of this' inspection

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are documented in'R0 Inspection Report No. 050-329/74-02.

4 In summary, as a result of this inspection, it is apparent that correction t

of these'small and random errors will *not change the original reinspec-1

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l ticn acceptance status ofJany of the.936 splice ends reinspected in

. Units 1 and 2. ~ Subsequent to the above inspection, a final report of this matter was submitted to RO:III. This report confirms that E

laccept/ reject ctatus of the subject Cadwelds did ~not change as a

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' result oficoriecting the cceputation errors.-

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Attachment:

JAttachment A

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MIDLAND TESTTMONY,;

By Cordell C. Williams LOtherbattersRevicwed~attheMidland'Construc. ion' Site.

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' A. ~ During the' inspection of November 6 and 7,1973, in addition to 1 matters associated withlCadwelding,;I' reviewed the following areas which'are likewise. documented in RO Inspection Report No.

050-329/73-10 and No'. 050-330/73-10.

1.

Concrete aggregate storage and implementation of sicve analysis requirements.-

.2.

Tendon trumplates, including all quality assurance / quality control and installation parameters.

B.

During the inspection of January 10 and 11,1974, in addition to i

. matters associated with Cadwelding and associated programmatic quality assurance consideration',-I revie.wed the following:

1.

Qualifications of containment tendon trumplates.

2.. Revision of-the nucle'ar quality assurance manual 1 provisions forL retention of records common,to. activities affecting quality.

3.

Corrective. action regarding maintenance of project stick files (drawing' control)'.

'4.'. Revision of the Bechtel. Corporation Nuclear Quality Assurance

. Manual;regardin"g ' engineering-design interface contro1' require -

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I' menes :(Commitment No.13)'.

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5. - Ameniment of the nuclear qualit'y assurance manual to ' provide h

the' project e'ngineer 'with flexibility to respond to quality 3

Jassurance - specification ; changes' and 'the Ldeletion 'of inapplicable 7

l nuclear; quality,assurancemanual: exhibits.

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