Text

IE Investigation Rept 50-483/81-04 on 810220,0303-06 & 23-27.Noncompliance Noted:Apparent Incomplete Fusion & Excess Reinforcement W/Pipe Piece Not Judged Unacceptable or Repaired.Exhibits I-XIII Encl
	ML20005B044
Person / Time
Site:	Callaway
Issue date:	06/25/1981
From:	Fiorelli G, Foster J, Hansen W, Key W, Streeter J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	;
Shared Package
ML20005B039	List: IR 05000483/1981004; ML20005B038; ML20005B042;
References
	50-483-81-04, 50-483-81-4, NUDOCS 8107060255
	Download: ML20005B044 (86)
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{{#Wiki_filter:e . . U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-483/81-04 License No. '?PR-139 Docket No. 50-483 Licensee: Union Electric Company Post Office Box 149 St. Louis, MO 63166 Facility Name: Callaway Nuclear Plant, Unit 1 Investigation At: Callaway Site, Fulton, M0 Investigation Conducted: February 20, March 3-6, 23-27, 1981 Investigator: h d (lo /@ //[/ E. Foster (Dated ~ Inspectors: ]

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/ Resident ' . Hansen, Senior (Datd Inspector Reviewed By: md,[I - D E!M d/ G. Fiorelli, Chief V (Dato$ Projects Branch 2 Mua hs 1.. ??,RP-l J.1 Streeter, Acting Director (Date), Enforcement & Investigation Staff t Investigation Sumary: Investigation on February 20, March 3-6, 23-27, 1981, l (Report 50-483/81-04)

Areas Investigated: Special, unannounced reinvestigation of a previously invest-igated allegation relating to an accumulator discharge line pipe crack; review l 8107060255 810625~ PDR ADOCK 05000453 ! O POR i -.-. --- .- - . -. --. - - _ _. -.. -.. .. . . -. . -. -.

. ~ of reccrds, interviews of personnel, inspection of weldments, review of radio-graphy. The investigation involved 88 investigation-hours by three NRC personnel oraite, and additional in-office review.

Results: In the areas investigated, one item of noncompliance was observed relative to radiographic examination. Nonconformances in the pipe piece in question had been identified and corrected as required. Examinations showed the pipe to be acceptable.

.. . -2-

. - REASON FOR INVESTIGATION During late 1979, NRC Region III (SIII) received an allegation concerning a crack in a vendor longitudinal weld on a discharge line associated with an accumulator tank at the Callaway site.

This allegation was investigated in March and May 1980 and the results of that investigation are documented in Inspection and Enforcement Investigation Report No. 50-483/80-10 (Exhibit I).

' By letter dated February 8, 1981, (Exhibit 17) the alleger informed RIII of what he felt were deficiencies in the depth and scope of the above investiga-tion. On the basis of the concerns expressed, a second investigation was initiated to review the initial investigation and tc expand upon the matters previously investigated.

SUMMARY OF FACTS The initial investigation was reviewed for scope, content and accuracy and compared to the expressed allegations.

Telephone contacts with the alleger, Individual A, were not electronically recorded during the initial investigation. The only records available were the original investigator's notes of the. telephone contacts which indicated that the alleger's concerns were understood to be limited to a crack in a vendor seam weld, excessiv# weld " fall-through", and containment wall penetration clo-sure plate weld co. figuration. A handwritten letter from Individual A dated April 19, 1980, (ixhibit III) is limited to a discussion of a " pipe crack" and " excessive fall-through".

The scope and content of the initial Investigation and Investigation Report No. 50-483/80-10 appeated to adequately address the allegations as understood by RIII with the exception of the penetration weld configuration concern.

It was found that the weld configuration concern had been reviewed and the con-clusion of that review (i.e., weld configuration was acceptable) was included in a draft letter transmitting Investigation Report No. 50-483/80-10 to In-dividual A.

Due to an administrative oversight, the letter was not sent.

A discussion of the weld configuration concern is included in this report by attachment of the draft trarsmittal letter which had been intended to be sent to Individual A.

Regarding accuracy, four errors in the report were identified but were judged to be insignificant.

Based on the information contained in the February 8,1981, let ter from the alleger, the present investigation was conducted with a wider scope than the previous investigation and included a review of all available quality documen-tation concerning the pipe piece in question. This included a review of the type of plate utilized, weld procedure records, vendor radiography, fabrication records, receipt records, Nonconformance Reports and vendor correspondence.

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. . Visual inspection of the weld was performed, measu ements of pipe ovality were taken, the weld was re-radiographed, and the radiographic film was evaluated by an NRC Level III radiograph interpreter.

Review of vendor radiographs indicated that one approximately four inch area of the pipe piece (the area of the alleged pipe crack) should have received further vendor review and possibly re-work to remove excess weld reirforcement.

The Region III interpreter concluded that the radiographic record indicated that this area of the pipe piece contained a defect that should have resulted in re-jection of the area for failure to meet American Society of Mechanical Engineers (ASME) Code criteria. This was considered an item of noncompliance with NRC requirements.

It was found that a site QC inspector had preserved detailed photographs taken of the weld in question prior to the dispositioning of a Deficiency Report which required removal of excess weld reinforcement. The pictures clearly indicate two overlap areas or " fissures" in the excess weld reinforcement which eight appear as a " pipe crack".

No crack was evident in the pipe material itself, and the area where the weld reinforcement was removed successfully passed a liquid penetrant exam.

_ Site actions and the ultimate disposition of two related Nonconformance Reports were acceptable. A review of a Nonconformance Report concerning the original excess weld reinforcement condition indicated that the Architect-Engineer (Bethtel) had incorrectly interpreted applicable Code requirements relating to which Section of the Code was applicable and returned the report without dis-position. However, the defect was removed via a site-initiated Deficiency Report. The visual inspections, measurements, and radiographic review of the pipe performed during this investigation indicate that the pipe piece presently meets all ASME Code requirements and is acceptable.

-4-

. DETAILS . 1.

Personnel Contacted Union Electric M. Doyne, General Superintendent, Callaway Construction H. Hess, Consultant, QA , . *S. Hogan, QA Assistant Engineer

J. Laux, Supervisory Engineer, QA Construction
R. Powers, Superintendent, Site QA
W. Weber, Manager, Nuclear Construction Daniel International Corporation
A. Arnold, Project Quality Manager P. Bohnert, QC Technician, Level III D. Council, Technical Services H. Dameron, QC Inspector E. Fluet, Radiographer T. Massey, J. Prince, Foreman
H. Starr, Project Manager
D. Stites, Project QC Manager W. Sykora, Assistant Preject Manager Bechtel Power Corporation (Bechtel)

H. Borda, Project Engineer, Plant Design N. Cherish, Site Plant Design Liason B. Lulla, Group Supervisor, Piping and Valves Hartford Steam Boiler Insurance Company H. Potter, Authorized Nuclear Ins;- +or . Individuals Individual A .Also contacted were other licensee and contractor personnel, including craftsmen, QA/QC, technical and engineering staff members.

Attended site exit interview March 27, 1981 I

2.

Scope and Chronology The investigation focused on the acceptability of the manufacturer's seam welding on a section of piping included as pact of the discharge line for-5-

_ . ~ discharge line for accumulator tank TEP01A.

Included were reviews of fabrication procedures, design documents, quality documentation (including manufacturer seam radiographs), nonconformance reports, inspections of the in place spool piece, and interpretation of a current seam weld radio-graph. Measurements of pipe ovality were also made.

A partial chronology of the manufacture of the pipe piece, site identifi-cation of deficiencies and corrective actions, and initial and present NRC ,, investigation efforts are included as Exhibit V.

This report is essentially in chronological order of occurrence.

3.

Introduction The emergency core cooling system (ECCS) is designed to cool the reactor core during accident conditions. Major components of the ECCS include the accumulators, refueling water storage tank, boron injection tank, boron injection surge tank, residual heat removal (RHR) pumps, centri-figual charging pumps, safety injection pumps, boron injection recircula-tion pumps, RHR heat exchangers, and assorted piping and valves. The accumulators are pressure vessels partially filled with borated water and pressurized with nitrogen gas during plant operation. There are four accumulator tanks, each with a discharge path to a reactor cold leg (part of the reactor coolant system). During normal operation, each accumulator is isolated from the reactor coolant system (RCS) by two check valves.

The design is such that a drop in RCS pressure below accumulator pressure opens the check valves and borated water in the accumulator tank is then forced into the RCS by nitrogen pressure. As indicated in the Callaway Final Safety Analysis Report, Section 6.3, the system is designed so that a minimum of three accumulators insures adequate core cooling in the event of a design basis accident.

Accuculator tanks and discharge piping are required to meet American Society of Mechanical Engineers (ASMI) Section III, Class 2 requirements (1974 Edition with Winter 1974 Addenda). As the piping is exposed to different pressures and temperatures along its length (due to the location of isolating valves) several different pressure classes of piping are involved. The spool piece in question, S002, is Bechtel Class BCB piping l (Pressure class B, Material Class C, Code Class B = ASMI III, Class 2).

Design pressure and temperature for this piece are 2485 psi, and 150 degrees F, and normal operating parameters are approximately 700 psi and 150 degrees F.

The pipe is 10 inch schedule 140 stainless steel with a nominal 1 inch wall thickness. Dimensions for such pipe are 10.75 inch outer diameter and 8.75 inch inner diameter.

During manufacture, installation and usage of nuclear safety-related piping, various Codes and Standards are applicable.

These Codes cover design, materials, fabrication, installation, inspection, and repair.

The following Codes and Standards apply to spool piece S002 (as well as other Standards referenced in those listed): -6- _.

. --. .. __ -. _. _, _ _ _ _ _. _ _. _ _. _, _ _ ___ _.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ .__. _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ .. . _ _ _ _ _ _ _ _ _ _ _ _ _ ___________________ _______ . American Society For Testing and Materials - (ASTM) A-240 (Plate material) ASME, SA-358 (1974) (Pipe manufacture, weld process, inspection, material, tests, dimensions) ASME, SA-540 (General requirements) , ASME Section III Class 2, NC (Materials) . ASME Section III, Class 2 (Components) ASME Section XI, (In-service inspection reouirements) 4.

Pipe Manufacture It should be noted that spool piece S002 is comprised of four pipe pieces. This report addresses the pipe piece questioned, No. SP, Heat No. 24942. Other pieces were manufactured by a different manufacturer.

The original purchase order ter the spool piece was issued May 15, 1975, and specified that the piece meet the requirements in Bechtel Specifica-tion 10466-M-201A (Q), " Design Specification for Shop-fabricated Piping to ASME Section III."

The original pipe picce was manufactured (plate bent and seam welded) at ARMCO Steel Corporation, Advanced Materials Division, during late 1977.

Stainless steel type 304 in the form of ASTM specification SA-240 plate and Weld Procedure No. 5, Revision 1, were utilized. Weld Procedure No. 5 is a submerged arc welding (SAW), double-weld, full automatic weld procedure.

In this procedure, the inner pipe diameter weld is made first, consisting of one pass, the seam is then backgouged, examined, and welded with one or more weld passes.

The entire seam weld (20 feet) was radiographed during September 15-16, 1977.

The manufactured pipe was sold to Guyon Alloys Incorporated and subse-que ntly sold to the Dravo Corporation, Pipe Fabrication Division (Dravo).

At Dravo the original pipe was cut and one of the pieces, approximately four feet eight inches in length, was used by Dravo in the fabrication of spool piece S002. The piece is adjacent to the location of field weld F004. This piece was designated by Dravo as No. SP.

Circumferential welds were performed by Dravo to manufacture the completed spool piece.

An inservice weld preparation was performed by counterboring the end of piece SP to the requirements of MS-6, "End Preparation Data," because.

field weld F004 requires periodic inservice inspection.

5.

Discovery of Nonconformances The spool piece was received on site and the receipt inspection detected no shipping damage.

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.-. . l ~ I: is not clear who initially identified deficiencies related to the pipe thickness at the counterbored area and vendor seam weld reinforcement overlap. Apparently, craft personnel called these deficiencies to the attention of Quality Control (QC) personnel in late April 1979 prior to spool piece fit-up.

Daniel QC Inspector B. Diggs indicated that it appeared that the counterbore was off-center, and that seam weld de-ficiencies were called to his attention by welder whose identity he did not know. This was in accordance with site procedure (AP-VII-02) which states "Nonconformances/ Deficiencies may be identified by any project ,' personnel observing a nonconforming condition".

An ultrasonic examination of the counterbored area was performed on April 26, 1979. This examination showed minimum wall violations involv-ing approximately a quadrant of the pipe. A Nonconformance Report (NCR 2SN-0496-P) covering this condition was originated on April 27, 1979. An inspection of the vendor seam weld indicated overlap and excessive weld reinforcement height in one area. A Nonconformance Report (NCR 2SN-0501-P) was originated to document this condition on April 30, 1979.

From discuss-ion with the originating inspector, the height of the reinforcement referred to in the Nonconformance Report pertains to the area of excess reinforcement only. Photographs were made of the excessive weld reinforcement area and they show overlap and two fissures which could appear to be " pipe cracks".

" Hold" tags were placed on field weld F004'pending disposition of the two Nonconformance Reports.

6.

Disposition of Nonccnformanets The Nonconformance Report (NCR 2SN-0496-P) documenting the minimum wall violation was dispositioned by Bechtel as "use-as-is."

The basis for that conclusion was a calculation utilizing design conditions which derived minimum wall thickness for the pipe class and pipe diameter.

RIII representatives discussed this calculation and its basis with Sechtel Engineers B. Lulla and H. Borda via telecon on March 6, 1981.

Minimum wall had been calculated as described in ASME Section III Division 1, Subsection NC (Class 2), Article NC-3640, " Pressure Design of Piping Products".

Bechtel personnel advised that two calculations had been performed, one using design temperature and pressure of 2485 psi and 200 degrees F (normal expected pressure and temperature are approximately 700 psi and 150 degrees F) and one using 2485 psi and 650 degrees F (assumes upstream valve leakage from the reactor coolant system, thus increasing line temperature). The first calculation yielded a calcu-lated minimum wall of 0.711 inches. The second, and most conservative-calculation, indicated a minimum calculated wall of 0.795 inches.

The actual measured minimum wall thickness was 0.814 inches and was there-fore acceptable.

The disposition of the NCR appears to be both acceptable and conservative.

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. - The Nonconformance Report (NCR 2SN-0501-P) documenting over:ap and excessive reinforcement was also sent to Bechtel for disposition.

By letter dated June 1,1979, the report was returned by Bechtel to the Callaway site with-out disposition. The reason for this action was a conclusion that the observed conditions did not " fall under NCR category".

It should be noted that to return a Nonconformance Report without disposition is not equivalent to a disposition to "use-as-is".

Such a response can indicate that (1) the NCR is in error, or (2) disposition by other means such as a Deficiency Report is more proper.

, , The. Tune 1,1979, Bechtel letter addresses both observed nonconforming conditions, excessive weld reinforcement and overlap (See Exhibit B of Investigation Report No. 50-483/80-10). The paragraph regarding reinforce-ment height requirements appears to be incorrect in that it references sections of ASME III, whereas Paragraph 5.2.3 of material specification ASMI SA-358 should have been identified as the applicable specification for a vendor weld, allowing 1/8 inch of reinforcement.

The paragraph in the June 1, 1979, Bechtel letter regarding overlap contains an incorrect observation that material specification ASME SA-358 eferences ASMI Section III, Paragraph UW-51 (b).

SA-358 references ASME Section I, Paragraph PW-51.

The reference to ASME Section VIII is likewise in error as Section VIII does not pertain to the piping covered by Section III.

However, the wording of both Sections is virtually identical (the Code often duplicates Sections) and neither refers to " overlap" ar. a rejectable condition for radiography.

This error is not considered significant.

What was significant was the apparent acceptance of overlap as a weld condition.

Discussion with Bechtel personnel involved with review of the nonconform-ance indicated that they felt that ASME Section III was the governing Code, superseding aspects of ASME Section II and material specification SA-358.

As the weld in question is a vendor longitudinal seam weld, this conclusion is incorrect. The relevant Code for such vendor (pipe manufacturer) welds is SA-358. ASMI Section III is relevant for welds made by the spool vendor and field welds made during installation.

Bechtel personnel stated that excess weld reinforcement height was not considered a significant nonconformance since it can be relatively easily removed by grinding if necessary.

They also noted that reinforcement height interpretation difference (ASME III vs SA-358) was 1/16 inch.

The review performed during this investigation indicated that the weld reinforcement defect, if uncorrected, would have been an unacceptable condition.

While, as detailed later in this report, the nonconforming condition was corrected prior to installation of the spool piece, it is of concern that the Architect-Engineer's failure to disposition the Nonconformance Report reflected a misinterpretation of Code require-ments.

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. Daniel International procedure AP-VII-02 details "Nonconformance Control ~ Reporting". Section III provides functions for both Nonconformance Reports (NCRs or NRs) and Deficiency Reports (DRs).

NCRs are intended to be used to document material deficiencies that are dispositioned as "use-as-is" or " repair", and DRs are intended to be used to document deficiencies dispositioned as " rework" or " reject". DRs may be "used to initiate corree-tion of either suspected or actual deficiencies in supplier material or equipment", and " nonconforming items shall be dispositioned as " rework" when the applicable specifisation provides for correction" of the nonconformance.

,

Appendix I of procedure AP-VII-02, page 1, defines " repair" as:

"A disposition which is imposed when it can be established that a nonconforming characteristic can be restored to a condition such that the capability of the item to function reliably and safely is unimpaired even though that item still may not conform to the original requirement."

" Rework" is defined as: "A disposition which is imposed when it can be established that a nonconforming item or activity can be made to be fully conform to a prior specified requirement."

From discussions with site QC personnel, they had not been in favor of the Bechtel response to NCR 2SN-0501-P and were dissatisfied with the reasons provided in the June 1, 1979, letter returning the nonconformance without disposition. They stated that several discussions with Bechtel personnel followed this letter.

On September 6, 1979, the NCR was superseded by DR 2SD-0699-P (See Exhibit B of Investigation Report No. 50-483/80-10). While the description of the nonconformance differs slightly from that in the superseded NCR, the same conditions are described.

Both the NCR and DR originally had photographs of the original weld condition attached. The photographs did not copy well and were not included in the file copy. According to file documentation, excess reinforcement was removed from the weld on November 5, 1979, and the DR was closed. Weld reinforcement was ground as far back into the pipe as practical (approximately 1 1/2 feet), removing the area of excess reinforce-ment, and the remaining reinforcement was considered acceptable.

7.

Review of Original Contacts With Alleger RIII was originally contacted and provided with allegations related to the spool piece on or about October 11, 1979.

Notes of telephone contact, referral memos, and letters to and responses from Individual A were re-viewed. Discussions were held with the investigators who took part in these contacts.

RIII Investigator James McCarten was the original contact with Individul A.

His notes indicate that Individual A, then working at the Wolf Creek - 10 -

- _ _ _ _ _ _ _ - _ _ _ . construction site, discussed concerns related to both the Wolf Creek and - Callaway sites.

By memo dated November 9,1979, Mr. McCarten documented this conversation, and concerns related to Wolf Creek construction were referred to NRC Region IV which has jurisdiction over Wolf Creek construction. The portion of the memo pertinent to Callaway concerns is as follows: "The alleger then went on to state that he had previously worked , for Daniels Construction Company at the Callaway Missouri Nuclear ' Plant Site and while working at the site he detected a 3/4 inch crack in a weld located near a valve in a 15 foot long section of 10 inch stainless steel pipe that ran from under an accumulator tank. He advised the pipe is located on the east side of the tank near the elbow of the pipe as the pipe runs toward the reactor vessel.

The alleger related he informed his supervisor regarding the crack in the weld but the supervisor was of the opinion that the welds had already been accepted, and he was reluctant to go back and inform the quality assurance personnel of the defect in the weld. The alleger did state a " hold" tag was place on the pipe for a short petiod of time, but it was later removed."

Since the allegations, even if substantiated, did not indicate an immediate threat to the public and rince there was no concern about perishability of evidence, the investigation was performed after other priority investi-gations. The investigation was subsequently assigned to Investigator R. Burton.

The initial investigation was begun without the benefit of contact with Individual A because efforts to contact him were unsuccessful. The exact weld alleged to be deficient was not known. Following repeated attempts, Mr. Burton was able to inform Individual A he wished to contact him.

Individual A telephoned Burton on April 11, 1980, at approximately 2:30 p.m.

Notes of the telephone contact indicate Individual A discussed " pipe cracks" on an inside seam weld, and attempted to describe the exact loca-tion of the pipe and seam weld.

Individual A also stated that he felt the pipe was " distorted at the seam" apparently from too much heat during the welding process.

In addition, he stated that Mr. Potter, the Author-ized Nuclear Inspector (ANI), had looked at the weld radiographs for the seam weld in question.

Individual A named two other people who would be knowledgeable of the " pipe crack".

During the telephone conversation, Individual A also questioned the weld configuration utilized for containment liner penetration closure welds, indicating that the welder performing root passes had some difficulty performing the welds.

In addition, concerns were expressed over welds in the turbine building (non-safety related areas).

Following the discussion, Mr. Burton mailed Individual A a drawing (piping isometric) of two accumulator tank discharge lines and requested that he indicate the location of the alleged crack (See Exhibit IV).

Individ- - 11 -

. ual A marked and returned the isometric drawing which was received at

RIII on April 19, 1980. Attached was a handwritten note (Exhibit III) describinr, the location and condition he believed to exist. The note and diagram are in error as to the present orientation of the longitudinal seam we2d.

It is located at approximately the 11 o' clock position as one faces into the spool piece at field weld F004. During a later dis-cussion with Individual A, he indicated that he had observed the spool piece prior to installation and the spool piece was in a differeat position at that time.

, All of the notes of telephone contacts and written communications appear to indicate that the central concern originally expressed dealt with a crack in the seam weld on spool piece S002.

8.

Review of Previous Investigation Report IE Investigation Report No. 50-483/80-10 was reviewed and discussed with the investigator. The investigation focused on what was perceived as the only allegation expressed; namely the existence of a 3/4 inch crack in an accumulator discharge line.

Four minor errors in the report were identified during this review as follows: The alleger is characterized as presently being a welder at the a.

Callaway site.

By his statement, he left the Callaway site some-time in August 1979.

b.

The "15 welds" section is mischaracterized.

The piping isometric included as Exhibit A shows the 15 welds counted. The isometric does not include pipe manufacturer seam welds (this is standard practice) which were also visually inspected (outside surfaces).

The date noted for NCR 2SN-0501-P, May 5, 1979, is in error.

The c.

ANI review took place on May 5, 1979, but the NCR indicates it was initiated on April 30, 1979.

d.

The date noted for the initial contact with Individual A may be in error.

Investigator McCarten's notes indicate October 15, 1979, as the contact date.

None of the above errors are viewed as having any significance to the alleged " pipe crack" which was the focus of the report.

Initial visual inspections of the two accumulator lines were made due to lack of infor-mation as to the specific location of the alleged pipe crack.

Interviews were held with those individuals alleged to be knowledgeable.

As noted in the initial report, when the specifir location of the weld alleged to be cracked was determined, the area was tested by liquid penetrant examination, an accepted test for a sur~ ace crack. No such crack was indicated.

The liquid penetrant examination was documented - 12 -

. both in the original investigatior. report and in IE Inspection Report - No. 50 483/80-15 (Exhibit VI).

9.

Lett.er to Individual A On July 15, 1980, a letter was drafted to transmit the original investi-gation report to Individual A and discuss the review of containment liner penetration closure weld configuration (Exhibit VII). Due to an administrative oversight, this letter was not sent.

, 10.

Contact With Representative Fiegenbaum On January 23, 1981, information was received to indicate that Missouri State Representative Robert Fiegenbaum (Chairman, House Energy Committee) had been contacted by an individual who indicated that unacceptable piping was present at the Callaway construction site. On January 28, 1981, Investigator G. Phillip contacted Representative Fiegenbaum and was advised that the alleger had been asked to document his allegations and send them in a letter to RIII.

11.

Letter From Individual A By letter dated February 8, 1981, Individual A indicated that the extent of his concerns had been misunderstood by the NRC and be felt the ori-ginal investigation of his concerns was inadequate (Exhibit II).

. This letter indicates the following concerns: An improper weld procedure had been utilized on accumulator piping.

a.

b.

The pipe is unacceptably out-of-round.

The acceptance of a minimal wall violation was improper (contrary c.

to Code Requirements).

d.

The pipe seam weld is cracked.

The pipe seam weld reinforcement is higher than allowed by the applic-e.

able Code.

f.

The pipe is unacceptable due to the above noted defects.

The letter contained comments critical of the original investigation and a total of forty-eight questions.

By letter dated Februarf 26, 1981, RIII advised Individual A that his concerns would be addressed and answers provid-d to the questions he had asked (Exhibit VIII). Tte response to individual A's letter is attached as Exhibit IX.

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. 12.

Review of Nonconformances . A review of Nonconformance Reports related to the pipe piece in question was performed as previously detailed in Paragraph 6 of this report.

These reports and their d' oositions appeared acceptable except as noted.

A portion of each.I the related nonconformance dispositions indicated that the vendor would ;e notified by Bechtel of the observed deficiency.

RIII personnel were advised the documentation of such notification was , . not available site and this is considered an unresolved item (483/81-04 vo.

13.

Discussion With ANI On March 6, 1981, a discussion was held with Mr. Howard Potter, Authorized Nuclear Inspector (Hartford Boiler Insurance Company). He stated that he was unaware of any uncorrected nonconformances on spool piece S002, and he had been on DR and NCR concurrences for ASMI Code acceptability review.

He stated that he had not reviewed the vendor seam weld radiographs for the pipe piece in question, nor for any other vendor weld at the Callaway site.

14.

Review of Vendor Radiographs On March 6, 1981, file radiographs for the vendor seam weld were examinea by NRC Inspector W. Key, a Level III radiograph interpreter.

The vendor radiographs covered all twenty feet of the original pipe and were considered acceptable with one exception. At film markers 13-14 an area of excess reinforcement was evident. This area was not at the pipe end (later cutting and f'abrication placed this area at the end of spool piece S002).

Three photographs of the internal weld condition prior to grinding were still available in a QC inspector's file. These three photographs clearly show excessive weld reinforcement and overlap, with two fissures or cracks in the excess reinforcement (Exhibit X).

These three photographs were compared to the vendor seam weld radiographs and matched exactly. This was the area noted on NCR 2SN-0501-P.

The reader sheet for the vender radiograph indicated " wash out" at film markers 13-14 and probable undercut. The reader had marked the defects as acceptable and approved the radiographs. No note as to additional inspection was included with the reader sheet.

The condition at film markers 13-14 appears to be a rejectable condition.

The NRC inspector identified apparent incomplete fusion and excess weld reinforcement.

It is possible that the additional weld reinforcement - 14 -

. . l = l

~ could have masked weld defects at these points. Apparently, those who subsequently reviewed the radiographs agreed with the interpretation of the original reader.

Improper acceptance of the radiographic record was considered as an item of noncompliance with 10 CFR 50 Appendix B, Criterion IX, " Control of Special Processes" (483/81-04-02).

15.

Re-Radiograph of Pipe Section , The excess weld reinforcement reflected in NCR 2SN-0501-P (later DR 2SD-0699-P), the three photographs, and the vendor radiograph had been removed as previously noted. Licensee inspection personnel, observed by the NRC Resident Irspector, had visually inspected the weld area and a liquid penetrant test had shown no surface defects in the area.

From discussions with the licensee and their consultant, it was determined that a radiograph of the weld area in its present condition would aid in answering any ques ( >ns as to its present acceptability. On the morning of March 20, 1981, the weld was radiographed, and each step of the radio-graphy was witnessed by the RIII investigator. The resulting radiographs were interpreted by Daniel International personnel and RIII inspector W. Key and were determined to be acceptable. Licensee personnel advised that the radiographs would be documented, reviewed for ASME Code accept-ability, placed intc r5e vendor seam weld radiograph file for the weld in question, and refereneed in that file.

16.

Pipe Diameter Measurements Visual insoection of spool piece S002 and the pipe piece in question (SP) did not itiicate any noticeable ovality.

On March 6, 1981, RIII personnel made outside diameter measuro ants at a location approximately 14 inches away from field weld F00I on spool piece S002. These were rough measurements made utilizing a non-direct reading caliper and tape rule. Measurements in three planes yielded the following diameters: 10 21/32 = 10.656 inches 10 24/32 = 10.750 inches 10 25/32 = 10.781 inches (Made on seam weld) Maximum outside diameter variation (maximum diameter minus minimum diameter) was therefore approximately 0.125 inches. However, the measure-ment technique was not considered sufficiently accurate for such a conclu-sion, and one measurement was made on the seam weld itself.

Following interpretation of various sections of the ASME Code it was determined that the outside diameter measurement on the pipe seam weld was inappropriate due to the inclusion of allowable weld reinforcement (allowable reinforce-ment is 1/8 inch or 0.125 inches).

- 15 - -- . . -- , , -

. A second set of measurements were taken at the same location by liceasee . personnel on April 14, 1981, using a more accurate technique and four planes of examination. These measurements were witnessed by the RIII Senior Resident Inspector. The resulting measurements were as follows: 10.758 inches (made adjacent to seam weld) 10.753 inches 10.678 inches 10.666 inches , . Maximum outside diameter variation was therefore approximately 0.0920 inches.

Material Specification ASME SA-358, Class I (1974), allows an outside diameter variation of 1%. As the pipe is 10 inch schedule 140 pipe, it has a standard outside diameter of 10.75 inches, and a variation of 0.1075 inches would be allowable per SA-358. The ovality of the pipe was considered acceptable.

Field weld F004 to valve 8956A was successfully fit-up and completed, a further indication of acceptable ovality.

17.

Concerns Expressed This section summarizes the findings related to the six concerns outlined in paragraph No. 11 of this report.

a.

Concern: An unacceptable weld procedure was utilized.

Findings: Review of the ARMCO seam weld procedure utilized, weld procedure No. 5, Revision 1, indicates it is an acceptable procedure for double welding of the metal and thickness involved. The weld procedure involves welding the inner diameter seam first, utiliz-ing one pass, and then backgouging and welding the outer diameter seam with one or rore passes of weld material.

The configuration of the completed weld visually resembles a single weld in that the inner diameter weld is less wide than the outer diameter weld (See Paragraph 4).

b.

Concern: The pipe is substantially out-of-round.

, Findings: Visual inspections and measurements of the pipe show acceptable ovality.

The comment on excessive ovality apparently came from reading NCR 2SN-0496-P regarding a minimum wall violation.

Differences in the range indicated (0.092 inches) are not normally , measureable by simple observation on a pipe whose outside diameter i is 10.75 inches.

In the "Cause of Nonconformance and Action to Prevent Recurrence" on the NCR, the QC inspector stated (in part) " ovality in pipe not recognized by vender prior to machining counter-bore".

This was the inspector's conclusioc, and appears to be at

- 16 - ! __ __ - ..

_.

.

1 east partially valid. However, as shown by the ultrasonic examina-tion report attached to the NCR, it also appears that the counterbore centerline may have bara off-center by some.030 inches (estimated).

The QC inspector made no notation or NCR to indicate that pipe ovality was unacceptable, but indicated his conclusion that it had played a part in the minimum wall violation (See Paragraph 16).

c.

Concern: Acceptance of the minimum wall violation was improper . - (contrary to Code requirements).

Findings: Pipe ordered to " nominal wall" includes a manufacturing tolerance above minimum wall requirements (desired by design) of 12.5%. Nuclear practice is to add a considerable safety factor to the above by designing systems to accomodate pressures which are not expected to occur.

When, through manufacturing tolerances or error, the minimum wall thickness for a pipe is violated, it can be evaluated for acceptability to Code and design conditions.

In inservice inspection weld preparation areas (which are counter-bored) minimum wall violations can take place due to the counterbore wall reduction.

" ]p 'g UT measurement area L a standard pipe wall counteYbored' area Minimum wall calculations utilized to disposition NCR 2SN-0496-P appear to meet Code requirements and were acceptable, as detailed earlier in this report (See Paragraph 6).

d.

Concern: The pipe seam weld is cracked.

Findings: None of the visual nor nondestructive examinations con-ducted indicated that the seam weld on pipe piece No. SP contains a crack anywhere along its length. Photographs of the weld condition adjacent to field weld F004 prior to grinding indicate an overlap condition and two fissures which could be mistaken for a pipe crack by a welder. The overlap has been removed by grinding and the weld surface now appears well blended with the adjacent pipe metal (See Paragraph 8).

e.

Concern: Seam weld reinforcement is higher than allowed.

Findings: Seam weld reinforcement was measured and found to be , j acceptable. The original NCR dealt with weld seam reinforcement ' height only in the limited area adjacent to field weld r004.

f.

Concern: The pipe is unacceptable due to the above defects.

Findings: As noted above, this is not a correct conclusion. The pipe appears acceptable in its present condition.

- 17 - l l

. 18.

Overview . The weld condition of the small section of the origional pipe was considered acceptable by the ARMCO radiographer and subsequent radio-graphy reviewers.

Spool piece S002 was fabricated and sent to the Call-way site.

A craftsman called the weld condition to the attention of a Quality , Control inspector and Nonconformance Reports were written.

. There was prolonged discussion on how to document and properly disposi-tion the nonconforming condition, but corrective actions were taken and documented.

The pipe has been examined and found to be acceptable in its present condition.

19.

Contact With Alleger Individual A was contacted by telephone on April 20, 1981. He expressed distatisfaction with the initial NRC investigation of his allegations, and the fact that RIII had failed to provide him with a copy of the investigation report. He stated that his central concerns were that the pipe was out-of-round, and that the seam weld reinforcement on spool piece S002 (5P) was higher than allowed by SA-358. He expressed dis-satisfaction with NRC actions to that date.

During additional telephone discussion on April 22, 1981, Individual A indicated that he had reviewed Callaway-related documents in the Public . Document Room. Among the documents he reviewed were Inspection and Enforcement Bulletins 79-03 and 79-03A. These deal with defects identi-fied in longitudinal seam welds in SA-312 fusion welded piping manufac-tured by Youngstown Welding and Engineering Company (and others). These defects were first identified in late 1978. He stated these reports had led him to incorrectly believe the accumulator pipe was manufactured by Youngstown Welding and Engineering Company.

20.

Bulletins 79-03 and 79-03A The NRC required certain actions by licensee in response to Bulletins 79-03 and 79-03A (Exhibits XI and XI.'.). Representatives of the Standardized Nuclear Unit Power Plant System (SNUPPS) Group and Union Electric responded to Bulletins 79-03 and 79-03A by letters dated May 11, }979, November 26, 1980, August 20, 1980, and January 26, 1981.

21.

Concern Related To Bulletin 70-03A During telephone discunsion Individual A stated that he believed Bulletin 79-03A (required action No. 3) imposed mandatory etching of all safety-related pipes manufactured according to SA-312, and he had not found any indication this had been accomplished by SNUPPS facilities.

- 18 - _. _ _ . _._. _ . _ _ . _ _

. A review of documentation related to Bulletin 79-03A indicated that by , memo dated April 8, 1980, (Exhibit XIII) the Director of the Division of Reactor Construction Inspection provided clarification of aspects of Bulletin 79-03A.

Item 3 (etching of SA-312 pipes) applied "only to those components subject to design stress greater than 85% of the Code allowable stress".

Responses from Union Electric and SNUPPS indicated that no SA-312 piping was in use or scheduled to b-used in which stresses exceeding 85% of the , Code allowable had been identified at their facilities. Therefore, etching ' would not be required by Bulletin 79-03A.

As some of the comments included in Individual A's letter of February 8, 1981, and later telephone conversation appear to connect the accumulator line pipe with IE Bulletins 79-03 and 79-03A, it should be noted that SA-358 and SA-312 pipes are not similar.

The welding process, wall thick-ness and other important aspects differ considerably.

22.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are ac:eptable items, items of noncompli-ance, or deviations.

An unresolved item disclosed during this investiga-tion is discussed in Paragraph 12.

23.

Exit Interview An exit interview was held with site personnel on March 27, 1981.

24.

Licensing Contentions The joint intervenors in the Callaway licensing proceeding submitted two contentions which relate to this report.

On March 6, 1981, Ms. Kay Drey and the Crawdad Alliance submitted a petition to intervene which included contentions on the accumulator pipe piece and SA-312 pipe acceptability.

This petition was ammended on March 24, 1981.

On May 5, 1981, the Joint Intervenors submitted their first set of Interrogatories to the NRC Staff under the discovery process. Question No. 81, Part A through W, duplicates the questions posed by Individual A in his letter of February 8, 1981.

25.

Media Contacts Several contacts were received concerning this investigation from media personnel who had been contacted by Individual A.

- 19 - . - -. . , - ,-- - - - - , ,,, - - - -., - - - -

. t .

Attachments:

Exhibit I, I&E Investigation Rpt. No. 50-483/80-10 Exhibit II, Ltr of complaint dtd 2/8/81 Exhibit III, Handwritten note by Ind. A dtd 4/19/80 Exhibit IV, Ltr to Ind. A dtd 4/11/81 Exhibit V, Partial chronology Exhibit VI, Page 4 of IE Inspection Rpt. No. 50-483/80-15 Exhibit VII, Drft ltr of transmittal to Ind. A dtd 7/15/80 Exhibit VIII, Ltr to Ind A dtd 2/26/81 Exhibit IX, Ltr to Ind. A Exhibit X, Photographs of seam weld at field weld F004 Exhibit XI, IE Bulletin No. 79-03 Exhibit XII, IE Bulletin No. 79-03A Exhibit XIII, NRC memo dtd 4/9/80 < l l I - 20 - - ... - -. - . .. -.. . - . _.., _ _ _ - -,. - - _. _ _ _ _ -... ,... -. -. _,_ -

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' UNITE D 5TATES ~, y i NUCLEAR REGULATORY COMMISSION 3,. 'J E REGION ill K t- - p 799 ROOSEVELT ROAD %.....[ GLEN ELLYN,ILUNolS 60137 - JUN t 0 980'

. . Docket-No. 50-483 Union Electric Company ATTN: Mr. John K. Bryan Vice President - Nuclear Post Office Box 149 St. Louis, MO 63166 Gentlemen: This refers to the investigation conducted by Messrs. R. M. Burton and W. A. Hansen of this office on March 26-27, and May 2, 1980, of activi-ties at the Callaway Nuclear Plant, Unit 1, authorized by NRC Construc-tion Permit No. CPPR-139 and to the discussion of our findinge with Mr. W. H. Weber, Manager, Nuclear Construction and others of his staff at the conclusion of this investigation.

The investigatio'n related to allegations which are identified in the enclosed copy of our investigation report.

No items of noncompliance with NRC requirements were identified during the course of this investigation.

In a

REGION III== i Report No. 50-483/80-10 . Doc-ket No. 50-483 License No. CPPR-139 Licensee: Union Electric Company Post Office Box 149 St. Louis, MO 63166 Facility Name: Callaway Nuclear Plant, Unit 1 Dates of Investigation: Marcl. 26-27, and May 2, 1980 Investigation At: Callaway Site, Fulton, M0 , Investigator: h*3 [[ //&hV f/6[fO Robert M. Bulton (Date) Investigator al'c 1( a l - 4AAv William A. Hansen ( ( '(Date) Res.ident Inspector Reviewed By:

h b/ 6/hMd C..arlesE.Norelp ' (Date) - Assistant to the Director arc 6 d 4o R. C. Knop, Chief M '(Date) ' Project Section 1 . Investigation Sumx.ary: Investigation on March 26-27, and May 2, 1980 (Report No. 50-483/80-10) Areas Investigated: Investigation was conducted into an allegation of the detection of a weld crack in a section of stainless steel pipe feading from an accumulator tank. Twenty-one manhours were spent on the investigation involving one inspector and one investigator.

Results: The allegation was not substantiated. No items of noncom-pliance were identified.

. Exhibit I Page 3 of 21

~ ( (~ ~ ... .. REASON FOR INVESTIGATION .. On October 11, 1979, the Region III office received a phone call from a Daniel's Construction Company employee at the Callaway Nuclear Plant. He alleged that he had detected a crack in a stainless steel pipe weld in the , vicinity of the accumulat ; tank. He further stated that he informed his pupervisor of the wel-o ek, however the supervisor was reluctant to re_ jport it to quality assurance personnel.

SUMMARY OF FACTS On October 11, 1979, an allegation was received by phone from a person re-questing that his identity be kept confidential. This alleger stated be was a welder at the Callaway Ntelear Plant, and while employed there had detected a three quarter inch crack in a weld located near a valve in a fif teen foot long section of stainless steel pipe running from under an accumulator tank. He further stated that he informed his supervisor of the crack, however his supervisor was reluctant to inform quality assur-ance personnel, because he was of the opinion the weld had already been accepted.

On March 26 and 27, 1980, an on-site investigation of the allegation was conducted.

During the course of the investigation it was determined that there were a total of fifteen welds encompassed in the area described by the alleger. Visual inspections of the fifteen welds were conducted in-dependently by both the NRC resident inspector and a Danie) International Quality Control inspector.

There were no visible cracks detected in any of the welds inspected.

Two foremen, who were determined to be in charge of welding operations during the course of the welds' completion, were questioned as to their receiving any reports of a weld crack in the ac-cumulator tank area. They both responded to the effect that they did not recall any of the company's employees ever reporting a weld crack to either of them.

_ Subsequent contact from reporters of the Witchita Eagle revealed they had been in contact with the alleger. Through their efforts, the alleger again contacted the NRC and provided a more detailed description of the - weld crack both orally, and by indicating the location on an isometric drawing of the accumulator tank area which was mailed to the alleger and returned to the NRC. This description of the location indicated that the crack was on the inside of the pipe on a longitudinal seam weld, rather than on an outside surface weld as originally suspected.

A Deficiency Report and a related Noncompliance Report were secured for the location described by the alleger. These docal.ents showed a repair 6f a weld overlap at the described location was made by grinding an area of excess reinforcement and poor fusion in November, 1979.

On May 2, 1980, a liquid penetrant test was conducted on the area of that repair and no cracks were detected. The excess reinforcement (" fall through") was also measured and found to be within ASME welding code tolerances.

. l-2-Exhibit I Page 4 of 21 .- - ._ . _. - - -. _. . _

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No items of noncompliance were identified during the conduct of this in-vestigation.

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em . i . . ~ ~ Exhibit I Page 5 of 21

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,

DETAILS 1.

Personnel Contacted j Union Electric Company .

M. I. Doyne, General Superintendent, Callaway Construction '

F. D. Field, Manager, Quality Assurance 'J. V. Laux, Assistant Engineer, Quality Assurance R. L. Powers, Supervising Engineer, Quality Assurance W. H. Weber, Manager, Nuclear Construction Daniel International (Contractor) J. R. Cook, Manager, Quality Control J. A. Holland, Manager, Project Quality Assurance . T. W. Linder, Piping Foreman 'J. D. Prince, Pipe Fitters' General Foreman H. J. Starr, Project Manager W. L. Sykora, Assistant Project Manager The inspector and investigator also contacted and interviewed other licensee and contractor personnel, including craf tsmen, QA/QC, tech-nical and engineering staff members.

2.

Introduction On October 11, 1979 the Region III office received by phone, an al-legation from a welder at the Callaway Nuclear Plant. He alleged that be had detected a crack in a stainless steel pipe weld in the vicinity of the accumulator tank. He further stated that he in-formed his supervisor of the weld crack, however, the supervisor was reluctant to report it to quality assurance personnel.

Prior to the initiation of the on-site investigation on March 26-27, 1980, efforts to recontact the alleger in an attempt to secure a more accurate location of the alleged weld crack were unsuccessful.

. 3.

Allegation The alleger stated he had detected a three quarter inch crack in a weld located near a valve in a fifteen foot long section of ten-inch stainless steel pipe that ran from under an accumulator tank. He further stated that he informed his supervisor of the crack, however, his supervisor was reluctant to inform quality assurance personnel - because he was of the opinion the weld Lad already oeen aceepted.

i , Finding - An on-site investigation was made on March 26 and 27, 1980.

Based on the description of the location of the weld crack supplied by the alleger, it was determined from the piping isometric drawings that a total of 15 welds (both vendor and field welds) were encompassed.

Exhibit I Page 6 of 21

C' ( . . (Exhibit A - Location of Welds Inspected).

(Field welds may be de-scribed as those welds made on-site by Daniel International welders in the process of fitting and installing pipe. Vendor welds are those welds made in the assembly of the pipe, (either longitudinal or cir-cumferential)byasupplierpriortoitsdeliverytothepljntsite).

Weld Control Records (F101's) were examined for each field weld made

g by Daniel International welders to verify that all finished welds had ,.been accepted after radiographic testing, or appropriate repairs made.

, The stainless steel pipe welds involved, being Class 2 pipe welds, required radiographic testing prior to acceptance.

For welds requiring repair, related Nonconformance Reports (NCR's) were examined to determine which welds were repaired and for what reason. Of the 15 welds involved, three had been repaired. The NCR's for these three welds showed each repair was made because of internal weld defects, rather than external weld defects (i.e., surface crack in weld). Based on these records, the possibility of the alleged weld crack (in the field welds only), being repaired between the time of the allegation and the time of the investigation was eliminated.

Visual inspections of the 15 welds were subsequently made by the NRC Resident Inspector (using a low power magnifying glass), and by a certified Daniel International Quality Control inspector (visually unassisted). These inspections were conducted in c manner which allowed each inspector to conduct a separate and independent in-spection of each weld involved.

During the course of these inspec-tions, no visible cracks were detected in any of the welds (field or vendor).

It was further ascertained that two foremen were in charge of welding operations in the "15 weld" accumulator tank area during the course of the welds' completion.

J. D. Prince was in charge of welding - operations from January 6, 1979 to August 6, 1979.

T. W. Linder was in charge subsequent to August 6, 1979. On March 27, 1979, both J. D. Prince and T. W. Linder were interviewed as to whether either of them had ever received a report of a weld crack in the "15 weld" ' accumulator tank area. Both responded to the effect that neither could recall any such weld crack ever being reported, or ever exist ing.

On April 8, 1980, the NRC Resident Inspector was contacted by Gary Hayden, a reporter for the Witchita Eagle. Hayden informed Hansen that he and another reporter, Julie Charlip, had been in contact with a person who made an allegation concerning the de-tection of a crack in a stainless steel pipe weld at the Callaway i Nuclear Plant. The description supplied by their source was con-sistent with the one received by the NRC on October 11, 1979, except that the crack was described as "in a seau weld on the inside of a stainless steel pipe" running from an accumulator tank.

. -5-Exhi'olt I Page 7 of 21 --._ -_, . _, , . __ _ _ .- -_ . _.

- L ( c . . ?* Both Hayden and Charlip were contacted by telephone and they veri-ficd this allegation. They declined to disclose the identity of their source, but stated their source would be requerted to contact the NRC.

j On April 11, 1980, a phone call was received from Hayden's source who identified himself as being the same person who made the Calliway a

weld crack allegation to the NRC on October 11, 1979. He furnishei

a description of the crack indicating it was in a seam weld on the - inside of a stainless steel pipe running from Accumulator Tank Tepo IA.

The alleger agreed to mark the location of the crack on a copy of the isometric drawing and return it to the NRC. A copy was mailed to him for that purpose on April 11, 1980.

On April 14, 1980, the NRC Resident Inspector obtained a NCR dated May 5, 1979 and a subsequent DR (Deficiency Report) dated September 6, 1979 for the pipe fitting the alleger's description and location.

(Exhibit B - Deficiency and Nonconformance Reports). The DR showed a repair had been made (an area of excess reinforcement and poor fusion was removed by grinding), to a defect referred to as a weld overlap (a condition <hich has been known to be visually interpreted as a crack, since it has a similar appearance).

This repair was made in the longitudinal seam weld of the S002 piping at weld F004 on November 5, 1979.

On April 23, 1980, the isometric drawing was received by the NRC from the alleger with the location of the weld crack indicated.

(Exhibit C - Isometric Drawing marked by alleger). A letter from the alleger transmitting the drawing, stated the crack was approxi-mately 4 to 6 inches from weld F004 in the S002 piping, and there appeared to be an excessive amount of " fall through" in the seam weld from the 45 degree pipe elbow to weld F004.

Subsequent visual examination by the NRC Resident Inspector revealed

that the grinding repair indicated on the Deficiency Report had been performed in the area of the alleged weld crack beginning at the end of the pipe at weld F004 (which had not yet been completed) and ex-tending approximately 14 inches inward. On May 2, 1980, the VRC Resident Inspector observed while a Daniel Quality Control Inspector performed a liquid penetrant test on the area of repair. No cracks were detected by the NRC Inspector or the Quality Control Inspector.

The remaining reinforcement ("fcil through") in the pipe was measured _ and found to be within ASME welding code tolerances.

Management Discussion . }t the completion of the investigation the findings were discussed with F. D. Field, Manager UE Quality Assurance, J. V. Laux, Assistant Engineer UE Quality Assurance, W. H. Weber, UL Manager of Nuclear Construction, J. R. Cook, DI Quality Control Manager, J. A. Holland, DI Project Quality [ Assurance, H. J. Starr, DI Project Manager, and W. L. Sykora, DI Assistant Project Manager.

s-6-Exhibit I Page 8 of 21 [. - -- . _ ..

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They were advised no items of noncciapliance were identified durinE this investigation.

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prior to machining count 2rborc, thereby - . i resulting in min wall violation.

Vendor.to be notified by Bechtel ' ! to o.r. e.v e.,n._t, e..e.._c_ur,r.en,c,,e. No DIC. action required.

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Rec,: tor Stilding. SNUPPS Unic #2 Pld'% l j F S-M- DR.

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Spool No. 2-EP-01-S002 Travent ?:o.- 03E?01 O l4.

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j Bechtel Specification 104c6-M-201A, Revision 11

,, 1 ! .! - ' ) ..e.1,- u .e ,.,:--e,._.- , - . . Visual Inspection of vendor longi:udinal weld on spcol #2-EP-01-S0t ! -

at weld number 2-E?-01-7004 indica:cs rejectable defects (cverlao) ,j of the inside surface.

Also, inside reinfcrcecen: is 3/16" (1/ 8

.

=axi=un required by ASME Section .- . N'h'65 W G iCC $ y-y.

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i * 'I l' 157.:0 Shaoy Grove Rogd v _rG;

.. Ca.tnersbu rg, Maryland '20760 hNE*j Ai 301-9432700 !.

. . . ' l.. * s. Mr. Nicholas A. Petrick Executive Director, SNU??S Jg,S 1 Igg . !, 5 Choke Cherry Road ,. j-Rockville, diaryland 20S50 ,.

' BLSI"l[lb\\ File: M-2 CIA - !i ' Bechtel Job Nr bar 1Cac6-0 . , g; SNU??S Project . . NCR 255-0501-? g.

. 9:

Dear Mr. Pet. rick:

. 5 il.' The subject NCR is being returned vi:hout disposi: ion for the following ,; reasons:

- - t 9.'. a) The subjec: pipe is 10" sched.

140 SA 35S double velded 1" nom. vall p! j s:ainless steel. AS>2 Section II: paragraph NC44:6.2 pe =its a =axi=um ,] reinforce =en: cf 3/16" separately to bo:h the inside and cc: side surface '

of the join: for 1" vali double welded but: poin:s.

il .c 't ,, b) The SA-35S =a:erial specifi,:a:1on references the AS.'.c. Code, See: ion III, ,ll paragraph L-/-51(b) for accep;an:e cri:eria of velds examined by radio-

'

graphy. The defec: described ir :his NCR as " overlap" is no: lis:ed as ) a rejectable defect in paragraph UN-51(b) of See: ion VIII of the AS12 . t' Code.

. . c) Per celephone discussien between Mr. C. R. Cardner of Daniel, Mr. Hec:or t >!

Borda, Mr. B. Lulla and M.r.. Ron Walker of 3echtel, it was agreed that the

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pipe =eers the code require =en:. and does no: fall under NCR ca:e;; cry.

L. l //./ '; Very, ':ruly you- , j,l/h ! .., - . - } .i .. ~ / J. L_. Turde_ra . Project En;;incerin;; ".:n:;c: - ,

. .. BL:js . l Enclosurc / cc: J. Lee Sippel, v/1 .

. D. W. Copene, v/3 ,. i , J. R. Jor;;ensen, v/3 J. A. Gailey, v/3 . H. M. DeLen*;. v/ l

. ", ' H. J. Starr, v/l .. , i S. J. SciLen, vil ' .-- -- rf I t

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.. _ _. __. _ _. 6C /o o Exhibih I - Page 20 of 21 . /0) L.

b_..--_____.____... . _ _ -. =_ _ _.______

r.. .- . Mr. Gerald Phillip United States Nuclear Regulatory Commission gegion III 799 Roosevelt Road Glen Filyn, Illinois 60137 .

Dear Mr. Phillip:

After reading NRC Report No. 50-483/80-10 in mid-December 1980, I realized that my phone calls to the Region III office had failed to communicate my concerns about pipe installed at the Callaway Nuclear Power Plant.

I also realized that I needed to write the Region III office and express those concerns again.

I would now like to restate the information I tried to convey over the phone and comment on the report.

In May of 1979 I saw a substandard piece of pipe installed in a safety-related system at the Callaway Nuclear Power Plant.

The pipe was part of a prefabricated spool piece, in a line of pipe that ran from an accumulator tank to the primary cooling loop.

This was a part of the Emergency Core Cooling System.

The pipe was substantially out-of-round, machined belcw the minimum wall and had rejectable weld defects on the inside of a longitudinal seam weld.

I believed that all of these problems were caused by an improper welding procedure used in manufacturing the pipe.

The weld appeared to be a single welded butt joint inwhich the root pass had fallen through.

By fall through I mean that the internal weld bead drooped down or protruded into the pipe an excessive amount and did not fuse uniformly into the plate surface.

Succeeding filler passes over the root pass had caused the pipe to distort, flattening the pipe at the weld and giving it an oval shape.

The combination of the fall through (a stress raising condition), and the distortion, made the pipe susceptible to cracking, and this was evidenced by a 3/4 in. long crack.

The crack was visible from the open end of the spool piece where a check valve was to be installed.

From 13 years experience in welding I believed these were rejectabk defects, especially when the pipe was being installed as a Class II safety-related component in the Emergency Core Cooling System dr a nuclear power plant.

s I'n May of 1979 I reported the defects to a reactor area Quality Control Inspector and my immediate supervisor.

The pipe had-1-Exhibit II Page 1 of 11 -. - -.. - - - . . -_ . - -- - -... _. - -. -. - - - - --. ..

b % -' e a hold tag placed on it for the minimum wall violation and . several persons came fiom the office to look at the pipe.

I talked to several credible and responsible persons about the pipe.

(I gave their names and positions to the Region III office in the phone calls of October 11, 1979 and April ll, 1980.)

According to my understanding, from conversations with these persons, several factors were involved in the decision-making process.

They are as follows: ' 1) ' The pipe had been approved for installation by Union Electric and had passed through the quality assurance programs of the pipe's manufacturer (known simply as " Youngstown") and the fabricator of the spool piece (Dravo).

. 2) The Daniel International Corporation was not responsible or liable for longitudinal seam welds in pipe.

Their concern with the pipe was the edge preparation of the weld they were responsible for making.

3) The pipes manufacturer had millions of dollars worth of pipe of questionable quality, some of which was installed, or going to be installed at Callaway.

' 4) Replacing any pipe would be costly for everyone and cause scheduling delays.

5) The argument was made that the defects I saw would not affect the function of the pipe; that the crack, or cracks if there were more, were on the internal surface and would not grow in size.

I left Callaway before a final decision was made, and I assumed that the problems witi. this piece of pipe would be resolved within the limits of the American Society of Mechanical Engineers ( code.

! l Several months after I left Callaway I heard that the pipe in l question was approved for installation "as is".

I was surpised by this and called the NRC Region III office to express my concern.

The NRC investigated and wrote Report No. 50-483/60-10.

The report did not seem to address my concerns but instead it seemed to obfuscate the deficiencies, especially as they relate to the

ASME code.

The ASME code is an essential instrument used to ensure the safety of nuclear power plants.

If the standards of the ASME code are ignored or misapplied we are inviting a dinaster.

-2-Exhibit II Page 2 of 11 . ..

. .- SUMMARY OF COMMENTS ON THE NRC REPOh7 . toexpressconcerhover I called the NRC Region III office .a substandard piece of pipe I saw being installed in the , Emergency Core Cooling System at the Callaway Nuc3 car Power , Plant.

The NRC investigated and wrote a report which concluded ,tbat, "The allegation was not substantiated.

No iten.s of noncompliance were identified."

In arriving at t!.i s cor.c] usj on the.NRC appeared careless and negligent in several areas of their investigation.

The NRC report made erroneous, misleading or incomplete statements which were as follows: 1) The report limited my concern to one 3/4 in. crack and did not rtate very completely the substance of what I expressed over the phone.

2)' The report raisquoted me in saying that my " supervisor was reluctant to inform quality assurance personnel".

3) The NRC did not examine all the welds the report implied they examined in the March 26 and 27, 1980 investigation.

The NRC accepted, without much scrutiny, statements and documents from the involved companies.

Instances of this are as follows: 1) A letter from Mr. Turdera, Bechtel's Project Engineering Manager was the basis for downgrading a nonconformance report to a deficiency report.

The letter ignored applicable paragraphs of the ASME code and misapplied other paragraphs of the ASME code.

2) The NRC accepted the downward recalculation of a safety-related minimum wall specificati on without substantiating I whether or not the recalculation complied with the requirements of the ASME code.

. In the documents presented with the report, possible code violations l were indicated which the NRC did not investigate.

J 1) A deficiency report, Exibit B page 1, referenced ASME Section II SA358 para.

5.2.3.

Violations of this paragraph ! _ were never investigated, s .2 ) A reference to ovality in the pipe was made in a non-conformance report, Exibit B page 3.

This could be a violation of SA 358 para. 15.1.2, but this was never investigated.

-3-Exhibit II l Page 3 of 11 l l l . _,. _ _ _ _ _.. _ _. _,. ~ _ _, _. _ _ _ _ .. . , - _. _. _.. _.,. _. _ _ _ _ _ _ _ _

. . .. . The report did not gupply information relevant to the investigatior.. . 1) The statement (page 6) that, "the remaining reinforcement in the pipe was measured and found to be within ASME welding code tolerances", was not dccumented.

No inspection report of this measurement was included in the exibits.

2) The names of the spool piece vendor and pipe manufacturer were not included in the report.

. . ' The,NRC overlooked vital documented evidence.

1) The radiographs (X-ray pictures) of the weld in question were not examined.

. . -4-Exhibit II Page 4 of 11 . -, - ... _ - - - . -. - -

~ . - DETAILED C0f1MENTS AND QUESTIONS . I would now like to comment on particular sections of the report and ask specific questions.

I would like the NRC to answer these questions in written form and send me a copy.

s ellegation,page 4

This paragraph states my concern over one 3/4 in, crack but neg'l.ects to mention the fall through, (refered to in the report as " overlap" and excess reinforcement), the distortion of the pipe, the minimum wall violation, and the possible existence of other substandard pipe.

I would not have called the NhC over one isolated crack, which could easily be ground out.

The condition of the pipe that caused the crack indicated an improper welding procedure and that concerned me.

The fact that the quality assurance programs at two different companies had apparently failed, concerned me.

Even though some of these items were indirectly addressed in the exibits. I believe they should have.been included in the allegation section.

I did attempt to communicate these items over the phone in the October 11,1979 and April 11, 1980 calls.

I (, not recall ever saying my supervisor was reluctant to inform quality assurance personnel.

My statements refered to the company, as a whole, being reluctant to acknowledge the existence of the defects, not my immediate supervisor.

Questions 1) Were the phone calls I made to the Region III office on October 11, 1979 and April 11, 1980 electronicly recorded? 2) If they were recorded may I listen to them or have a transcript? 3) May I have a copy of the notes taken by Mr. Burton, Mr.

McCartney or others whc listened in on the calls? ( Finding,p.ge 4 l In the first paragraph of this section the report states; "that a total of 15 welds (both vendor and field welds) were encompassed".

Vendor welds are defined on page 5 thusly; " Vendor welds are thoue welds made in the assembly of the pipe (pither longitudinal cr circumferential)".

The welds marked apd numbered on Exibit A involve four spool pieces, i.e. S 001, S.OO2, S 007, and S 008.

These four pieces were the. subject of the NRC investigation on March 26 and 27, 1980.

From Exibit A j we can count 26 welds - 6 field welds, 11 circumferential factory welds, and 9. longitudinal factory welds.

The report gives the impression thAt all of the relevant welds from the piping isometric drawing were encompassed, including longitudinal welds.

This was not so.

Exhibit II-5-Page 5 of 11 , , _.,. . ___ _ _ _ _ .... _. _ _ _ _ _ _ _ _ _ _ _ _ _... _,

. . Qu2stions 1) Why were only 15 welds inspected?

2) Exactly which welds were inspected and which were omitted in the inspections made on March 26 and 27, 19dO.

3) Specifically, what efforts were made to contact me concerning the exact location of the crack? . . Also on Exibit A is a hand written note with a line drawn to S 002 and it says; " Seam inspected by WLK".

Questions . 1) Who is WLK? 2) When did he make the seam weld inspection? 3) Did he look into the end of S 002 and examine the inside of the seam weld? Finding page 6 In the third paragraph of page 6 the report cites a Nonconformance Report and a Deficiency Report.

I presume these to be page 7 and page 1 of Exibit B.

The descriptions of the deficiencies and nonconformances agree in citing excess reinforcement, but they disagree in how they describe another defect.

The NCR calls the defect " overlap" and the DR states that, "the vendor's longitudinal weld... is not fused uniformly into the plate surface as required by Material Spec. SA 358, Para.

5.2.3".

Questions 1) Is the NCR and the DR talking about the same defect? 2) Would " overlap" be a violation of Material Spec. SA 358, Para. 5.2.3? Exibit & pages 7 and 8 NCR No. 2SN-0501-P was downgraded to a DR based on a letter from Mr. J.L. Turders, Bechtel's Project Engineering Manager.

In paragraph (a) of his letter Mr. Turdera deals with the maximum allowable reinforcement and cites ASME Section III but ignores ASME Section II, listed as a " Controlling Document" in the NCR.

Concerning maximum reinforcement, Section II SA 358 para. 5.2.3 states; "The joint shall be reinforced at the center of the weld on each sid2 of the plate by at least 1/16 in. (1.6mm) but not more than 1/8 in. (3.2mm)".

Questions 1) Why did Mr. Turdera ignore Section II in his discussion-6-Exhibit II Page 6 of 11 . .-.

_

.

., of maximum rainforcamsnt when it was listed in the "Cor.tro]Iing Documents"? . 2) Why didn't the NRC Resident Inspector question this wher.

he received these documents on April 14, 1980? - B) In the investigation that occurred on March 20 and 27, 1sbu,

why didn't the investigators have these documents then, 4. since they involved the pipe in question? Exibit B.page 8 In paragraph (a), Mr. Turdera cites ASME Section III para.

NC 4426.2.

Article NC 4000 from which this is taken is titled Fabrication and Installation and is not a material specification.

Section III para. NC 2561, Required Examination, states; " pipe made in accordance with... SA 358... shall be treated as material".

This would make Section II SA 358 the basic controlling document governing longitudinal seam welds in SA 358 pipe.

Both the NCR (Exibit B page 7) and the DR (Exibit B page 1) agree in this and cite Section II SA' 358.

Questions 1) Was Mr. Turdera correct in citing NC 4426.2? 2) If yes, will you please give code references? Exibit B page 8 paragraph (a) states that, "ASME Section III paragraph NC 4426.2 permits a maximum reinforcement of 3/16"... for 1" double welded butt joints".

The pipe used in spool No. 2-EP-01-SOO2, by visual appearance, was single welded.

(SA 358 para.

1.3, the 1977 edition, shows that the pipe can be either single or double welded.)

Paragraph NC 4426.2 gives a maximum inside reinforcement of 5/32" for 1" single welded butt joints.

If the pipe in questioh was single welded it would not meet this requirement.

Questions 1) Was the pipe in 2-EP-01-S002 single or double welded? 2) What documents verify this? In paragraph (b), of Exibit B page 8, the letter states; "The SA 358 material specification references the-ASME Code, Section III, paragraph UW-51(b)".

I have not found such a reference in SA 358.

The letter also cites; " paragraph UW-51(b) of Section VIII of the ASME Code".

This reference also appears to be an error.

Question 1) Do these references exist?

7-Exhibit II Page 7 of 11 l

L

i - , , o Exibit B, page 8, paragraph (b) deals with " overlap",a defect detected by visual examination.

Acceptance criteria of welcs examined by radiograpy is the wrong place to look in the ACME code for a defect found by visual examination.

In Weldina Inspection, a book published by the American Weldind Society.

the following statement is made; " Overlap is the condi tion in which weld metal protrudes beyond the bond line at the toe of a weld.

The condition tends to produce notches that are dangerous, due to the resultant concentration of stress under - lo,ad."

ASME Section II SA 358 para. 5.2.3 states; " The contour of the reinforcement should be reasonably smooth and free from irregularities.

The deposited metal shall be fused uniformly into the plate surface."

Overlap violates this paragraph.

. Questions 1) Why didn't Mr. Turdera deal with " overlap" as a violation of Section II SA 358 para. 5.2.3? Exibit B, page 8, paragraph (b) mentions acceptance criteria for welds examined by radiography.

The longitudinal seam welds in spool piece 2-EP-Ol-SOO2 were radiographed.

The radiography should have been done according to Section V.

Article 2, para. T-221.2 which states; "The weld ripples or weld surface irregularities on both the inside (where accessible) and outside shall be removed by any suitable process to such a degree that the resulting radiographic image due to any irregularities cannot mask or be confused with the image of any discontinuity."

Overlap is a surface irregulari.ty that can mask or be confused with the image of a discontinuity.

The overlap was accessible prior to the fabrication of the spool piece.

This ASME code paragraph seems to have been violated.

Questions 1) Why wasn't the overlap removed prior to fabrica ting the spool piece? 2) How were the radiographs of the longitudinal welds in spool No. 2-EP-Ol-SOO2 correctly read and accepted with weld overlap? In paragraph (c) of Exibit B, page 8, several persons listed there, " agreed that the pipe meets the code requirements and does not fall under NCR category".

Questions 1) Did they base their decision on the information given in paragrapns (a) and (b)? 2) If not what did they base their decision on? -8-Exhibit II Page 8 of 11 . -. _. _ . _ _ _ , - - - -. _ -,- _ ._ _

'. . < 3) Did any of these individuals read the NCR and censider

the requirements of Section II SA 358? 4) Was this letter a basis for the NRC report saying that, "no items of noncompliance were identified"? 5) Are there cases where ASME code violations in Class II piping do not fall under the NCR category? If yes please a explain.

. .. Finding page 6 The fifth paragraph states; "The remaining reinforcement (fall through) in the pipe was measured and found to be within ASME welding code tolerences."

Questions 1) What examination method was used in making this measurement? 2) At what intervals and over what length of the pipe were these measurements made? 3) Was the reinforcement measured back to the 45 degree elbow? 4) Was an inspection report used to document the measurements? 5) Is the inspection report available? 6) What section and paragraph of the ASME code was used to establish the allowable amount of reinforcement? Exibit B,page 3 This page is an NOR describing a minimum wall violation.

The cause of the nonconformance is given as, " ovality in pipe".

ASME Section II SA 358 para. 15.1 states; " Permissible Variations - The dimensions at any point in a length of pipe shall not exceed the following:" and 15.1.2 states; "Out-of-roundness - Difference between major and minor outside diameter 1 percent."

Questions 1) After the ovality was noticed was the pipe checked for conformance to SA 358 para. 15.1.27 2) Was this measurement documented? 3) At what intervals was it measured? 4) Did the pipe conform to SA 358 para. 15.1.27 Exhibit II-9-Page 9 of 11 .- - - . - -.. -... - -. , -. --- . -,.. ---

. ' . - . , Exibit B,prgas 3 end 5

Page 5 is an Inspection Report to determine the wall thickness of the edge preperation.

It lists the ASME code as the controlling code and as the inspection standard.

The NCR, page 3, does not list the ASME code as a controlling document.

Questions 1) Should the NCR, Exibit E page 3, list the ASME code as a controlling document? 2) Do Bechtel specifications take precedence over ASME specifi-cations? . Exibit B,pages 3 and 5 On page 3 under the heading, " Recommended Disposition and Basis for Recommendation" is the statement, "Bechtel to determine that min. wall of.814 will meet design criterias"; and on page 4, Exibit B, the statement is made that, "the calculated minimum wall thickness for 10" BCB... is.795".

Questions 1) What desiEn criteria where used to determine this minimum wall? 2) What paragraphs of Section III were used in this determination? 3) What paragraphs of Section III were used in recalculating the minimum wall? General Comments Nowhere in the report is the vendor of the spool piece named, nor is the manufacturer of the pipe.

Their work was investigated , in the NRC report.

It seems fitting that they should be named.

l [ Questions i l 1) Who was the spool piece vendor? 2) Who. supplied the pipe to the vendor? 3) When was the pipe manufactured? Even though the area of the crack was ground smooth, radiographs existed which could have shown the existence of a crack prior to grinding, or they could have shown an abrupt density change f. overlap) which could mask a crack.

No mention was made in the report of these radiographs and presumably they were not checked.

-10-Exhibit II Page 10 of 11 - - . ... _ _, -, -- -. .-..-

' .

. . Quastions , 1) Wbre the radiographs of the long.itudinal welds in spool TJo. 2-EP-01-SOO2 checked by the NRC? 2) If they were what were their findings? .It took the T!RC over five months to investigate iny a l l e,'s t i v n s. . Ir} many cases defects could become inaccessiDie in that an.c un t of, time.

Questions 1) When were Daniel International, Union Electric, Dect.tel, and S!!UPPS first notified. formally or inforn. ally, or my allegations.

Everything said in this letter is true to the best of my know-ledge and belief.

Sincerely, i ! I l I l l l-11- ! Exhibit II Page 11 of 11 i

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%'o,

s UNITED STATES

j NUCLEAR REGULATORY COMMISSION

,.. D e REGION lit ? M 7M ROOSEVELT ROAD %, 'o... +,o* ' GLEN ELLYN,ILLINolS 60137 April 11, 1980 . . . Dear Mr.

Per our conversation on April 11, 1980, enclosed is a drawing of the accumulator tank area at Callaway.

Please indicate the seam veld involved and return the drawing in the enclosed envelope.

Again I would like to thank you for your cooperation in this matter.

Sincerely, L\\ Robert Burton Investigator .

Enclosure:

as stated Exhibit IV Page 1 of 1

.. . CALLAWAY ACCUMULATOR LINE SPOOL PIECE S002 , PARTIAL CHRONOLOGY 8/17/77 Certificate of compliance date, ARMCO, Huston 9/15/77 Radiography date, ARMCO (Pipe completed) 4/26/79 UT test of weld preparation area, 814 lowest wall measurement . 4/27/79 NCR 2SN-0496-P, minimum wall violation 4/30/79 NCR 2SN-0501-P, overlap on longitudinal weld (B. Diggs, originator) 5/79 Individual "A" states he advised a QC inspector of " crack" (approximate) 5/5/79 Date noted in first report, in error Date of ANI concurrence . on 2SN-0501-P 5/16/79 Dispostion of NCR 2SN-0946-P, use-as-is, reduced wall a

REGION lil o, [ l* , 799 ROOSEVELT ROAD % c.... o CLEN E LLYN, ILLINOIS 60137 Mr., . . Deat Mr.

Enclosed is a copy of NRC Inspection and Enforcement Investigation Report No. 50-483/81-04 which documents an expanded investigation into the quality of a section of accumulator discharge piping at the Callaway Nuclear Power Plant.

I apologize for our oversight in not sending you a copy of the initial investigation report.

This investigation was initiated in response to the letter of concern ycu sent to Region III c:" February 8,1981, which indicated that we had not fully understood.ad investigated your concerns in the earlier investigation.

I trust that the enclosed report is more responsive to your concerns.

As you requested, a response to each question in your February 8, 1981, letter is contoined in an enclosure to this letter.

The report itself contains additional detailed information on many of the questions.

Sbould you have any additional questions regarding the information contained in the report or the conduct of our investigation into this matter, please feel free to contact this office.

Sincerely,

J. F. Streeter, Acting Director Enforcement and Investigation Staff Enclosures: IE Investigation Report 2.

No. 50-483/81-04 2.

Responses to questions Exhibit IX Page 1 of 15

, . RESPONSES TO QUESTIONS , 1.

Question: Were the telephone calls I made to ti.e Region III office on October 11, 1979, and April 11, 1980, electronically recorded? Answer: By NRC policy, telephone calls are not electronically recorded without advisement and consent of the parties involved. Your telephone calls were not electronically recorded.

, 2. '- Question: If they were recorded may I listen to them or have a transcript? Answer: See ans.er to Question 1.

3.

Question: May I have a copy of the notes taken by Mr. Burton, Mr. McCartney or others who listened in on the calls? Answer: The investigstors referred to are R. Burton and J. McCarten.

By NRC policy, an Investigator's notes are his property unless entered into an official file. As the notes are often brief phrases meant to jog the memory of the individual, there is a high probability that interpretation of notes without the individual present would result in erroneous conclu-siens. However, the investigators agreed to provide their notes which are attached (Individual A's name has been deleted).

4.

Question: Why were only 15 welds inspected? Answer: As noted in Investigation Report 50-483/81-04, the characteriza-tion of "15 welds" was in error. The reference was to a piping isometric which did not include longitudinal seam welds.

Seam welds were also inspected.

5.

Question: Exactly which welds were inspected and which were omitted in the inspections made on March 26 and 27, 1980? Answer: All external surfaces of completed welds on the two accumulator

discharge lines, an isometric of which is Exhibit A of IE Report No.

50-473/80-10, including the seam welds, were visually inspected. The isometric indicates this consisted of three field welds, 11 circumferen-tial welds, and 15 lingitudinal welds.

Only two accumulator lines had , l been completed at the time.

These inspections were made due to lack l of an exact location of the weld in question and were of the external l weld surfaces due to lack of specific information.

The number of welds inspected is immaterial as the wrong welds were inspected.

6.

Question: Specifically, what efforts were made to contact me concerning l the exact location of the crack? ! l Answer: The investigator's log notes four telephone call attempts on March 24, 1980, one on March 15, 1980, one April 9, 1980, and one call l l l [ Exhibit IX l Page 2 of 15 l ' , ~

. to empicys:s of th2 Wichite Ergle newsp:p;r. You cre aw:re of your first call on or about October 11, 1979, the call you made on April 11, , 1980, the letter to you with ar. attached piping isometric, and your handwritten note to us which accompanied the marked isometric utilized to locate the weld.

7.

Question: Who is WLK? Answer: WLK are the initials of a Level II Daniel Quality Control , inspector, Wayne L. King, who was assigned to visually inspect the

welds on the two accumulator discharge lines, along with NRC Resident

' Inspector William Hansen. During the present investigation, we re-viewed this inspector's certifications and found them to be acceptable.

8.

Question: When did he make the seam weld inspection? Answer: March 27, 1980.

9.

Question: Did be look into the end of S002 and examine the inside of the seam weld? Answer: Inside seam welds were not inspected until receipt of information identifying the weld at F004.

10.

Question: Is the NCR and the DR talking about the same defect? Answer: Both reports document the same reinforcement deficiency. The NCR identified it as overlap; the DR called it poor fusion.

Both terms can apply to similar situations, depending on the judgement of the inspector. Until an overlap is removed, it cannot be ascertained if there is actually a crack.

In this case, when the area of overlap / poor fusion was removed there was no crack.

11.

Question: Would " overlap" be a violation of Material Spec. SA 358, Para. 5.2.3? Answer: Photographs of the original weld contour at the location near field weld F004 show " irregularities" and the metal is not " fused uniformly". This would be a violation of SA 358, Para. 5.2.3.

12.

Question: Why did Mr. Turdera ignore Section II in his discussion of maximum reinforcement when it (Section II) was listed in the " Con-trolling Documents"? Answer: As detailed in the Investigation Report, Paragraph 6, it is not apparent that any requirement was " ignored".

Mr. Turdera was not avail-able for interview, but discussion with Bechtel personnel indicated that they considered ASME III as the governing code.

Our position is that that is incorrect as the weld was a manufacturer weld.

-2-Exhibit IX Page 3 of 15 .. - ~ __ _ _ _. . _ - .. -

.

13.

Question: Why didn't the NRC Resident Inspector question this (Turdera letter) when he rece.ved these documents on April !4, U 80? s Anav During the initial investigation, the principal importance of - tt 3 and DR referenced was in locating the pipe weld in question.

Also, the referenced defect had been removed per the disposition of the DR.

There was no reason to qu stion the interpretations contained ir.

Mr. Turdera's letter as it was not a significant point. The significant point was that the deficiency was identified, documented, and corrected

prior to installation.

14.

Question: In the investigation that occurred on March 26 and 27, 1980, why didn't the investigators have these documents then, since they involved the pipe in que tion? Answer: As previously noted in the original report and in the present report, the location of the pipe o-weld in question was not clear on those dates due to inadequate information.

From the information avail-able at that time, it was pre umed that the " pipe crack" would be visually evident and on an external surface. Related nonconformance reports were not believed important at that time.

15.

Question: Was Mr. Turdera correct in citing NC 4426.2? Answer: Our pcsition is that the ASME SA-358 (the material specification) was the relevant requirement, rather than NC 4426.2. The principal difference between these two Code references in the area of weld reinforce-ment is that SA-358 allows 1/8" maximum reinforcement whereas NC 44262 allows 3/16".

16.

Question: If yes, will you please give code reference? Answer: Although we do not believe it was the correct Code reference, the section Mr. Turdera quoted was: American Society of Mechanical Engineers, ASME Boiler and Pressure Vessel Code, Section III, Division I, " Nuclear Power Plant Components", Subsection NC, " Class 2 Components", Paragraph NC-4426, " Reinforcement of Welds", Subparagraph NC-4426.2, " Thickness of Weld Reinforcement for Piping".

17.

Question: Was the pipe in 2-EP-01-S002 single or double welded? Answer: Double welded utilizing an automatic submerged are welding process.

18.

Question: What documents verify this? Answer: Manufacturer documents, including the weld procedure sheets, weld procedure qualification documents, and radiographic reader sheets.

l , ! l-3-Exhibit IX Page 4 of 15 i l l ... -

. 19.

Question: Do these references (UW-51b) exist? - Answer: UW-51(b) is found in ASME Section VIII as indicated in the letter signed by Mr. Turdera. As noted in the investigation report, Section VIII does not apply to the pipe in question. However, PW-51 which is the correct reference from SA-358 is found in the ASMI Code Section I and has wording providing the same requirements and criteria.

20.

Question: khy didn't Turdera deal with " overlap" as a violation of ".Section II SA (58. para 5.2.3? Answer: Mr. Turdera was not available for interview, but he appar ntly assumed it was an acceptable defect based on applicable nondestructive examination requirements.

21.

Question: Why wasn't the overlap removed nrior to fabricating the spool piece? Answer: Acccrding to documents available, it was considered an accept-able defect, based on accepted radiographs.

The Code allows for accept-ance of certain indications, and acceptance / rejection can be an indivi-dual judgement factor.

22.

Question: How were the radiographs of the longitudinal welds in spool No. 2-EP-01-S002 correctly read and accepted with weld overlap? Answer: As noted in the Investigation Report, our position is that the section of the radiographic film for an area near field weld F004 should have been rejected.

The area in question was approximately four inches long, not the entire seam weld as suggested. The remainder of the radiography was acceptable.

23.

Question: Did they base their decision on the information given in paragraphs (a) and (b)? Ansv-r: The information contained in the letter was apparently part of L. conclusion that the nonconformance was not appropriate for an NCR. The letter is brief, and apparently summarizes discussions.

24.

Question: If not, what did they base their decision on? Answer: As detailed in the Investigation Report, Paragraph 6, additional guidance was contained in the procedure for dispositioning nonconformances.

25.

Question: Did any of these individuals read the NCR and consider the requirements of Section II SA 358? Answer: The incividuals read the NCR, as that was the information dis-cussed. See :nsver to Question 12.

-4-Exhibit IX Page 5 of 15 -. _ _ _ _ _ _ _ _ _.

_ __ .. .

. ' 26.

Question: Was this letter a basis for the NRC report saying that, "no items of noncompliance were identified"? Answer: The basis for the statement was that the defect had been removed under the QC program and there was no pipe crack as alleged.

27.

Question: Are there cases where ASME Code violations in Class II piping do not fall under the NCR category? If yes, please explain.

. '

Answer:

Yes.

Under the provisions of site procedures, nonconformances can also be dispositioned by way of a Deficiency Report. From the NRC viewpoint, it is not significant which methed documents and dispositions a nonconformance as long as the nonconformance is documented and dis-positioned properly (including an engineering review where necessary).

In practice, items dispositioned via an NCR are usually significant items which require engineering reviews.

28.

Question: What examination method was used in making this measurement? Answer: Visual inspection and comparison with an object known to be exactly 1/8".

29.

Question: At what intervals and over what length of the pipe were these measurements made? Answer: Visual inspection was performed by the Resident Inspector (and by QC Inspector Dameron on November 5,1979, according to the DR) on the weld reinforcement just beyond the area where the excessive weld rein-forcement had been removed.

The size of weld reinforcement (height, width, contour) on the rest of the seam weld was uniform and appeared to meet Code requirements (SA-358, 1974). NRC Inspector W. Key also visually inspected the weld.

30.

Question: Was the reinforcement measured back to the 45 degree elbow? Answer: The seam weld was visible back to the 45 degree elbow and appeared uniform for the length of the piece in question; however, it was not measured for the entire length.

31.

Question: Was an inspection report used to document the measurements? Answer: A separate site report would have been expected only if the measurements had indicated a nonconformance. The initial Investigation Report was used to convey the r'esults of NRC measurements.

32. Question: Is the inspection report available? Answer: See answer to Question 31.

33. Question: What section and paragraph of the ASME Code was used to establish the allowable amount of reinforcement? -5-Exhibit IX Page 6 of 15 . - _. -- -

. Answer: See answer to Question 15.

, 34.

Question: After the ovality was noticed was the pipe checked for tonformance to SA 358 para. 15.1.2? Answer: Ovality of pipe was thought to be the cause of the observed minimum wall violation, and was not observed as a nonconformance. Some ovality is acceptable as provided by the material specification. Mini-num wall violations at a counterbored area can be caused by (1) mis- " location of the counterbore centerline, (2) excessive counterbore, (3) ' ovality of the pipe, or (4) a combination of any of the three. Ve did not locate records 'o indicate that the pipe was checked for ovality after the NCR was issued. The pipe has since been measured and sound acceptable as documented in the attached investigation report.

35.

Question: Was this measurement documented? Answer: See answer to Question 34.

36.

Question: At what intervals sas it measured? Answer: See answer to Question 34.

We selected one representative point for our measurements as no iaterval was specified by Code. Spec-ification SA-358 does not specify the measurement method, but other sections of the Code (NC-4221.3 for example) indicate such measurements should not be made on a weld seam.

37.

Question: Did the pipe conform to SA-358 paragraph 15.12? Answer: See answer to Question 34.

38.

Question: Should the NCR, Exhibit B, page 3, list the ASME Code as a " controlling document"? Answer: It is not necessary since the Bechtel specification contains references to the ASMI Code.

39.

Question: Do Bechtel specifications take precedence over ASME speci-fications? Answer: Only when their requirements are more stringent than those of the ASrfE Code as provided in Bechtel Specification No. 10466-M-201A, Section 3.3.

40.

Question: What design criteria were used to determine this minimum wall? Answer: American Society of Mechanical Engineers, ASME Boiler and Pressure Vessel Code, Section III, Division I, " Nuclear Power Plant Components", Subsection NC, " Class 2 Components", Subarticle NC-3640, Exhibit IX Page 7 of 15-6- -. . -. _ _ _ ~ ..

. . " Pressure Design of Piping Products", Paragraph NC-3641, " Straight Pipe", Subparagraph NC-3641.1, " Straight Pipe Under Interna' Pressure".

Values for temperature and pressure were taken from the EP pip;ng class summary.

41.

Question: What paragraphs of Section III were used in this determination? Answer: See answer to Question 40.

.: 42.

Question: What paragraphs of Section III were used in recalculating the minimum wall? Answer: See answer to Question 40.

43.

Question: Who was the spool piece vendor? Answer: Dravo Corporation, Pipe Fabrication Division.

44.

Question: Who supplied the pipe to the vendor? Answer: Guyon Alloys supplied the pipe to Dravo which had been pur-chased from Armco, Incorporated, Advanced Materials Division, the manufacturer of the pipe.

45.

Question: When was the pipe manufactured? Answer: The pipe was manufactured by Armco approximately September 19'7 (radiography was performed September 15-16, 1977).

46.

Question: Were the radiographs of the longitudinal welds in spcol No. 2-EP-01-S002 checked by the NRC? Answer: These radiographs were not examined during the initial investi-gation. They were interpreted as a part of the present investigation.

47.

Question: If they were, what were their findings? Answer: Findings are detailed in the investigation report. With the exception of an area approximately four inches long, all of the radio-graphs of the pipe piece in question were acceptable. For the four inch area, it is our position that this area should have been rejected based on the origional radiographs.

48.

Question: When were Daniel International, Unicn Electric, Bechtel, and SNUPPS first notified, forma]Iy or infomally, of my allegations? Anst.er: Union Electric and Daniel International personnel were first advised of allegations concerning a " pipe crack" on March 26, 1980.

The identity of the informant was not provided. NRC did not inform Bechtel or SNUPPS of the allegations, although their personnel were i contacted during the investigations to secure technical information.

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NUCLEAR REGULATORY C0petISSION . 0FFICE OF INSPECTION AND ENFORCEM WASHINGTON, D.C.

20555 a.

. L March 12,1979 i IE Bulletin No. 79 03 ... LONGITUDIN4.L WELD DEFECTS IN ASME SA-3 PIPE SPOOLS MANUFACTURED BY YOUNGST0m NY Description of Circumstances: On September 27, 1978, . defects had been discovered in longitudinal welds ir. ASM a class 2 pipe supplied for the Palo Verde Nuclear Generating Sta n III (PVNGS). On November 17, 1978, reported similar *fects in pipe supplied for the San Onofre Nu Generating Station, Units 2 and 3.

r Pullman Power Products of Los Angeles, California supplies safet related fabricated piping spools of various diameters for the PVNG , l y-steel pipe supplied to Pullman by Youngstow i . n ess Company of Youngstown, Ohio.

into cylinders and then fusion weldng the longitudinal seam w filler metal.

, Pullman discovered defects in the longitudinal welds while radiog their circianferential shop welds.

the longitudinal welds revealed rejectable porosity and lack of Pullman then performed ultrasonic examination of the full length of th . longitudinal welds and discovered indications exceeding the accept criteria of ASKI Section III.

indications in other piping subassemblies where pipe was Youngstown.

Two indications verified by radiography were identified as porosity and measured 0.350 inch by 0.125 inch in one case and 0.300 inch by 0.125 inch in another case in pipe with a nominal well thickness of 0.375 inch.

The additional examinations revealed that of 103 spools and four pipe supports sbf ped to PVNGS, 44 spools and one pipe support were found to

contair, ultrasonic indications exceeding those permitted by the ASME Code.

Of 65 partially fabricated piping spools, 30 were found to be similarly defective.

The acceptance criteria for the pipe supplied by Younostown includes 100 percent ultrasonic examination of the longitudinal 1 of 3 . Exhibit XI - Page 1 of 4 pgl%Q __ i

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4(- i IE Bulletin no. 79-03 March 12,1979 , melds in accordance with ASME Section III.

The documentation provided with the pipe indicated that the required ultrasonic examination had been performed by Youngstown but the rejectable indications were not identified.

- , A special insGecticn was performed at Youngstown by NRC inspectors during the week of January 22, 1979.

It was determined that the apparent cause of the identified defects was inadequate control of welding parameters although no specific ASME Code violations could be identified. Youngstown has recently hired a consultant to reevaluate the fusion welding parameters and revised their welding procedures to provide better control of welding current, voltage and travel speed for all material thickness ranges.

Ultrasonic examinations of the pipe welds wre performed by a subcontractor to Youngstown. The reason why this subcontractor's ultrasonic testing did not detect indications exceeding ASME Code acceptance criteria was not determined. The piping was known to have been tested in the heat treated condition, prior to the removal of surface oxides.

However, a comparison of attenuation of the pipe in

as heat treated vs. heat treated and pickled condition did not reveal a discernible difference.

l l The NRC inspectors could not determine a definite time period during which the welding and ultrasonic testing problems are thought to have existed.

All type 304 or 316 SA 312 pipe manufactured before mid-November,1978 may have been shipped in similar condition. As a large supplier, Youngstown is known to have supplied piping for nuclear applications to the Dravo Corporation. Chicago Brid e and Iron.

Flowline Corporation and ITT Grinnell Industrial Piping Inc.

In addition, piping was also supplied to material warehousing operations including Albert ?ipe Supply Guyon Alloys Inc., and Allegheny Luditan Steel Corporation which may have eventually been used in safety-related nuclear applications.

l ' Action to be 'en by the Licensees and Permit Holders: For all power reactor facilities with an operating license or a l construction pennit: 1.

Determine whether ASME SA-312 type 304 or other welded (without filler metal) pipe manufactured by Youngstown Welding and Engi-l neering Company is in use or planned for use in safety-nlated l systems at your facility.

l 2 of 3 Exhibit XI - Page 2 of 4 <

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. ) v !E Bulletin No. 79-03 March 12, 1979 . &g3f ..

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For those safety-related systems where the subject piping is.in use or planned for use, identify the application 3f the piping including ~.' system, pipe location, pipe size and design piessure/teeperature . requirements.

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Develop a program for volumetric examination of the longitudinal (- . . welds including acceptance criteria for the piping identified in Item 2 above.

Describe planned corrective actions if acceptance A a . criteria are not met.

If a sampling program is utilized explain , the basis for the sample size.

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For facilities with an operating license, a report of the above " actions, including the date(s) wnen they will be cospleted shall.be . submitted within 30 days of receipt of this Bulletin.

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For facilities with a construction pemit, a report of the above ' actions, including the date(s) when they will be completed shall be submitted within 60 days of receipt of this Bulletin.

Reports should be submitted to the Director of the appropriate NRC Regional Office and a copy should be fon.arded to the NRC Office of Inspection and Enforcement, Divition of Reactor Construction inspection, Washington, D.C., 20555.

Approved by GAO, B180225 (R0072); clearance expims 7-31-80.

Approval was given under a blanket clearance specifically for identified generic i problems.

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IE Bulletin No. 79-03 Jist. i , ? Longitudinal Weld Defects in ASME SA-312 Type 304 Stainless Steel . Pipe Spools Manufactured by Youngstown Welding and Eng1 erin Company ' .k*. Distribution: i-

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L. V. Gossick, EDO 'f h.B-6209 - J. R. Shea, Dir. OIP 'c.MBB-8103 J. J. Fouchard, Director, PA 'MB8-3709 ,- - N. M. Haller, Director, MPA MBB-12105

" R. B. Minogue, Dir., SD - .

NL-5650 " . W. J. Dircks Dir., NMSS , - SS-1130 .. 55-958 5. Levine Dir., RES . ' . .H. R. Denton, Dir., NRR i f. - ..Ph11-428.w. p.,. .. R. S. Boyd, Dir., DPM:NRR TPhil-268 . ~' D. F. Ross, Deputy Director DPM:NRR Phil-278 - . - V. Stallo, Dir., DOR:NRR . Ph11-542 -

J. R. Miller, DOR:NRR '. .Ph11-216,, ..

- D. G. Eisenhut, Dep. Dir., DOR:NRR ',,.c F Ph11-266 '., ' R. H. Vollmer, Asst. Dir., SP: DOR:NRR - .: ' P-514 G. C. Lainas, Chief, PSB: DOR:NRR ?.,jI. f ', Ph11-416 B. K. Grimes, Asst. Dir., E/P:00R:NRR Phil-370 " R. J. Mattson, Dir., DSS:NRR Ph11-202 W. P. Naass, Chief, QAB:0AO:NRR P-320 - r R. F. Fraley, ACRS H-1016 V. Harding, Legal Assistant, OCM H-1149 G. Wayne Kerr, Asst. Dir., SA:SP MP8-7210A J. Liebeman, ELD MBB-9604 J. G. Davis Acting Dir., IE D. Thompson, X005:lE 4. C. Paulus, XOOS:IE L. N. Underwood, X005:!E (Original)

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H. D. Thornburg, RCI:IE G. W. Reinmuth, RCI:IE N. C. Moseley, ROI:IE E. L. Jordan, ROI:IE 5. E. Bryan, ROI:!E J. H. Sniezek, FFMSI:IE L. B. Higginbotham, FFMSI:IE E. M. Howard, SI:!E L. I.-Cobb, X0MA:IE W. R. Rutherford, RCI:IE L. E. Tripp, RI IE Files NRC Central Files IE Reading Files Mike Atsalinos, DSB:TIDC:ADM %11-050 (Note: See separata mailing list for distribution of outside requests for Bulletins, Circulars and Information Notices) .~. Exhibit XI Page 4 Of 4 . . -.. - . -.. .. ..

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' Accessica No.:

UNITED STATES 8002280644 :)

, NUCIJ.AR RIGUIATORY CorNI551M "..g - , OFTICE OF INSPECTION AND FNFORCEMENT , , 3.Y N f,. WASHINGTON, D.C.

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, , April 4, 1980 ,. b e

11 Bulletin No. 79-03A -'

IDNCITUDINAL WELD DEFECTS IN ASME SA-312 TYPE 304 STAIW12.55 STIN.L PIPE 'hl '

' ' , ' - Description of Circumstances: . < ... . -

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.1 . ,., IE Sulletin No. 79-03 ree.uired t.be licensee to determine if ASIE SA-312. Type ,, g 304 pipe manufactured by Youngstown Welding and Engineering Company is is use - T.

' - er planned for use in safety-related systems. Since the issuance of IE .M Bulletin 79-03 on March 12, 1979, subsequest findings indicate additional .-~h ' information and clarification is needed to resolve the SA-312 Lasue.

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. It has been determined that conventional ultrasoalc testing (UT) and radio s

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. graphic testing (RT) techniques (as required by ASIE Section III) are not

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cdequate to detect centerline lack of weld penetration (CLP).

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- . rediography and UT esaminations say detect the presence of C1.P under special

ccaditions, but neither can be considered reliable enough tr* detect CD even g v.

when significant percentages exist.

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BasedupontheaboveandpreviousfindingsduringinspectionsAtToungstownit'.~ ' har. been determined that the bungstown Welding and Engineering Company did comply with the ASME Code requirements, but that the Code EDE regoirements are d2ficient.

Consequently any manu'acturers' SA-312. Type 300 Series, anstenitic , , - stainless steel fusion welds may contain undetected CLP. This problem is .. . 32neric to all welded SA-312/A-312 material and is not restricted to esterial manufactured by the Youngstown Welding and Engineering Company.

.. The NRC has verified that the CLP condition also asists in the SA-312 and/or A-3 2 fusion welded pipe manufactured by ARHCO's Advanced Materials Division, the {WEPCO Tube Corporation and Crucible's Trent Tube Division. These cer9panies are known to have supplied SA-312 and/or A-312 asterial for anclear application cod are now inclu$ed within the scope of this tallatia.

I Several Licensee'r responses to the II Balletin 79-03 were inadegaata. The responses were inadequate because they were based on the purchase order EEE l requirements rather than the taformation requested in the Bulletta. As setun czample of an inadequate resposae was as follows: Radiography of a circum-forential weld sean revealed CD in the longitudinal seas of a secties af l SW.PJO fusion welded pipe. The licensee did not believe the case was reportable l if the original EDE requirements for the SiEPCO pipe did met require volumetric I czamination.

l This CLP problem is considered by the NRL to be a significaat deficiency which I requires estensive evaluation and could result in repair or replacement of P1Pe and/cr fittings.

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h ^ IE Bulletic Ns. 79-03A April 4, 1930 - p:32 2 of 3 ' o u The information requested in this revised Bulletia is to be provided eithout - regard to the purchase order IEE regs.irementa er any sehsegment M performed ' for er by the licensee. The informaties requests in this talletia supersede , , the requests for information in the II tulletta 79-03.

' ~ . .< , c ._ The ERC staff position se this issue and any other case where' defects er ? ! i - s deficiencies are dia..:evered is safety-related components is as follows: - Ee'gardless of the circumstances under which poteottal deficiencies or potential-defects in safety-related components are discovered the matter shall be identi- , fied, evalus Led, dispeettiseed, deensated and reported sa strict accordance with the appropriate Federal Regulations. Although the ASA Code rules and requirements may be used whe: approspriate to evaluate defects or deficiencies and to justify a=d accept the saistence of a defect er deficiencies, the Code casi met be need

as justificaties for not reperting the defect, deficiency and ciremstances to the NRC whom that defect er deficiency has been identified by the E as a " ' potential generic problem. them the licensee, his agent er vender discovers a * ( defect er deficiency that any be a pseeric problem er a sismificant leae .. deficiency a >aservative position shall be adopted regarding the reporting of Q the situation to the BC.

For those power reacter facilities that have the sebject pipe installed the action identsfied in this am!!etia is limitad to identifying the specific , applicatiosa and prvviding information releted to the structural integrity of ' the piping components. Additional 341 dance related to E E's and/or precam-tionary or corrective actions will be provided la a later Balletin revision if necessary.

Revised action to be taham by Licensees and permit Enleers: ' l l For all power reactor facilities with as operating license or a eeestructies ) i p ruit: 1.

Determine whether SA-312 er A-312. Type 300 Series fusies welded pipe is , , in use or planned for use is safsty-related s7stans subject to desigs >

stresses greater thaa 85 percent of the Code allowable stressee. por the purpose of this cbsch the octual well thicknesa of the pipias preemets will be considered adequate if the code requirements for pressure desip

of the pipias preemeta are satisfied using 85 percent at the==h ' l allowable stress at the design tamperature, l 2.

For t.bose piping composenta asing greater than SS percent af the allowable stresses identify the application of the piping including the systen, pipe locaties, pipe siae, pipe ceafiguration (elbow, tee), design pressure / temperature represents and the manufacturer.

3.

For these facilities under construction and where access permita, the esta of all safety-related 84-312 and A-312 fastem welds should be etched te determine if CLF exista. Identify the anastacturer and the degree of CIF as a percentage of the pipe well thickases.

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' April 4, 1980 ~

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For facilities with an operating license, a report of the above information shall be submitted within 120 days of receipt of this ta11stia.

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For facilities with a constructies permit, a report of the above informaties aball be salseitted withia 120 days of receipt of this ta11stia.

' ..%: $.19 ? - ~ . Reports should be submitted to the Director of the appropriate NRC Regf emal Office ' and a copy should be forwarded to the NRC Office of Inspecties.and Inforcement, Division of Beactor constructies Inspecties, Washingtse, D.C.

20555.

. . ., - , Approved by GAO, B180225 (30072); clearance aspires 7/31/80. Approval was . givenanderablanketclearancespecificallyforidentifiedgenericproblems.'4.. rv . . .- . ' ,,, . W.

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__ 0 *"' c,, o O *f ~?, UNITED sT AT[s n , $gis. ; ; NUCLEAR REGUL ATORY COMMISSION (( ~l WASNNGTON, D. C 20555 %.',,. **' APR 9 1380 MD40RANDUM FOR: B. H. Grier. Director, RI J. P. O'Reilly, Director, RII J. G. Keppler Director, RIII . " K. V. Seyfrit, Director, RIV R. H. Engelken, Director, RV FROM-Harold D. Thornburg, Director, Division of Reactor Construction Inspection, IE SUBJECT: IhTERPRETATION OF IE BULLETIN 79-03A ' Several questions have been raised regarding Bulletin 79-03A.

We are not planning to revise the Bulletin, but we are providing the following interpretations so that all Regions respond with a consistent answer if the same questions are asked by licensees.

1.

Does the Bulletin also apply to SA 312 pipe welded from one side? Since you can not produce centerline lack of penetration (CLP) welding from one side, the Bulletin does not apply.

2.

Does Item 3 on page 2 apply to all safety-related SA 312 fusion welds or just those in components subject to design stresses greater than 85 percent of the Code allowable stresses? Item 3 applies only to those components subject to design stresses greater than 85 percent of the Code allowable stresses.

If you find other clarifications are necessary please advise.

G cd ( W4 H rold D. Thornburg ( Director Division of Reactor Construction Inspection, IE C0KIACT: W. R. Rutherford, IE 49-27551 APR 1 4 1980 Exhibit XIII y Page 1 of 3 v - .. - - _ _ _ _ _., _ _ _ _ _ _ _ _ _ _ - _. _ _ _ _ _ _ . _. - - _ }}

v t e Inspection Report - Callaway - 1981004
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \|
1981 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 12(0) 7(0) 9(0) 10(0) 11(0) 12(0) 13(0) 14(0) 15(0) 16(0) 17(0) 18(0) 19(0) 20(0) 23(0) 24(0) 25(0) 26(0) Security Operator Exams Emergency Planning Other

IR 05000483/1981004