ML20011A462
| ML20011A462 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/30/1981 |
| From: | Key W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20011A456 | List:
|
| References | |
| NUDOCS 8110130438 | |
| Download: ML20011A462 (2) | |
Text
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i IN)1f.D 51 A1ES Us A.I K1CA HilCLP.AR RECL'LAloRY CO.515510N hETOME THE ATOMIC SAFIIT AND LICE!; SING h0AILD In the P.ntter of
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Docket Nos. S1X 50-4ft1 I?nion Elt ct ric Cu::pany
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(Callaval Plant, Unita 1
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AFFIDAVIT or WILL1/Ji EEY I, William Key, being duly tworn, dispose and state:
I have been an inspector with NRC's Of fice of Int.pection and Enforcement, Region Ill, since 1975. As part of :ny job. I conduct int.pections of piping installation, welding and nondest ructive er.ac.ination at operating 1
plants, pisnts under conntruction, and ersist en investigations.
Between February 20 an.1 March 6, 1981, I visited the Callaway site two times to amnist Region III Investigator. Jan,es Toster, on an investigation of n13cgations oM*c(ective scam welded piping being innta11ed.
se i I visually inspectef the identif fed pipe. SA-358, reviewed docuentation, j
and radiographs of t.he wc1d scam atter rereval of the idenaf f ed defect.
i This inspectinn showed the wc3d to be within ASME Coda neceptance criteria, l
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, s I reviewed the shop radiographs of the heam veld.
In one 1or tfon. 3 jdesitified porae drop through in the root.
This had been identified on the radiographic scport es washout and accepted by the nanufacturer.
Fo11oving ran11ographic exaninntion of this veld in its present condition.
I reviewed the radiogrsiph sind f ound it te be f ree of veld defects.
I hereby certify that the inf orssation remtnined in this af fidnvit is true and accurate to the boet of any pet sonni know1 cage, s
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a Docket No. 50-483 Union Electric Company ATTN:
Mr. John X. Bryan Vice President - Nuclear Post Office Box 149 St. Louis, MO 63166 Gentlemen:
This refers to the investigation conducte1 by Messrs. J. Foster, W. Key, and W. Hansen of this office on February 20, March 3-6, 23-27,1981, of activities at the Callaway Nuclear Plant, Unit 1, authorized by NRC Construction Permit No. CPPR-139 and to the discussion of our findings with Mr. W. H. Weber, 4
Manager, Nuclear Construction, and others of your staff at the conclusion of the investigation.
This investigation involved a review and expansion of a previous investigation j
of an allegation relating to a weld in an accumulator discharge line pipe.
The enclosed copy of our investigation report identifies are37 examined during the investigation. Within these areas, the investigation co;4isted of a selective exam: nation of procedures and representat:ve records, observations, and inter-views witt. personnel.
During this inspection, certain of four activities appeared to be in non-l compliance w:th NRC requirements, as specified in the enclosed Appendix A.
j A written response, submitted under oath or affirmation, is required.
We are alsc c:ncerned regarding your Architect-Engineer's failure to disposition Nonconformance Report 2SN-0501-P.
In your response to this letter, please advise us of act: ens you plan to take to prevent recurrence of similar errors.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this l,
..-ter, the enclosures, and your resp;cse to this letter will be placed in the i
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- :.n Electric Ce pany 2-JUN 2 5 GM NRC*s Public Docu=ent Room.
If the enclosures contain any information that you or your contractors believe to be exe=pt from disclosure under 10 CFR 9.5(a)(4),
it i. necessary that you (a) notify this office by telephone within seven (7) days from the date of this letter of your intention to file a request for v2th-he.1 ding; and (b) submit within twenty-five (25) days from the date of this let'ter a written application to this office to withhold such information.
Section 2.790(b)(1) requires that any such applicatian must be accompanied by an aff 2 davit executed by the owner of the infcreation which identifies the
-* cr part sought to be withheld, and which contains a full statement
- f *re reasons on the basis which it is claimed that the informat:en should be
-; tine: d f rom public disclosure. This section further requires the stat:aent to address with specificity the considerations listed in 10 CFR 2.790(b)(4).
The infer:ation sought to be withheld shall be incorporated as f ar as possible into a separate part of the affidavit.
If we do net hear from you in this regard within the specified periods noted above, a copy of this letter, the enclosures, and your response to this letter will be placed in the Public Document Room.
We will gladly discuss any questions you have concerning this investigation.
Sincerely, Janes G. Keppler Director
Enclosures:
1.
Appendix A Not:ce cl Viclation 2.
!E Investigation Report No. 50-;53/5 -0; l
cc w/encls:
W. H. Weber, Manager Nuclear Construction 4
DME/ Document Contrci Desk (RIDS)
Region IV K. Drey l
Ronald Fluegge, Utility Division, Missouri Public Service Co==ission l
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4 Appendix A NOTICE OF VIOL.ATION Union Electric Company Docket No. 50-483 As a result of the investigation conducted on February 20. March 3-6, 23-27, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980), the following violation was identified.
10 CFR Part 50, Appendix B, Criterion IX, states, " Measures shall be estab-lished to assure that special processes, including welding, heat
- treating, and nondestructive testing, are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements."
Pipe piece No. SP, part of the accum 21ator disch3:ge line from accumulator TEPOIA, was manufactured to material specification ASME SA-358.
Specifica-tien SA-358 requires " Radiographic Examination in Accordance with
.. ASME. "
Section :, Paragraph FW-51.
AS.'fE Code,Section I, Paragraph PW-51 states " Sections of weld that are shown by radiography to have any of the follcwing types of imperfettions shall be judged unacceptable and shall be repaired..."
51.3.1 1.ny type of crack, or zone of incomplete fusion or penetration.
Contrary to the above, on March 6,1981, the inspector determined from a review of radiographs of the seam weld on pipe piece No. SP at film location markers 13-14 that the film indicated apparent incomplete fusion and excess reinforcement and yet the pipe piece had not been judged unacceptable or repaired.
This is a Severity I.evel V violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within twenty-five days of the date of this Notice a written statement or explanation in reply.
Since the investigation indicated action had been taken to correct the identified noncompliance, your rep 1.y need only address actions to be taken to avoid further noncompliance.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Dated p \\h ~
James G. Keppler
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Yn Director 9Yq
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k U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION A?is ENFORCE."NT REGION III Report No. 50-483/81-04 License No. CPPR-139 Docket No. 50-483 Licensee: Union Electric Compacy Post Office Box 149 St. Louis, MO 63166 Facility Name:
Callaway Nuclear Plant, Unit 1 Investigatio: At: Callaway Site, Fulton, MO Investigation Conducted: February 20, March 3-6, 23-27, 1981 Investigator: h d
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E. Fosur (Da te?
Inspectors:
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f.Hansen, Senior (Date;r e Resident Inspector Reviewed By:
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G. Fiorell:, Chief V
(Dated Projects Branch 2
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"'.'s A i-J.l Streeter, Acting Director (Date)
Enforcement & Investigation Staff Investigation Sunraarv:
Investigation on Februarv 20, March 3-6. 23-27
- 1981, (Report 50-483/81-04)
Areas Investigated: Special, unannounced reinvestigation of a previousIf invest-igated allegation relating to an accumulator discharge line pipe crack; review g$l'1 g4
k of records, interviews of personnel, inspection of weldments, review of radio-graphy. The investigation :nvolved 88 investigation-hours by three NRC perscnnel onsite, and additional in-office review.
Results:
In the areas inv stigated, one item of noncompliance i.s observed relative to radiographic examination. Nonconformances in the p pe piece in question had been identified rod corrected as required. Exami ations showed the pipe _to be acceptable.
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A REASON FOR INVESTIGATION During late 1979, NRC Region III (RIII) 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 (Exbibit I).
By letter dated February 8, 1981, (Exhibit II) the alleger infor2ed 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 to expand upon the matters previously investigated.
SLMMARY 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, excessive weld " fall-through", and containment wall penet rat 2cn cic-sure plate weld configuration. A handwritten letter from Individual A dated April 19, 1980, (Exhibit III) is lirited to a discussion of a " pipe crack" and " excessive fall-throurb The scope and content of the initial Investigation and Investigation Report No. 50-;83/80-10 appeared 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 cen-clus2on 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 transmittal letter which had been intended to be sent to Individual A.
Regarding accuracy, four errors in the report were identified but were judgeo to be ins 12nificant.
a Based on the information coetained in the February E 1981, letter from the alleger, the present icvestigation 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 C
type of plate utilized, weld procedure records, vendor radiography, fabrier* ion
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records, receipt records, Nonconformance Reports and vendor correspondenc - _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ - _ _
6 Visual inspcetion of the weld was performed, measurements 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 reinforcement.
The Region III interpreter concluded that the radiographic record indi:ated 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 Mectrnical Engineers (ASME) Code criteria.
This nas considered an item of noncompliance w2th 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 might 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 Nonconfor=ance Report concerning the original excess weld reinforcement condition indicated that the Architect-Engineer (Bechtel) had incorrectly interpreted applicable Code requirements relating to which Section of the Code was applicable and returned the report without dis-position.
Howeve-the defect was removed via a site-initiated Deficiency Repert.
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.
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s 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, hanager, Nuclear Construction Dan:e1 International Ccrporation
- A. Arnold, Project Quality Manager P. Bohnert, QC Technician, Level III D. Council, Technical Services H. Dameron, QC Insp ctor E. Fluet, Radiograpner T. Massey, J. Prince, fcreman
- H. Sta rr, Project Manager
- D. Stites, Proj ect QC Manager W. Sykora, Assistant Project Manager Bechtel Power Corporation (Bechtel)
H. Scrda, Project Engineer, Plant Design V. Cherish, Site Plant Design Liason
- 3. Lulla, Group Supervisor, Piping and Valves Hartford Steam Boiler Insurance Ccepany H. Pctter, Authorined Nuclear Inspector Indniduals Individual A Also contacted were other Jicensee and contractor personnel, including craf tsmen, QA/QC, technical and engineering staff members.
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- At
- 13d site exit interview March 27, 1981 2.
Scope and Chronology i
The investigation focused on the acceptability of the manufacturer's seam welding on a section of piping included as part of the discharge line for l
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o discharge line for accumulator tank TEp01A.
Included were reviews of fabrication procedures, design documents, quality documentation (incluc:ng manuf acturer seam radiographs), nonconformance reports, inspections of the in-place spool piece, and interpretation of a current seam weld rad:o-graph. Measurements of pipe ovality were also made.
A partial chronology of the manufacture of the pipe piece, site ident:fi-cation of deficiencies and corrective actions, and initial ond present NRC investigation efforts are included as Exh: bit V.
This report is essent: ally in chronological order of occurrence.
3.
Introduction The emergency core cooling system (ECCS) is designed to cool the reactor core during ace: dent conditions. Major components of the ECCS include the accumulators, refueling water storage tank, boron injection tank, boren :njection surge tank residual heat removal (RRR) pumps, centri-s figual charging pumps, safety injection pumps, boron injection recircula-tion pumps, RER 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 reacter coolant system). During normal operation, each accumulator is isolated from the reactor coolant system (RCS) by two check valves.
The des:gn 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 :nto 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 ever*
of a design basis accident.
Accumulator tanks and discharge piping are required to meet American Society of Mechanical Engineers (ASMI)Section III, Class :
requ:rements (19'4 Ed:t:on with Winter 1974 Addenda). As the piping is exposed tc d:fferent pressures and temperatures along its length (due to the location of isolating valves) several different pressure classes of piping are l
involved.
The spool piece in question, 5002, is Bechtel Class BC3 pi :ng (Pressure class 3, Mater:a1 Class C, Code Class B = ASME III, Class 2).
l Des:gn pressure and t*cperature 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.
Dimensious for such pipe are 10.75 inch uter diameter and 8.75 inch inner diameter.
l During manufacture, installation and usage of nuclear safety-related piping, various Codes red Standards are applicable.
These Codes cover design, materials, fabrication, installation, inspection, aed repair.
The following Codes and Standards apply to spool piece S002 (as well as other Standards referenced in those listed):
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American Society For Testing and Materials (4STM) A-240 (Plate material)
ASMI, SA-353 (1974) (Pipe manufacture, weld process, inspection material, tests, dimensions)
ASMI, SA-540 (General requirements)
ASME Section III Class 2, NC (Materials) t.SME Section III, Class 2 (Components)
ASMI Section XI, (In-service inspection requirements) 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. 249e2.
Other pieces were manufactured by a diff? rent manufacturer.
The original purchase order for 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 Secti'n Ill."
The original pipe piece was manufactured (plate bent and seam welded) at ARMCC Steel Corporation, Advanced Materials Division, during late 1977.
Stainless steel type 304 in the form of ASTM specification SA-24C plate and Weld Procedure No. 5, Revision 1, were utilized. Weld Procedure No. 5 is a submerged are welding (SAV), 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 we!i (2C feet) was radiographed during September 15-16, 1977.
The manuf actured pipe was sold to Guyon Alloys Incorporated and subse-quently scid to the Dravo Corporation, Pipe Fabr: cation Division (Drave).
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 fabricatien of spool piece 5002. 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 Dravc to manufacture the completed spool piece.
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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 requirea periodic inservice inspection.
5.
Discovery of Nonconformances The spool piece was received on site and the receipt inspection detected no shipping damage.
7
It 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 ofi-tenter, and that seam Peld de-ficiencies were called to his attention by welder whose ideutity he did not kn ow.
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 vis performed on April 26, 1979. This examination showed minimum wall violations involv-ing approximately a quadrant of the pipe.
A Nonconformance Report (NCR 2SN-OL96-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.
Phetographs 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 FOO4 pending disposition of the two Nonconformance Reports.
6.
Disposition of Nonconformances The Nonconformance Report (NCR 2SN-0496-P) documenting the minimum wall violation was dispcsitioned by Bechtel as "use-as-is."
The basis for thtt conclusion was a calculation utilizing design conditions wnich derived minimum wall thickness for the pipe class and pipe diameter.
RIII representatives discussed this calculation and its basis with Bechtel Engineers B. Lulla and H. Borda via telecon on March 6, 198:.
Minimum wall had been calculated as described in ASME Section III l
Divirien 1, Subsection NC (Class 2), Article NC-3600, " Pressure Design of Piping Products" Bechtel personnel advised that twc 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 syste=,
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 0.314 inches and was there-fore acceptable. The disposition of the NCR appears to be both acceptable l
and conservative.
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The Nonconformance Report (NCR 2SN-0501-P) documenting overlap 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 Nonconiormance Report without disposition is not equ: valent to e 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 June 1:
1979, Bechtel letter addresses both observed nonconforming conditions, excessive weld reinforcement and overlap (See Exhibit B of Investigation Report No. 50-483/BO-10). The pa ragraph regarding reinfcrc- -
ment height requirements appears to be incorrect in that it refertaces sections of ASME !2I, whereas Paragraph 5.2.3 of material specification ASME SA-355 she sid have been identified as the applicable spec:fication 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 references ASME Section III, Paragraph UV-51 (b).
SA-358 references ASMI Section I, Paragraph PW-51.
The reference to ASME Section VIII is likewise in error asSection 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" as a rejectable condit:en 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-ante indicated that they fe;t that ASME Section III was the governing Code, superseding aspects of ASME Section II and material specification SA-35E.
As the weld in question is a vendor longitudinal seam weld, this conclusion is incorrect.
The relevant Code for such vender (pipe manufacturer) welds is SA-358.
ASME 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 censidered a significant nonconformance since it can be relatively easily removed by grinding if necessary.
They also noted that reinforcement be:ght interpretation difference (ASME III vs SA-358) was 1/16 inch.
The review performed during this.nvestigation indicated that the weld reinforcement defect, if uncorrected, would have been an unacreptable i
condition.
While, as detailed later in this report, the nonconfe: ming condition was corrected prior to installation of the spool piece, it is of concern that the Architect-Engineer's failure to disposition the Nonconfor=ance 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 correc-tion of either suspected er actual deficienclos in supplier material or equipment", and " nonconforming items shall be dispositioned as " rework" wher the applicable specification 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 le 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 concoe.formance without disposition. They stated that several discussions with Bechtel pe r s onnc '. followed this letter.
On September 6, 1979, the NCR was superseded by DR 2SD-0699-P (See Exhib;t B of Investigation Repcrt No. 50-483/S0-10). While the description of the nonconP,rmance dif fers slightly f rom that in the superseded NCR, the same conditions are described.
Both the NCR and DR originally had photographs of the origi al weld condition attached. The photographs did not copy well and were n 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 reinferce-ment, and the remaining reinfercement was considered acceptable.
7.
3eview 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
- .o and responses from Individual A were re-viewed. Discussions were held with the inve=tigators who took part in these contacts.
RIII Investigator James McCarten was the original contact tith Individul A.
His notes indicate that Individual A, then working at the Wolf Creek
construction site, discussed concerns related to both the Wolf Creek and Ci.'laway sites.
By memo dated November 9, 1979, Mr. McCarten documented this conversatsen, and concerns related to Wolf Creek construction vere referred to NRC Reglen 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 ubile working at the site be 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 ne informed his supervisor regarding the crack in the welo 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 assurtace personnel of the defect in the weld.
The alleger did state a " hold" tag was place on the pipe for a short period of time, but it was later removed."
Since the allegations, even if substantiated, did not indicate an immediate threat to the public and since there was no concern about perishability of evidence, the investigation was performed af ter other priority investi-gations.
The investigatins 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 kn own. Following repeated attempts, Mr. Burten was.ble 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-tien of the pipe and seam weld.
Individual A also stated that he felt the pipe was " distorted at the sesm" 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 rel ted 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- __
o ual A marked and returned the isometric drawing which was received at RIII on April 19, 1980. Attached was a handwritten note (Exhibit III) describing the location and coadition he believed to exist.
The note and diagram are in error as to the present orientation of the longitedinal seam weld.
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 indica ted that he had observed the spool piece prior to installation and the spool piece was in a different position at that time.
All of the notes of telephone contacts and written communicat:ons appear to indicate that the central concern originally expresset dealt with a crack in the seam weld on spool piece S002.
8.
Review of Previous Investigatien 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 r.eview as fellows:
The alleger is characterized as presently being a welder at the a.
Callaway site.
By his statement, he left the Callaway s:te some-time in August 1979.
b.
The "15 welds" section is mischaracterized. The piping isometr:c included as Exhibit A shows the 15 welds coanced. 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, "ay 5. 1979, is in error.
c.
The ANI review took place on May 5, 1979, but the NCR ndicates it was init:ated on April 30, 1979.
d.
The date noted for the initial contact with Individual A may be in Investigator McCarten s notes indicate October 15, 1979, as error.
the contact date.
None of the above errors are viewed as having any sign:ficance to the alleged " pip-crack" which was the focus of the report.
Initial visual inspections cf the two accumulator lines were made due to lack ot infor-mation as to the specific location of the alleged pipe crack.
Interviews were held with those individuals alleged to be knowledgeable.
As rated in the initial report, when the specific lecation of the weld a'.eged to be cracked was determined, the area was tested by liquid penetrant examination, an accepted test for a surface crack. No such crack was indicated.
The liquid penetrant examination was documented 12 -
bcth in the original investigation report and in IE Inspection Report No. 50-483/80-15 (E).hibit VI ).
9.
Letter to Individual A On July 15, 1980, a letter was drafted to transmit the original investi-gat:en report to Individual A and discuss the review of containment liner penetration closure weld configuration (Exhibit VII). Due to an admin:strative oversight, this letter was not sent.
10.
Contact With Representative Fiegenbaum On January 23, 1981, information was received to indicate that Missour:
State Representative Robert Fiegenbaum (Chairman, House Energy Committee) had been contacted by an ind:vidual who indicated that unacceptable piping was present at the Callaway construction site. On January 28, 1981, Investigator G. Philli" 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 he felt the ori-ginal investigation of his concerns was inadequate (Exhibit II).
This letter indicates the following concerns:
An improper eld procedure had been utilized on accumulator piping.
a.
The pipe is unacceptatly out-of-round.
o.
The acceptance of a minimal wall violation was improper (contrr.ry c.
to Code Requirements).
d.
The pipe seam weld is cracked.
The pipe seam wcli rainforcement is higher than allowed by the applic-e.
able Code.
f.
The pipe is unacceptable due to the above ncted defects.
The letter :entained comments critical of the original investigation and a total of 'orty-eight questions. By letter dated February 26, 1981,
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RIII advised Individual A that his concerns would be addressed and answers provided to the questions he had asked (Exhibit VIII). The response to t
individual A's letter is attached as Exhibit IX.
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12.
Review of Nonconformances A review of Nonconformance Feports related to the pipe piece in question was performed as previously detailed in Paragraph 6 of this report.
These reports and their dispositions appeared acceptable except as noted.
A portion of each of the related nonconformance dispositions indicated that the vendor would be notified by Bechtel of the observed deficiency.
RIII personnel were advised the documentation of such notification was available on site and this is considered an unresolved item not (483/31-04-01).
13.
Disea sion With ANI On March 6, 1931, a discussion was held with Mr. Howard Potter, Authorized Nuclear Itspector (Hartford Boiler Insurance Company). He stated that he was unaware of any uncorrected nonconformances on spool piece 5002, and he had o n 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 Re'. l es of Vendor Radiographs on March 6, 1981, file radiographs for the vendor seam weld we.
acined by NRC Inspector W. Key, a Level III radiograph interpreter.
The vendor radiographs covered all twenty feet of the original pipe m were considered acceptable with one exception. At film markers 13-14 an area of excess reinforcement was evident.
Thts area was not at the pipe end (later cutting and fabrication 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 exae:1y.
This was the crea noted on NCR 2SN-0501-P The reader sheet for the vender radiograph indicated " wash v.:t" at film markers 13-14 and probable undercut.
The reader had marked the defects as acceptable and approved the radiographs. No note as to t.cditional inspection was included with the reader sheet.
The condition at film markers 13-14 appears to be a rejectatle condition.
The NRC inspector identified apparent incomplete fusion and excess weld reinforcement.
It is possible that the additional weld reinforcement l
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could have masaed weld defects at these points. Apparently, those who subsequently reviewed the radiogg aphs 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 Inspector, had visually inspecteo the weld area and a liquid penetrant test had shovn 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 questions 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 ASMI Code accept-aD111ty, placed into the vendor seam weld radiograph file for the weld in question, and referenced in that file.
16.
Pipe Eiameter Measurements Visual inspection of spool piece S002 and the pipe piece in question (5P) did ret Indicate any noticeable ovality.
On March 6, 1931, RIII personnel made outside diameter measurements at a location approximately 14 inches away from field weld F004 on spool piece S002.
These were rough measurements made utilizing a non-direct reading caliper and tape rule.
following diameters:
Measurements in three planes yielded the 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 interpretatice of various sections of the ASMI Code it was determined that the outside d.ameter measurement on the pipe seam weld was inappropriate due to the it.clusion of allowable weld reinforcement (allowable reinforce-ment is 1/8 inch or 0.125 inches). -
/ second set of measurements were taken at the same location by licensee 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:
10.75S 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 ASMI SA-358, Class I (1974), allows an outside diameter variation of 1%.
As the pipe is 10 inch schedule 140 pipe, has a standard outside diameter of 10.75 inches, and a variation of it 0.1075 inches would be allowable per SA-358.
was considered acceptable.
The ovality of the pipe 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 fe-double welding of the metal and thickness involveo.
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 more 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 a;ter diameter weld (See Paragraph 4).
b.
Concern: The pipe is substant: ally out-of-round.
Findings: Visual inspections and measurements of the pipe show acceptable ovality The comment on excessive ovality apparently came free 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 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 vendor prior to machining counter-bore" This was the inspector'- conclusion, and appears to be at _ ~-
least partially valid. However, as shown by the ultrasonic exaiuina-tion report attached to the NCR, it also appears that the counterbore centerline may have been 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 in the minimum wall violation (See Paragraph 16).
part 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.
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"T measure =ent area L
a s:andard pipe wall w ou n t e'ib ore d'a re a "inimu= wall calculations utilized to disposition NCR 2SN-0496-P appear to meet Code requirements and were acceptable, as detailed earlier in th s repo * 'See Paragraph 6).
d.
Concern: The pipe seam weld is cracked.
Findings: None of the visual nor nendestructive examinations con-ducted indicated that the seam weld on pipe piece No. SP contains a crack anywhere along its length.
Photographs of the weld conditian 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 ucw 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 acceptable. The original NCR dealt with weld seam reinforcement height only in the limited area adjacent to field weld F004 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..
18.
Overview The weld condition of the small section of the origional pipe was considered acceptable by the ARMCO radiographer and subsequent radic-graphy reviewers.
Spool piece S002 was fabricated and sent to the Callaway 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 hew 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 A11eger
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Individual A was contacted by telephone on April 20, 1981.
He expressed dissatisfaction 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.
Dur:ng additional telephone discussion on April 22, 1981, Individual A indicated that he had reviewed Callaway-related documents in the Public Document Roo=.
Among the documents he reviewed were Inspection and Enforcement Bulletins 79-03 and 79-03A.
These deal with defects ident:-
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 inccrrectly 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 XII).
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, 1979, November 26, 1980, August 20, 1980, and January 26, 1981.
21.
Concern Related To Bulletin 70-03A During telephone discussion Individual A stated that he believed Bulletin 79-03A (required action No. 3) imposed mandatory etching of all safety-relat.t.i pipes manuf actured according to SA-312, and he had not found any indication this had been accomplished by SKUPPS facilities...
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 be used in which stresses exceeding 85% of the Code allowable had been identified at their facilities.
would not be required by Bulletin 79-03A.
Therefore, etching 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 ecceptable 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 Licens4.ng 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 petittor cas 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, Pa rt A through 'd, duplicates the questions posed by Individual A in his letter of February 8, 1981.
I 25.
Media Contacts Several contacts were received concerning this investigation from media i
personnel who had been contacted by Individual A.
i :
Attachments:
Exhibit I, I&E I vestigation Rpt. No. 50-483/80-10 Exhibt: II, Ltr of complaint dtd 2/8/81 Exhib:t III, Handwritten note by Ind. A dtd 4/19/80 Exhibit IV, Ltr to Ir~,. 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 Exh: bit XI, IE Bulletin No. 79-03 Exh: bit XII, IE Bulletin No.79-03A Exhibit XIII, NRC memo dtd 4/9/80 f
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CLEN E LLvN. 4LLINois 6o137 n
JUN 10 980 a
6 Docket No. 50-483 Union Electric Company ATTN:
Mr. John X. Pryan Vice President - Nuclear Post Office Box 149 St. Louis, MO 63166 Gentlemen:
This refers to the investigation conducted by Messrs. R. M. Burton and V. A. Hansen of this office on March 26-27, and.h y 2, 1980, of activi-ties at the Callaway Nuclear Plant, Unit 1, auth,.,rized by.Wr.C Construc-tion Permit No. CPPR-139 and to the discussion of our findings with Mr.
V. H. Weber, Manager, Nuclear Construct:en and others of his staff the cond esi:n of this investigation.
at The investigation related to allegations which are identified in the enclosed ecpy of our investigation report.
No ite=s of nonc:mpliance with NRC requirements were identified during the course of this investigation.
In accordance with Sectica 2.790 of the NRC's " Rules of Practice," Part 2, T:G e 10, Code of Federal Regulations, a copy of th:s lette:
and the enclosed inspection report will be placed in the NRC's PAlic Document Room, except as follows.
If this report contains information that you or your contractors believe to be proprietary, you must apply in writing to this off:ce, within twenty days of your receipt of this letter withtc1d such infermation from public disclosure.
to The applicaticn must include a full statement of the reasons for which the infarmation is con-sidered proprietary, and should be prepared so that proprietary informa-tion identified in the application is contained in an enclosure to the application.
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We w:ll gladly discuss any questions you have concerning this 1
3avestigat:on.
Sincerely, f
Jaces G. Keppler Lirector
Enclosure:
IE Investigation Report No. 50-4E3/50-10 cc w/ encl:
Mr. V. H. Veber, Manager 3
Nuclear Construction Central Files Keproduction U::t NRC 20b PDR j
Local PDR NSIC TIC Regi:ns I & IV Ms. K. Drey Mr. Ronald 71uegge, Ut:lity Div:sien, Miss:uri Public Service Commission t
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4 U.S. NUCLEAR REGULATORY COSISSION OFFICE OF INSPECTION AND ENP0hCE.T NT REGION III i
5 Report No. 50-483/SO-10 Docket No. 50-I.83 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: March 26-27, and May 2, 1980 Investigation At:
Callaway Site, Fulton, M0 Investigator:
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Febert M. Surton In estigator (Date)
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William A.
Hansen V(.
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Resident Inspector s.
Beviewed By
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Assistant to the# Director f(/'W()
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Investi gation Su:=.a rv Investigation on March 26-27, and May 2, 198C
_(Repo r t No. 50 -5 3 ' E0-10 )
Areas Investigated:
Investigation was conducted into an allegation of t.he detection of a weld crack in a section of stainless steel pipe feading from an accumulator tank.
Twenty-one manheurs were spent on the investigation involving one inspector and one investigator.
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Results: The allegation was not substantiated. No items of noncom-t P11ance were identified.
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REASON FOR INVESTIGATION On October 11, 1979, Daniel's Construction Company e=ployee atthe Region III office received a phone call f the Callaway Nuclear Plant. He alleged that he had detected a crack in a
, vicinity of the accumulator tank.
stainless steel pipe weld in the He further stated that he inf ormed h2s pupervisor of the weld crack, however the supervisor was reluctant it to quality assurance personnel.
to re, port
SUMMARY
OF FACTS On October 11, 1979, questing that his identity be keptan allegation was received by phone from a person re-ettfidential.
This alleger stated he was a welder at the Callaway Nuclear Plant, and while employed there had detected a three quarter inch crack in a weld located near a valve in a fifteen foot long section of stainless steel pipe running from under an accumulator tank.
the crack, however his supervisor was reluctantHe further stated that he informed his to inform quality assur-ante personnel, because he was of the opin:on 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 encempassed in the area described by the alleger.
Visual inspections of the f:fteen welds were conducted in-dependently by both the NRC resident Qual:ty Control inspector.
inspector and a Daniel Internat:enal of the welds inspected.
There were no visible cracks detected in any of welding operations during the course of the welds'Two foremen, who were determine completion, were quest:ened as to their rece:ving 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 cocpari's employees ever reporting a weld crack to either of them.
Subsequent contact had been in contact with the alleger.from reporters of the Witchita Eagle revealed they 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 locatzen on an isometric drawing cf the accumulator tank area which was = ailed to the alleger and returned to the NRC.
This description of the location indicated that crack was on the inside of the pipe on a longitud:nal seae weld, ratherthe than on an outs:de surface weld as originally suspected.
A Deficiency Report and a related Noncompliance Report were secured for the location described by the alleger. These documents showed a repa:r 6f a weld overlap at of excess reinforcementthe describei location was made by grinding an area and poor tusion in November, 1979.
On May 2, 1980, a liquid penetrant test was conducted on the area of that repatr and no cracks were detected. The excess reinforcement was also measured and found to be within ASMI welding code tolerances (" fall through")
2 Exhibit I Page 4 of 21
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No stems of nonese.p12ance were,dentified during the conduct of this in-vest gation.
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DETAILS 1.
Personnel Contacted j
Un:en Electric Company i
I M. I. Doyne, General Superintendent, Callaway Construction i
F. D. Field, Manager, Quality Assurance J. V. Laux, Assistant Engineer, Quality Assurance R. L. Powers, Supervising Engineer, Quality Assurance V. H. Weber, Manager, Nuclear Construction Daniel International (Contractor)
J. R. Cook, Manager, Quality Control J. A. Holland, Manager, Project Quality Assurance T.
V. 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 centractor personnel, inclucing craftsmen, QA/QC, tech-nical and engineering staff me=bers.
2.
Introduetto:
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 he had detected a crack in a stainless steel pipe weld in the vicinity of the accumulator tank.
He further statec that he in-fermed his superviser of the we'.d crack, however, the supervisor was reluctant to report it to quality assurance personnel.
Prior to the ialtiation of the on-site investigation on March 26-27, 1950, efforts to recentact the alleger in an attempt to secure a more accurate location of the alleged w: 1 crack were unsuccessful.
3.
Alleration 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 stal..less steel pipe that ran from under an accumulator tank.
He further stated that his supervisor was reluctanthe informed his supervisor of the crack, however, to inform qual 2 y assurance personnel because he was of the opinion the weld had already been accepted.
i Tindine - An on-site investigatien was made on March 26 and 27, 1980.
Based on the description of tne location of the weld crack supplied by the alleger, it was determined from the piping isometrie drawings that a total of 15 welds (both vendor and field welds) were encompassed.
4 Exhibit I Page 6 of 21
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(Exhibit A - Location of Welds Inspected).
(Tield 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 velds 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 veld defects, rather than external weld defects (i.e.,
surface crack in veld).
Based on these records, the possib:lity 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 Res: dent Inspector (using a low power magnifying glass), and by a cert:fied Daniel International Quality Control inspector (visually unassisted). These inspections were conducted in a =anner which allcwed each inspector to conduct a separate and independent in-spect:en of each weld invclved. During the course of these inspec-tions, no visible cracks were detected in any of the welds (f: eld or vender).
It was further ascertained that two feremen were in charge cf welding operat: ens in the "15 weld" ac:u=ulator tank area during the course of the welds' complet:en.
J. D. Prince was in charge of welding operations fro.? 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. Pr:nce and T. W. Linder were interviewed as to whether either cf 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 repcrted, or ever exist ing.
On April 8, 1980, the NRC Resident Inspector was contacted by Gary Hayden, a reporter for the V:tchita Eagle. Hayden nformed 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 Nuclear Plant.
The description suppl:ed by the:r source was con-sistent with the one received by the NRC on October 11, 1979, except that the crack was described as "in a seam weld on the ins:de of a stainless steel pipe" running from an accumulator tank.
3 Exhibit I Page 7 of 21
Both Hayden and Charl:p were contacted by telephone and they ver:-
f2ed th:s allegat:en.
They declined to d:sclose the identity of the:r source, but stated the:r source would be requested to contact the NRC.
~
i On April 11, 1980, a phone call was received from Hayden's source who ident:fici samself as being the same person whc made the Callawa.
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weld crack allegat:en to the NRC on October 11, 1979. He furnished a description of the crack ind: eating it was in a seam weld on the inside of a sta:nless steel pipe running f rom Accumulator Tank Tepo IA.
The alleger agreed to mark the location of the crack on a copy of the :sometric draw:ng and return it to the NRC.
A copy was ma: led to him for that purpose on April 11, 1980.
On Apr:1 14, 1950, the NRC Res: dent Inspector obtained a NCR dated May 5, 19'9 and a subsequent DR (Def:ciency Report) dated Septe:ber 6, 1979 for the pipe fitting the alleger's description and location.
(Exh:b:t B - Def:ciency and Nonconfor=ance 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 overler (a condition which has been known to be visually interpreted as a crack, since it has-a s :ilar appearance).
This repair was made in the longitudinal sea weld of the 5302 piping at weld 700' on November 5, 1979.
On Apr: 1 23, 1950, the isometric drawing was received by the NRC frer the alleger w:th the locat:oc of the weld crack indicated.
(Ex n.- t : t C - Isometr:c Drawing =arked by alleger). A leu.er from the alleger transmitt:ng the drawing, stated the crack was apprcx -
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 sea =
weld frc the 45 degree p:pe elbow to weld F004 Subse; ent visual examination by the NRC Resident Inspector revealed
~
that the gr:nd n; repair indicated on the Deficiency Report had been performed :n the area of the alleged weld crack beg:nning at the end of the pipe at weld F004 (which had not yet been completed) and ex-tending appr:ximately I' inches inward.
Oa May 2, 1980, the NEC l
Resident Inspector observed wh:le a Daniel Quality Contr:1 Inspector
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performed a 1:qu:d penetrant test on the area of repa::. No cracks j
were detected by tha NRC Inspector or the Quality Contrcl Inspector.
The remain:ng reinforcement (" fall through") in the pipe was measured and f;unc to be w:tn:n ASME welding code tolerances.
Management Discussion
{tthecompletionoftheinvestigationthefiriingswerddiscussedwith D. Field, Manager UE Qual:ty Assurance, J. V. Laux, Assistant Engineer e.
UE Quality i.ssurance, W. H. Weber, UI Manager of Nuclc ir Constraction, J. R. Cook, DI Quality Control Manager, J. A. Holland, DI Project Quality Assurance, H J. Starr, DI Project Manager, and V. L. Sykora, DI Assistant Pro;ect Manager.
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! l Exhibit I l
Page 8 of 21
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They were advised no items of concomp!:ance were identified during this investiga' son.
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Mr. Gerald Phillip United States Nuclea.r Regulatory Commission gegion III 799 Roosevelt Road Clen Ellyn, Illinois 60137 Doar Mr. Phillip: After reading NRC Report No. 50-483/80-10 in mid-December lee 0, I real::ed that my phone calls to the Region III office had failed to communicate my concerns about pipe installed at the Cc11away Nuclear Power Plant. I also realized that I needec to yrite 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 below the minimum wall and had rejectable weld defects on the inside of a longitudinal seam weld. I believed that all of these problems care caused by an improper welding procedure used in manufacturing the pipe. The weld appeared to be a eingle welded butt joint inwhich the root pass had fallen through. By fall through ! m2an that the internal weld bead drooped down or protruded into the pips an excessive amount and did not fuse uniformly into the plate surface. Succeeding filler passes over the root pass hac 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 ond of the spool piece where a check valve was to be installed. From 13 years experience la welding I believed these were rejectabk d3fects, especially when the pipe was being installed as a Class II safety-related component in the Emergency Core Cooling System di a nuclear power plant. I fn May of 1979 I reported the defects to a reactor area Qualfty Centrol I.spector and my immediate gupervisor. The pipe ht Exhibit II Page 1 of 11
t a hcId tag placed on it for the minimum wall violation and several persons came from the office to look ac the pipe. I talked to several credible and responsible persorc aoout the pipe. (I gave their names and positions to the Region III office in the phone calls of October ll, 1979 and April 11, 193I.) According to my understanding, from conversations with these persono, several factors were involved in the decision-making process. They are as follows: 1) The pipe had been approved for installation by Union E;ectric and had passed through the quality assurance programs of the pipe's manufacturer (known simply as " Youngstown") anc the fabricator of the spool piece (Dravo). 2) The Daniel International Corporatica was not responsicle 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 wcrtn 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 wculd nct affect the function of the pipe; tnat tne crack, or cracks if there were more, were on the internal surface and wculd not grew in size. I left Callaway before a final decfsion was made, and I assumed that the preelems with this piece of pipe would be resolved withtn the limits of the American Society of Meenanical Engineers code. Several months after I left Callaway I heard that the pipe in question was approved for installa tion "as is". I use surpise; by this and called the NRC Region III office to express my concern. The :;nC insestigated and wrote Report No. SC 483/50-1C. The report did not seem to address my concerns but instead it seemed to otfuscate the deficiencies, especially as the;. relate to tne ASME code. The ASMI code is an essential instrument used to ensure tne safety of nuclear power plants. If ne standards of the ASME code are ignored or misapplied we are inviting a disaster. Exhibit II Page 2 of 11
SU." MARY OF COMMENTS ON THE NFi R E F ~,, i i I called the NRC Region Ill office to express concur over a substandard piece of pipe I saw being installed in the , Emergency Core Cooling System at the Callary Nwc 2 c or Fo. e r Plant. Tne NRC investigated and wrote a report wnlen cone..ced 6 ,tbat, "Che allegation was not substantiated. Nc iten s of noncompIla nc e were identi fied. " In arriving at it.i s ccr.c ; as; on the NRC appeared careless and negligent in several areas o: '. heir investigation. The NRC report made erroneous, misleading or incomplete state ents whien were as follows: 1) The report limited my concern to one 3/4 in. crack and did not state very completely the sucstance of what I exp.essed over the phone. 2) The report misquoted me in saying that my " super-iser was reluctant to inform quality assurance personnel". 3) The NRC did not examine all the welds the report ir.p l i e d they examined in the Merch 26 and 27, 1980 investigation. The NRC accepted, without much scrutiny, statements and documents from the involved c0mpanies. Instances of tnis are as fcilows: 1) A letter frem Mr. Turdera, Bechtel's Project Engineering Manager was the basis for downgrading a nonconformance report to a deficiency report. The letter ignored appi:cacle paragraphs of the ASME code and misappiled other paragra;n.= of the ASME code. 2) The NFC accepted the downward recalculation of a safety-related einimum wall specifica tion wi thout sucsteq 1ating wnetner or not the recalculation complied witn the requirements of the ASME code. In the docume nts presented with the report, possitie code violations were indicated which the NRC did not investigate. 1) A deficiency report, Exibit B page 1, referenced ASME see:1on II SA255 para. 5.2.3. Violations of this paragraph a were never investigated. 1 i i 2) A reference to ovality in the pipe was made in a non-conform.ance report, Exibit B page 3. This could be a i violation of SA 358 para, 15.1.2, but this was never investigated. l l Exhibit Il Page 3 of 11
The report did not supply informaticn relevant to tne investigatior.. i 1) The statement (page 6) that, " the remaining rei nforcer./.nt in-the pipe was measured and found to be witnir. ASME welding code tolerance =", was not documented. No insiteetion report of this measurer.ent was included in the exidits. 2) The names of the spec 1 piece vendor and pipe manufacturer were not included in the report. The' NRC overlooked vital documented evicence. 1) The radiographs (X-ray pictures) of the weld in questien were not examined. i i i i } i "4~ Exhibi: II i Page 4 of 11 L ..... -.. -. - - - - - - -. - - - - - - ~ - - - - - - - - - - - - ~ ' ~ - - - ' ' - ~ ~ " " ~ ~ ~ ~ ~ " ~~~~'
DETAILEO COMMENTS AND QUESTIONS I weald now like to comment on particular sections of the re;crt cnd esx specific questions. I would like the NRC to:answcr these Quest 1 ores in written form and send me a copy, s elleration page 4 6 This paragraph states my concern over o' 3/4 in, crack but neg'I.ects to mention the fall througn, (refered to in the report as " overlap" and excess reinforcement), the distortion of tne pipe, the minimum wall violation, and the possible existence of other substandard pipe. I would not have called tne Nh; over one isolated crack, which could easily be ground out. The condition of the pipe that caused the crack indicate: an improper welding procedure and that concerned me. The fact that the quality assurance programs at two different companies hod apparently failed, concerned me. Even though solte of these items were indirectly addressed in the exibits, I believe tney scnuld have.been included in the allegation section. I did Ottempt to communicate these items over the phone in the Octocer 11,1979 and April 11, 1980 calls. I de rot recall ever saying my supervisor was reluctant to $nfarm tuality assurance personnel. My statements refere: to tre company, as a whole, being reluctant to acknowledge the existence of the defects, not my immedia te supervisor. Questions 1) Vere the phone cells I made to the Region III office on October 11, 1979 and April 11, 1980 electronic 1y recorded? 2) If tney were recorded may I listen to them or have a transcript? 3) M a.. I have a copy of the notes taken by Mr. Burton, Mr. McCartney or others who listened ir on the calls? FindinE,page 4 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; "yender welds are those welds made in the assemcly of the pipe (pither longitudinal or circumferential)". The welds marked apd numbered on Exibit A involve four spool pieces, i.e. S 0C1, S.002, S 007, and S 008. These four pieces were the subject of the NRC investigation on March 26 and 27, 1980. From Exibit A no can count - welds - 6 field welds, il circumferential factory walds, and 9 longi tudinal factory welds. The report gives the impression that all of the relevant welds from the piping isometric drawing were encompassed, including longitudinal walds. This was not so. Exhibit II Page 5 of 11
Questions 1) Why were only 15 welds inspected? 2) Exactly which welds were inspected and which were omi ttec i in the inspections made on March 26 and 27, Iva0. 3) Specifically, wha t efforts were made the exact location of the crack? to contact me concertir.g Alyo 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? FindinL 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. and ncn:enformances agree The descriptions of the ceficiencies in citing excess reinfer:ement, but they disagree in how they descrite anotner defect. The NCR calls the defect " overlap" and the DH states tnat, "tne vencer's longitudinal wel2... is not fused uniformly into tne ;;1 ate surface as requi.ed by Materiol Spec. SA 356, Para. 5.2.3". Cues 1cns 4 I) Is the NCR and the DR talking about the same defect? 2) Would " overlap" be a violation of Material Spec. SA 355 Para. 5.2.37 Exici E pages 7.and 8 NCR No. 2SN-05DI-P was downgraded to a DR based on a letter frem Mr. J.L. Turdera, Bechtel's Project Engineering Manager. In paragraph (a) of his letter Mr. Turdera deals witn the maximum allowable reinforcement and cites ASME Section III but ignores ASME Section II, listed as a " Controlling Document" in the NCR. Conce.aning maximum reinforcement, Section II SA 358 para. 5.2.3 states; "The joint shall be reinforced at the center of the weld on each side 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 Exhibit II Page 6 of 11
e of maximum reinforcement when it was li sted in the "Cc.;;Wling Documents"? 2) Vny didn't the NRC Resident Inspec tor question this whe-he received these documents on April 14, Iv8v? B) In the investigation that occurred on March 2L and 27, ; :., ( why didn't the investigators have these documents then, since they involved the pipe in question? Exibit B page 8 In paragraph (a), Mr. Turcera cites ASME Section III para. NC 4425.2. Article NC 4000 from which this is taken is tit;ed patrication and Installation and is not a material specification. Section III para. NC 2551 Retuired Exa-ination, states; " pipe made in accordance wi th... SA 356... shall be treated as material". This would make Section II SA 358 governing longi tudinal the basic controlling document seam welds in SA 358 pipe. Both the NCP (Exitit 3 page 7) and the DR (Exibit B page 1) agree in this and cite Section II SA' 358. Ouestions 1) Was Mr. Turdera correct in citing NC 4426.27 2) If yes, will you please give code references? Ex1 cit S page 3 paragraph (a) states that, "ASME Section III paragraph NC 4426.2 permits a maximum reinforcement o f 3 /16 "... for 1" double welded butt joints". The pipe used in spool No. 2-Ep-01-SOC 2, by visual appearance, was single welded. (SA 352 para. 1.3, the 1977 e:itior., shows that the pipe can be either single or doutie welded.) paragraph NC 4426.2 gives a maximur insice reinforcement of 5/32" for 1" single welded but: 1:ints. If the ptpe in question was single welde: it would not meet this requirement. Ouestions 1) Was the pipe in 2-Ep-01-SCO2 single or double welded? 2) What dccuments verify this? In paracraph (b), of Exitit B page 8 the letter states; "The SA 358 material specifica tion references the ASMI Code, Section III, paragraph UW-51(b)". I have not found such S reference in SA 358. The letter also oites; " paragraph UW-51(b) of Section VIII of the ASME Code". This reference also appears to be en error. Question I) Do these references exist?
- 7 Exhibit II Page 7 of 11
Exibit B, page 8, paragraph (D) deals with " overlap",a defect detected by visual examination. Acceptance criteria of we.cs exanined oy radiograpy is the wrong place to loox in tne AS::E code for a defect found Dy visual examinatirn. In Weldin;' Inspection, a book puolished by tne American Welding society, the fo;10 wing statement is mad 9; " Overlap is tne condi tion ar. 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 unde-lo.ac." ASME Section II SA 358 para. 5.2.3 states; rne contour of the reinforcement should be reasonably smootn anc free from irregularities. The deposited metal shall be fusec uniformly into the plate surface." Overlap violates tnis paragraph. Ouestions 1) Why didn't Mr. Turdera deal with " overlap" as a violation of Section II SA 356 para. 5.2.3? Exibit B, page 8, paragraph (b) mentions acceptance criteria for welds examined by radiography. The longitudinal seam welds in spoel piece 2-EP-01-SOO2 were radiog.aphec. 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 accessiele) and outside shall be removed by any suitable process to such a degree tnat the resulting radiographic image due te any irregular 1:1es cannot mask or be confused with the image of any discontinuity." Overlap is a surface irregularity that can rask or be confused with the image of a discontinuity. Tne overla; was accessiole prior to the facrication of the specI piece. This ASME code paragrapn seems tc nave been violatec. Ouestions 1) Why wasn't the overlap removed prior to faorica ting tne spool piece? i 2) How were the radiographs of the longitudinal weldo in spool No. 2-EP-Ol-SOC 2 correctly read and accepted with welc overlap? In paragraph (c) of Exibit B, page 8, several persons listed { there, " agreed tnat the pipe meets the coce recuirements and does not fall under NCR category". Questions 1) Did they base their decision on the information given in paragraphs (a) and (b)? 2) If not what did they base their decision on? I Exhibit II Page 8 of 11
3) Did any of these i ndi vi dua10 read the NCR and consider the requirements of Sectian II SA 358? 4) Was this letter a basis for the NRC report saying that, "no items of noncompliande were identiflec"? 5) Are there cases where ASME code violations in Class 11 piping do not fall under the NCR category? If yes please a explain. Find'inz tage 6 The fifth paragraph states; "The remaining reinforcement (fall through) in the pipe wss measured and found to be witnin ASME telding code to.'erences." Questions 1) What examination method was used in making this measurement? 2) At what intervals and over what length of the pi;,e were these measurements made? 3) Was the reinforcement measu."ed back to the 45 degree elocw? 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? Exitit E,page 3 This page is an NCE descriting a minimum wall viciation. The cause of the ncnconformance is given as, " ovality in pipe". ASME See:1cn II SA 358 para. 15.1 states; "Permissicle Variations - The dimensions at any point in a length of pipe shall not exceed the fcilowing:" and 15.1.2 states; "Out-cf-roundness - Difference between major and minor outside diameter 1 percent." Questions 1) After the ovality was noticed was the pipe checked fcr 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 g. Exhibit II Page 9 of 11
Exibit B,pages 3 cnd S Page S is an Inspection Report to determine the wall thickness of the edge prepera tion. It lists the ASME co: as the controlling L code and as the inspection standard. The NCH, grige 3, does not list the ASME code as a controlling document. Quest gns 1) Should the NCR, Exibit & page 3, list the Anr:E ce,Je as a controlling document? 2) Do Bechtel specifications take precedence over ASME specifi-cations? Exibit 3,pages 3 and S On page 3 under the heading, " Recommended Disposition and Bas's for Recommendation" is the statement, "Bechtel to determine that min, wall of.814 will meet design criterias"; and on page 4, Exitit 3, the statement is made that, "tne calculated i minimum wall thickness for 10" BC3... is.79E". Questions 1) What design criteria where used to deternine tr,is minimun wall? 2) What paragraphs of Section !!! were use: in this determination? 3) What pcragraphs of Section III were used in recalculating the minimum wall? General Cec ents +- Newhere in the report is the vendor of the speci piece named, ner is the manufacturer of the pipe. Their work was investigatec in the ';RC report. It seems fitting that they should be natt Cuestions 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, radiograpns existed which could have shown the existence of a crack prior to grinding, or they could have shown an abrupt density change (overlap) which could mask a crack. No mention was made in the report of these radiographs and presumably they were not checked. Exhibit II Page 10 of 11
i i Ouestions 4 J 1) Were the radiographs of the lon;itud:nal welds 3r. s, col f;e. 2-EP-01-SOO2 checked by tne NRC? 2) If they were what were their findi ngs? .It toca the T;RC over five months to investi,,ete u.y a23e.3;aor.. .In r.any cases defects could become inaccess1LAe i r. tnat u n.w r. ;. of, time. Questions l 1) When were Daniel International, Union Electric, Decntel, and SZ'.t?S first notified, formally or inforn.ially, 31 my allegations. l ) Every: Ming said in this letter is true to the best of my know-ledge an: celief. 4 i N Sincerely, l 4 d l l 11-Exhibit II t Page 11 of 11 ---9v, =--n ---c,--y .--.---ve.,,r.%.,-. .,,..----,,%-,,,-u%,.,,,.,,--_.,-,s ,.yr,---
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'i f 790 Coostvt 6Y ccAD ?# GLEN E LLYN.1LLINots 60137 -ee..* April 11, 1980 Dear Mr. Per our conversation on April 11, 1980, enclosed is a drawing of the accu =ulator tank area at Callaway. Please indicate the sea = veld involved and return the drawing in the enclosed envelope. Again I would like to thank you for your cooperation in this matter. Sincerely, ri$ \\ Robert Burt on j Investigator En:1:sure: as stated Exhibit IV Page 1 of 1
CALLAVAY ACCUMULATOR LINE SPOOL PIECE 3002 PARTIAL CERONOLOGY 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 Iovest vall measure =ent 4/27/79 NCR 2SN-0496-P, minimum vall violation 4/30/79 NCR 2SN-0501-P, overlap on longitudinal veld (B. Diggs, originator) 5/79 Individual "A" states he advised a QC inspector of " crack" (approximate) 5/5/79 Date noted in first report, it. error. Date of ANI concurrence on 2SN-0501-P 5/16/79 Dispostion of NCR 2SN-0946-P, use-as-is, reduced vall acceptable 4 5/31/79 Last date, 2SN-0496-P, hold tag removed. 6/1/79 Turdera le::er re: NCR 2SN-0501-P, "no: fall under NCR category" S/79 Linder is fore =an of accumula:or piping area welding 5/79 Individual "A" leaves work at the Callaway site 9'6/79 DR 2SD-0699-P ini:ia:ed (overlap), NCR 2SN-0501-P superseded 10/11/79 Phone call fro: Individual "A", Callaway and Wolf Creek cen:e rms 11/5/79 Grinding of sea: veld per 2SD-0699-P, re=cval of excess veld reinferce:ent 1 11/9/~9 Meme to File (McCar:en) documents call of 10/11/79 11/15/79 2SD-0699-P signed as co:pleted (grinding completed and inspec:ed) 11/19/79 Final signature date on 2SD-0699-P 3/24-25/SO At te= pts to call Individual "A", no success 3/26-27/B0 Investigation en si:e at Callaway (initial investigation) 3/27/80 Linder interviewed, mee:ing with licensee representatives. 4/8/80 Phone call from G. Rayden, Wichita Eagle 4/9/80 Phone call attempt, no success 4/11/80 Telephone contact with Individual "A", send isometric to "A" for marking Exhibit V Page 1 of 2 t
1 . 4/14/80 Hansen (RI) pulls NCRs/DRs related to accu =ulater line welding 4/16/80 Hansen interviews QC inspector Daceron 4/19/80 Handwritten note fro: Individual "A", sarked isometric drawing with veld 4/23/80 Above letter and iso =etric drawing receivad at RIII 5/2/B0 Hansen (r!) witnesses LP test of ground area on sea: weld identified 6/10/80 Initial Investigation Report issued, attach =ents o=itted 6/17/80 Attach =ents to Investigation Report sent out. 7/11/80 Kay Drey letter to RIII, questions regarding Investigation Report B/29/30 Respense to Kay Drey letter sent 1/2/81 Receive infer =ation Representa:ive Feigenbau: has been conta::ed 1/23/S1 G. Phillip atte= pts to call Feigenbau=, no success 1/27/81 G. Phillip contacts Feigenbau=, discusses contae: with alleger 1/25/51 G. Phillip con: acts leigenbau=, he advises alleger vill wri:e
- o Regien III 2/S/31 Date of 11 page let:er of co= plaint to G. Phillip, Region I:1 2/17-20/51 J. Fos:er on si:a at Callaway 2/26/51 Let:er sent to Individual "A" advising we will review expanded concerns 3/3-6/51 J. Foster onsite at Callaway 3/23-27/81 J. Foster on site at Callaway 3/:a/51 Prehearing conference (Contentions include :he spool piece)
Exhibit V Page. of 2
(7) High Pressure Coolant Injection 2EM-03-F013 (a) For each of these welds, one or more of the following f abrication activities was observed. Handling and protection of piping and partiilly completed welds was sa t i s f a cto ry. Purge gas was carrectly used. The joint fit-up dimensions were within precedural requirements and the weld area was free of any grease or particles of tools such as grinders, brushes, and files were properly color codes for use on stainless steel. Welders were certified as qualified for the procedure specified to be used for welding the pipe joint. (b) During the reporting period, the inspector observed the liquid penetrant test of tha longitudinal seam weld in spool 5002 near joint F001 sL,; on Drawing M03EP-01 Revision 6. The veld had oeen ground smooth as part of the d;sposition of Deficiency Report 2SD-0699-P in November 19. The results of the test indicated that there was no crack within the test area. The test area consisted of the weld, the metal extended from the face of the pipe back into the pipe for approxi-mately 12 inches. The liquid penetrant technique used to perform the examination was satisfactery. (c) During the reporting period, the inspector observed the radiographic test of an incere instrument joint. The radiation protection techniques were satisfactcry No items of noncompliance or deviations were identified. 5. Material Sterare During the reporting period the storage areas for reinforcing si el and other steel material, and electrical cable was observed. The steel material was orderly and placed on wood beams off the ground. The electrical cable spools were stored of' the ground and cable ends were taped and prctected from moisture. It was noted that much of the cable is manufactured by Rockbestos Coepany. Based on reports that some Rockbestos electrical cable has been spliced, the licensee was requested to determine if splices might also exist in cable that has been purchased and in-stalled at Callaway. This is an unresolved item. (483/80-15-01) No items of noncomplisnce or deviations were identified. ~'* Exhibit VI Page 1 of 1
m Dra f t Burton /cg 7/15/80 Dear Mr. Enclosed is a ecpy of a report of an investigation conducted on March 26-27, and May 2, 1980 of-activities at the Calla.ay Nv: lear Plant, Unit 1, authorized by NRC Const ruction Permit No. CPPR-139. In re'erence to the concerns you expressed about possible ele:tri:al arc danage to one of the heaters on the feed watea line inside the turbine buitding and 00ssible incr0:er fit u: methocs of related heater 4 0 ing; i< has beer J*: ermined t hat these areas are not safet. related an theref: e not under the j urisdi: tion of the NRC. These :0ncerns 50-ever have been br0ugr-t to the attention of Union Ele:t-i: recre-sentatives by the NRC Resicent Insce: tor at Callaway. In efe en:e t0 the torcerns you ex ressed about the Ovality of welds on sections Of the containment.ait, where root catfes na: been made; th*t matter has been revie=ed by the NRC Rtsident Ins:ect0r. It is rec 0gni:ed that the -eld is difficult, however the crecedure has been cualified and it meets the code recuirements. The nondestructive testing crescribed by the coce to det ermine the soundness tf the wel: is re:uired to be Performed On each weld,,t hereoy assuring its at:e:t acility. As you know, Deriodic inspections are conducted to nonitor compliance with NRC i t recuirenents. Exhibit VII Page 1 of 2 i
s 2 Should you have any questions concerning this investigation, we will be pleased to discuss ther with you. Again I would like to express my .aporeciatice for your assistance in this matter. Sincerely, Robert M. Burton Invest igat ion Speciali st I l ( Exhibit VII Page 2 of 2 ) i
I l' l f E* 2 5 GS' Dear Mr. This is to acknowledge receip af your letter dated February 8,1981. As indicated in our Investigation Raport No. 50-483/30-10, it was our urmierstanding that your concern was limited to a weld crack detected in a sectien of stainless steel pipe leading fres an accumulator tank. It is unfortunate that an apparent miscomarunication occurred regarding t t,s. extent of your concerns. We will carefully review the information contaiced in your letter and con-duct an investigation to address those questions for which we do not ha ve a r espense. Won c:nupletion cf the investigation, we vill provide you a copy of our report. We vill also provide responses to ameh of the ques tions you have raised. Sincerely, C. A. Phillip Exhibit VIII Page 1 of 1
V @Uce4 s 8 UNITED STATES 8 s, E NUCLEAR REGULATORY COMMISSION 3-f REGION ill g%,* e.. *,/ GLEN ELLYN. *LLINOls 60137 798 AOOSEVEL7 ACAD M r.. Dear Mr. Enclosed is a copy of NRC Inspection and Enforcement No. 50 '83/SI-04 which documents an expanded investigation into the quality Investigation Report of a section of accumulator discharge piping at the Callaway Nuclear Power Plant. I apologize for our oversight in not initial investigation report. sending you a copy of the This investigation was initiated in response to the letter of concern you to Region III on February 8, 1981, which indicated that we had not sent fully understood and investigated your concerns in the earlier investigation. I trust that the enclosed report is more respons:ve to your concerns. As you requested, a response to each question in your February 8 letter is contained in an enclosure to this letter. , 1981, The report itself contains add::1onal detailed information on many of the questions. Should you have any additional questions regarding the information contained in the rep:rt feel free to contactor the conduct of our investigation into this matter, please this office. Sincerely, J. F. Streeter, Act ng Director Enforcement and Investigation Staff
Enclosures:
1. IE Investigation Report No. 50-453/81-04 2. Responses to questions Exhibit IX t Page 1 of 15
i RESPONSES TO QL'ESTIONS i 1. Question: Were the telephone calls I made to the Region III office on October 11, 1979, and April 11, 1980, electronically record-d' 4 Answer: By NRC policy, telephone calls are not electronically recorded witheut advisement and consent of t!.e partses involved. Your tclepnene calls were net electronically recorded.
- 2. ~ Question:
If they were recorded may I listen to them or have a transcr:pt? Answer: See answer 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 investigators referred to are R. Burton and J. McCarten. NRC policy, an Investigator's notes are his property unless entered intoBy an official file. As the notes are often brief phrases meant to jog the memory of the individual, there is a h2gh 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. Quest:on: Why were only 15 welds inspected? Answer: As noted in Investigation Report 50-483/81-04, the character::a-tion of "15 welds" was in error. The reference was to a piping 1semetric which d:d 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/S0-10, including the seam welds, were visually inspected. The isometric indicates this consisted of three field welds, 11 circumferen-tial welds, and 15 longitudinal welds. Only two accumulator lines had been completed at the time. These inspections were made due to lack of an exact location of the weld in question and were of the external weld surfaces due to lack of specific information. The number of welds inspected is immaterial as the wrong welds were inspected. l 6. Question: Specifically, what efforts were made to contact me concerning the exact location of the crack? l Answer: The investigator's log notes four telephone call attempts on March 24, 1980, one on March 25, 1980, one April 9, 1980, and one call l l Exhibit IX Page 2 of 15 l l \\ \\
to enployees of the Wichita Eagle newspaper. You are aware of your first call on or about October 11, 1979, the call you made on April 11, 1980, the letter to you with an attached piping isometrie, and your bandwritten note to us which accompanied the marked isometric utilized to locate the weld. 7. Question: Who is WLK? Answer: WLX are the initills of a Level II Daniel Quality Contrcl inspector, Wayne L. King, who was' assigned to visually inspect the welds on the two accumulator discharge lines, along with N'RC Resident Inspector William Hansen. During the present investigation, we re-viewed this inspector's certifications and found them to be acceptable. 8. Quest:or.. When did he make the seam weld inspaction? Answer: March 27, 1980. 9. Question: Did he look into the end of S002 and examine the inside of th-seam weld? Answer: Inside seam welds were not inspected until recaipt 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 NCE ident:fied it as overlap; the DR called it poor fusion. Both terms can appli to similar situations, depending on the judgement of the inspecter. Until an overlap is removed, it cannot be ascertained if there ir actually a crack. In this case, when the arer of overlap / poor fusion was removed there was no crack. 11. Question: Vould " overlap" be a violation of Material Spec. SA 358, Para. 5.2.3? Answer: Photographs of the criginal 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 ASMI III as the governing code. Our position is that that is incorrect as the weld was a manufacturer w"~' Exhibit IX Page 3 ef 15
13 Quest. v.. Why didn't the NRC Resident Inspector question this (Turdera letter) when he received these doew. ants on April 14, 1980? Answer: During the initial investigation, the principal impactance of the NCR and DR referenced was in locating the pipe weld in question. Also, the referenced defect had been removed per the dispesition of the DR. There was no reason to question the interpretations contained in Mr. Tardera's letter as it was not a significant point. Tre signifi snt point was that the deficiency was identified, documented, and :orreci d ~ 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 question? Answer: As previously noted in the original report and in the present the location of the pipe or veld in questi.n was not clear on
- report, those dates due to inadequate information.
From the information avail-able at that time, it was presumed that the " pipe crack" would be visually evident and oc an external surface. Related nonconformance reports were not believed impsttant at that time. 15. Question: Was Mr. Turdera correct in citing NC 4426.2? Answer: Our position is that the ASMI SA-358 (the material suecification) was the relevant requirement, rather then NC 4426.2. The principal difference between these two Code references in the area of weld re:nf:rce-is that SA-356 allows 1/S" maximum reinforcement whereas NC 44262 ment 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 qucted was: American Society of Mechan: cal Engineers, ASMI Boa'.er and Pressure Vessel Code, Section III, Division I, " Nuclear Power Plant Components", Subsection NC, " Class 2 Cempenents", 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 dauble welded
- Answer:
Double welded utilizing an automatic submerged are welding process. 18. Question: What documents verify this: Answer: Manufacturer documents, including the weld pro edure sheets, weld procedure qualification documents, and radiograph;c reader sheets. Exhibit IX Page 4 of 15
19. Question: Do these references (UW-51b) exist? Answer: UW-51(b) is found in ASME Sectis? VIII as indicated in the letter signed by Mr. Turdera. A; 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 ASME Code Section I and has wording providing the same requirements and criteria. 20. Question: Why didn't Turdera deal with " overlap" as a violation of Section II SA 358. para 5.2.3? Answer: Mr. Turdera was not available for interview, but he apparently assumed it was an acceptable defect based on applicable nondestruct:ve examination requirements. 21. Question: Why wasn't the overlap removed prior to fabricating the spool piece? Answer: According 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 long::udinal 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 4 section of the radiographic film for an area near field weld F004 sh:uld have been re;ected. The area in question was approxit tely four inches long, not the entire seac weld as suggested. The rema nder of the radiography was acceptable. 23. Questicn: Did they base their decision on the information given in paragraphs (a) and (b)? Answer: The information contained in the letter was apparen-ly part of the 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 individuals read the NCR, as that was the information dis-cussed. See answer to Question 12. ; Exhibit IX Page 5 of 15
26. Question: Was this letter a basis for the ";. report saying that, "no items of noncompliance were identified"? Answer: The basis for the statement was that the defect had been remove 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 explu n. Answer: Yes. Under the provisions of site procedures, nonconfermances can also be dispos 2tioned by way of a Deficiency Report. From the NRC viewpoint, it is not significant which method documents and dispositions a nonconformance as long as the nonconformance is documented and d:s-posit 2oned properly (including an engineering review where necessary). In practice, items dispositioned via an NCR are usually significant which require engineering reviews. items 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: V:sual inspection was performed by the Resident Ins;tetor (and by QC Inspector Dameron on Ncvember 5, 1979, according to the DR) on the weld reinforcement forcement had been removed.just beyond the area where the excessive weld rein-The size of weld reinforcement (height, width, contour) on the rest of the seam weld was uniform and appeared te meet Code requirements (SA-353,1974). visually inspected the weld. NRC Inspector W. Key alse 30. Quest:en: Was the reinforcement measured back to the 45 degree elbew? inswer: The seam weld was visible back to the 45 degree elbeu and appeared un:for= for the I agth of the piece in question; however, it was act 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. Report was used to convey the r'esults of NRC measurements.The initial Invest:gatten 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? Exhibit IX Page 6 of 15
l. I Answer: See answer to Question 15. 34. Question: After the ovality was noticed was the pipe checked for conformance 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 obs-rved as a nonconformance. oval Some is acceptable as provided by the material specification. Mini- "' locatit n of the counterbore centerline,num w 11 v2clations at a counterbored area ovality of the pipe, or (4) a combination of any of the tbree.(2) excessive counterbore, (3) We did locate records to indicate that the pipe was checked for ovality not after the NCR was issued. The pipe has since been measured and found 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 was it measured? Answer: See answer to Question 34. We selected one representative point for our measurements as no interval was specified by Code. ification SA-353 does not Spec-speczfy the measurement mett.rd, but other secticns of the Code (NC-4221.3 for example) indicate auch measurements should act be =ade on a weld seam. 37. Question: Did the pipe conform to SA-35S paragraph 15.12? Answer: See answer to Question 34 38. Question: Should the NCR, Exhibit 5, page 3, list the ASME Cede as a " controlling document"' Answer: It is not necessary since the Bechtel specification contains references to the ASMI Code. 39. Questicn: Do Bechtel specifications take precedence over ASME speci-f2 cations? Ans.3r: Only when their requirements are mere stringent than those of the ASMI Code as provided in Bechtel Specification No. 104e6-M-201A, Section 3.3. 40. Question: What design criteria were used to detettine this minimum wall? Answer: American Society of Mechanical Engineers, ASME Boiler and Pressure Vessel Code, Section III, Division I, "Suclear Power Plant Components", Subsection NC, " Class 2 Components", Subarticle NC-36 0, Exhibit IX Page 7 of 15 !
" Pressure Dessgn of Piping Products", Paragraph NC-3641, " Straight Pipe", Subparagraph NC-3641.1, " Straight Pipe Under Internal Pressure" Values for temperature and pressure were taken from the EP piping class summary. 41. Question: What paragraphs of Section III were used in this determinatzen? Answer: See answer to Question 40. 4 2 '.' Question: What minimum wall? paragraphs of Section III were used i= recalculating the Answer: See answer to Question 40. 43. Question: Who was the spool piece vendor? Answer: Dravo Corporatica, Pipe Fabrication Division. 44. Question: Who supplied the pipe to the vendor? Ans c.- Guyon Alloys supplied the pipe to Dravo which had been pur-chased free Armco, Incorporated, Advanced Materials Division, the manufacturer of the pipe. 45. Question: When was the pipe manufactured? Answer: The pipe was manufactured by Armee apprcximatel September 1977 (radiography was performed September 15-16, 1977). 46. Quest:en: Were the radiographs of the longitudinal welds in spool No. 2-EF-01-S002 checked by the NRC? Answer: These radiographs were :.ot sation. They were interpreted as examined during the initial nvest:- a part of the present investigatzen. 47. Question: If they were, what were their f.nlings? Answer: Findings are detailed in the investigation report. With the exception of an area apprcximately four inches long, all of the radio-graphs cf the pipe piece in question were acceptable. For tha four inch area, it on the origional radiographs.is our position that this area should have been rejected base i 48. Question: When were Daniel Internatienal, Union Electric, Bechtel, and l SNUPPS first notified, formally or infcmally, of my allegations? Answer: Union Electric and Daniel International personnel were first advised of allegations concerning a " pipe crack" on March The identity of the informant was not provided. 26, 1980. NRC did not inform Bec "el or SNPPPS of the allegations, although their personnel were contacted during the investigations to secure technical information. Exhibit IX Page 8 of 15 j.
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gio 3 /6 0 /3 i UNITED STATES NUCLEAR REGULATORY CO*!SSION 0FFICE OF INSPECTION Ah0 ENFORCEMENT MASHINGTON, D.C. 20555 March 12,1979 IE Bulletin No. 79 03 PIPE SPOOLS MANUFACTURED BY YO STEEL Description of Circumstances: NGINEERING COiPANY On September 27, 1978, defects had been discovered in longitudinal welds ithe Arizona Publi g any reported that class 2 pipe supplied for the Palo Verde Nuclear Generating Sta n ASME Section I!! (PVNGS). On November 17, 1978, on Generating Station, Units 2 and 3. reported similar defects in p any an Onofre Nuclear Pullman Power Products of Los Angeles related fabricated piping spools of various dia, California supplies safety-The defects were discovered by Pullman in ASNE SA 312 t meters for the PVNGS. steel pipe supplied to Pullman by Youngstown Welding and Engin ype 304 stainless Company of Youngstown, Ohio. into cylinders and then fusion welding the longitudinalThe pipe is manu eering filler metal. seam rithout Pullman discovered defects in the longitudinal their ciretmiferential shop welds. Further radiographic examination ofwelds wh the longitudinal welds revealed rejectable porosity and l ack of fusion. Pullman then perfomed ultrasonic examination of th criteria of ASME Section III. longitudinal welds and discovered indic e full length of the e acceptance indications in other piping subassemblies where pipe ws suppli Youngstown. Two indications verified by radiography wre identified as y porosity and measured 0.350 inch by 0.125 inch in one case inch by 0.125 inch in another case in pipe with a nominal all thi k and 0.300 of 0.375 inch. c ness The additional examinations revealed that of 103 spool supports shipped to PVNGS, 44 spools and one pipe support werit s and four pipe contair. ultrasonic indications exceeding those pemitted by the ASME found to Code. Of 65 partially fabricated piping spools, 30 wre found to be similarly defective. Youngstown includes ICC percent ultrasonic examinatioThe accepta n of the longitudinal 1 of 3 puf f: 00 Exhibit XI - Page 1 of I. ~ ]qQl@Q $
b a IE FJ 1etin no. 79 03 Marcn 12,199 wlds in accordance with ASME Section !!!. The docunentatien provided with the pipe indicated that the required ultrasonic examination had been performed by Youngstown but the rejectable indications wre not identified. t mecial inspection was performed at Youngstow by NRC inspectors i I during the week of January 22, 1979. It was determined that t.w accarent 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 melding procedures to pmvide better control of welding current, voltage and trtvel speed for all material thickness ranges. Ultrasonic examinations of the pipe welds wre pedormed by a subcentractor to Youngstown. The reason why this Iubcontractor's ultrasonic testing did not detect indications exceeding ASME Code acceptance criteria was not detemineo. The piping was known to ha ve been tested in the heat treated condition, prior to the removal of l surface 02 ides. However, a comparison of attenuation of the pipe in l. as heat treated vs. heat treated and pickled condition did not reveal a discernible di fference. The NRC inspectors could not determine a definite time period during which the welding and ultrasonic testing problems are thought to have existed. All tyoe 304 or 316 SA 312 pipe manufactured before mid-November,1978 may have been shipped in similar conditinn. As a larce supplier, Youngstown is known to have supplied piping for nuclear applications to the Dravo Corporation Chicago Bridge rao Iron l Flowline Corporation and 'TT Grinnell Industrial Piping Inc. In s addition, piping was also supplied to material warehousing operations including Albert ?ipe Supply, Guyon Alloys Inc., and Allegheny Ludium Steel Corporation which may have eventually been used in safety-related i nuclear applications. Acticn to be ' en by the Licensees and Pemit Holders: For all power reactor facilities with an operating license or a construction pemit: 1. Determine whether ASME SA-312, type 304 or cther wided (without filler metal) pipe manufactured by Youngstow Welding and Engi-neering Company is in use or planned for use in safety-related systems at your facility. 2 of 3 l Exhibit XI - Page 2 of 4
o lE Su!1etin No. 79-03 March 12, 1979 a.
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For those safety-related systems where the subject piping is.in use or planned for use, identify the application sf the ptring includ;ng system, sipe location, pipe size and design pr essure /Lemperature requi renents. .c? ? "-I.c . r. 3. Develop t program for volunetric examination of the for.gitudinal ~ welds inciuding acceptance criteria for the piping identified in Itsm 2 above. Describe planned corrective actions if acceptance .t criteria are not met. If a sampling program is utilized explain the basis for the sample size. 4 For facilities with an operating license, a report of the above actions, including the date(s) wnen they will be completed shall be submitted within 30 days o.' receipt of this Bulletin. 5. For facilities with a construction permit, 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 ta the Director of the appropriate NRC Regional Office and a copy should be forwarded to the NRC Office of Inspection and Enforcement, Div' tion of Reactor Construction Inspection, Wasnington, D.C., 20555. Approved by GAO, B180225 (R0072); clearance expires 7-31-80. Approval was given under a bianket clearance specifically for identified generic p roblems. -r 3 of 3 1 Exhitit XI Page 3 of.4 l l i n e,
i {;'.T; X7,, IE Bulletin No. 79-03 -g *,- .h ' ?. Longitudinal Weld Defects in ASME SA-312 Type 304 Stainless Steel Pipe Spools Manufactured by Youngstown Welding and Engineering Company Distribution: pr W.*e'.S - L. V. Gossick, EDO J. R. Shea, Dir., OIP - 2 88-6209 . 2 88-8103 J. J. Fouchard, Director, PA ' M 88-3709 ' r N. M. Haller, Director, MPA 2 88-12105 R. B. Minogue, Dir., SD NL-5650 W. J. Dircks, Dir., NMSS 55-958 S. Levine, Dir., RES .- 55-1130 .H. R. Denton, Dir., NRR R. S. Boyd, Dir., DPM:NRR . Ph11-428 .u...,i.,. 'Phil-268
- 0. F. Ross, Deputy Director, DPM:NRR Phil-278 V. Stello, Dir., DOR:NRR J. R. Miller. DOR:NRR Phil-542 Ph11-216 '
D. G. Eisenhut, Dep. Dir., DOR:NRR .c ' Phil-266 R. H. Yollmer, Asst. Dir., SP: DOR:NRR G. C. Lainas, Chief, PSB: DOR:NRR P-514 ' g,. ; Phil-416 B. K. Grimes, Asst. Dir., E/P: DOR:NRR Phil-370 R. J. Mattson, Dir., DSS:NRR Phil-202 W. P. Naass, Chief 0AB:0AO:NRR P-320 R. F. Fraley, ACRS r H-1016 V. Harding, Legal Assistant. OCM H-ll49 G. Wayne Kerr, Asst. Dir., SA:SP MB8-721M l J. Liebeman, ELD M88-9604 J. G. Davis Acting Dir. IE D. Thompson, X005:!E R. C. Paulu's, XOOS:IE L. N. Underwood, X005:IE (Original) H. D. Thornburg, RCI:IE G. W. Reinmuth, RCI:IE N. C. Moseley, ROI:!E E. L. Jordan ROI:!E
- 5. E. Bryan, ROI:IE J. H. Snfezek, FFMSI:IE L. B. Higginbotham, FFMSI:IE E. M. Howard, SI:!E L. I. Cobb, X0m :!E W. R. Rutherford, RCI:!E l
L. E. Tripp, RI IE Files NRC Central Files IE Reading Files Mike Atsalinos, DSB:TIDC:ADM Phil-050 (Note: See separate mailing list for distribution of outside requests for Bulletins, Circulars and Information Moticas) l .~. Fxhibit XI Page 4 Of 4
l q 'SSINS No: 6820 Accession No.: UNITED STATIS 8002280644 NUCLEAR REGULATORT CCit!ISSIM 077ICZ OT INSPECTION AND TNTORCIMENT .y WASHINGTON, D.C. 20555
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p April 4, 1930 II Dulletin No. 79-03A IDNGITUDINAL WELD DEJICTS IN ASME SA-312, TT7E 304 STAINIJ55 STZ5L PIPE -[ Description of Circumstances: IE Bulletin No. 79-03 required '.he licensee to determine if ASME SA-312, Type ., 4 304 pi; e manuf actured by Youngstown Welding and Engineering Company is in use Y or planned for use in safety-related systans. Since the issuance of II ..i b Bulletin 79-03 on March 12, 1979, subsequent fiadings indicate additional information and clarification is needed to resolve the SA-312 issue. ,...y "
- v4 It has been determined that conventional ultrascale testing (UT) and radio J'Q graphic testing (RT) techniques (as required by ASEE Section III) are not G
adequate to detect centerline lack of weld penetration (CI.P). Coevestional radiography and ITT exaaf nations may detect the presence of CIJ ander epecial ~ ' ' conditions, but neither can be considered reliabit, enough to detect CIJ even when significant percentages exist. f Based upon the above and previous findings during inspections at Youngstown it has been determined that the bungstown Welding and Eagineering Company did comply with the ASME Code requirements, but that the Code M requirements are deficient. Consequently any samu'acturers' SA-312, Type 300 Series, sastenitic stainless steel fusion welds may contain undetected CLP. This problem is generic to all welded SA-312/A-312 saterial and is not restricted to material manuf actured by the Toungstown Welding and Engineeriar, Company. The NRC has verified that the CIJ condition also exists in the SA-312 and/or A-3 2 fusion welded pipe manufactured by ARHCO's Advanced Materiala Division, the JWEPCO Tube Corporation and Crucible's Trent Tube Division. These c1rgmties are known to have supplied SA-212 and/or A-312 asterial for noclear applications and are now included within the scope of this Bulletia. Several Licensee't responses to the II Dulletin 79-03 were inadegaste. The responses were inadequate because they were based oe the purchase order M requirements rather than the iaformation requested ia the Bulletia. As actual crample of an inadequate response was as follows: Radiography of a circise-ferential weld seaa revealed CIJ in the longitudinal seas of a section of SWEPCO fusion welded pipe. The licensee did s.ot believe the case vos reportable if the original NDE requiremes.ts for the SWEPCO pipe did not require volmetric examination. This CIJ problem is considered by the NRC to be a significaat deficisec7 which requires extensive evaluation and could result ia repair er replaesenet af P1Pe and/or fittings. DVPb OP foo,LMo6M Exhibit XII Page 1 of 3 g .m . _ _,... _ _ _. - _-.-i_____
11 Bulletin No. 79-03A pril 4, 1980 Pas? 2 of 3 't S.? The Laf ormation requested in tAis revised Bulletia is to be provided without regard to t.he purchase order IEE requirement.a or any subseqenant EE performed for er by the licensee. The information requests is this Balletia swersede the requests for informatios is the II Bulletta 79-03. ~ l The IRC staff position on this issue and any other esse where defects er ? l l deficiascies are diwevered is safety-related cas Manests is as follows: s { Regardless of the circumstances under which potential deficiencies er potap.ial-defects is safety-related components are discovered the asttar shall be Ideati-fied, evalus ted, dispositioned, documented and reported la strict accordance with the appropriate Tederal Regulatiosa Although the A.52 Code rules and requirements may be used when appr.9riate to evaluata defseta er deficiencies and to justify l and accept the existence of a defect er deficiascies, the Code cas' met be used j as justification for met reporting the defect, deficiency and circumstances to the NRC when that defect er deficiency has been identified by the ERC as a potential generic problem. Men the licensee, his agent er vender discovers a '. defect or deficiesey that any be a generic problem er a significaat laae deficiemey a oaservative positica shall be adopted regarding the reperting of the situation to the ERC. ~ For those power reactor facilities that have the sebject pipe installed the action identified in this Dalletia is limited to identifying the specific applications and providing information rel.ted to the stractarsi integrity of the piping components. Additional guidance related to EE's and/or preese-tionary or corrective actions will be provided la a later kiletia revisien if necessary. Xavised action to be tdme by Licensees and Pamit Bolders: Tor all power reactor facilities with an operating license or a esastractles perutt: 1. Determine whether SA-31 or A-312. Type 300 Series fusies welded pipe is in use or planned for use is safety-related r7steme subject to desias l stteasee areatar tima 85 pereest ef the Code allossable atressee. For the purpose of this check the octual well thickness of the pipias predects I will be considered adequata if the code requirements for pressure desism of the pipias prodnets are satisfied using 35 percent of the emaisen allowable stress at the design tamperstare. 2. For those piptag componesta asing greetar than 25 percent of the allowable stresses identify the applicaties of the pipias incl =dt me the systas, pipe location, pipe siae, pipe esafigst: tion (elbeer, tae), desian pressure /tamperstare requi m en and t.he asaufacturer. 3. For these facilities under construction and where accesa permits, the eeds of all safety-related SA-311 and A-322 fusion welds should be etched to determine if ClJ esista. Idestify the M aetarer and the degree of CI.F es a percentage of the pipe well thickases. Exhibic XII Page 2'of 3
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\\ II Bullotis No. 79-( ' April 4,1980 1* , Page 3 of 3 4 1 4. For facilities with an operatina license, a report of the above information i shall be submitted within 120 days of receipt of this Ballatia. 1:,. ) 5. For facilities with a construction pemit, a report of the above information shall be submitted within 120 days of receipt of this Dalletia. i ,.K #2.re ? ~ Reports should be submitted to the Director of the appropriate IRC Regional Office l J and a copy should be forwarded to the IRC Office of Inapection and Eaforcement, i Division of Reactor Construction Inspection, Washington, D.C. 20$55. i Approved by GAO, 3180225 (20072); clearance empires 7/31/80. #troval was ... h.. 1 given under a blanhat clearance sPecifically for identified generic probleme. i 3- .. T, '#g 'i p. l.y S~5..]Yy ' ' ~ ;,'f-f...t Q ".. l . c- .s r a -:. ~, a: l t 2- ,. / ; - b i F.xhibit XII Page 3 of 3 e 4 6 O ---w,-rw..-.
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NUCt. EAR f1EGUL ATORY COMMISSION 7 j,=h){flj. l WAS68tNCTON. D C 205M %.l' ?$. 'l APR 91550 MEMORANDU". FCF.: B. H. Grier Director, RI J. P. O'Reilly, Director, RII J. G. Xeppler, Director, RIII K. V. Se<frit. Director, RIV R. H. Engelken, Director, RV FROM: Harold D. Thornburg, Director, Divisi:n of Reactor Construction Inspection, IE
SUBJECT:
INTERPRETATION OF IE BULLETIN 79-03A Several questions have been raised regarding Bulletin 79-03A. 'n'e are not planning to revise the Bulletin, but we are providing the follcwing interpretations so tha+. all Regions respond with a consistent answer if the same questions are asked by licensees. 1. Does the Bailetin also apply to SA 312 pipe welded from one side? Since you can not produce centerline lack of penetratien (CLP) welding from cne side, the Bulletin does not apply. 2. Does Item 3 on page 2 apply to all ' 2.'ety-related SA 312 fusion welds.c just those in components subject to design r?9sses 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 ycu find other clarifications are necessary please advise. 0 t.e A H rolo D. Thornburg ( Director Division of Reactor Construction Inspection, IE CONTACT: W. R. Rutherford, IE 49-27551 APR 0 1 4 1980 { gi Exhibit XIII I Page 1 of 1 k W
i 4 4 a 1 1 4 'l t i t ) 4 i t. k I i J r I ATTACHMENT 2 1 ) r I I 4 4 f I i f- --.
w ..f g/ h,l '= t the examination problems associated with the requirements of NC 2551(b) and related set:tions of NR 2550 where radiographic and ultrasonic techniques are not able to detect, amounts of CLP, significant to the safe operation of a nuclear plant. The "85% allowable stress" criterrion is a substitute assurance of siruetural integrity and quality the.t is not consistent with Section 111 and may be considered ger rerse to Section III. (c) The following: (1) 'ihe problems presented in IE Bulletin 79-03 and the June 1979, Bechtel report, relating to the inability of radiographic and ultrasonic techniques to detect CLP, are generic to the fusion welding of double welded butt joints. The only significent diffference between detection and non-detection of CLP defects is the existence of a discrete gap between the unfused faces of the weld joint. This difference !s not 5 function of the SA-312 raaterial spee!fication but is associated with the welding process procedure. The Bechtel report and 79-03A limited the problem's investigation to SA-312 material, when it affects all material specifications examined in accordance with NB-2550 or NC-2550. (2) The evaluation and acceptance of SA-312 piping with clouded structural integrity and quality as explained in the answer to quastion Q-11(b) is unacceptable. f (C((M/ Many unacepetable portions of NRC Repo have been clarified in NRC Report No. 50-483/81-04 and are now acceptable. Howeve, the cause of the welding defects reported in Report No. 50-483/81-04 has not been determined. 20 ..}}