ML20031H483

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Testimony of La Gunther & RA Frazer Re Doherty Contention 35 on Welding.Describes Planned Welding Program.Prof Qualifications Encl
ML20031H483
Person / Time
Site: Allens Creek File:Houston Lighting and Power Company icon.png
Issue date: 09/18/1981
From: Frazer R, Gunther L
EBASCO SERVICES, INC., HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20031H319 List:
References
NUDOCS 8110270530
Download: ML20031H483 (14)
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Text

o September 18, ]981 1

2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 3

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the matter of S

HOUSTON LIGHTING & POWER COMPANY Docket No. 50-466 6

6 (Allens Creek Nuclear Generating 9

Station, Unit 1)

S TESTIMONY OF LOUIS A. GUNTHER 8

AND RICHARD A.

FRAZAR CONCERNING DOHERTY CONTENTION 35-WELDING 9

10 Q.

Please state your name and your position, and 11 describe your educational and employment background.

A.

My name is Louis A. Gunther.

My business address 12 is Two World Trade Center, New York, New York.

I am employed 3

by Ebasco Services Inc. and act as the Welding and Materials Engineer for the Allens Creek Project.

The statement of my background and qualifications is attached as Attachment 16 LAG-1.

17 My name is Richard A.

Frazar.

I am the Manager, l

18 Quality Assurance, for Houston Lighting & Power Company.

The statement of my background and qualifications is attached as Attachment RAF-1.

21 Q.

Mr. Gunther, what is the purpose of your testimony?

22 A.

The purpose of my testimony is to describe the 23 welding program being planned by Ebasco for the Allens Creek 24 construction site.

8110270530 810918 PDR ACOCK 05000466 T

PDR

I 2

Q.

What steps will Ebasco take to assure the qualifi-3 cations of the welders employed at Allens Creek?

A.

Only welders with proven capabilities who use 4

approved fabrication methods are employed at Ebasco sites.

5 These welders will be selected from available union personnel.

6 All welders who will fabricate safety related equipment, I

piping systems and other components covered by the ASME Code 8

or ANSI B31.1 will be qualified in accordance with the 9

latest hRC accepted edition and addenda to Section IX, 10 Articles I & III of the ASME Boiler and Pressure Vessel 11 Code.

12 At Ebasco construction sites, we use a generic 13 document which provides procedures for welder performance 14 qualification testing.

These procedures assure that the 15 conditions and requirements specified by the Code have been 16 addressed in each test.

This generic document is then used 17 to develop procedures tailored to specific projects such as ACNGS.

This process has been successfully used by Ebasco at 18 ther projects.

19 The generic document described above also assures 20 that compliance with ASME Section IX, Paragraph QW-322 for performance qualification testing is included in the welder testing project specific procedures.

23 24

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1 2

Qualification of the personnel which make up the concrete reinforcing steel splicing (such as cadwelds) crews 3

is performed in accordance with the requirements of Regulatory 4

Guide 1.10, Revision 1.

Qualification of welders for velding 5

of mechanical splices to structural steel is performed in accordance with the requirements of American Welding Society i

Code Dl.1 and Section IX of the ASME Code.

Requirements for 8

qualification of splicing crews and welders are contained in 9

the Allens Creek Project Specifications.

It should be noted

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^

that cadwelding is actually not an arc process similar to 11 that used in pipe welding; rather cadwelding is a mechanical 12 means of butt splicing concrete reinforcing bar.

Concrete 13 reinforcing steel splicing will be performed, like welding, 14 by qualified personnel who will be thoroughly trained prior 15 to the performance of work at ACNGS.

16 Q.

Will welding be conducted "...by persons being 17 trained to be welders..."?

A.

No.

It is Ebasco's intent that all welders who 18 perform production welding will have completed union welder 19 training supplemented by an Ebasco qualification testing 20 program.

Welders will not be hired for welding work at ACNGS until they have had welder training with the union and have successfully completed the welder qualification testing 23 program.

HL&P Quality Control (QC) frequently reviews the 24 1

2 welder qualification records to ensure that all welders have 3

been properly qualified.

4 Q.

What requirements will be imposed upon the work 5

d ne by the welders at Allens Creek?

A.

Welders must use comprehensive fabrication instruc-6 tions which are prepared by the Ebasco Materials Applications Department for piping systems and structures.

These instruc-tions guard against the misapplication of fabrication 9

procedures, thermal treatments or non-destructive tests.

10 The welding requirements imposed by the specific instructions 11 are derived from Ebasco specifications.

Together, the 12 fabrication instructions and Ebasco specifications contain 13 the following information:

14 (1)

Field Weld Joint Identificatior. - Used to avoid 15 fabrication methods misapplication.

16 (2)

Required Weld Joint Geometry - Identified to 17 insure that the weld joint configuration shall gg conform to that geometry used for the weld procedure qualification.

g (3)

The Weld Procedure to be employed on the weld joint - Specified to assure that the welding 21 method most suitable for the weld joint is applied, 22 so as to reduce defective weld possibilities.

23 24 s.

1 2

(4)

Thernal Treatment, Preheat and Postheat - Specified 3

to assure that satisfactory weld zone cooling 4

rates, heat affected zone softness and stress 5

relief is achieved.

6 (5)

Non-destructive Tests - Those test,s imposed are specified by ANSI B31.1 for non-nuclear piping i

systems and, ASME Section III, Subsections NB, NC and ND for nuclear piping systems.

Ebasco 9

specifications concerning examination and non-des-10 tructive testing requirements for piping system 19

~~

materials, welds and components compile and

'~2 coordinate the applicable Code test requirements.

13 Q.

What steps will be taken by Ebasco to assure that 14 all welds satisfy applicable requirements?

~

15 A.

The ACNGS nuclear site will maintain a staff of 16 experienced " hands-on" welding specialists (engineers and 17 field experienced personnel), designated by Ebasco as the yg Special Processes Group, for the purpose of minimizing l

defective welds.

These specialists monitor all site weld g

activities, provide technical direction to contractors and site quality control and quality assurance personnel; resolve specification requirements questions; review erection fabrica-22 tion plans to assure that all technical and quality requirements 23 are met; review all non-destructive test results to assure 24

1 2

evaluation adequacy; resolve test results evaluations questions; 3

determine weld defects problem causes and trends and initiate 4

action for resolution of any problems identified.

Those 5

welds which have been rejected because of failure to satisfy 6

the required non-destructive tests are repaired using Ebasco welding procedures qualified in accordance with the applicable i

Code requirements.

The welding procedures selected for making the repairs are established such that they minimize the possibility of introducing additional unacceptable 10 defects into the weld.

The performance records of weiders 11 on repair work requiring radiographic examination is monitored 12 by the Special Processes Group in the same manner as the 13 original welds to assure that the best available personnel 14 are assigned to repair welding to thus minimize the number 15 of repair cycles.

16 Q.

Have Ebasco's efforts at quality control proved 17 successful in the past?

18 A.

Yes.

The effectiveness of Ebasco's welding control can be exemplified by the record at the Louisiana Power and yg l

l Light Company Waterford 3 Huclear project where weld rejection rates in piping systems were held to a low level.

This result was achieved by the non-destructive test records 22 l

monitoring system used by the Special Processes Group.

l 23 Welders generating more than the designated maximum defect l

24 1

1 1

2 rate we're removed from production welding for further 3

training.

A similar activity is planned for the Allens 4

Creek project.

5 Finally, Ebasco has established a Project PSAR Position in response to Regulatory Guide 1.71 concerning 6

welder qualifications for welding in areas of limited physical access.

This position establishes conservative 8

performance testing conditions compared to those imposed by 9

the ASME Code Section IX and, therefore, establishes 10 stringent evaluations of the welder's skills before they are 11 assigned to welds having a ree~ricted access.

c 12 Q.

What are your conclusions?

13 A.

The Ebasco welding program is a comprehensive and 14 mature corporate system derived from great care and experience is over many years of nuclear construction experience.

It has 16 been proven effective and will continue to be so for the 17-ACNGS project.

Q.

Mr. Frazar, what is the purpose of your testimony?

g A.

The purpose of my testimony is to describe the methods by which HL&P will assure the quality of the welder 20 training and qualification program; the quality control 21 program to monitor weld performance at Allens Creek; and the 22 HL&P commitment to conduct welding activities at Allens 23 Creek in accordance with the appropriate codes, standards 24 and NRC criteria'.

1 2

Q.

What is HL&P's role in the training and qualifica-3 tion of welders?

4 A.

HL&P will be responsible for overseeing the imple-mentation of training and qualification testing.

This will 5

be carried out by QA/QC personnel who perform periodic 6

assessments to assure that the program meets all applicable codes, standards, and NRC criteria.

8 Q.

How. 11 these assessments be performed?

9 A.

The assessments will be performed at many levels.

10 The first level of assuring quality lies with the

  • 1 1

person performing the actual weld.

His training, qualificm-12 tion testing, experience and interfacing with his supervisor 13 ensure he will perform a quality weld.

14 The second 2 cvel of responsibility for assuring 15 quality lies with the welding supervicors.

They are expected 16 to carry out their job in a manner that will result in highly qualified skilled welders.

The welding supervisors 17 provide the primary source of supervision for the welders.

g To provide a third level of assurance that the welding is being properly implemented, Ebasco also employs 20 numerous quality control personnel whose primary responsibility 21 is to monitor the conformance of the welding program to the 22 standards and commitments in the PSAR.

23 24

1 2

HL&P monitors the implementation of the welding 3

program as well as the Ebasco QC program.

HL&P performs 4

surveillance as an additional check on the thoroughness of the Ebasco QC program.

In addition, HL&P conducts compre-5 hensive audits of the welding program that is being carried 6

out by Ebasco.

A fourth level of quality is provided by the S

Ebasco Special Processes Group.

This group, discussed in 9

detail in the testimony of Mr. Louis Gunther, acts essentially

'^O as the site welding coordinator.

QA/QC reviews and addits is are fed back to the Special Processes Group for disposition.

~~

12 Dispositions may result in welding procedures modifications, 13 welder requalification, or modification of supervisory 14 guidelines and etc.

15 The use of these levels to assure quality build a 16 high level of confidence that a quality weld will be obtained.

Q.

In the review of the Ebac;;o QA program, what 17 specific items are reviewd?

g A.

The HL&P QA Organization group reviews applicable codes, standards and regulatory commitmentc to determine the 20 requirements which must be met in carrying out the welding 21 program.

22 In addition, the HL&P QA personnel review Non-23 destructive Examination (NDE) records, construction procedures 24 c

_9_

1 2

and. engineering specifications.

QC procedures provide that 3

during the process of welding, inspections must be performed 4

at designated " hold points", and that QC personnel periodically 5

must check such items as voltages, currents and travel 6

speeds.

A visual examination is performed when welding has been completed, and if required, non-destructive examination i

is performed and the results are evaluated by certified NDE inspectors.

9 Q.

Do the QC inspectors receive training?

10 A.

Yes.

Inspectors must receive formal training 11 prior to being certified as QC Inspectors.

12 Q.

Mr. Doherty alleges that the shortage of skilled 13 workers wi.11 lead to anqualified personnel performing the 14 process welding at ACNGS.

Will this be a problem at ACNGS?

15 A.

No.

We do not anticipate a shortage of skilled 16 welders in the Houston area; however, unqualified welders 17 will not be allowed to perform welding at the Allens Creek l

18 proj 1ct.,

It is Ebasco's intent that trained welders will normally be hired from the local union shops.

If necessary, g

however, welder selection can be made from distant shops and other unions.

As an additional, but unpreferred alternative, 21 complete welder schooling could be provided for potential i

22 l

welders prior to performing production welding at ACNGS.

I 23 l

Q.

If a weld is discovered to be defective, how is it 24 handled?

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2 A.

If upon inspection a weld is determined to be 3

deficient ir. that it does not meet specification requirements, 4

the treld will be reworked or repaired in accordance with 3

approved procedures.

Q.

What are your conclusions?

g A.

Since both HL&P and Ebasco will assure compliance I

with the required codes and standards in additice to maintain-ing many levels tc assure quality, ACNGS will have qualified 9

welders and grality welds.

10 11 12 13 14 15

~

16 1s 19 20 21 22 23 24

. /

\\ttachment RAF-1 RICHARD A.

FRAZAR I graduated from Lamar University with a B.S.

in Chemical Enganeering in 1968.

From 1968 until 1972, I was employed by Monsanto Company in the Material Technology Section as a corrosion engineer.

In this capacity, I was responsible for conducting corrosion studies and field investigations in support of chemical operations.

During this time I gained extensive experience in the use of metallographic techniques for failure analysis and nondestruc-tive testing techniques for flaw detection purposes.

In 1972, I transferred within Monsanto to the Manufacturing Department where I supervised the operation of a pressurized reaction copolymer resin unit.

I joined HL&P in 1973 as a Metallurgical Engineer in the Quality Assurance (QA) Department.

Since joining HL&P, I have been associated with QA.

In 1974, I was named Supervising Engineer for the South Texas Project (STP) QA program.

I was promoted to Project QA Manager for STP in 1975 and then promoted to Manager of the QA Department on April 1, 1977.

I am currently in charge of QA for both STP and Allens Creek.

r-Attachment LAG-1 LOUIS A. GUNTHER r

Polytechnic Institute of Brooklyn EDUCATICN BS (Magna Cum Laude) Metallurgical Eagineering,1968 New York University MS Metallurgy, 1970 New York University MBA Management Systems, 1975 American Welding Society MEMBER American Society for Metals Registered Professional-Engineer, New York QUALIFICATIONS Method for Welding Tubes to Tube Sheets, Patent No. 3,824,663 PATENTS HONORS & AWARDe - Tau Beta Pi Noah A. Kahn Memorial Award - ASTM TT-4 Pratical Nuclear Pow'r Plant Technology Course e

SPECIALIZED TRAINING sporaored by Ebasco - 1976 B & W Basic Steam Generating Technology Course sponsored by Ebasco - 1976 GE-BWR Course - sponsored by Ebasco - 1976 Titanium and Its Alloys sponsored by the American Society for Metals - 1968 EXPERIENCE Ebasco Services Incorporated, New York Office; 1974 Principal Engineer, Materials Applic:?.tions.

Involved on matters concerned with welding and materials selection during the design, procurement and construction phases on assigned projects.

Special assignments included directing development of autumatic fixed position pipe welding procedures, and providing materials engineering support to the Ebasco Materials 4

Engineering Laboratory.

e

r l

PAGE 2 LOUIS A. GUNTRER PRINCIPAL ENGINEER l

EXPERIENCE (CONT'D)

Curtiss Wright Corporation; Senior Engineer.

1971 - 1974 Assigned to the Welding Technology Department.

Responsible for development, implementation and surveillance of specialized welding procedures employed in the manufacture of Naval Nuclear Components to seal welding, automatic tube-to tube sheet welding, and automatic orbital pipe welding processes.

Additional responsiblities included metallurgical studies for development projects and production suppor*J, manpower and schedule estimating for new welding projects, capital equipment selection, and vendor auditing.

Curtiss Wright Corporation; Engineer.

1969 - 1971 Assigned to the Process Metallurgy Department Aerospace Division.

Responsible for development projects concerned with repair welding and heat. treatment of turbine blades, plasma are welding, inertia welding and production welding.

of D6AC steel assemblies for the Grumman F14 Program.

j U. S. Naval Applied Science Laboratory; Physical l

1968 - 1969 l

Metallurgist.

Assigned to the Titanium Development Program, responsible for carrying out welding develop-ment studies and welder training programs on heavy section titanium alloys in support of U. S. Navy deep submergence vehicle programs.

Ebasco Services Incorporated; Materials Laboratory Summer 1967 Technician.

Responsible for specimen preparation,-

metallographic work on f ailure analyses, and brazing

+

and machining operations performed during laboratory _

studies for the power industry.

.

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