ML20087N774
| ML20087N774 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/19/1984 |
| From: | Arnold J, Cady D, Fink R, Karner H, Torstrom R BECHTEL GROUP, INC., PACIFIC GAS & ELECTRIC CO., PULLMAN POWER PRODUCTS CORP. (FORMERLY PULLMAN, INC.) |
| To: | |
| Shared Package | |
| ML16340E243 | List: |
| References | |
| NUDOCS 8404040370 | |
| Download: ML20087N774 (67) | |
Text
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'84 MAR 22 A10:13 UNITED STATES OF AMERICA NUCLEARREGULATORYCOMMISSIk;h.klg,,
BRANCH BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARO
)
In the Matter of )
) Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC ) 50-323 COMPANY )
) (Construction Quality Assurance)
(Diablo Canyon Nuclear Power ) -
Plant, Units 1 and 2) )
)
AFFIDAVIT OF J. ARNOLO. 0.R. CADY. R.G. FINK. H.W. KARNER. R.A. TORSTROM STATE OF CALIFORNIA )
) ss.
COUNTY OF SAN LUIS OBISP0 ) l The above, being duly sworn, depose and say:
I, J. Arnold, am Resident Mechanical Engineer for Pacific Gas and Electric Company.
I, D. R. Cady, am Engineering Supervisor - NOE Level III for Bechtel Group, Inc.
I, R. G. Fink, was employed as jobsite QA/QC Manager at Diablo Canyon Nuclear Power Plant for M. W. Kellogg (now Pullman Power Products) from 1971 to early 1974.
I, H. W. Karner, am Quality Assurance /Qtfality Control Manager for the Pullman Power Products Corporation.
k I, R. A. Torstrom, am Technical Administrative Assistant to the Resident Mechanical Engineer for the Pacific Gas and Electric Company.
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- 1. The issues raised in Joint Intervenors Allegations Nos. 59, 60, 61, 62,
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- 63. 74, 75, 76, 77, 78, 85, and 89 stem f rom Mr. Hudson's
. misunderstanding of code requirements related to the development of Procedure Qualification Records (PQR) and Procedure Qualification Tests (PQT) for Nondestructive Examination (NDE) and the requirements which were applicable to the valve thickness verification program ordered by the AEC.
- 2. Mr. Hudson assumes tnat the QA/QC records maintained for NDE should be the same as those for welding. This is not required.
- 3. In the case of welding, the code establishes standards for the process that must be met. It does not establish the method that must be used to perform the process. In order to assure that the process used results in a product that meets the standard, the welding process utilized must be qualified with a PQT and PQR. In contrast, for NDE, the code itself
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establishes and qualifies the method which must be used, and except for special circumstances not applicable to the allegations below PQRs and/or PQTs are not required due to the prequalification of the NDE methods utilized.
- 4. 10 CFR 50 Appendix B for special processes requires only that qualified personnel using qualified procedures be used.
- 5. All NDE procedures referenced in Mr. Hudson's allegations were implemented using qualified and appropriately certified personnel.
- 6. All NOE procedures referenced by Mr. Hudson were developed from code
( ASME V, ASTM) established methods and were verified for compliance by documented review and approval by a NDE Level III.
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- 7. A minimum wall thickness verification requirement was imposed on the industry by the .AEC in 1972 (see Exhibit 1, attached). Several of Mr.
Hudson's allegations on the lack of PQRs and PQTs stem from an additional misunderstanding of the AEC requirements for the valve thickness measurement program. The valve thickness measurement program was a special program developed for an AEC identified problem. Nowhere in the AEC directive were the requirements of PQRs or PQTs made mandatory. It should also be noted, that where practical, each set of measurements on each valve used a micrometer reading to check UT system calibration. The result was documented on a data report which in itself is the equivalent of a PQR and POT.
JI #59, Motion at 21.
It is alleged that:
k TherW is no evidence that the ultrasonic thickness measurement procedure for reactor coolant pressure boundary valves was qualified through tests to demonstrate the 98 percent level of accuracy required in 1972 by the AEC. Since the measurements were conducted with an uncontrolled procedure, they cannot be accepted as the basis for conclusions about the quality of the valves. Pullman's internal auditor could neither find evidence of a Procedure Qualification Record (PQR), nor a i
Procedure Qualification Test (PQT). (citina Hudson Aff.
at 15-16.)
- 8. The allegation is erroneous. The valve measurement program conducted by PGandE was accepted by the NRC as fully satisfying its requirements in l
1975. By letter dated May 12, 1975, the NRC stated:
i The inspector examined the final records for the ultrasonic and physical measurement of valve wal',
thickness. All on-site valves had 5een measured and l
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dispositioned in a satisfactory manner. Records were complete and provided evidence that the licensee and his 1 Js contractor had satisf actorily implemented the program.
Th'e inspector stated that he considered the item closed for both Diablo Units (see Exhibit 2 at 4, attached.)
- 9. Demonstration of the procedure qualification was evidenced each and every
- time calibration was accomplished and documented on data sheets. The l
procedure in question (ESD 236) was controlled by date and revision number. Pullman's auditor (Hudson) could not find evidence of PQRs or PQTs since there was neither a requirement for either of these documents nor were they prepared.
- 10. Mr. Hudson was informed of the NRC approval by Mr. Karner at the time he raised his alleged discrepancy.
JI #60, Motion at 21. -
It is alleged that:
Pullman's auditor could find no evidence of " procedure verification tests' required by engineering specifications for the transducers. As a result, the ability of the procedure to take into account the curves, ridges and irregularities that exist on every valve and significantly affect the measurements remains indeterminate. (citina Hudson Aff. at 16.)
{ 11. The Pullman engineering specification referred to by Mr. Hudson is ESD 236. ESD 236.6,7 states:
Transducers will be of suitable size and adapted with shoes, wedges or saddles as each valve measurement requires, as determined from procedure verification test.
- 12. The suitability of the procedure and accuracy of the transducer were verified against a known standard of like material with each application. This verification was documented on each data report. All '
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records reflecting this information are currently available. Thickness measurements were conducted at a frequency capable of resolving the l thickness range to be measured, as evidenced on the data reports. The tranducers utilized were of adequate size so as not to require the use of shoes, wedges, or saddles to adapt the transducers to surface contour. Therefore, PQTs for the transducers were not required.
JI #61, Motion at 21.
It is alleged that:
In 1982, Pullman's internal auditor could not find any evidence that management conducted the measurements with any qualification test, despite prior warning in 1973 that the procedure was too flawed to provide meaningful results. (citina Hudson Aff, at 16.)
- 13. Contrary to the allegation, the April 17, 1973, Pullman interoffice correspondence from R. G. Fink to W. R. Fox was not a " warning" that the procedure was too flawed to provide meaningful results. The
( correspondence was written by the QA/QC manager in response to a field change order (FCO) f rom PGandE requiring Pullman to UT test 177 valves.
It identified questions which the QA/QC Manager felt needed to be resolved before testing could begin, but did not condemn any testing procedure.
- 14. At the time of the correspondence, Pullman did not have an ultrasonic testing (UT) procedure in place for wall thickness measurement. The Pullman procedure, ESO 236, was in the process of being developed and was adopted on April 26, 1973. Pullman began the UT measurements on May 8,1973, almost three weeks af ter the FC0 was received from PGandE.
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- 15. In the time between the receipt of the FC0 and the first measurements, the questions raised by Mr. Fink were resolved and a reliable thickness measurement procedure (ESD 236) was developed by Pullman.
JI #62, Motion at 22. ,
It is alleged that:
Pullman QA manager Harold Karner improperly refused to take corrective action in January 1982, when the auditor disclosed the lack of procedure qualification records or tests for ESD 236 and ESD 244, the UT. Thickness Gauge Procedure. The problem remains uncorrected. His excuse was that nondestructive meat.urements are not tests, and therefore do not represent "special processes" that must be controlled. (citina Hudson Aff. at 4.) The semantic excuse is irrelevant. The results had to be accurate in order to comply with a 1972 AEC directive. (Id. at 17.)
- 16. Mr. Karner did not improperly refuse to take corrective action when Mr.
Hudson discussed the lack of PQRs for ESD 236 and ESD 244. A discussion k was held with various knowledgeable individuals in this area, and the determination was made that the applicable codes for this Project did not require a POR for thickness measurements by UT. The procedures themselves require a calibration and demonstration of accuracy prior to each use and are adequately controlled.
- 17. The UT system calibration was performed using calibration blocks traceable to National Bureau of Standards. Verification measurements l
were within the 2% accuracy requirement of the AEC which is verifiable on the data reports prepared for each valve.
- 18. This audit was closed by Mr. Hudson on :iarch 72, 1983, with no further comments pertaining to the need for PQRs (see Exhibit 3, attached). At 1
no timd was Mr. Hudson threatened or coerced in any way to accept this I
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' determination, and it was assumed that Mr. Mudson, by his actions, accepted the resolution.
JI #63, Motion at 22.
It is alleged that:
Pullman's linguistic distinction improperly excludes nondestructive measurements from the scope of 10 CFR 50, Appendix B, Criterion IX, despite their critical significance to plant safety in this case. As Mr. Hudson explained, "They are special process (sic) because they are uniquely created to perform a specific quality-related function." (Id.) The QA boundary created by Pullman is not specified in 10 CFR 50. Mr. Karner added the limitation, which is inconsistent with the safety goals of the Atomic Energy Act. (citina Hudson Aff at 17.)
- 19. This allegation is also incorrect. Thickness measurements are not considered to be either nondestructive testing or destructive tes' ting; rather, they are quantitative measurements, not examinations of material
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quality. Thickness measurement procedures used for checking the reactor coolant pressure boundary valves were not uniquely created procedures .
but are procedures based upon industry accepted standards including ASTM Ell 4 and ASME V. The inherent repeatability of the thickness measurement process provides assurance that the process will yield accurate measurements.
JI #74, Motion at 24.
It is alleged that:
The QA breakdown for UT thicknes measurement procedures was not unique. Nondestructive test procedures also lacked documentation of Procedure Qualification Records or Tests. On January 18, 1982, in Internal Audit (IA)
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- 101, Mr. Hudson found this flaw in seven procedures out of 21 examined, including the two UT thickness procedures. This leaves the quality of work examined under those procedures indeterminate for items such as groove welds on pipe rupture restraints prior to 1979; safety yoke rods on safety valves; and welds in tne (sic) crack repair program on Unit #1 Steam Generator Feedwater Nozzles. (citina Hudson Af f. at 19-20.)
- 20. The seven NDE procedures referenced in this allegation are: :
a) ESO 246 and ESO 247, magnetic particle (MT) procedures b) ESO 236 and ESO 244, ultrasonic (UT) procedures developed i
j specifically for thickness measurements l c) ESD 270, a liquid penetrant (PT) procedure which at the time of IA l
- 101 had not been used at the Diablo Canyon Power Plant
! d) ESO ?il, an ultrasonic (UT) procedure for inspection of safety i
valve yoke rods e) ESD , an ultrasonic (UT) procedure for inspection of groove welds on rupture restraints. .
- 21. Procedures ESD 246 and ESO 247 are magnetic particle procedures that were qualified by Mike MacCrae, Pullman NDE Level III. These procedures were qualified using equipment equivalent to that used during the original examination of the welds in question. The'MT exams using 4
ESD 247 were performed on only two welds, FW 197 and FW 244, as an aid in eliminating a discontinuity on or near the welds. These tests were not code required but used as an aid in construction. Since this was'
- the only place procedure ESO 247 was used, and it was not a code-j required test, there was no code violation in using the procedure
, without a'PQR. ESO 246 was never used for any examination et Diablo Canyon.
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required by any code to have PQRs.
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- 23. NDE procedures are developed encompassing three main elements:
i scope / application, technique requirements, and acceptance criteria.
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) When required by a referenced code, qualification of a NDE procedure is accomplished for verification of technique only. Once the technique element has been verified as being capable of producing interpretable
- indications, any specified acceptance criteria may be utilized in
- conjunction with the established technique. Since AWS has different i
- accept / reject criteria than ASME, separate procedures were generated.
ESD 270 was written for AWS work, and ESO 210 was written for ANSI and ASME Section III work. The technique and penetrant materials are
{ identical for both, hence the PQR prepared for ESO 210 supports both.
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This nrncedure was produced using the Dresser Instruction SP-52-166 as a i
guideline. The inspection of the Unit i safety valve yoke rods, i
l although not a code requirement, was performed at PGandE's direction.
Pullman was directed to use Dresser's Instruction for the inspection i
guidelines, which was dor.e, while using a more restrictive sensitivity for the acceptance level than called for by Dresser's Instruction.
There was no requirement for a formal PQR for this inspection and one was not prepared. The qualification of this procedure is the ability to repeatedly calibrate to a known standard. The calibration results
! recorded on the data reports provide adequate documentation of the procedure qualification.
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m 25. ESO 234 is a procedure for UT inspection for groove welds on roture restraints. Although neither the AWS code nor PGandE specification I 8833XR required a PQR for this procedure, Paul Dawson, Dullman's UT Level III, produced a PQR for this procedure at H. Karner's directive on October 1,1982 in response to Mr. Hudson's audit (see Exhibit 4, attached.)
JI #85, Motion at 25.
It is alleged that:
Pullman violated NRC reporting requirements and PG&E (sic) contract specifications by only reporting.the deficiencies for two out of the seven nondestructive procedures identified in IA #101 to PG&E (11c.) on Discrepancy Reports. (citina Hudson Aff. at 21-22.)
- 26. Although a PQR was not required by Code or PGandE specification 8711, a Discrepancy Report (DR) identifying the lack of PQRs for procedures ESD 246 and ESO 247 was initiated. OR 4662 was initiated 'to resolve Mr. Hudson's audit findings and was dispositioned by PGandE to " accept as is."
- 101 for lacking a PQR. Since there were no code or PGandE specification requirements to have PQRs for these procedures, there was no need to submit a DR for any of the seven. .
JI #89, Motion at 26.
It is alleged that:
The corrective action for ESO 246 and 247 involved procedure qualifications after-the-fact, which are the least reliable means available and should not excuse PG&E
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,' (sic.) f rom accountability under NRC rules. Further, the PQT's were conducted with different equipment than had been used originally. No documentation was supplied to support the asserted Corrective Action Response that the new equipment made the results more conservative.
(citina Hudson Aff at 22-23.)
- 28. PQRs developed af ter the fact though not required still verify the techniques delineated in the procedure. As stated earlier,. the PQRs were developed to resolve Mr. Hudson's audit. Only two welds were inspected using procedure ESD 247 and these two welds, FW #197 and FW
- 244, were identified on DR 4662 as being inspected without a PQR. -
PGandE dispositioned the DR to " accept as is." The MT inspection of the referenced welds using ESD 247 was only an aid in verifying defect removal, and no code required this examination. Hence, a code violation did not exist by the use of the procedure ESD 247. ESD 246 was never used at Diablo Canyon, so no code violation existed with this procedure.
( 29. As stated in paragraph 21 above, the equipment capabilities used for the procedure qualifications discussed here was equivalent to that used for the original weld examinations.
- 30. Contrary to the allegation, no assertion was made that the new equipment made the results more conservative. Adequate documentation was supplied to support a PQR, if one were needed (see Exhibit 2 to Exhibit 4, attached). Qualification would result when a procedure would indicate a known flaw in a test specimen. In this case, the specifications of the procedure were followed, and acceptable and repeatable results were obtained. Because the amperage specified by the procedure was employed, the fact that a different piece of eqcipment was used in the qualification is not relevant. The result of the qualifying test was
_ the same and not more or less conservative.
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JI #75, Motion at 24.
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~ It is alleged that: ,
The corrective action for procedure ESO 234, UT inspection of pipe rupture restraint welds, consisted of unreliable, "after-the-fact" Procedure Qualification Tests, whose use was not controlled and accomplished using qualified procedures. (citina Hudson Aff. at 19-20.)
- 31. Since a PQT was never required, the allegation is false. ESO 234, the UT procedure for inspection of rupture restraint welds, was developed for use with AWS. The AWS Code does not require a procedure qualification record for UT procedures. The UT unit and the procedure are verified each time calibration is performed on the required calibration blocks.
- 32. Despite all of the above, the procedure qualification was demonstrated on October 1,1982, by Paul Dawson, NDE Level III at Harold Karner's request in response to Mr. Hudson's concern (see Exhibit 4, attached).
k This was. accomplished by performing ESO 234, as written, using all of the control elements of the procedure.
JI #76, Motion at 24.
It is alleged that:
IA #101 did not find evidence that management reviewed and approved the procedures for the PQT. (citina Hudson Aff. at 19-20.)
- 32. The allegation is false. The AWS Code, which ESO 234 is written to, does not require a procedure qualification record for ultrasonic examination procedures. Contrary to the motion, Mr. Hudson's affidavit states there is no evidenee that management reviewed and approved the l
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procedures for the PQT. The procedure ESD 234 was, in fact, approved by Pullman (R. Fink) and PGandE (J. Holly) as evidenced by their signature at the bottom of the procedure (see Exhibit 5, attached).
JI #77, Motion at 24.
It is alleged that:
QA Manager Harold Karner improperly prevented any corrective action for the lack of procedure qualification records on ESD 270 for Liquid Penetrant Tests. Instead, he directed that the Procedure Qualification Records for a dif ferent procedure ESD 210, should be used for
. ESD 270. "The unique features of ESD 270 inherently will not have a proven demonstration of their abil'ity to identify defects. This QA violation remains ignored."
(citing Hudson Af f. at 19-20.)
! 34. The allegation is false. ESD 270, was written to comply with the AWS Code. The AWS does not require a PQR.
(. 35. When temperature is outside code limits, a liquid penetrant PQR is .
required by ASME Code to demonstrate the ability of the technique and materials to detect surface discontinuities. A liquid penetrant procedure and supporting PQR, when required, are developed independently from the accept / reject criteria of the procedure. When two procedures use the same step-by-step technique and the same penetrant materials, the qualification of one logically qualifies the other. As ESD 210 and ESD 270 use the same technique and materials, even though their accept / reject criteria may differ, Mr. Xarner's decision to apply the PQR from ESD 210 to ESD 270 was correct. No corrective action was l
necessary.
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JI #78 Motion at 24.
m It is alleged that:
No investigation identified where ESD 270 was used. The QA manager told the internal auditor to just write up what he had learned already as an audit finding. (citino Hudson Aff at 19-20.) j
- 36. As discussed above, ESD 270 does not need a POR. Therefore, no audit finding was necessary and there was no need to find out where ESD 270 was used.
. 37. ESO 270 was written only as a contingency procedure for liquid penetrant of rupture restraint welds where MT would be impractical.
- 38. Regardless of the above, Mike MacCrae and Paul Dawson reviewed the liquid penetrant inspection daily log sheets from the date ESO 270 was approved until the date of the review and no area was found where ESD 270 had been used (see Exhibit 4, attached).
JI #50 and 51, Motion at 19.
It is alleged that:
Since July 1979 full penetration welds less than 9/16 inch thick have not been ultrasonically tested (UT). All such welds in the pipe rupture restraint program were left with indeterminate quality status, including those in the weld crack. repair program which already had been judged deficient. (citino Hudson Aff. at 9.)
PG&E (sic) engineers accepted the UT loophole informally, without the required review and without revising the relevant contract specification that was being ignored.
The loophole also violated specific corrective action commitmen,ts on nonconformance reports, and procedures for the weld crack repair program. (citina Hudson Aff, at 9.)
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- 39. In contrast to the Motion, Mr. Hudson's affidavit does not allege that rupture restraint welds are of indeterminate quality status or that any l welds had already been judged to be deficient in the weld crack repair p rog ram. Hudson actually alleges that PGandE engineers accepted
" loopholes" in Pullman's (rupture restraint) program in July 1979, and that full penetration welds less than 9/16" thick were not ultrasonically examined in violation of contract specifications.
- 40. This allegation is false. Beginning in late 1978, when PGandE identified a weld cracking problem in Pullman full penetration field welds on rupture restraints, PGandE conducted an extensive program to determine the cause and to formulate corrective action. This program was first documented on nonconformance report DCl-RM-78-008 dated October 3,1978, and reported to the NRC.
- 41. In mid-1979, PGandE's Department of Engineering Research (DER) conducted a thorough investigation and metallographic study of the welds as part of the rupture restraint field weld repair program.
, DER and PGandE Engineering Department made specific changes in welding and inspection procedures to assure weld quality. The single most important change was to add the requirement for magnetic particle examination (MT) after completing full penetration welds on all thicknesses. This change was included in Revision 13 to construction specification 8833XR on August 24, 1979 (see Exhibit 6, attached.) In conjunction with this change, the minimum thickness requirement for UT examination of full penetration welds was raised f rom 5/16" to 9/16" by issuance on May. 31,1979, of f
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PGandE UT Procedure DER 3523. " Manual Ultrasonic Examination of Weids and Plate in Pipe Rupture Restraints." Pullman was provided with, and instructed to use, Procedure DER 3523.
- 42. PGandE engineering revised specification 8833XR to make the important addition of MT examination to the weld inspection requirements but inadvertantly overlooked revising the specification to exclude a requirement of UT examination on all full penetration welds thinner than 9/16". The language of the specification appeared to require that welds less than 9/16," continue to be examined by UT as well as the newly added MT procedure. This created the quarter inch paper " loophole" about which Mr. Hudson complains.
- 43. At the time of the revision to specification 8833XR, Pullman modified its weld examination procedures to require MT for all full penetration welds and UT procedures for full penetration welds 9/16' and greater.
This revision was approved by PGandE in 1979, reflecting the clear intent of the specification change (see Exhibit 7, attached).
- 44. Contrary to the allegation, the corrective action comitment in the NCRs and weld crack program was not to examine full penetration field welds less than 9/16" with UT but rather to use MT.
- 45. Since 1979, consistent with the specification, procedures, and the comitment in the NCRs and weld crack program, the quality of all new full penetration welds on rupture restraints has been assured by the application of MT procedures.
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I JI #58 and 29, Motion at 20-21 and 15, respectively.
It is alleged that:
In some instances, the unreliability of nondestructive examinations is due to manipulation of the test results in order to mask deficiencies. This allegedly occurred ,
in 1982, with respect to tests involving around 230 Unit I (sic) full penetration welds - some in the containment
-- where UT examinations revealed large numbers of rejectable conditions, including voids, slag, and lack of fusion in the roots of the welds. These deficiencies raise questions about weld bonding. 8echtel and PG&E (sic) management responded by manipulating the UT procedure in a manner that would lower the number of rejected indications. The welds were then " accept (ed) as is" on the basis of relaxed acceptance criteria. (citing 1/12/84, Anon. Aff. at 8; 1/16/84, Anon. Aff. at 2-3.)
The failure to comply with weld procedure requirements led to "truly pathetic" welds for the pipe rupture restraints. In one case a backing bar for the weld was permanently held by tack welds designed to provide temporary support. The fusion was so weak that a light tap with a hammer knocked it off completely. (citina 1/16/84, Anon. Aff. at 2.)
- 46. These allegations combine the allegations from two anonomous affidavits
( dated January 12, 1984, and January 16, 1984. However, the first sentence, namely that test results were manipulated, is not supported by either of the affidavits cited as authority. One-underlying affidavit spoke only to " change of ' acceptance criteria,'" which is substantially different than " manipulation of test results." (1/12/84, Anon. Aff. at 8.)
- 47. In August 1982, field welds on rupture restraints in Unit 2 were observed by a PGandE inspector to have incomplete fusion to backing bars. In order to visually inspect the field welds, the backing bars were removed by chiselling and grinding. To identify and track the problem, two NCRs (00;-82-RM-N001 and DC2-82-RM-N002) and an i
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investigation procedure (8833XR-001) for the full penetration welds in Unit I were written.
- 48. As originally written, the investigation procedure required the welds to be re-examined both by the UT procedure in existence at the time the weld was made and by the 1982 UT procedure. Most of the welds examined with the 1982 procedure showed indications which may or may not have
- required rejection under the original ~ acceptance criteria.
- 49. Independent of the investigation program, an analysis of the UT procedures being utilized by the program was performed by Bechtel Materials and Quality Services, the equivalent of PGandE's DER. The analysis determined that examinations using the original procedure were not repeatable. This conclusion corresponded to a determination made by PGandE in 1979, when use of the. original procedure was discontinued and all welds examined under this procedure were addressed by PGandE engineering. The analysis also determined that the procedure developed by PGandE in 1979, and still in use in 1982, was more stringent than the applicable requirements of AWS.
- 50. As a result, a third procedure (PGandE Procedure 3523-M), the one challenged by Mr. Hudson, was developed and utilized, which reflected the current AWS requirements. This UT procedure was not manipulated in any way. As direct proof, under the new procedure, 40% of the welds did not meet AWS acceptance criteria.
- 51. Characteristics and location of each individual weld included in the 40%
j were submitted to engineering for a deta.;ed analysis to determine each i
weld's fitness for use under its intended design purpose.
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- 52. The weld's fitness for intended design purpose was demonstrated by engineering analysis or the weld was replaced or repaired. As a result l of this program thirteen welds of the same joint configuration were repaired..
- 53. Under the program, there was no manipulation of test results.
Procedures utilized adopted code requirements, and individual welds were analyzed to determine fitness for intended design purpose consistent with proper engineering standards.
- 54. From the initial discovery of the problem through its resolution, a well thought out and well controlled program was conducted in accordance with established quality assurance requirements.
JI #64, Motion at 22.
( It is alleged that:
Mr. Hudson's January 1962 Unscheduled Internal Audit (UIA) #34 of 254 Valve Wall Thickness Data Reports demonstrated that the Data Reports are incomplete and not traceable, as required. For example, none listed the size, shape, or manufacturer's designation of the transducers that performed the wall thickness. The .
ESD 236 Documentation Packages at most included the serial numbers for the testing equipment, and not in all
. cases. (citina Hudson Aff, at 17-18.)
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- 55. The allegation is in error. When performing thickness measurements, transducer size, shape, or type is not required as an entry on the data report by procedure or any referenced code. For example,Section V of ASME requires only that thickness measurements be conducted at a frequency capable of resolving the thickness range to be measurtp.
While the concern referenced in the allegation might be applicable for ultrasonic flaw detection, it is simply not an issue as applied to
( }, thickness measurements.
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- 56. The basic requirement is that measurement innruments be routinely calibrated. Traceability of transducers is not required and such a requirement would make no sense since it is only a part of the calibrated system. If a transducer fails, it is thrown away. Another transducer is then used and the system is recalibrated. Retaining a
" paper trail" on the transducer would serve no QA or QC purpose and there is no such requirement.
- 57. As previously discussed, the apparent origin of Mr. Hudson's allegation is a basic misunderstanding of NDE QA/QC requirements.
JI #65, Motion at 22.
It is alleged that:
The Data Reports offered unreliable, inconsistent information, such as 19 reports crediting two different
, UT machines for measuring the same valve. Valves checked physically had serial numbers different from those listed in the Data Reports. Original information in the reports was whited-out and altered without signature or explanation. (citina Hudson Aff at 18.)
- 58. The preprinted Data Report used during this time period identified two UT machines (a Nortec and a Branson Unit). The record keeping technique was to either line through the unit not used or circle the unit which had been used on the data sheet. Neither a line nor a circle appears on 19 data reports, thereby failing to indicate which unit was used.
However, the Nortec unit was only used during procedure development, not to collect actual wall thickness data. Therefore, the Branson unit was applied in all cases identified by Mr. Hudson.
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The minor documentation discrepancy is of no substance, since only one machine was actually used. Even this discrepancy which has no technical significance was caught and resolved satisfactorily, thereby demonstrating a fully functioning QA program.
. 60. The second aspect of this allegation relates to questionable serial j numbers on valves. The two valves Mr. Hudson identified have been physically checked by PGandE, and the serial numbers do indeed match the Data Report serial numbers and are traceable.
- 61. Mr. Hudson was correct regarding use of white-out on the reports. -
j White-out was commonly used for correcting clerical or transcription errors on paperwork by Pullman Power Products prior to 1974 and it did not seem to pose any credibility problems at the time. This practice t
was prohibited in the mid-1970's.
b JI #66, Motion at 22-23.
It is alleged that:
Necessary records were not consistently available to demonstrate calibration of the measuring equipment. To demonstrate the potential, lack of calibration skewed 4
results from 2.6% - 48%. The maximum error permitted by the AEC was 2 percent. (citina Hudson Aff. at 18.)
- 62. Contrary to the allegation, the records of UT equipment calibration are maintained in Pullman's quality assurance documentation vault and are i available for review. PGandE has confirmed the thickness accuracy of the ultrasonic calibration blocks by the use of micrometers calibrated to steel reference blocks traceable to the National Bureau of Standards. The ultrasonic machine had been calibrated using calibration l
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- 63. For example, one calibration report noted that the mechanical (micrometer) point on the valve body being measured was .260". The subsequent UT measurement showed .280". The UT machine was then adjusted to .260" and the wall measurement taken.
- 64. According to Unscheduled Internal Audit (UIA) #34, Mr.. Hudson compared the mechanical reading and the UT reading, identified the difference and assumed the test was conducted without accounting for this difference.
Mr. Hudson's concern with this alleged failure to account for the difference in measurements once again points to his lack of understanding of the technical aspects of ultrasonic equipment
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operation. It is standard for an ultrasonic technician to make this type of adjustment to compensate for acoustic variations when needed even though the technician records the actual mechanical and UT reading (see Exhibits 8 and 9, attached).
JI #67. Motion at 23.
It is alleged that:
Valve measurements from equipment that failed minimum reliability standards improperly were used to accept the valves as sufficiently thick. (citina Hudson Af f. at 18.)
- 65. Contrary to ...e allegation, the ultrasonic equipment did not fail. The equipment was calibrated using calibration blocks and calibration points i
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requirement. The machine then was checked against micrometer points to account for any accoustical difference between the blocks and the valve body. Had the machines failed, they could not have been calibrated.
The machines and procedure met the accuracy requirements and showed all valve body measurements within the 2% accuracy required (see Exhibit 2, attached).
JI #68, Motion at 23.
It is alleged that:
Valves that should have failed may still remain uncorrected. Although forty-two Data Reports disclosed that the valves were below the minimum thickness, on the paperwork they were marked as " accepted" without
- explanati.on. (citino Hudson Af f. at 18.)
( 66. This allegation is false. No valves that failed the AEC requirements were installed.
- 67. The Motion, as worded, is somewhat dif forent than the allegation as described in the referenced Hudson affidavit. The first sentence,
" Valves that should have failed may still remain uncorrected," does not appear in Mr. Hudson's affidavit. UIA #34 referenced in the affidavit i does mention a concern that rejected valves might possibly be installed in the plant but does not address valves that should have failed being
-uncorrected.
- 68. The signoff on Line 7 of the data report, " Valve Identified," was to verify the valve was tagged with a white identification (ID) tag. These 10 tags were applied to all valves. As required by Pullman's QA manual, l
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, and stored in a hold area. PGandE has reviewed all associated data sheets and confirmed that all valves identified as under minimum wall thickness were either replaced, repaired, or accepted through engineering evaluation, and all are adequately documented.
JI #69, Motion at 23.
It is alleged that:
In 11 cases, the measurements were incomplete, with missing data for required areas of the valve, such as the
- flat pad at the bottom. (citino Hudson Af f. at 18.)
- 69. This allegation is incorrect. Mr. Hudson was unaware of other data for the valves collected by Westinghouse. The eleven valves in question were new valves that Westinghouse had shipped to replace originals that had been returned for unacceptable wall thickness. Westinghouse performed full UT thickness measurements on the new valves prior to shipment to the site. Therefore, ng measurements were required by Pullman. However, upon receipt of these valves at the site, it'was noted that certain areas on the valves were identified in the supplier's documentation as being close to minimum.
- 70. PGandE elected to perform certain additional thickness measurements on i
the valve areas in question. Pullman performed these tests _ and found the valve wall thickness to be acceptable. Pullman was not requested to, nor did they, examine all areas of the valves. This.*? sting was an j G w n mm_~:q<;.c;*-W
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a PGandE memo to file from H.E. Petersen, " Wall Thickness of 10C482 l Check Valves documented in Westinghouse letter PGE-2479," dated December 5, 1973. Mr. Hudson apparently did not gather this information in his audit.
.11 #70, Motion at 23.
It is alleged that:
UIA #34 could not find evidence that all required welds were measured. In 14 valve locations, there was no documented evidence of an examination. (citina Hudson Af f at 19.)
- 71. This allegation is factually correct, but has no technical or QA significance and the implied conclusion is incorrect. Mr. Hudson did not have access to information discussed below demonstrating that these
(' valves were acceptable.
- 72. The fourteen valves identified were excluded from valve wall thickness requirements either as a result of the valve body not being the pressure containing item, or they were deleted at a later date by an amendment to the original list by Westinghouse, because evaluation showed these valves were not part of the primary pressure boundary. These valves are:
1-8010 A, B, & C Valve wall measurement was not 2-8010 A, B, & C required in accordance with the exception described in Westinghouse Letter PGE-2080.
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Valve identities were changed by an amendment issued March 14, 1973 (Westinghouse Letter PGE-2273).
JI #71, Motion at 23.
It is alleged that:
UIA #34 reported the lack of documentation indicating that weld repairs on the valves were controlled. To illustrate, the Data Repor ts do not have a requirement to list whether valves were weld-repaired, or the weld procedure used. (citina Hudson Af f at 19.)
. 73. This allegation is incorrect. Although documented elsewhere, no requirements exist in ESO 236 for UT thickness data reports to include documentation on valve weld repairs.
- 74. Valves that were found to have unacceptable wall dimensions were returned to the vendor for repair or replacement. These valves, when returned to the site, were remeasured, as described in paragraph 69 above and UT data reports for these repaired or replacement valves are included in the documentation packages for ESD 236.
- 75. Weld repair procedures used by the valve vendor were controlled by the vendor and submitted to the AEC July 23, 1974. Since repairs were not performed on site, there was no requirement or reason to submit these weld repair procedures to the site contractors.
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JI #72, Motion at 23.
It is alleged that:
None of the valves meet AEC and PG&E (sic) design requirements. Westinghouse, the manufacturer, had explicitly declared that they "were not designed to meet the minimum wall thickness requirements of ANSI B16.5" --
one of the relevant professional codes listed by the AEC i in 1972. Based on a comparison of Westinghouse's t communication with PG&E (sic) contract specifications, the valves also do not meet the design requirements in the contract. (citino Hudson Aff. at 19.)
- 76. The allegation is in error in that the AEC did not establish valve design requirements. Additionally, ANSI 816.5 was one of numerous codes referenced by the AEC in 1972. Mr. Hudson erroneously compared the valves to Pullman's contract specification 8711, not as he should have done, to Westinghouse's contract specification 8700.
- 77. As a component of the Nuclear Steam Supply System supplied by Westinghouse in accordance with Specification 8700, the subject valves
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were actually designed and fabricated to the requirements of USAS B16.5, properly using the stress criteria of ASME BPVC,Section III, as the basis for establishing stress levels. ASME Section III, Article 9, was properly used for operational design requirements.
- 78. The requirements of USAS B31.1.0 were. met. The requirements defined in subsection 50.55(a) of 10 CFR 50 specify the use of USAS B31.1 or USAS 831 .1 .0. USAS B31.1.0, Chapter IV, " Dimensional Requirements,"
paragraph 126, directs the use of USAS B16.5 for design and fabrication of valves and is the basis for its being used as the criteria for the pr. surizer safety valves. As defined by Westinghouse in letter i
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- 79. In summary, Mr. Hudson was erroneously attempting to audit valves supplied by Westinghouse to Pullman's contract requirements, a classic
" apples and oranges" comparison.
JI #73, Motion at 23.
It is alleged that:
Management did not work with the originator of UIA #34 to develop corrective action. As a result, the quality of the welds may be as indeterminate now as in 1972, again because of a deliberate management decision not to find out. (citing Hudson Aff, at 19.)
- 80. Again Mr. Hudson has cited a single correct fact f rom which he draws a
( completely erroneous conclusion. In accordance with established procedures, receipt of UIA #34 was acknowledged in writing by Mr. Paul Dawson, NDE supervisor, on February 15, 1983. This acknowledgement signifies Mr. Dawson's responsibility for preparation of the appropriate corrective action. As Mr. Hudson was not certified as an NDE technician and, therefore, could not be expected to provide detailed technical input, Mr. Dawson investigated the ' matter and verified that 14DE procedures were properly utilized without requesting additional assistance f rom Mr. Hudson.
- 81. Mr. Hudson left his job with Pullman QA/QC on May 19, 1983. The ,
development of an acceptable corrective action for UIA #34 required an extended period of time. The audit was, however, closed out on g-
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- 34 demonstrated that, in fact, the UT examination of boundary valve
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i wall thicknesses was performed in an acceptable manner.
- 82. The motion also alleges that "the quality of the welds may be indeterminate." As UIA #34 did not deal with welding, but rather with ultrasonic measurement of boundary valve wall thickness, the allegation as contained in the motion has no basis even in theory, let alone in fact.
i JI #80, 81, Motion at 24-25.
! It is alleged that:
( ESD 241 was used for tests f rom December 17-20, 1973, before the UT procedure itself was even issued on December 26, 1973, and prior to PG&E's (lig,) February 12, 1974 approval. The testing was totally uncontrolled for i
the yoke rods on these valves, which control the release of radiation from the containment. (citine Hudson Aff.
at 20-21.)
i- ESD 241 violated inst uctions from Dresser, the vendor for bolts and studs, that required examination of the
~i rods before threading. In ESD 241, the UT's (sic) were conducted af ter the threading. ESD 241 also ignored the Dresser instruction to determine the reference point for sensitivity, and the reporting criteria for questionable items. (citina Hudson Aff. at 20-21.)
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- 83. The yoke rods in question are part of the Unit 1 Steam Generater Safety Relief (SGSR) valves. Contrary to the allegation of Mr. Hudson, the purpose of the valves is to prevent over-pressu.*zation of the non-radioactive secondary side of the steam generators, not "to control-O "'
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. 1 m the release of radiation f rom the containment." The valves were ordered from Dresser Industries in 1969 under PGandE Purchase Specification 8730. The purchase specification required that the valves be manufactured to meet the requirements of ASME,Section III, Article 9.
This article of the code does not require any type of nondestructive examination of the valve yoke rods. At the time of the manufacture of the rods, Dresser had no requirement for nondestructive examination.
Consequently, nondestructive examinations were not performed on the yoke valve rods by the manufacturer before shipment of the Unit 1 valves to Diablo Canyon in May 1972.
- 84. During the later manufacture of the valves fo'r Unit 2, Dresser revised their manufacturing process to include ultrasonic examination of the bar stock to be used for valve yoke rods. This requirement was implemented using Dresser Engineering Instruction SP-52-166.
. 85. UT examinations on the Unit 2 rods being manufactured disclosed anomalies in the rods causing their rejection.
- 86. In response to the examination results. PGandE directed Pullman to perfons UT inspections of the Unit I rods, utilizing the applicable portions of Dresser Instruction lSP-52-166. However, the Dresser Instruction was designed for testing during the manufacturing process prior to threading of the rods. Since the Unit 1 rods were already manufactured and installed, the' Dresser Instruction could only be used as a starting point to develop a procedure for UT of the already installed valve yoke rods. -
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wave inspection, neither of which were included in Dresser Instruction SP-52-166.
- 88. At PGandE's direction the Level III from Pullman documented the UT procedure he developed and utilized to examine the rods in Unit 1. The UT method developed by the Level III resulted in a conclusive and repeatable examination wh,ich was formalized in Procedure ESD 241.
- 89. While Mr. Hudson is procedurally correct in his alleg.ation that ESO 241 was referred to as the applicable procedure prior to its approval date, assigning a numeric designation prior to procedure approval is a common industry practice, especially when, as here, a modified method is developed for use to meet a specific condition.
JI #79, Motion at 24.
It is alleged that:
ESD 241 for UT of the safety valve yoke rods also was performed without evidence of Procedure Qualification Records, according to IA #101. (citino Hudson Aff. at 24.)
- 90. As has been noted throughout this affidavit, a PQR was not required for ESO 241. The procedure was developed and approved by a NOE Level III
- and qualified each time calibration wts accomplished in accordance with l the procedure.
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It is alleged that: )
The existing test documentation fails to comply with either the ESO 241 or the Dresser Instructions. IA #101 concluded that required information on the testing surface and instrument calibration was missing. (citina Hudson Aff. at 21.)
- 91. Mr. Hudson alleges that the test reports failed to document the surface or surfaces f rom which the yoke rod examination was to be performed as required by ESO 241 and Dresser SP-52-166.
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- 92. Contrary to the allegation, there is adequate information on th'e data reports to satisfy the requirements of the procedure. The reports specify that the material examined were rods from bar stock. Only two surfaces of the rod can be measured: the length, which is the curved outer face, and the flat portion of each end. Since the data reports also state that transducers with curved shoes were used to perform the examination, it is obvious that the examination was conducted from the curved outer face of the rod. Mr. Hudson concedes this fact on page 2 of Exhibit 3 to Attachment 2 of JI Motion which page was conveniently omitted from that exhibit (see Exhibit 10 at 1-2, attached).
- 93. Mr. Hudson alleges that the test reports failed to include a description of the calibration block (size, material, basic calibration reflectors),
as required by ESD 241 and Dresser SP-52-166. This is correct, but not significant. A description of the test block is contained in ESD 241 i
l Sections 11.4 and 13.1. The basic calibration reflectors are described
( in ESD 241- Sections 11.4.1 and 13.2. The calibration method is described in ESO 241 Sections 10,11, and 12. Th.e purpose.of describing h
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procedure itself has sufficient data to reproduce the block if it were not. A comparison of the test block used in the 1973 tests, and one of the yoke rods examined in the 1973 tests, was made on February 29, 1984, by both a Level II and Level III UT Technician. This comparison confirmed that the yoke rods and the test block are acoustically similar. The results of this comparison have been added to the yoke rod data packages.
- 94. Mr. Hudson alleges that the required calibration intervals described in Dresser SP-52-166 and ESD 241 were not adhered to. The procedure did not require documentation of all specified calibration intervals.
Despite not being required to document calibration intervals, the NDE technician reconded sufficient information on the data reports to assure that any differences between the actual calibration interval and the frequency interval required by the procedure can be determined. ESD 241 required the identical calibration intervals as Dresser SP-52-166. The
. checks were to be made before and after each production run, each 1/2 hour, and each time the machine was believed to be malfunctioning. The summary report from the 1973 tests shows that calibration checks were made before and af ter each yoke rod was examined, approximately 15 minutes prior to each technique, and whenever a discontinuity was suspected (see Exhibit 11, attached),
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p 95. While the summary report does not specifically indicate calibration each 1/2 hour as discussed above, the information on the report is more than adequate to determine the. accuracy of the equipment, and the lack of this entry is of no significance. Even Mr. Hudson concedes that the calibration intervals were "most adequate," although this information was also omitted from the exhibit attached to Joint Intervenors Motion (see Exhibit 10 at 2, attached).
JI #83, Motion at 25.
It is alleged that:
Neither ESD 241 nor the UT test documents demonstrated compliance with a PG&E-imposed (sic) requirement for backup inspection of the yoke rod ends for indications of cracking that might extend into the threaded area. . ."
(citino Hudson Aff. at 20-21.)
- 96. At the time the UT procedure was directed to be performed on the valve
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yoke rods of Unit 1, PGandE's responsible Design Engineer indicated that "In addition to the UT inspection, a back-up inspection should be performed with the dye penetrant technique to check the yoke rod ends for indication of cracking that might extend into the threaded area of the yoke rods." On February 5, 1974, approval to eliminate liquid penetrant examination through an engineering release was sought and received f rom the responsible engineer who had suggested the additional test (see Exhibit 12, attached).
- 97. The threadea portion of each rod is approximately 25% of the overall rod l length and is inaccessible for the PT 6. amination without disassembly of l
the valve. However, the manufacturing process and the materials used do i
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not normally produce isolated discontinuities. This information, together with the fact that there were no rejectable indications in the remaining 75% of each rod, provides reasonable assurance that each rod is acceptable without examining the. threaded portion.
- 98. Mr. Hudson's concern that PGandE review elimination of the PT requirement was satisfied in February 1974 (see Exhibit 10 at 3, attached).
JI #84, Motion at 25.
It is alleged that:
Mr. Karner improperly reneged on corrective action commitments on the basis of a memorandum from John Guyler, Mr. Hudson's successor as internal auditor. Mr.
Guyler dismissed the detailed, documented OR which Mr.
Hudson had proposed with an inaccurate assertion: "PPP has accomplished this per instruction from PG&E (si.c.). c It is evident that a nonconformance does not exist and a b- DR is not necessary. (citino Hudson Aff. at 21.)
- 99. As opposed to reneging on the corrective action cons.:itments agreed to during a September 14, 1982, meeting (i.e., to prepare and submit a DR to P6andE), Mr. Karner instructed Mr. Hudson to prepare a draft OR which was submitted for appropriate review on November 3,1982. In the course of reviewing this draft DR, it was determined that the work in question was performed in accordance with an appropriate procedure. Mr. Guyler, the Pullman Internal Auditor, reported this investigation and conclusion in his memo of January 16, 1983, which stated that a'nonconformance did not exist and that a DR was not necess'ary.
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100. Mr. Hudson fails to state that he was involved with the final closure and approval of the action that was taken. He reviewed the responses, signed of f and closed Audit Action Request ( AAR) #1 of Audit 101 on March 22, 1983. At the time of closure, Mr. Hudson did not indicate that he was dissatisfied with the response and manner of closing AAR #1 (see Exhibit 3, attached).
Oated: March 19, 1984 J. ARNOLD
$.O. R. CA09 c&f' H. W. KARNER
/2a/s A..A.TORSTROM Subscribed and sworn to before me this 19th day of March, 1984. , , , , _ .
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Notary Public in and for the e-County of San Luis Obispo
- State of California My connission expires January 2, 1987
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LINITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
)
In the Matter of )
) Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC ) 50-323 COMPANY )
) (Construction Quality Assurance)
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) )
)
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AFFIDAVIT OF RONALD G. FINK STATE OF CALIFORNIA )
) ss.
COUNTY OF )
SAN LUIS OBISP0 )
f I, Ronald G. Fink, being duly sworn, depos.e and say:
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- 1. I am Vice President of Reactor Controls, Inc.
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I have reviewed the Joint Intervenor's Motion to Reopen the Record on Construction Quality Assurance and Licensee's Character and Competence dated February 22, 19,84 I have assisted in the preparation of responses to allegations, #61, 65, 68 and 76 in the Motion. The responses to these issues are true and correct to the best of my knowledge.
DATED: March 19, 1984
,/
Mr. Ronald G. Fink
/
Subcribed and sworn to before me this 19th Day of March, 1984
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Notary Public in and for the State of Florida - ,, '
My Commision' expires ,
j Noisy Puh5r, State of Ra,ge
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Date %.M Egiras Der,6.1986
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Exhibits
- 1. Atomic Energy Commission letter to PGandE dated June 20,'1972.
- 2. Nuclear Regulatory Commission letter to PGandE dated May 12, 1975.
- 3. Audit Action Request No.1 to Internal Audit #101.
- 4. Affidavit of P. Dawson dated March 18, 1984.
- 5. ESD 234, page 1.
- 6. Revision 13 to Specification No. 8833XR, dated August 23, 1979.
- 7. QA Instructions 143, dated July 6, 1979.
- 8. Af fidavit of G. Larson and D. R. Cady dated March 16 and 17,1984, respectively.
- 9. Affidavit of D. Geske dated March 17, 1-984.
- 10. Interoffice Correspondence of H. Hudson to QA/QC Manager, dated November 22, 1982.
- 11. Report of Ultrasonic Examination dated December 17, 1983.
- 12. PGandE Memorandum f rom C. K. Maxfield/M. R. Tressler to M. H.
Chandler /R. S. Sain, dated February 5,1974.
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- i IIeRMEl.cY. cal.lftoT4MIA 9INd Truriesssas esta6 tat sam us 5
June 20, 1972 i ,
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O Facific Cas and Slactric Coopsny
/
, 77 Benie Strast Docket ilo. 050-0133 -
san Yrancisco, California 94106 Docket No._0f0-0278
. , - Docket No. 050-03M
'1 Attantion! Hr. Frederick T. Searla ~
S!
Vice President and'Canaral Counsel T Centlement Information obtained during "inapactions conduerad by the Directorate C of Regulatory Operations has disclosed that a number of facilitics I C3 have bewn- equippi.d with valves with ' wall thicknesses below tha mini- I munt rcipiirements specified by the applicable codas, standards and '
precurenant specifiestions. In other instances,11cenaces have not C been chie to docueiant whathor or not their valvas raat minir.us wall thicknasa requirements. Cur / survey of this subject has disclosed thne the matter la not limited to any cinsa of licensas or valva suppliar.
In light of the abova information, you are raquested to verify, through manufacturing' reecrds or other suitable taeans, that valves important to nuclear esfaty installed or to be dnatalled at your facility (iss) mean the minicu.s us11 thickness requirements of the specified codes or g ctsndards. To the axtant thac varification records are currently ;
available, you ara requestad to promptly accumuista thosa. recorda at .-
tha plant site, and to advise this office within thirty (30) days of the d:re of this letter of uhat records are available and when our l lumpcctor m.ty exa. mins them st the plant site. ;
I In the avant that records sea rict currently available, you ora re- !.
quested to advise this office within thirty (30) days of your plana -
. and acnadules for deconstrating by nuitable algarriate means that
- valves it.: percent to nuclear antaty installed or to bn tieweniled at yaar fa :1Ur.y(1sv) . ira accopta:s La wLeh c.rspect to u.ill ch td.ws.1.
Racords of conformancs shall bo 'mainesiaod current uith inspec:ioco performud.
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20# 1100102 .
22:21 20/20 x e e' -
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Pacific mi.s .aad 31octric Co, 2 Juns 20.'1972 _
l The vsivoa which ra.tuire demonar.rnctin of acceptabla wait thichnsas are the followina,:
Each valve within the reactor coolant pressure boundary, sa C definor.t in subsection 50.55(e) (Codas and Standerda) of 10 l CFR 30, where the valva ta: .
4 i e (s)- Over 1-inch nominal pipe size for pressurized water :
reactors; !
e- 1 y (b) Over 11/4-inch nominal pipe sis's in water 11nos for
- 1 boiling water reactora; ,
N (c) avar 2 1/2-inch nominal pipa sino in sesum lines for i y boiling water ranctors. I N 'nte following techniques are censidered to be a sufficient demon .
atration of acceptable wall thickness'. Alternata techniques may be C cff ared. but there is no nasurance that thay will, be found acceptablet'
( (1). Documented direct physical masaurament, of actual well thickness with ccmperizon to apscifisd minimum wall I thickness.
(2) Documented results of ultrasonic canautement of wall thickness with campsrison to apkcifical minimum wall l thicknssa, and docus antation that the ultrasonic measurs-ment techniqua is damonstrated to have a maximum error in repeatability and accuracy of not :nors the!i 2% of "'
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the wall chickn".sa. l '
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! I (3) !!all thicknesses, verified by either of the above _
techniques. to be not less than 90% of specified .
ninimum unit thickness will be acceptable, provided I that the documenend machanics1 characteristics of ths msential oxceert the specificacion minimum by an anount .
sufficient to compensate for the measurad roduction in :
un11 thickness. I (I.) "Specified liinimum tin 11 Thicknar a," as used above, means
..ha
- 'll tSLchn na remite. l by the rol.ivant codon nmt c eaiusu rda (e. g. , .ti.\ 01.1 (195.1); UCAS 331.1.0 (1967)i USAS 316.5 ; MSS-S!'-66) in eff e.ct on the date of the purchase ordce.
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1 80 30 80# T100TC2 92:2T 20/20 June 20, 1972 l h -
Pacific ca.4 EndElectricco. 3
. I (S) Certain ei your valves may have, for procurement con-g venienca,'been ordered to ratings higher than actually required by service conditions. In such instances, you
. may, if you wish, provide for our raview an engineering justification fo. accepting valves which do not conform to procuren>ent spesifications, but do, in your opinion, satisfy service requirements. Such justification should be .promptly transmitted to this offica in tan (10) copise.
l (6) In certain instances, you may wish to repair valves found co have well thickness below the specified minimum. In such instances, you are requested to provide to this offics for our review the proposed repair procedure, including
- a description of techniques to ha used to verify ths l
- .s.'" acceptability of the repaired components. Such a pro- -
pesed precadura should also be submitted in ten (10) copies. ,
Acespenbla documentation of conformance with tha abovs requirements must be complaced within thrse (3) years of the dets of this latter.
j Sincerely,
$ ( ~, -
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- 3. \l, Selth Dirsctor, Region V. -
( . Directorate of i
N gulatory Operations cc: Warren Ray =end, Humboldt Ecy lluclear Pcuer Station J. D. lierthington, PC&E C. Richards, PC&E Decket Mos. 50-?75 323 - Diablo 7anyon 'Jnita 1 and 2 i
bcc: S LSiblay MCerdes JFLlonner PJIPeterson JDWorthington HPBraun , g FFMaut: 1GGlielke FTSearls CH5e'am BWShackelford JF?aylor JCMorrissey F;EHall WBAllan RVBettinger MHQ.andler JACrockwell NHDaines. REDewey ARTodd WRJohnson DVKelly PMatthew A:IMcCollum HRPerry GVRichards RWWhite J0Schuyler WJr.indb lad JGFoster Vitt,ind Wufurray VCNevarino (J. W. Dorrycott)
PRDraeger JGMeyer 77.Cu1Well AC0minh t
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UNtTCD STATES 4
.Uct. EAR REGULATORY CoMr.11sSION. MHC RECEIVED DJt.'
acctON v - MANAGER'S HJC UNE svare zoz.wawur execx ri.aza EH CJK
' . isse w. cauronma soui.cvano WRH CFP wamur enecx. cauronma sassa REM MAY I 61975 ' ,,
sranon censr.
CEPARTMENr l exarsIT so. 2 ,t;y { 3 3g{
Pacific Gas & Electric Company Docket No. 50-275
- 77 Beale Street Diablo Canyon Unit 1 San Francisco, California 94106 Attention
- Philip A. Crane, Jr.
Assistant General Counsel Gentlemen:
This refers to the inspection conducted by Mr. W. G. Albert of this office on April 28-30, 1975 of activities authorized by NRC Construction '.
Permit No. CPPR-39, and to the discussion of our. findings held by Mr.
Albert with Mr. C.' K. Maxfield and other members of you.' staff at the conclusion of the inspection. , ,
' Areas examined during this inspection are described in the enclosed' /
y inspection report. Within these areas, the inspection consisted of" '
selective examinations of procedures and representative records, inter -
- views with personnel, and observations by the inspector.
! No items of noncompliance with NRC requirements were ident.ified within .
the scope of this inspection. .
4 in accuraance with Section 2.790 of the NRC's " Rules of 'iractice,"
Part 2. Title 10, Code of Federal Regulations, a copy of this letter and .
the enclosed inspection report will be placed in the NRC's Public. .
l Document Room. If this report contains any information that you believe
' to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the'date of this letter,'r.equesting i that such information be withheld from public disclosure. The applica-tion must-include a full statement of the reasons why it is claimed that the information is proprietary. - The application should be prepared so
(
- that any proprietary information identified is contained-in an enclosure' -
l to the application, since the application without the enclorure will i
also be placed in the Public Document Room. .If we do not hear from you in this regard within the specified period, the report will be placed in -
the Public Document Room.
. yet.uno, 5f.Q E i 6 $c E Y
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1 1 1 Pacific Gas & Electric Company MAY 121975 e i Should you_ have any questions concerning this inspection, we will be ,
glad to discuss them with you.
Sincerely, q'r u
'h R. H.
wiu gelken 6 Director
Enclosure:
IE Inspection Report No. 50-275/75-06
, cc w/o enclosure:
G. V. Richards, PG&E J. D. Worthington, PG&E .
bcc: CPUC Application No. 49051
- bhcc: ,JFBonner JDWorthington HPBraun FFMautz FWMielke
, CHSedam BWShackelford JFTaylor GABlanc_ WBAllen-
- k. TABettersworth KVBettinger RFCayoh h g ndler7 -'
JAcrockwell NHDaines EEHall WRJohnson DfiGlly '
PMatthew AJMcCollum HRPerry GVRichards JOSchuyler WJLindblad ARTodd RWWhite JGFoster WLMurray GFClifton SLCulwell ACSmith JCCarroll HReynolds .
(NUS) (JWDorrycott)
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0FFIc9 0F INSPECTION AND ENFORCEMENT t- . REGION V .
.. ~
, b Inspection Report No.
- 50-275/75-06 -
Pacific Gas & Electric Company Docket No. 50-275 Licensee 77 Beale Street . . -
License No. CPPR-39
- San Francisco, California 941'06 Priority A
, Facility Diablo Canyon Unit 1 Category Location San 1.uis Obispo County', California ,
Type of Facility PWR, 3411 MWt Westinghouse -
. Type of Inspection Routin9. Unannounced Dates of Inspection Aoril 28-30, 1975 l Dates of Previotts In' s pection Fab. 10-17. lo74 /ree+,..u.*wf Pr# cipal Inspec' to'r - h (' '-( . '] ' h ~ Y[
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. . W. G. Albert, Reactor Inspector ,
/.Date
- i Accompanying Inspectors None l Date
" Date Other Accompsnying Personnel: None -
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- Reviewed by .[ c E .,t2 w C [t -
bo 7, G. S. Spencer, w Chief, P.eactor Testing & Operations Br. D <
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SUMMARY
t . .
Enforcement Action
. . I None _
Action on Previously Identified Enforcement Matters
- Not applicable Design Changes Not examined Unusual Occurrences The inspector discussed repairs to the Unit 2 containment liner as a result of a fire on March 6,1975. No new information of significance
.- .was noted, therefore further reporting will be deferred until the next routine inspection of the Unit 2 facilitf. , ,
Other Significant Findings .
A. Construction is 92.3% complete. (Paragraph 2 in Details)
.__(~-
B. The NSSS supplier has completed implanting sample tubes for corrosiore
.- testing in a steam generator. (Paragraph 3 of Details)
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C.. The NSSS Supplier has completed the tube expansion program.in the steam generators in preparation for the use of volatile chemistry treatment for the secondary system. (Paragraph 3 of Details)
~
MaEaqsmb5t" Interview .
At the conclusion of the inspection the inspector met %ith C. K. Maxfield and other members of his staff to review the findings from the inspection.
The following significant items were discussed:
A. Yalve itall Thickness Measurement Program _
The inspector stated that he had examined the final data packages for the measurement of. valve wall thickness and considered the item closed for both units. (Paragraph 4ofDetails)
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!.' 2 B. Housekeedinq -
The inspector noted that cleanliness controlsThe observed licenseeinstated the area of the reactor pit seemed to. be ineffective.
that the situation would be examined to see what improvements could '
. be reasonably made. (flo reference in Details) ,
C. Electrical Insulation Reoairs 4 & 12 KV Switchgear This item was re-opened after noting a difference After examining theinrepairsthe methodthe - of repair for Unit i versus-Unit 2. (Paragraph 5 i
difference in repair methods appeared to be warranted.
of. Details) .
D. Close Out Records '
The inspector found that some contractors still had minor pro-cedural kinks to work out before putting together final data The packages on their work. These were noted to the licensee.
inspector also informed the licensee that examination of these packages would be an item continuing through several future flRC
, inspections. (Paragraph 8ofDetails) /
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. DETAILS
- 1. Individua'Is Cont'ac'ted
- a. Pacific Gas & Electric Co. (PG&E) ,
C. K. Maxfield, Project Superintendent ,.
- W. J. Tomei, QA Engineer .
R. D. Etzler, Field Engineer .
D. W. Day, QC Engineer R. C. Lorenz, Coordinating QC Engineer
- C. T. Tallon, Project Scheduler C. A. Hemstock, Project Coordinator P. D. Newel,1, Project Materials Supervisor E. W. Barredo, QC Engineer .
. b. Westinghouse Elec'tric Co. (Westinghouse)
R. H. Baulig, Site Manager -
- c. Wismer & Becker . ,
- .H. W. Machado, QA Manager -
- d. M. W. Kelloeg Co. (Kellogg)
('
/
J. P. Runyan, QA Manager E. Y. Martindale, NDE Supervisor
.W. R. Johnson, Inspection Supervisor
-~ e. H. P. Foley Co. (Foley)
R. V. Green, QA Manager.
Nora Grunberg, Clerical Inspector .,
- f. Pittsburg DesMoines Steel Co. (POM) 'i C. Bauer, QA Manager .
W. G. Morris, Documentation Supervisor ,
- 2. Plant Status At the time of the inspection Unit I was 92.3% complete and Unit 2 54.6% complete. The current Unit i fuel loading date of October 1975 appears realistic. .
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' Steam Generators 3.
The.NSSS supplier has modified the Unit ~l steam generators by expanding the tubes against the tubesheet for the full depth of the This expansion was accomplished utilizing a
- tubesheet (22 inches).
Westinghouse process (WEXTEX) which explosively expands the tubes to eliminate any crevice between the tube and the tube sheet.
Westinghouse , states that when volatile chemistry treatment is used
- on the secondary side, impurities in the steam generator are held to a low level and free caustic formation is prevented. With these conditions, stress corrosion cracking is not expected However, to occur evenit is if the tube to tubesheet crevice is not eliminated.
considered conservative to eliminate the crevices on those steam generators that have not operated, thus removing a potential problem area in the remote event of free caustic formation.
QC controls consisted essentially of dye penetrant examinations of the tube-to-tubesheet shop welds on selected tubes, and instrumen-
. tation monitoring of shock and pressure loads on steam generator '
components-during an evaluation phase to determine the maximum number of tubes which could be expanded at one time. This number was determined to be 50 tubes because one attempt witti 75 tubes resulted in steam generator components reaching approximately 75%
of design load. All dye penetrant examinations performed showed no indications.
1
( -
- Another program initiated by Westinghouse is the . implanting of 16 tube sections, 30 inches long, in the hot side of steam generator No. 1 of Unit 1 in order to test the corrosion characteris. tics of four different tube materials. It appears to be Westinghouse's
- intention to test these materials in plants with sea water cooling, river cooling and tower cooling. The' installations for Diablo had been completed at the time of. the inspection and the implanted tube
- sections had been successfully vacuum tested. This program was described in a PG&E letter to ORL dated April 7, 1975.
- 4. Valve Wall Thickness. Measurement Program The inspector examined the final records for the ultrasonic and physical measurement of valve wall thickness. All on-site valves -
had been measured and dispositioned in a satisfactory manner.
'- Records were' complete and provided evidence that the licensee and his contractor had satisfactorily implemented the program. The e
inspector stated that he considered the item closed out for both Diablo Units. -
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bn April 3,1975 ~the licensee reported by letter on the status of this program and noted that all future valves would be routinely examined for wall thickness. This would include any rejected valves that need to be replaced as a result of the wall thickness measure- ,
ment program. -
- 5. ' 4 and 12 KV Insulation Repairs. .
The inspector noted that different methods had been utilized between the insulation repair on the two units. It appeared that the insula-tion sleeve material utilized for Unit 2 was less susceptible to cracking than the sleeve material originally utilized for Unit 1.
The Unit 1 sleeves were completely replaced by taped insulation while the Unit 2 sleeves were simply tape reinforcad at the ends of sleeve sections. .
'6. Electrical Contractor QA program
- The inspector examined recent procedure changes relating to inspec-tion planning for equipment installation. This was an item of concern from a previous inspection. The procedural changes appeared satisfactory.
Primary System Installation r 7.
. The inspector observed field preparation of welds (grinding) for
. - baseline ultrasonic inspections. Nothing questionable was noted.. ,
~
. 8. system comoletion Checks
- The inspector examined procedures in effect at Wismer & Becker, PDM, Kellogg and Foley for determining that systems under their
~- responsibility were complete, that records to be turned over to the
- plant operator were complete, and that necessary instructions for proper filing and retrieval were available. The inspector found that procedures required some minor development at two of the contractors (Wismer & Becker and Kellogg) but that activity and controls were commensurate with the status,of work in these organizationc.
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The inspector also examined the system.in use by PG&E which provided j
" Exception Reports" on uncompleted systems. The PG&E " Exception Report" System appeared to be a detailed and satisfactory method of
- preparing and controlling open' items for completion of systems.
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. Fort F-125 rev. 7/6/78 rev. 3/30/79 - -
HHIBM NO. 3 DIABLO CANYCN P.E 1 OF 3
.3 .- .
31UCLEAP,POtiP.J.,pLA!T:',
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FILE TO.: I AUDIT 30.: 101 A. A. R. .i0. : 1 OBSERVATION CCDE : 1 ACTIVITY AUDITCD: NDE Procedures AUDIT DATE: 1-18-82 l REFERENCE DOCUMENTS: PG&E 8711. pq&P 8811To_ m 1. 0 14 mnoh4 en ch r FDTDING:
There are no for=al procedure qualification records for the following NDE procedures:
Continued on Page 2.
FI'TDING BY: H. Hudson- DAT2: 9-2252 ACT D 2'I: M DA"'E : 1 v SUSP2C'"ID CAUSE :
Fi'ai"Er il - Per the QA/QC Manager the requirements of ESD 234.9.1 and 9.2 establish the qualification of this procedure. Paragraph 9.1 states that "Iellogg-standards of Configuration to represent the veld under test with known defects vill'be used as refercuce. Pirure 1. 2 and 9. Continued on Page 3. --
~ 2ECOtr'CNDED CORREC'"IVE ACTION:
- 1. NDE procedures be qualified and:these qualification records be maintained; or, f { ..
absite.those NDEuprocedures which management decides are not anplicable to th C delete s q m a % m %
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/Jiasrptd) #,5~&ds D .2 7o J.dvs.1c>o re facusepessorg Agrg 's os 6:p an .1*a A-N BY: Co/'cerda dy'fersuc/$
4Vr v. _4 __v APPROVED BY: do d g-I. 0,-
ST:PS TO PC.CNT ECURRE'TC3: - ' N ff,,e ,c/d u A/06 fotoCd Ca sted ins tL 4 de' Closy &m/xm to sq ssa see t/s f9ft'S RA.& s#c c uOc'O-l TAKEN BY: 4' "
L- APPROVED BY: Notl 4-4 41 .
I FOLLCW UP: ACTIVITY COMPLIES WI"S APPROVED CORP.'!:CTIt/5 ACTIO" IF !! - PLEASE E:. PLAIN: - "US 10
% t'#3 D '# 4 \ m .J. p h 8 . # A $ + A ---
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DATE: 'b 1~2.-%
A.A.R. CLOSED BY: d . Or* DATE : 3 ,.2.2. 3 3, APPROVED BY: DATE:) 7- M v.
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FORM N12b rO V. . / /.ts / / u . ~p :
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- .! DIhDLO CNIXqN :;
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PE OF
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PILE.NO.:. I AUDIT NO.: 101 A. A. R. NO. : ,
.. 0aSERVATION CODE : 1 ACTIVITY AtDITED: NDE Procedu*es AU.DIO. DATE :
1-18-82 .
REF" 9"'" DOCULE3TS : PG&E 8711, PG&E 8833n. IFP-1.2.16. ESD 246. ESD 247 FINDING: CONTINUED FROM PAGE 1
- 1. ESD 234 - Ultrasonic Inspection Gzcove Welds AWS-Dl.069, ASME Section VIII and Section V. (Noncompliance to PG&E 8833n Section 3.4.128 and 4.1211).
f
/ 2/ ESD 241 - Ultrasonic h==4"atien of Safety Yoke Rods ozr 3707 RAI6-21 Safety Valves-
/ (Noncompliance PG&E 8711 Section 4.3.23 and 3 29 or PG&E 8833n Section 3.4.128 and
- 4.1211, IFP-1.14.5, IFP-2.3 and 2.4, IFP-16.5.T. ) .
3 ESD 246 - Magnetic Particle Procedure / Dry / Continuous Coil B31.7. (Nonconpliance to PG&I
,3 8711 Section 4.3.23 and 3.29, IFP-1.14.5, IFP-2.3 and 2.4, EFP-16.5.T. ESD 246.13 2).
l -y- ESD 247 - Magnetic Par %cle Procedure / Dry / Continuous Coil _ B31.1, (Noncomuliance to PG&I
. . 4. 8711-section 4 -3,23 and 3.29, ESD 247.13.2.) _ . . . _ _ _ . _ _ . . . _
e..)2
'i 5. Liquid Penetrant ha=ination Procedure (Noncompliance to PG&E 8833n Section 3.V.128 an:
4.1211.) EM -27o. g p g J.".. Finding fl - ESD.234 and Finding 12.- ESD 241, have established in their urocedures a means
~
9 to demonstrate the qualification of the procedures each time the procedur' s is used (see
. ... . Susnected_Cause)_hnt there is no formal documentation of the qualification. ,
Finding f5 - ESD 270 uses similar penetrant materials and ===4mation me2cds ~as ESD 210 -
Liquid Penetrant Procedure (ANSI B31.7). ESD 210 has procedure qualifications records which demonstrate the ability to detect the specified discontinuities. -
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FOLLO:i' UP : ACTIVITY CO!TLIES WITi! APPROVED CORRECTIVE AC* ION
~~
IF NO - PLEASE E::PIJ.IN: .
~ YES ,' NO l BY: - -
DATE: _
A.A.R. CLOSED BY: DATE:
j, ' APP ROVED BY:- DATE:-
1
TORM F;125 rev. 7/6/70 A 'y
,P re v. 3/30/79 h ,.DIADLO CANYON-Se*C PAGE OF ?
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AUDIT ACTION RCOUEST .
AUDIT NO.: ici A. A. R. NO. : 1 FILE NO. r ,
i OBSERVATION-CODE.--1 ACTIVITY AUDITED: NDE Procedure-
- AU.DIT DATE: 1-18-82 . .
PG&E 8711, PG&E 8833XR, KFP-1,2,16, ESD 246 and ESD 257
-rmw dCT Docucuf..d5 r SUSPECTED CAUSE CCm.suw: .
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Finding #1 continued - A radiograph of each standard shall be on file for proof' of defects".
Paragraph 9.2 states "the operator will check his test unit to this standard and shota known defec%". .
Finding 12 - Per the QA/QC Manager the requirements of ESD 241.11.4 establishes the qualifi-cation of the procedure. Paragraph 11.4 states "the ==mination .shall be conducted with a frequency that is capable of producing a =4"*== of 50 to a ==wmum of 75% of full scale reflection fzem the provided drilled hole in the reference speciment (MWK 001 Sketch #1).
Paragraph 13.1 states " reference specimen shall be of.same nominal diameter, thickness and composition and heat treated condition as the product being namined. The separation between standard defects placed in the same reference specimen shall not be less- than twice the- .
( length of the sensing unit of the inspection equipment". 8
~ F*m m r 83 & 4 - ESD 246 and.ESD 247 - Unknown.
Findinkf5-ESD270-Unknown.
RECCMfENDED CCRRICT1TE ACTION: .
- 2. Request Willia =$ port office to ch'e ck if they have P.Q.R.'s for ESD 246 and ESD 247, if they do, to forward copies to the job site. .
3 Per the QA/QC Manager a copy of ESD 210 Procedure Qualification Record be filed with
.- ESD 270 based on the sistleities of tho' procedures.
.? ----- ._
FOLLON UP: ACTIVITY CO!TLIES WIT!! .%' PROVED CORRECTIVE ACTION NO IF NO - PLEASE E;TLAIN:
- YES l *-
W: DATE:'
- DATE :
CA.A.R. CLOSED DY:
APPROVED BY: DATE:
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9 1
EXHIBIT NO. 4 4
'T UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD i
) i In the Matter of )
) Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC ) 50-323 COMPANY )
) (Construction Quality Assurance)
(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2) -) -
)
AFFIDAVIT OF PAUL DAWSON STATE OF CALIFORNIA )
) ss. -
COUNTY OF )
SAN LUIS OBISPO )
(...
I, Paul Dawson, being duly sworn, depose and say: -
~
I have been an employee of Pullman Power Products at Diablo Canyon
~
(formerly M. W. Kellogg) since April 2,1978. My responsibilities have mostly ~ ~
consisted of Quality Control involving Non-Destructive Examination (NDE) using Liquid Penetrant (LP), Ultrasonic (UT), Magnetic Particle (MT) and Radiography (RT).
- 1. At the time period that Pullman Internal Audit #101 was written by Harold Hudson, my responsibilities were NDE Supervisor, UT, MT, PT Level III, and RT Level II. My primary function was to coordinate NDE work c,
l and review NDE reports and daily work sheets.
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- 2. During the process of closing out Internal Audit #101, Mike MacCrae and I reviewed all the daily NDE ' reports from the date of ESD 270's original issuance, February 15, 1979. We. found no evidence that ESD 270 had ever been used at Diablo Canyon Nuclear Power Plant up until March 22, 1983, the date of closeout for the audit.
- 3. Additionally, at the request of Mr. Harold Karner, I performed a Procedure Qualification Test demonstrating the ability of ESD 234 to detect known defects. This test was performed on October 1,1982, and recorded as a Procedure Qualification Record (see Exhibit 1, attached).
Mike MacCrae also prepared PQRs for ESD 246 and ESD 247 (see Exhibit 2, attached). These actions were done to assist Mr. Hudson and Mr. Karner in closing out the audit.
DATED: March 18,1984
[
aa/S0au FAUL DAW 50N Subscribed and sworn to before me this 18th day of March, 1984 V
i Wendy Sproul U '
! Notary Public in and for the ' --
County of San Luis Obispo, - ^--- -^^^^^ -
s State of California.
My Commission expires
& OQyip NOTARY PV8UC
- CAUFORNIA June 30,1986 i san was asispo coum
[ __
My comm. apra Jun aa, isse ;,
J _.,
M
-v-- p. -3
__. Exhibits
- 1. ESO 234 Procedure Qualification Record dated October 1,1982.
- 2. Response of M.S. MacCrae to Internal Audit #101, AAR fl.
L_ j
EXHIBIT NO. &
E!D 222 ::0CEDUREOUALIQCATIONDECORC .
--s *1 ,t W er. cec crececure ha :een demonstra:e: using':he felic. - pr: .2 cr:
- :e se '<nown cedects as sne.4n in 01 raser i: Stancard el and =~.
MATERIAL' CARBON STEEL EQUIPMENT KROUTKRAMER MODEL USM-2 SERIAL NUMBER 804002 TRANSDUCER KROUTKRAMER-BRANSON-GAMMA
. SIZE 1/2 x 1/2 FREQUENCY 2.25 MHZ 0
ANGLE 4' a5 , 60 , 70 0 CALIBRATION BLOCKS AWS-IIW PG&E'S/N 4R58211 AWS-SC ATS S/N 783116 PPP REF. CAL BLOCK PPP CB - 1 & 2 COUPLANT EX0SEN - 30 and WATER U.T. STANDARU FIGURE #1 * *T" S/N "E" 0
FIGURE #2 "45 " S/N "A" DEMONSTRATED BY PULLMAN POWER PROD CTS SNT-TC-1A LEVEL III 8 N [_DATE /M ~!O b 4
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EXHIBIT NO. 2 r
Response to Internal Audit $101, A.A.A. #1 A procedura qualification was performed in order to qualify ESD-247 is wil as EID-246 (ref. Internal Audit #101. A.A.A. #1).
As both EID-246 and 247 have been withdrawn frem use and the equipment
, listad in both procedures is no longer available for use, the equipment used for these PCR's ws the Magnaflux Model P-90 for the coil technique only. All other fac. ors are tae same as specified in the procedures.
As the Magnaflux .% del P-90 puts)Lless amperage than the equipment listad in EID-246 and EID-247, and acceptable results wers obtained (i.e; !.D. and 0.D. surfaca and I.D. subsurface indications were locatad), the demonstration of this technique is deemed adequata to approve this method employed by the equipment listad in the acove
. procacurts. .
A record of the precadure qualification desanstration is he'reby sutznittac along with this response. The originals will be filed with the applicable precadures.
.5 ,.
, La the ayent that either cr"both proceduras are re-ectivatad in the future,
.O aer 411
- r=v4 = 4 := <a==r>=re== ca s==<i== a=< i 7-io <a== :n i t == o< <=4 = mea =-
^y; As both precadures are carrantly withdrawi frca use, no revision is deemed necessary i- at this time.
7 4d 7 A C. -u__
Micasel S. .*acCrae MT Level III 11-9-42 l
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. Procedure Qualification No. WT-3 '
Mathed Orv powder Continuous: Hal f Vave 0.C. . Coil Equipment Manufasturs wa-n el.,r r- e lesad Name meaa dief y Model Emmber P-30
- Magnetta Partialas: stand ran ena flux Twee orv Magnetization current Hal f wave aectif teo 0.C. Cale= cA.aec Out Put '- u 4000 knos.
Tast Piaes Positten ve-i1cai Test Macartal Carson steel -
Type Test Pisee '
Surfass Candistas
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'Jeacher 700 Orv 1sso Metal Calav Oare Grawn ane shsev =stal Castrust of Partistas ta same metal Goce
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Qut Ptst Asaperts 1000 Antes, Tast Piesa Position . Verti ca l Tast Macartal C.a r Jon S teel -
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'Draluation of Prosseure Goec-ina'catSe inc de#9 c thewed well.
~ Procedure: C Approved C .'fot Apr. .ed , Test C.anducted 37 '*
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.. i EXHIBIT NO. 5 ES 0-2
ENGINEERING DE? ART 4ENT ULT.u'20NI C 1:iSPECT10N Groove welcs A.W.S. - 01.0 - 69 1 SCOPE (WELDING IN BUILDING CONSTRUCTION CODE) 8' N ; d 1.1 - _ _ This procedure is applicable to structural groove welds.
- 1. 2 - This procedure shall be employed when ultrasonic inspection. Is
- -- ' 'speci fied to comply with the A.W.S. - 01.0-69 welding in Building .
Construction Code, Appendix-C, and AWS-Welding Handbook, Section 1,
~ Sixth Edition.
1.3 .This procedure shall be used when angle beam (shear wave) for groove-weld Inspection is specified. - -
1.4 After the weld is completed and before the angle beam examination, the area of the base material (through which the sound will travel in angle beam examination) shall be completely scanned with a
~ - - ~
straight beam search uni.t to detect reflectors which might affect .
~ ~
~~- the interpretation of angle been results. Consideration mus t be. _.
,given to these reflectors during interpretation of weld examination
. . _ . _ results, but their detection is not a basis for rejection of the
. ( _ ._
i . .___... __b a s e ma te r i a l . -
1.hf Ultrasonic inspection shall be performed only by qualified personnel certified by the M.V. Kellogg Company in accordance with ASNT-TC-IA._
- 2. COVERAGE 2.1 When possible, welds shall be examined from both sides of the ki_dh x_
,_ _ . ~ ~ ..
2.2 Contact surfaces shall be free from weld spatter and any roughness that would Interfere with the search unit or ultrasonic vibrations.
3.. EQUIPMENT 3.1 Approved ultrasonic test equipment:
_ ( A) Branson, Krautkramer, Magnaflux, Automation Industries,
- _ . Sonic, or equivalent.
.._ _ ..- (8) Transducers-- ~- ' ~ ~ ~ ~~
- a. Angle--45 , 60 , or 70 (+ or -2 0),
- b. Straight beam.
Q R. r; . FINK ' " ' " ' '
l- PREPARED BY DATE OF ISSUE PAGE 0F l u. . 7
. DATE OF REV. 1/20n3 'iz/
APPROVED BY ,
M^ " ' " * " ' '
ej
EXHIBIT NO. 6 PACIFIC GAS AND ELECTRIC COMPANY SAN FRANCISCO, CALIFORNIA Department of Engineering SPECIFICATION NO. 8833XR ACCOUNTING DATA GM 167027, 169972 REVISION NO. 13 Loc. Div. 18 Nuclear Safety-Related/10CFR21(a)
Account 61 Applies: Yes X No.
Activity Item Various Location and/or Item 40 (a)Part 21 of Title 10 of the Code of Federal Regulations Project File No. 143.61 2.
SPECIFICATION FOR FURNISH AND ERECT STRUCTURAL STEEL FOR UNITS I AND 2 CIABLO CANYON POWER FIJFr .
APPROVED BY CONTRACTOR SIGN HERE TO INDICATE Ay THIS REVISION IS ACCEPTABLE J. J. McCa h a.
L (NLT J[
R. V. Hettinger/ G )
Firm -
~N%. e2 J. V. R6cca/CER By ACCEPTED Y Date J. B. Hoch 1 1
- j DATE August 23, 1979 i
" Revision Index Specification No. 8833XR Revision 13 SPECIFICATION REVISION INDEX Page No. Rev. No. Date Page No. Rev. No. Date Page No. Rev. No. Date
. . , , Cover 10 9-14-78 2-6 10 , 9-14-78 1-15 11 10-25-78 2-7 12 2-06-79 2-6a 13 8-24-73 .
\,
a e
- Denotes revision
\. / ** Denotes addition
- Denotes deletion
i .. . . . . .
8833XR 2-6a Revision 13
~
- 7.211 All completed full penetration and partial penetration welds and all fillet welds 1/2 inch and larger shall be magnetic particle inspected.
If the as-welded surface condition makes interpretation difficult, the surface shall be ground smooth and the weld retested. Acceptance criteria shall be in accordance with AWS D1.1.
- P.
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- gump 1
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PAgE 1 cf 2 July 6, 1979
- 0. A. INSTRUCTION 143 EXHIBIT NO. 7 s
NDE REQUIREMENTS - STRUCTURAL WELDING s
t
- 1. 0 PURPOSE: Effective immediately, the following information shall be applied to implement the requirements of PG&E Specification 8833I1. This instruction is an addenda to ESD 243 and shall be incorporated during it's next revision.
2.0 SCOPE
This instruction shall apply to all manners of welding governed by the AWS Dl.1-79 Structural Welding code, PG&E Spec. 8833XR, Para. 1.3. It does not apply to welding of Pipe Supports under PG&E Spec. 8711.
3.O N. D. E. REQUIREMENTS:
3.1 Magnetic Particle Examination - PG&E 3212 3.1.1 All Full Penetration Welds.
3.1.2 All Partial Penetration Welds 1/2" and larger.
3.1.3 Fillet velds 1/2" leg size and greater.
3.2 Ultrasonic Examination - PG&E 3523 3.2.1 Full Penetration Welds 9/16" and greater effective
() 3.2.2 throat.
Base Material repairs 9/16" sad greater depth.
l 4.O FIEID Q. C. INS 7ECTOR REQUIREMEKrSi 4.1 Verify location of work, co: sparing issued process sheets versus physical location.
4.2 Verify traceability of all materials being instalfsd7f l 4.3 Conduct Visual Examination of the weld preparation .
y -
l for cleanliness.
4.4 conduct Dimensional Examination to assure fit-up within tolerance of the required weld procedure and technique.
4.5 Verify preheat prior to velding and/or thermal cutting operation. Re-verify preheat after any interruption of preheat, see Q.A. Instruction 142.
4.6 Monitor interpass eaperatures during all welding operations, see Q.A. Instruction 142.
C 4.7 conduct Visual Examination of root pass of all multiple pass sillet welds.
o
---vv
- , i 1
'\;.
- PAGE 2 of 2 Q. A. INSTRUCTION 143 (Cont.)
4.8 Conduct Final Visual Examination of all complete welds, to include preparation for N.D.E.
4.9 Conduct Dimensional Examination of all fillet welds for proper size. Dimensional Examination shall be conducted after all surface conditioning for N.D.E. is completed. ,
Donald R. Gaske Field Q.A./Q.C. Manager PG&EAPPROVAL:\ - d mf DATE: If a . DRG/dc
; .9 .4*] [
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