DCL-84-231, Responds to NRC Re Violations Noted in IE Insp Repts 50-275/83-37 & 50-323/83-25.Corrective Actions:Reinsp Program Implemented for Welds Originally Accepted by Unqualified Inspectors

Responds to NRC Re Violations Noted in IE Insp Repts 50-275/83-37 & 50-323/83-25.Corrective Actions:Reinsp Program Implemented for Welds Originally Accepted by Unqualified Inspectors

ML20094B979
Person / Time
Site:	Diablo Canyon
Issue date:	06/18/1984
From:	Schuyler J PACIFIC GAS & ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20094B970	List: DCL-84-231, Responds to NRC Re Violations Noted in IE Insp Repts 50-275/83-37 & 50-323/83-25.Corrective Actions:Reinsp Program Implemented for Welds Originally Accepted by Unqualified Inspectors
References
DCL-84-231, NUDOCS 8408070327
Download: ML20094B979 (8)

Text

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PACIFIC GAS AND EIaE C T RIC C O M PANY 1:

POW 3 l 77 SEALE STREET . SAN FRANCISCO, CALIFORNIA 94106 . (415)781 4211 . TWX 9:0 372 6587

";.*",tf" cmo.. . . . ... .

June 18,1984 PGandE Letter No.: DCL-84-231 Mr. John B. Martin, Regional Administrator U. S. Nuclear Regulatory Comission, Region V 1450 Maria Lane, Suite 210 .e Walnut Creek, CA 94596-5368 & # ,/ # f e en!GI M pk/ i Re: Docket No. 50-275, OL-DPR-76 ~ cartWCS E ~

Docket No. 50-323 Diablo Canyon Units 1 and 2 Pullman Welding Inspectors

Dear Mr. Martin:

NRC Inspection Report 50-275/83-37 and 50-323/83-25, dated February 29, 1984, included a notice for a Severity Level IV violation. PGandE responded to this L tice on April 11,1984 (PGandE Letter No. DCL-84-140).

PGandE stated that a final report would be submitted for Unit 1 and Unit 2 after completion of all corrective actions. Corrective actions were completed by May 11,1984 for both units. This submittal is a final report which details the results of all inspection activities and the disposition of suspect welds.

Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely, r

k J. O. Schuy r Enclosure cc: Service List 940007o327 c.",

840001 ADOCK C4000

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.. PGandE Lstter No.: DCL-84-231 ENCLOSURE FINAL REPORT DETAILING RESULTS OF THE REINSPECTION PROGRAM FOR PULLMAN WELDING INSPECTORS Backgrourid On February 29, 1984, PGandE received a Notice of Violation (" Notice"),

Severity Level IV, as part of NRC Insps-tion Report Numbers 50-275/83-37 and 50-323/83-25. The Notice cited twenty-eight Pullman Power Products (PPP)

. employees who began inspecting and accepting weldments prior to completion of required training and certification as welding inspectors. This had previously been identified in a 1977 audit of PPP by Nuclear Services Corporation (NSC).

In letters to the NRC dated March 23,1984 (DCL-84-115) March 29,1984 (DCL-84-124) and April 11,1984 (DC:.-84-140) PGandE:

1 Noted that 11 of the 28 individuals identified in the NSC Audit were non-destructive (ND) test inspectors who were fully qualified to perfom ND testing prior to beginning those activities.

2. Described the causes and background of the Violation regarding the remaining 17 inspectors.

3. Outlined a program requiring reinspection of all or a portion of those welds originally accepted by the 17 inspectors.

4. Committed to providing a final report detailing the results of all reinspection activities and the disposition of all welds identified as suspect during the reinspection prograr.

Results Attachments A and B provide a summary of the reinspection program. A comparison of this sumary and those provided in previous submittals will reveal minor differences resulting from increases in sample size and correction of tabulation errors.

Of the 2,996 welds originally examined and accepted by the 17 inspectors, 1,269 were reinspected by PPP as part of PGandE's corrective action program.

Fifty-eight of these welds were identified as suspect and reported to PGandE on PPP Discrepancy Reports DR No. 5872 (Unit 1) and DR No. 8321 (Unit 2) dated April 7,1984 Although 39 suspect socket welds were discovered, 35 were found acceptable by applying tolerances supplied by Project Engineering. The remaining four socket welds and 19 other welds, either butt or attachment welds, required Engineering evaluation and/or analysis. All of these welds were found acceptable by Engineering for their intended application. A listing of the suspect welds, and a brief summary of the basis for their acceptance are contained in Attachment C.

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4 Most suspect melds are attributed to the weld gauge used and the inspector's interpretation of the results during the original inspections. The minspection used state-of-the-art weld measurement gauges which provide more )

accuracy and require less interpretation. This greater accuracy resulted in small differences in the measured size of socket welds when compared with the l original inspection. Suspect welds exhibited minor variations from acceptance criteria. Such variations are of the type that any weld reinspection program l of this scope would reveal and do not represent a failure of the original inspectors to verify the acceptance criteria. In identifying a low percentage of suspect welds and finding no rvquirements to have welds repaired, the l reinspection program verified that the original inspectors followed existing )

plant procedures.  ;

Based on the acceptance of all welds sampled during the reinspection program, l no further action is planned.

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Attachment A REINSPECTION PROGRAM FOR i

PROVI5IONALLY QUALIFIED INSPECTORS (1)

~

Minimum No.

No. of -

to be No.

Name Inspections (2) Reinspected (3) Reinspected (4) Suspect (5)

Allmendinger 69 14 31 1 Bloom 2 2 2 0 Bowlby 385 78 176 7 Boyd 193 39 51 1 Finch 299 59 114 4 Jennings 396 80 96 4 Kaz 3 3 1 0 Kincade 83 17 23 2 Page 149 30 42 2 Pennie 274 55 80 2 0'Brien 42 9 16 0 Sarvatari 294 59 74 1 Silver 47 10 11 0 Thomas 17 10 10 0 Willard 420 84 268 18 2673 551 995 42 NOTES:

1. Provisionally qualified inspectors were identified in the April 11, 1984 submittal (DCL-84-140) as individuals who were knowledgeable to inspect welds based on previous work experience and education but who did not meet the requirements of Engineering Standard Diablo (ESD) No. 237,

2. No. of Inspections - Number of weld inspections prior to meeting the requirements of ESD-237

3. Minimum No. to be Reinspected - 205 (or all if less than 10) of accessible welds which are to be reinspected.

4. No. Reinspected - The minimum number of reinspections were accomplished for all inspectors with the exception of Kaz. Two welds were inaccessible.

5. Suspect - Welds which were identified as su::pect and were evaluated or analyzed by Project Engineering and found acceptable.

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Attachment 8 REINSPECTION PROGRAM FOR

, UNQUALIFIED INSPECTIONS (1) -

Minimum No.

No. of to be No.

Name Inspections (2) Reinspected (3) Reinspected (4) Suspect (5)

Guy 300 300 263 15 Cubbage 23 23 11

_1 323 323 274 16 NOTES:

1. Unqualified inspectors were identified in the April 11, 1984 submittal (DCL-84-140) as individuals who were not knowledgeable to inspect welds based on previous work experience and education until they met the requirements of ESD-237.

2. No. of Inspections - Number of weld inspections prior to meeting the requirements of ESD-237.

3. Minimum No. to be Reinspected - Number of welds to be reinspected, provided they are all accessible.

4. No. Reinspected. (Remainder are inaccessible).

5. Suspect - Welds which were identified as suspect and were evaluated or analyzed by project engineering and found acceptable.

l l

I l

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F 7; a .

\ Attachment C DISPOSITION OF SUSPECT WELDS Field Weld Isometric Number Number Disposition UNIT 1 WELDS 8-285 776A .By application of tolerance

• this is* acceptable.

1798 204 32C 34A 34D 1405 No Code requirement for profile; therefore acceptable.14-207 65B By application of tolerance "

this is" acceptable.

8-349 3498 14-258 1001 1010 19-266 505C 505G 8-5 21 01 Acceptable, review indicates this is not a reject.19-266 503G By application of tolerance "

this is" acceptable.19-250 309F Lack of fusion noted has been rechecked, it is actually a crease. Therefore, weld is acceptable.

. The following are acceptable based on review by stress or pipe suiport groups, as applicable.

8-24 582 Acceptable, weld is on Code Class E portion of the line. Weld size is acceptable - no stress analysis is required. Design wall thickness for line is 0.009"; therefore acceptable.

8-50 322B Acceptable, same reason as for 582 above.

8-54 266A Acceptable, same reason as for 582 above, except design wall thickness for line is .002" 14-14 207E Excess reinforcement reviewed by stress group.

There is no significant effect on analysis.

Therefore, it is acceptable.

9-240 352 Acceptable, analyzed by OPEG stress. Stress levels low. Therefore, increase in stress intensification factor (SIF) would have no adverse effect.

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l l

\ 19-303 849B Acceptable by review / analysis by pipe support group.14-201 65E Acceptable. New SIF = 2.7. This is a 29%

increase. Since analyzed by simplified method, this incmase is lower than margin in DCM M-40. Therefore, it is acceptable.24-220 -

170 Acceptable. Same reason as for weld 65E above.

170A y 7) ." . ." ." . . ". .

Ib224 582 Acceptable, new SIF = 2.9. This is a 38%

increase. Since analyzed by simplified method, this increase is lower than margin in

. DCM M-40 Therefore, it is acceptable.24-202 31 5 Axial restraint not required on Code Class E lines. Line was originally Code Class C but subsequently downgraded. Therefore, weld size is acceptable. 1 24-202 315A Acceptable. Same reason as for weld 315.

9-254 987A Acceptable. Weld length is sufficient. ]

9-26 X401 Acceptable, reviewed by pipe support group. l Attachment weld size acceptable for loads. l UNIT 2 WELDS 9-403 1 By application of tolerance this is acceptable.

62A 14-217 127 14-425 4 81  :

485 21-404 10 No Code requirement for profile. Acceptable.21-406 98 No Code requirement for excess socket weld

. size. Acceptable.  !

By application of tolerance this is acceptable.21-407 106 276 4 277 21-409 No Code requirement for profile. Acceptable.

283 i Also, by application of tolerance this is acceptable.

290 Acceptable. Same as weld 283 above.

21 -41 9 236 By application of tolerance this" "

is acceptable.

237 275 24-412 104E No Code requirement for profile. Acceptable.

8-51 9 1101 21-407 104 Acceptable, undercut within Code allowable.

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The following are acceptable based on review by stress or pipe support groups, as applicable. ...

9-2 9 Acceptable by review"/ analysis "by stress "

group.

12-10 105 " " ~ " "14-425 496 " " "

M-406 268 " " "

21 -409 284 S-490 21108 Acceptable

• by review /" analysis "by pige supgort group.14-223 2192 " " " "

m -1 2M 4

9 1

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