ML20107L983

Affidavit of WE Baker,Responding to ASLB 841029 Memorandum Requesting Addl Info Re in-process Weld Repair Hold Point. Related Correspondence

ML20107L983
Person / Time
Site:	Comanche Peak
Issue date:	11/09/1984
From:	Baker W BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.)
To:
Shared Package
ML20107L964	List: ML20107L962 ML20107L969 ML20107L979 ML20107L983
References
OL, NUDOCS 8411130726
Download: ML20107L983 (6)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC- ) 50-446 COMPANY, et al.

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) (Application for

-(Comanche Peak Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

AFFIDAVIT OF W.E. BAKER I, William E. Baker, being first duly sworn hereby depose and state, as follows:

I am the Senior Project Welding Engineer employed by Brown &

Root, Inc. at Comanche Peak. My educational and professional qualifications are attached to Applicants Exhibit 177, admitted into evidence in this proceeding at Tr. 9976.

The purpose of this affidavit is to respond to the Licensing Board's request for information as set forth below:

[T]he Board is concerned with obtaining an explanation for why hold points are required on authorized welds [1] but appear not to be required at all for in-process welds. What is there about repairs of in-process welds which makes it appropriate for the welders to make their own inspection of cleanliness, without a hold point, when such an inspection, solely by the welder, is not considered sufficient for repair of a final 1 It is my understanding that the term " authorized welds" was clarified by a phone conference of Novemoer 1, 1984 with Judge Bloch to mean welds identified as defective during inspections and repaired pursuant to the resultant repair documentation.

8411120726 841109 gDRADOCK 05000445 PDR ,

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-e e-weld? This just does not seem to make sense and we need an exptanation. [ October 29 9

Board Memorandum at.1-2.]

In response to the Board's request, I will discuss below the requirements for and. purposes of fit-up and cleanliness inspections for both initial and repair welding. (For the purposes of this Affidavit, the term inspections refers to 4

inspections performed by individuals certified in accordance with ANSI N45.2.6, or QC inspectors, as is the case at CPSES.)

For initial welding, the only inspections specifically mandated by the welding codes are final inspections. See e.g.,

ASME Code, Section NX-5000. However, to assure conformity with

.the intent of the codes, Applicants' welding program has established in-process inspection hold points. (As it relates to ASME welding, our welding program has been approved by both the ASME and the independent Authorized Inspection Agency. ) For example, our welding program requires a fit-up inspection for all full penetration and some partial penetration welds (not fillet j welds). . (Such fit-up inspections would not be applicable-to in-process corrections.) In addition, it is our policy that whenever a fit-up inspection is required, a cleanliness L inspection will also be conducted. The purpose of the cleanliness inspection is to assure that the inside diameter of

-any pipe is clean, all oil or contaminants resulting from machining are removed and all paint is removed, as applicable.

i (The purpose of such cleanliness hold points are also obviously l inapplicable to in-process corrections.)

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With regard to welds repaired pursuant to repair documentation, our welding program requires that a standard cleanliness hold point be imposed for all repairs requiring grinding and rewelding. The purpose of the cleanliness hold point is to assure that all paint, rust or other contaminants which may have been introduced subsequent to the completion of the weld but prior to the repair have been removed prior to

' welding. (This purpose is again not applicable to in-process corrections.)

In addition, neither the welding codes nor our welding program _ requires a specific hold point immediately before welding a " cover pass" for either initial or repair welding. With specific regard to in-process corrections, welders are taught proper interpass cleaning techniques including not only the physical cleanliness of the welds, but also removal of 4

unacceptable indications suchI as lack of fusion, porosity etc.,

prior to depositing additional weld metal.

While the Board's request for information and my response i focuses on cleanliness and fit-up inspections or inspections

! immediately proceeding a coveb pass, the ASME Code 2 requires that when necessary, unacceptable defects discovered by required ASME inspections, must be removed and in some cases the cavity l inspected to assure removal. The primary purposes of these requirements are (1) to assure that the defect, which for some reason had in the first instance escaped the welder's detection, 2 Testimony reflects that Mr. and Mrs. Stiner were only qualified to perform limited ASME welding, i.e., welding supports to ASME piping systems (Tr. 9981-87T7~

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is indeed found and removed, and (2) to attempt to minimize the number of repairs on a specific weld. After repair, the weld must undergo the same level of inspection which detected the original defect.

1 I might add that neither the AWS nor A&M5 Code requires in- l process corrections to be inspected. Further, in my opinion these inspections are not necessary, warranted er justi fiable to produce structurally sound welds. I know of. no other welding enginesrs oc code specialists who would advocate such i inspections. Indeed, to my knowledge no one in the entire welding industry requires such inspections. ,

A weld is not technically " defective" or cannot be said to have a " defect" until inspected and evaluated by the designated authorities (e.g., QC personnel) to the acceptance criteria specified by the applicable code.

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.575re ee rw s w.n. naker*

da.VYY o#.So.+r N l Subscribed and sworn to before me this 9th day of November, 1984.

ALG dw tary blic Y'd f W*</ PA M Co p e rs sse.J c cpists m c y is, W f This is a telecopy of the original last page of W.E. Baker's Affidavit.

The original will be provided under separate cover.

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g y g o g /96 w ) r#4.t'r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '84 00V 13 A9 :33

-BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In'the Matter of ) gc;

) Docket Nos. 50-445 and TEXAS UTILITIES ELECTRIC ) 50-446eN-COMPANY, et al. )

) (Application for (Comanche Peak Steam Electric ) Operating Licenses)

Station, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Response to Board Request for Raw Data Regarding Cinching Down U-Bolts" and

" Applicants' Response to Board Request for Additional Information Regarding In-Process Weld Repair Hold Point" in the above- -

captioned matter were served upon the following persons by deposit in the United States mail, first class, postage prepaid, this 9th day of November, 1984.

Peter B. Bloch, Esq. Chairman, Atomic Safety and Chairman, Atomic Safety and Licensing Appeal Panel Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Mr. William L. Clements Dr. Walter H. Jordan Docketing & Service Branch 881 West Outer-Drive U.S. Nuclear Regulatory Oak Ridge,-Tennessee 37830 Commission Washington, D.C. 20555 Dr. Kenneth A. McCollom Dean, Division of Engineering Architecture and Technology Stuart A. Treby, Esq.

Oklahoma State University Office of the Executive Stillwater, Oklahoma 74074 Legal Director U.S. Nuclear Regulatory Mr. Robert D. Martin Commission Regiona'l Adrainistrator, Washington, D.C. 20555 Region IV U.S. Nuclear Regulatory Chairman, Atomic Safety and Commission Licensing Board Panel 611 Ryan Plaza Drive .U.S. Nuclear Regulatory Suite 1000 Commission Arlington, Texas 76011 Washington, D.C. 20555 ~

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Q Renea Hicks, Esq. Mrs. Juanita Ellis Assistant Attorney General President, CASE Environmental Protection 1426 South Polk Street Division Dallas, Texas 75224 P.O. Box 12548 Capitol Station Elizabeth B. Johnson Austin, Texas 78711 Oak Ridge National Laboratory l

Post Office Box X Lanny A. Sinkin Building 3500 114 W. 7th Street Oak Ridge, Tennessee 37830

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Suite 220 Austin, Texas 78701 Ma0.c61th H. Phil s, Jr.

cc: John W. Beck Robert Wooldridge, Esq.