ML20127M220

Affidavit of Kw Caruso Supporting Applicant Motion for Summary Disposition of Joint Intervenors Contention 8 Re QA

ML20127M220
Person / Time
Site:	Vogtle
Issue date:	06/21/1985
From:	Caruso K BECHTEL GROUP, INC.
To:
Shared Package
ML20127M179	List: ML20127M175 ML20127M186 ML20127M192 ML20127M201 ML20127M220 ML20127M234 ML20127M256 ML20127M294 ML20127M308 ML20127M334 ML20127M347 ML20127M390
References
OL, NUDOCS 8507010157
Download: ML20127M220 (16)

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UNITED STATES OF AMERICA l NUCLEAR' REGULATORY-COMMISSION I Before the Atomic Safety and Licensing Board In the Matter of:  :

GEORGIA. POWER COMPANY, et~al.: DOCKET NUMBERS

50-424 and 50-425 (Vogtle Electric. Generating  :

plant, Units 1 and 2)  :

AFFIDAVIT OF K. W. CARUSO COUNTY OF BURXE STATE OF GEORGIA Before the undersigned officer duly authorized to administer oaths did appear K. W. CARUSO, who after being duly sworn, did: state as follows:

- 1. My name is Keith W. Caruso. 14y business address is. ogtle. Electric;Generat'ing plant, Route'2, Waynesboro, Georgia 30830. I am employed-by Bechtel Group, Inc. as Materials and Quality. Services Job Site Coordinator. In that position, my primary responsibility has been welding and materials engineer; I participated in the development of ASM5 an AWS welding programs at VEGp; I have~ assisted

-Bechtel. site engineering in the resolution of' welding, metallurgical, NDE, and code related questions. A summary of professional' qualifications is attached as Attachment " 1A.'"

2. I make this Affidavit in support of Applicants' Motion for Summary Disposition of Joint Intervenors' 8507010157 850624 PDR ADOCK 05000424 Q PDR

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' Contention No. 8 (Quality Assurance). I have personal knowledge of the matters stated herein and I believe them

.to.be,true1and correct. First, I will describe the weld-ing procedures used at the Vogtle Project; I will include l;

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. within that description a discussion of the relevant organizational responsibilities, the training and qualifi-cations of welders and inspectors, the procurement and storage of welding equipment and materials, and the fabri-cation; installation, inspection and testing procedures.

i Second, I will discuss Intervenors' allegation concerning

" welding in a light misting rain." Third, I will discuss Intervenors' allegation concerning pipe rack cracking.

WELDING PROCEDURES Organization and Resoonsibility

3. Georgia Power Company Nuclear Construction Departmentfh as the overall responsibility for completion of-VEGP and has established a Project Welding ,Section to implement the field welding program for those contractors working under the GPC Quality Assurance Manual and assist contractors working under their own Quality Assurance pro-gram (i.e. Pullman Power Products, NISCO, Pullman /Kenith-Fortson, Chicago Bridge and Iron). Contractors working under the GPC Quality Assurance Manual (Cleveland Elec-

~tric, Ingalls/Mosher, Walsh Construction) use welding procedures qualified by GPC and their work is inspected by GPC Quality Control Inspectors. The VEGP weiding program ensures _ quality in functional areas which are generic to

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-7 Lall contractors. Although. contractors with their own LQuality' Assurance programs may use different methods'to

' meet their required need, all contractors who perform welding, perform-that. welding under an approved QualityL fAssurance program.

4. Welding is controlled as a special process at nuclear-power plant construction sites. To ensure this responsibility is met, a ' proven, qualified welding program has been implemented at Plant Vogtle.

Qualification of Weldina Procedures

5. The Welding Procedure Specification (WPS) is a document ~providing. direction to the welder or welding operator while making production welds to code require--

ments. .WPS.'s used by contractors under the GPC Quality Assurance Manual are developed at the Vogtle site by GPC Welding Specialists. Welding procedure qualification welds are welded, inspected, and tested in accordance with the applicable. code (ASME Boiler-and Pressure Vessel Code, AWS'DL.~li AWS D1.3,-etc.). A Procedure Qualification Record.(PQR) is then completed documenting the actual s

welding variables'used to produce an acceptable weld and-

- the' test results obtained. ' Mechanical testing is per-formedLoffsite by an independent testing laboratory to determine the test weld's. tensile. strength,-notch When

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toughness,-etc. as required by the applicable code.

'WPS' development and qualification is completed and docu-p

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mented-it.is then reviewed by Bechtel project Field Engineering group prior to issuing the procedure for use.

.These-procedures are audited peri odi cally by the Quality Assurance group and the Nuclear Regulatory Commission.

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Qualification of Welders

6. Welders for the Vogtle site are requisitioned from the union locals by the contractors. When arriving on site'they are sent to the Weld Test Shop prior to per-

-forming any welding on site. At the Weld Test Shop the Nelders are required to weld test coupons under the diroc-tion of the Weld Test Shop supervisor. The purpose of this test-is.to determine the welder's ability to make

-sound welds that meet the requirements of the applicable code. Tests are administered in accordance with written procedures, such as GpC Field procedure WG-T-01 for AWS welding or pullman power products Field procedure II-8.

Welder tests are inspected during the test by the Weld Test Shop supervisor, and if during'the test'it becomes apparent that the welder does not have the required skill to produce satisfactory results, the test is terminated and considered failed regardless of the stage of.comple-tion. Weld test coupons that are completed and pass visual inspection receive destructive bend tests or other tests required by the applicable code. Welders that fail are returned to the contractor, who usually terminates

'them if: they cannot be assigned to other work. Welders

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that pass are assigned a unique identifying symbol consis-ting of letters or numbers that he must use to identify j all welds th'at he performs.on site. The-welder is then  ;

returned to the contractor for training on welding proce-

-dures, electrode control, quality assurance, quality con-trol, .and any other new-hire orientation required by each company.

.7. The Weld' Test Shop supervisor documents the test

! results on a: Welder Qualification Test Record, attaches a

-picture 'of the welder to the form and forwards it to the project Welding supervisor who reviews it, signs it, sends

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a copy to the QA Records Vault, and maintains the original I for file. These-records are reviewed and audited periodi-i

.cally by. Quality Assurance and the Nuclear Regulatory LCommission.

!, Welder Training l-

8. When welders _need instruction and/or training to upgrade their skill - to pass welder. tests for specialized procedures,.the welder is sent to a training facility, separate from the test shop, where he receives detailed instruction and is allowed to. practice on sample weld

-coupons.until the training instructor is satisfied the welder has obtained a level of skill sufficient to pass the welder testuand be capable of performing-satisfactorily in the field. 'Only then is he-sent to the Weld Test Shop for testing. Contractors administer classroom training, y + -e ---r - - - - - - -

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abs.needed, tockeep the welders informed of procedural

requirements. This-includes new-hire orientation, j

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' refresher training, electrode control. requirements, and WPS. requirements.

WELD-FILLER MATERIAL PROCUREMENT, STORAGE, ISSUE AND FIELD CONTROL

-- Procurement

9. Weld filler materials-(coated electrode, bare wire, consumable inserts, etc.) are procured for Plant Vogtle in accordance with-specifications written and control' led by Bechtel. These specifications are prepared

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.in accordance with the design criteria prepared by Bechtel and contained in the VEGP Project Design. Manual. These criteria. incorporate the licensing commitments of the PSAR andl10 C.F.R. 50.

-10. All suppliers of "Q" related hard materials are frequiredito implement a. Quality Assurance program. A supplier does this by submitting his Quality Assurance Manual for review and approval. This manual then becomes the basic document upon which his work is audited.

Quality surveillance is ba' sed upon the specifications and all codes referenced therein.

11. Each supplier must produce certified documen-

tation-in executing this Quality Assurance program.

Requirements for this documentation were established by Bechtel and comply with 10 C.F.R. 50 Appendix B criteria, e

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I' These criteria require documented evidence that material j and equipment-conform to procurement requirements, and L th_at they be available at the site prior to installation t

or use'of the item.

Storage of Materials on Site

12. Georgia Power Company purchases, receives, finspects, and stores piping,-equipment, and material, including welding materials, required for construction at Plant Vogtle. GPC is also delegated the responsibility as

.the material supplier for ASME III, Division 1 material.

Requirements of the ASME B&PV Code Section III, Division 1 necessitate that receipt inspection and control of ASME Code items and materials be performed by the "NA" installers, Pullman Power Products (PPP), and Nuclear Installation' Services Company (NISCO). N!SCO responsi-bility is limited to components and activities that are within the Westinghouse Electric Company scope of supply

~(the NSSS System).

13. -All materials, including restricted consumables, are initially received and inspected at the job site.by GPC. After satisfactory completion of receipt inspection, the material is released for use until it is inspected and all documentation is reviewed-to confirm that the material conforms to specified standards.

14. ' Welding Material. Distribution Centers (WMDC) maintain inventories of welding materials sufficient to

support the needs of construction. Welding materials are  ;

handled and stored in a manner that prevents contact with dirt, dust, grease, moisture, or other contaminants. The WMDC is a Level "B" storage area. A Level "B" storage area is a well-ventilated facility with a temperature range of between 40'F and 140'F, paved floors, and satisfactory pallets for material storage.

15. The material stored in "Q" storage areas, which contain permanent Plant material, is segregated into ASME and non-ASME material, with the exception of large bore pipe spools, which are intermingled. Fittings are sepa-rated by the type of material, material description, code

. class, or use. Carbon steel material is separated from stainless steel material and pipe or storage. racks made from carbon steel are suitably protected to avoid contam-ination of stainless steel material. Small bore fittings and miscellaneous material (bolts, nuts, etc.) are stored in separate bins, barrels, boxes, and similar containers.

The material or its container is clearly marked for ease of identification and to prevent unnecessary opening of crates or boxes. Storage areas are monitored every 30 days to assure acceptable material status. Inspection of material in storage is performed pursuant to a periodic schedule and is documented on a Storage Inspection Report.

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s Issue and Field Control ,

16. Field issuance of weld filer materials to the welder is controlled. The craft-foreman prepares an appropriate ~ requisition in accordance with the isometric or' piping' detail. It is then submitted to the WMDC where it is'r'eviewed for accuracy and. completeness. Once the requisition has been reviewed, the welder is issued the quantity, type, and size of weld material specified on the requisition and the correct log,. heat, or control number

= of weld filler materials is recorded on the requisition.

FABRICATION, INSTALLATION, INSPECTION AND TESTING Overview

17. Georgia. Power Company Construction Division is responsible for: site fabrication, installation, inspec-tion, and testing activities for process piping and

. equipment. GPC Construction Quality Control monitors these activities in accordance with written Plant Vogtle field procedure. ASME Section-II, Division 1 Code work is performed in accordance with the 1977 Edition through the 1977 Wint'er Addenda and under ASME Certificates of Author-ization'No.-1102-3 for "NA" installation and 1101-3 for "NPT" ' fabrication.

18. Welding is performed in the-field under con-tractor' supervision. Welders are assigned.to welds by their foreman who gives them the WPS to use, the type of

~ weld.requiredi and the size'ot the weld. This information

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l-I l is taken from drawings and procedures prepared by engi-neering. The GPC Project Welding Section performs random surveillance of in-process welding-operations to assure welders are. welding within the' parameters of the qualified

'WpS, within the-limits of their qualification, and the welding material ~ control procedures are being followed.

GPC Welding Specialists, Contractor Welding Engineers and Welding Coordinators provide technical assistance to the welder and supervisor when needed.

19. Craftsmen perform the physical work activities i

i under the technical direction of craft superintendents and field engineers. The primary documents used by the craftsmen are piping drawings and WPS or process sheets.

.The process sheet specifies work activities, sequence, procedural references, and inspection hold points.

Craftsmen notify the QC inspector when a hold point is reached and inspections are performed and documen,ted.

Quality Control Insoections

20. The inspector verifies that the welding materials agree with the ro'd requisition, that the welding procedure specification is correct for the joint to be welded, and

-that the description and identification entries on the WPS or process sheet are correct. Prior to releasing the

. joint for welding, the inspector assures that the weld area is adequately protected from high winds, rain, snow,

.or other adverse environmental conditions. When the joint is found' acceptable, the inspector enters the welder's

I' symbol on the appropriate documents and signs off the required hold points. Any ANI hold points for ASME Section III weld fit-up operations are conducted at this time.

21. The contractor is responsible for performing the required Nondestructive Examination (NDE). A report is issued for each examination performed.in accordance with the applicable NDE procedure (radiographic, ultrasonic, liquid penetrant, magnetic particle, eddy current or leak testing). The item examined, method of examination, and examination results'(accept or reject) are documented.

22. The Quality Assurance group' performs periodic audits to ensure work is being performed in accordance with the applicable procedures and that the procedures are adequate to ensure the quality required by the applicable codes and NRC guidelines. The NRC also performs periodic inspections of. work activities to ensure they are being performed in accordance with the applica le codes, regulations, NRC guidelines, and industry standards.

23. Documentation of the required Quality Control inspections, procedure qualification records, welder qualification records, and welding material documentation are maintained on file in the QC Records Vault as objective evidence that activities affecting quality are performed and controlled in accordance with written f

i approved procedures that will ensure the applicable code-requirement:is met.

WELDING IN LIGHT MISTING RAIN

24. Intervenors have challenged the assurance of quality at Plant Vogtle based, in part, upon an instance which occurred on November 18, 1982 in which an NRC inspector observed welding being performed on No. 2 primary containment dome sections in what he characterized as "a very light misting rain." The rain was not yet enough, at the time, completely cover a flat surface,

.however, if the condition were to continue, it would have become detrimental to the quality of the weld. The NRC inspector documented his findings in I&E Report 82-29.

25. The inspector noted that he discussed the condi-

-tion with the welding supervisor and the site QA super-visor. Work'was stopped for the day although the welding supervisor and the QA supervisor were of the opinion that this condition was acceptable for welding and this posi-

-tion could be substantiated by appropriate CB&I procedures.

26. With regard to the safety of the weld, it is clear that the weld is safe. Not only did the weld under-go routine final inspection'as required by appropriate procedures, this particular weld was dry at the time and the " light misting rain" occurring in the vicinity had no effect on integrity of the final weld. I have no question as to the credibility of the welds performed in this type t.

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-of weather based upon extensive work with this type of material. .There are no metallurgical problems that will surface provided the minimum temperature of the sur-rounding metal is maintained according to appropriate procedures. The minimum temperature is maintained in weather conditions such as that which existed on Thursday, November 18, 1982 when the NRC senior resident inspector called into question the procedures.

CRACKING IN CONTAINMENT PIPE RACK WELDS

27. The.next attack which Intervenors make upon the welding program at VEGP concerns their suggestion that cracking has. occurred in containment pipe rack welds.

This was a situation which was first identified by Georgia Power Company and. reported as a licensee identified item.

28. Containment pipe rack is a supporting structure ma'de of structural steel members which supports and arranges.. critical piping inside,the containment building.

29. The pipe racks are fabricated by welding struc-tural members using a fabrication procedure defined by Pullman Power Products (PPP) field welding engineer.

Bechtel reviewed the design documents and related welding procedures. These procedures were found to be acceptable and did not need to be revised. The crapks in the pipe racks were discovered subsequent to finat Cuality Control inspections. On April 24, 1984, Pullman Power Products

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' issued eight'nonconformance reports-covering two welds with cracks on containment pipe rack R0002 and seven welds with cracks on containment pipe rack R0003, Thus, nine j

' welds _out of approximately 12,000 welds had cracks. l

30. Subsequently, an evaluation of the nonconformance

. report indicated the existence of a potentially signifi-cant deficiency which was reported to the NRC by GPC. To resolve'the. situation, Georgia Power Company requested the assistance of Bechtel Material and Quality Services Organi-zation. After extensive investigation and review, it was determined that there was no problematic breakdown in the Quality Assurance program of the PPP.

31. A repair of.the welds in question was performed, and all uncracked welds with generic rack designs similar to those which cracked were identified. With regard to each of those, corrective action was planned which would include one of theifollowing:

(1). local stress-relief;

.(2) reinforced. joint'with. doubler plates;

-(3) remove and replace weld; or (4) load test to 25*5.over size of load.

32. The NRC has reviewed the corrective action and' has indicated a preference that all generic weids be removed and replaced. However, Georgia Power Company may

-justify why the other alternatives are also viable. The l

corrective actions in question have not been completed.

'Therefore, the item remains open pending review and

acceptance o'f'the corrective action. No additional NRC enforcement action is anticipated.

'Further Affiant sayeth-'not.

M' hO 4'.'W. CARUSO l

Sworntoandsubscgbedday before me this a of 0- , 1985.

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'KEITH.W. CARUSO EDUCATION: -B. S., Engineering (Welding) Technology California Polytechnic State University, San Luis Obispo

SUMMARY

4 YEARS: February 1981'to present, hired _as a junior engineer in the Los Angeles Area Office of Materials &

Quality Services and proceeded from this position to Materials & Quality Services Coordinator on the Vogtle Job to Materials & Quality Services Jobsite Coordinator for the Vogtle Project.

EXPERIENCE:

1982 to Present: Project Coordinator at the Vogtle.

Jobsite providing technical services to Client (Georgia

' Power Company) in Welding, NDE and related areas.

Developed AWS and ASME welding programs for Georgia Power Company. Additionally assisting Bechtel site engineering in welding as it relates to the BPC N-stamping of piping systems. Support of site engineering in interfacing with-the NSSSLSupplier (Westinghouse) and the "NA" installer (Pullman Power Products). Qualified as Auditor-in-Training-(1983).

1981 to 1982: Assigned to the Vogtle Project part time coordinating the. work betweer Materials & Quality Sarvices and the project.

1981: Junior Engineer in Materials & Quality Services, Los Angeles Area Office reviewing specifications and suppliers procedures.

Three months (summer) with Stoedy Company as Lab Technician tes!.ing Welding Consumables and developing procedures for_hardfacing, cladding and rebuilding.

Three months (summer) Welding, Repairing and Coating of Bailey Bridge Components.

Four months with Wolff Manufacturing designing. Machine Welders for rebuilding under carriage components of Crawler Tractors.

PROFESSIONAL DATA:

Member of AWS and ASM.

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