ML20138C503
| ML20138C503 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/17/1985 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20137J690 | List: |
| References | |
| NUDOCS 8510220445 | |
| Download: ML20138C503 (87) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of:
Meeting Between NRC Staf f and Texas Utilities Generating Company to Discuss the Official Inspection of Painted Support Welds Docket No.
Location: Bethesda, Maryland y _, 71 Date: Tuesday,. September 17, 1985 p,g,,,
ANN RILEY & ASSOCIATES Court Reporters 1625 I St., N.W.
8310220445 851017 5 Suite 921 DR ADOCK O Washington, D.C. 20006 (202) 293-3950 L ___ _ __ . _ _ _ __
a t 1
1 UNITED STATES OF AMERICA
~
2 NUCLEAR' REGULATORY COMMISSION 3
4 Meeting Between NRC Staff and Texas Utilities Generating 5 Company to Discuss the Official Inspection of Painted Support 6 Welds.
.7 8 Room P-118 9 7920 Norfolk Avenue 10 Bethesda, Maryland I
11 Tuesday, September 17, 1985 s
12 13 The meeting convened at 9:00 a.m., pursuant to I
14 notice, Annette Vietti-Cook presiding.
15 APPEARANCES:
16 A. Vietti-Cook s
17 C. Early 18 L. Shao ,
19 D. Smith 20 P. Cortland 21 I. Barnes 22 S. Hou 23 C. Richards 1
j 24 B. Dacko 25 F. Faery
- warh&w w e- -a # , y
- - , - - , w -- .- -
a e 2
.s 1 D, Ellis 2 J. Hansel
- 3. J. Christensen 4 B. Liaw 5 P. Wilson 6 R. Gad 7 V. Hoffman 8 S. Burwell 9 R. Bachmann 10 C. Baty 11 G. Mizuno 12 13 14 15 16 ~'
17 18 19 20 21 22 s
23
/
24 25
e i l
2 MS. VIETTI: I think we are all set. .
3 Just for the record, my name is Annette Vietti. I 4 am Project Manager, Division of Licensing, Comanche Peak
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I 5 project.
6 This meeting this morning is between NRC Staff and 7 Texas Utilities to discuss the official inspection of painted i
8 support welds.
9 On July 2nd, members of the Region IV staff met with [
10 representatives of the ~ Applicant at the Comanche Peak site to [
11 discuss the inspection of the component support welds. At t
12 that time Region IV was provided with a position paper by 13 Stone & Webster.
14 This position paper was then forwarded to NRR and 15 placed in a public document room, and we also received a j 16 letter request on this subject on August 1st. l 17 The position paper was given to the Materials
- i 18 Engineering Branch to review, and the review was conducted I
19 with ocordination with Region IV's office, Inspection & ,
20 Enforcement and members of the Technical Review Team, i 21 The meeting this morning is for the staff to get a 22 better understanding of what exact 1y the objective is of Texas *
, 23 Utilities in reinspecting the painted welds, what they are ;
j 24 trying to accomplish, and based on the information that we get l 1
25 today,-we are in a position to give you guidance depending on l
- - ~ - - , * . - , . .
e e 4
1 the attributes that you are looking for.
2 What I would like to do now is I think you have --
3 we have already introduced ourselves, so what I can do is just 4 turn the meeting over to you for your presentation.
5 MR, DACKQ: I am Bob Dacko with Tugco L i c e n's i n g .
6 Basically,' I want to turn the meeting t iv e r to John Hansel He 7 is our CPRT, QA/QC team leader. He will talk about this 8 issue.
9 MR. HANSEL: My name is John Hansel. I'm with ERC.
10 I'm the QA/QC review team leader for the Comanche Peak 11 Response Team. I have with me this morning on my left John 12 Christiansen, who is my deputy at the site, Don Ellis, on my 13 right, who is with Stone & Webster and has done most of the 14 work for.us in looking at the aspect of inspecting painted 15 welds. He has many, many years of code experience and
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16 welding experience, and certainly I consider him to be an '
17 expert on the subject.
18 To his-immediate right is Fred Ferry, who has also 19 helped and assisted in some of the review at the site in terms 20 of documentation and that process controls are in place and 21 the actual application at t h e .s i t e '. And, of course, Bob 22 Dacko.
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23 Reviewing the letter that we sent you back in July,
'" 24 I would like to reiterate a couple of points. In looking at 25 that last night, I feel that there are several things that
o .
5 1 were maybe missing that possibly I can help clear up.
2 We did, as Don Ellis is going to point out this 3 morning, a good bit of research at the site to come to the 4 point of making this recommendation. He is going to discuss 5 the details of that, some of the studies, the documentation 6 reviews, and the other studies that have been conducted on the 7 subject.
8 We will be inspecting welds that fall in this 9 category in a number of populations. Again, for some of those 10 who may not be familiar with the total Comanche Peak Response 11 Team, we are taking all hardware in the facility and putting 12 it into what we are going to classify as reasonably 13 homogeneous population. We will then select samples from each 14 of those populations, and in each case where we select an
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15 item, there will be a number of welds onLparticular items. We 16 will be looking at a number of welds in that plant, both Unit 17 1 and Unit 2.
18 The bottom line to that is that the end result is we 19 will'have a large population of data to look at when we are 20 finished. We will be drawing conclusions on the adequacy of 21 construction on each of those populations as we go, and if it 22 involves welding as an attribute, the we will certainly we 23 looking at the welding population by population.
3
%s 24 When we finish the review of those populations, the 25 cumulative effect was the totality of a!! of that data from h
. e i
6 i
,s t 1 all of those populations will be looked at for cumulative [
i 2 effect, so we will be looking at the results of welding 3 inspections from a number of populations.
J 4 The bottom line to all of that is that the process j 5 is just beginning, we will be at this for a long time, and we ,
6 will have a tremendous amount of data. We have not made any 7 sweeping conclusions to date. We will go at that at a very i 8 deliberate process, on a population-by-population basis, and 9 also, then, looking at the effects of welding in the totality, f i
I 10 And, of course, if we see in that process anything l 11 that concerns us from a safety significance standpoint, or
'i 12 even an adverse trend, either by population or throughout the 13 plant, we plan to investigate that. That could lead us into a 14 number of avenues, if, for instance, we were to find flaws or i
15 defects that say there is an indication of a lack of process ;
i 16 control or inadequate inspection or whatever the case may *be.
i 17 So we will be looking at a number of welds over a i r
18 long period of time covering a number of processes. We feel !
19 --
in fact, we know that we will cover the entire span of, !
i 20 time, and we will also cover craft and inspection in the ;
I 21 processes.
22 I think another key point that ! need to make is f 23 that a,high percentage of the welds in Unit 2 are unpainted, f f, ,,i .
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24 so we will be looking at some unpainted welds. Likewise, we i I
t 25 have instructed the inspectors that if they see something that l
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r
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m .. _ .
7
,n 1- bothers them'and is troublesome that they feel they cannot see 2 adequately through the paint, we will get that paint removed
, 3 for them.
1 4 There was a case yesterday that John just informed 5 me of, John Christiansen, that we found some bubbling in a ;
6 paint or blistering on a weld yesterday. We had to remove the 7 paint from that. That option is there for the inspectors if 8 they feel unsure of themselves.
9 With that introduction I think, so that we are all 10 on a common footing, I would like to ask Don Ellis to give you 11 a presentation which he made back at the Region in early 12 summer, late spring. Then at least he can bring us all up to a
! 13 the same point. We will have background knowledge of the 14 studies that were c o n d u o't e d , his knowledge of the processes, 15 and then we can open it up for questions and discussion of any i i j 16 concerns at that time, r
! [
l 17 So if there is no further comment here, we will turn ;
i 18 to Don Ellis.
19 MR. LIAW: May I ask you a couple of clarificati,ons j
- I t
20 of what you have said? You said cumulative effect. What do t 21 you mean by that? [
We will have data that we will draw i 22 MR. HANSEL:
l 23 from a number of populations. !! I find a problem in one weld j i '
/ I l
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24 in one population, it may or may not.he significant in and of l l
h 25 itself. If I find two more in another population, another one f f i i
,1
I
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1 in another population, and three more downstream in another 2 population, there may be some trend associatee with all of 3 those as 1 look at them in a cumulative manner.
4 There could be indications -- there could be a 5 common link to an inspector or to a craft.or to a particular 6 tot of material, so I would be looking at the cumulative 7 effects and also adverse trends.
8 MR. LIAW: Trending I can understand.
9 MR. HANSEL: I'm sorry, I misled you. On cumulative 10 effects let's say that I had a number of hangers in a row and 11 1 found weld problems on a number of those hangers. I would 12 certainly be interested in looking at the cumulative effects, 13 of each of those weld effects in the totality as well as 14 individually.
15 MR. LIAW: I guess most essentially I would like to 16 know to what standard do you intend to inspect tof 17 MR. HANSEL: We have planned on inspecting to the 18 modified visual acceptance criteria, as indicated in our 19 letter, ,
20 MR. LIAW: From there you assess the cumulative 21 effect.
22 MR. HANSEL: Yes, 23 MR. LIAW: The second thing is totality. You don't 24 sean to imply anything about the potential repair or remedial 25 action with regard to hot weldt
. e 9
1 MR. HANSEL: I'm not sure I'm understanding you.
2 MR. LIAW: I don't understand you, in the first 1
1 3 place. l
. 4 MR. HANSEL: We will conduct the inspections. If a 5 repair has been made and has been accepted prior to the point 6 in time of our inspection, then we will inspect and take that 7 prior disposition of that nonconformance into consideration.
8 Now, if we see a major problem with that, we may ask Tugco to 9 reassess it. After we conduct our inspection on any
)
10 discrepancies that we find, two things happen to them. One is 11 they are given to the utility for the preparation of a i
12 nonconformance report and their disposition and rework as they 13 sit fit.
14 We have a system in process or in place to make sure 15 that that happens. We also take each of those deviations or 16 nonconformances and analyse those ourselves as an independ'ent l 17. body to determine if they are safety significant in terms of 18 the item that they are found on. We also, our group as an 19 independent body, will do their review for adverse trends, 20 I don't know if I answered your question or not, i
1 21 MR. LIAW: It did help me understand it, anyway.
I 22 Last one. The PM indicated earlier what you
- 23 intended to use with the standard you proposed for the s
~./ 24 position paper you prooposed.
l What is the purpose of that?
t
- 25 !s that to be generic, that eventually Stone & Webster might
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. e 10 1 apply it to other sites? Is that your intention?
2 MR, HANSF.L: No. The intention is the app 1toation 3 on this site for this job and our reassessment for the 4 construction.
5 MR. LIAW: Thank you.
6 MR. HANSEL: Any other questions?
7 CNo response.)
8 MR. ELLIS: Good morning.
9 CS11de.3 10 A decision had been made to reinspect previously 11 accepted safety-related component supports, piping, electrical 12 raceways and heating installation equipment. As I said, the 13 supports were previously fabricated and inspected to the 14 requirements by AWS or ASME NF. 'The question addressed during 15 this review is can previously inspected welds he reinspected 16 through the paint to arrive at a logical decision that the-17 fitness for safety or safety ramification can be fully 18 evaluated?
19 For the purpose of this discussion, pressure ,
20 containing welds are excluded. This is a general 21 background. This is my first involvement on the Comanche Peak 22 job.
23 , MR. LIAW. Is it appropriate to ask you why you had
- 24 reached the conclusion that you had to "requalify" your 25 welding that had been inspected previously'
l i
11 1 MR. ELLIS: This was not my particular charter. My 2 charter was to come up with the estimates --
3 MR. LIAW: I just asked whether it's appropriate to 4 ask you that.
5 MR. HANSEL: Perhaps ! should answer that. We are ;
6 chartered to do an evaluation of the adequacy of the 7 construction of Comanche Peak as an independent body. To 8 do that, we have broken the plant up into items of equipment 9 that have similar or like work processes. Welding is one of 10 those work processes. So we will be sampling and reinspecting i
11 the welding that was previously conducted and inspected by l
l 12 either Brown & Root or by Tugco and making a determip,ation of i 13 was the earlier construction accomplished in accordance with i
1 14 the specifications and requirements and was it inspected i
i 15 properly.
16 So we are doing a complete reassessment of the 17 adequacy of the construction *of the plant. One piece of that 18 is welding. In this particular plant, the welding happened to 19 be painted, so rather than remove the paint, we chose to go to f 20 the position of inspecting through the paint.
- 21 MR. LIAW: ! guess you just restated your charter. I 22 don't believe you answered my question, why Tugoo reached the 23 decision to see a need for requalification, if I may use the i '
24 word. Is there anybody from Tugco -- i t
25 MR. HANSEL: We are doing a reinspeetton, not i
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e .
12 1 requalification. We are doing a reinspection, not a 2 requalification.
3 MR. LIAW: The reinspection to verify the quality of 4 your previous --
5 MR. HANSEL: Previous work and inspection, 6 MR. LIAW: Right. Why did Tugoo reach the decision 7 that there was a need for doing that, by code or by 8 regulation?
9 MR. HANSEL: It's a voluntary move on the part of to Tugeo. There have been a number of questions raised.
11 MR. LIAW: I would advise you to say that 12 carefully. Is that voluntary without clear indication of the 13 need? You might get hit back for prudence of issue.
14 MR. HANSEL: There were a number of concerns raised 15 by the NRC technical review team. One of those concerns had 16 to do with welding and supports, primarily. In the evaludtton 17 'of that, we are looking at each of those concerns and 18 individual problems i d e n t i f 1*e d by the NRC, 19 Tugoo felt that it was a prudent move on their part 20 to go above and beyond that to provide an extra level of 21 assurance that, yes, the plant was properly constructed. The 22 sample that was pulled by the NRC technical review team was 23 very small. We don't know if it was biased or not, and it was 24 certainly not representative of the entire plant.
25 Based on those reasons. Tugoo and ourselves chose to 1
l .
- - - -. . .. ~ . . _ _ .--
13 1 go with the additional program, self-iniated program.
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! 2 MR. LIAW: You are saying that the NRC independent 3 review team inspecting welds did discover some defects that i
1 4 caused sufficient concern for you to embark on the larger 5 program.
]
l 6 MR. HANSEL: They identified some concerns. We have 7 not as yet validated totally all of those issues or concerns.
8 We are in the process of reinspecting that hardware now. The
. l l 9 thing that the NRC did not do that we are doing is evaluating i
10 each of those to determine if, in fact, they can be considered 1
i 11 to be safety signifteant, l 12 MR. LIAW: I have not reached the safety significant 1 ,
13 question yet. I'm trying to understand the process, how this '
14 came about. Let me ask you; are there any NCR reasons on this I
15 issuet How many of them, roughly? I 16 MR. HANSEL: Again, I will have to back up and "
17 retrace history. The technical review team identified some s !
18 concerns, and those came out in several SSERs. Those in and
! 19 of themselves were indleative that there could have been a f 20 problem in terms of welding along with other types of 21 defects. We are investigating those ourselves through 22 reinspection. This is looking at the same items that the NRC r
i 23 did, I
~' 24 Tugoo felt that to provide an extra level of 25 assurance, they would do a self-initiated program to take a
. ~ - . . . . . . - _-. . - . - - . _ _
t i 14 [
] 1 sample of all equipment in the plant. It is through that .
l 2 program, what we are calling our self-initiated program, that 3' we are getting to other items of equipment that have welds 3 i '
} 4 that fall into this category, i !
5 Now, I am certain that there are some NCRs,' how many I
$ 6 I cannot tell you. We have the specifies that were given to f
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l.
7 us on the NRC findings through the various supplemental [
J 8 evaluations, and we have also written or required Tugoo to r
9 write NCRs on our inspections that we have to date.
j 10 MR. LIAW: Can Tugno answer that question? f 4 .
I !
i 11 MR. DACKO: I don't have that information with us. l i
e i j 12 MR. COURTLAND: Could a distinction be made? Are [
J r 1 i
! 13 you trying to check the adequacy of the construction or the !
1 l I
J 14 quality of the welding? It is not the same thing. [
I j 15 MR. HANSEL: We are out to determine the adequacy of 1
- I 16 construction, is it safe. Now, you may have some other minor I
i 17 defoots that are not in and of themselves safety signiftoant.
l
! [
18 That kind of information will allow us to also make -- to draw r 19 'conotusions about the adequacy of the QA/QC program early,on.
l f 20 We are chartered to do two things. One is to j r
21 evaluate the adequacy of construction, is the safe plant to j l t
} 22 operate, and two, the adequacy of the quality l l
j 23 assurance / quality control program.
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i , -
i 24 MR. COURTLAND: That you can't do unless you use the I
25 f f original quality program and the original quality ortteria. i j . i l
t i
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15 1 What you are proposing for adequacy of construction seems to 2 make sense to me, but to apply a different standard to check 3 the original quality doesn't make sense.
4 MR. HANSEL: But I'm looking at a number of other 5 aspects over and above the inspection as one piece of the 6 information.
7 We have reviewed procedures, inspector 8 qualifications, craft qualifications, process controls, and 9 the inspection data we get is just one piece of data that wo 10 will take into totality to evaluate the QA/QC.
11 We feel we will get sufflotent information in the 12 case of welding to allow us to draw those conotusions, plus we 13 will have it on all the other kinds of work processes that are 14 accomplished in the plant.
15 MR. ELLIS: Doing the old Army thing, I'm going to 16 tell you what I'm going to tell you, then I'm going to ..
17 summarise what I told you.
18 CSlide.)
19 I'm going to review the various weld attributes we 20 think are important to the job. I will discuss the general 21 welding metallurgy of materials and their weldability, I will 22 discuss the program that was used to determine the thickness 23 and the variation thereof, and I will review the results of 24 its paint thickness. And I will review the results of the 25 other independent review which had been conducted, how
) . .
15 2 -
1 they support our decision. The result will be integrated into 2 what we believe is a logical conclusion for future work on 3 reinspection supports at Comanche Peak.
4 [ Slide.3 ,
I 5 The materials involved.
6 Fundamentally, they are very common low carbon, low t
7 sulfur steels. They are A-500, ASTM A-36, A-588, Grade B, and 8 there are a few A-240s, which is Type 304 stainless steel that i l
! 9 are used for lugs on the piping systems. These materials are l l
10 well known to most people involved in the nuclear business. !
l 11 A-36 and A-500 are classified as carbon steels. They are i
12 readily weldable. They have low hardonability, low carbon, '
13 usually less than .26 carbon. They have resultant low i 14 hardness after the welding process. They are not particularly ,
t r
J' 15 prone to hydrogen embrittlement, should there be a difficulty I i 16 with the welding electrodes. They are considered to be fa'irly .
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{ 17 insensitive to hydrogen embrittlement. !
18 We have good ductility. I would classify them as i l 19 forgiving materials. ,
I 1
! 20 A-500 again has a little higher alloy, but still is ;
i 21 classified as low carbon steel. It has the same general good l
i 22 attributes, except it's a little more prone to hydrogen j 1
t
, 23 cracking, but not significantly; has a little bit higher l
,)
l 24 hardonability, and it is a material which has been !
k 25 pre-qualifted for use by the AWS code. ;
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17 1 The electrodes used to join the carbon steels were 2 the E-7018, which is a standard quality electrode for these i
- 3 combinations, very common use; low hydrogen type of low 4 welding electrodes.
i S Most welders are very experienced with this.
1 6 Overall, it matches the base strength very well; a little bit 7 higher strength than some of the base materials, but normal 8 welding combination for these materials. Has toughness, has 9 good fusion due to the high penetration rate of the
. i 10 electrodes, and it's typically of the low carbon variety, 11 typically less than .1 percent carbon.
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12 It has good slag removal characteristics.
13 Given the weldability of the material, the welding l
14 electrode which has been used fundamentally we believe a f 15 cossbina t i on saa t e r i a l is a good weldable combination of i
j 16 materials, and with electrode control of the potential -
1 17 hydrogen probless, there should be no resultant generio [
l i
- l 18 cracking problems with this combination of materials, i 19 Please ask questions as we go stong. I e
20 MR. LIAW: I agree with everything you say, except l 21 the third item on the second bullet, controlled issue and 1
22 storage. You cannot satisfy yourself that they have good .
i
, 23 control of the process and the material used, and it's kind of l
- - 24 difficult for you to draw an overall conotusion yet l
- 25 I guess I would like to know what you intend to i
e
18 1 review in that area and what your conclusion is.
2 MR. ELLIS: There's later on --
3 MR. LIAW: You mentioned material compatibility and 4 general workmanship.
5 MR. ELLIS: Could I ask you to hold'your question?
6 Because later on I will get into some of the detailed things 7 which have been done'at the site to support that issue that 8 you are raising, sir.
9 CS11de.)
10 Weld attributes.
11 I guess there are several things. You want to 12 determine whether the weld is satisfactory for its intended 13 service.
14 One of the first things you want to consider is does 15 the weld exist in the right location. If it's a fillet weld, 16 this would not apply to normal girth weld'-- if it's a i t !'l e t 17 weld, does it have the proper length and sise?
18 Thirdly, an issue is cracking. Has thi weld 19 cracked? Is there any tendency of the material to crack and 20 is there any crack present?
21 Various codes have various criteria, but one of the 22 attributes of a weld is undercut, particularly on a fillet 23 weld. Is there undercut present that indeed would interfere 24 with the serviceability of the weld? And is there fusion 25 between the weld's metal and the base metals which are
! 'I' 1 joinin2 ?
l 2 We believe those are the issues significant to the
{ 3 strength of load-carrying capability of the material.
, 4 The other attributes.which are many -- one could 5 make a very long list of attributes, but normally the" other u attributes associated with welding include slag and spatter.
7 Slag is the flux which is on top of the weld to i
8 protect the molten metal when it solidifies to keep the oxygen 1
j 9 out of it. There have been many studies on slag. I guess I'm i
10 going to lump those things together, slag and porosity.
l 11 There have been many studies of which I have j 12 references, should you care to have them, which indicates slag I
f 13 and porosity are rather benign defects in welds, particularly 1 14 in a weld that is not controlled by fatigue.
t l
i j 15 There are studies which indicate porosity -- it 16 varies from 2 to 7 percent, but up to 7 percent of the vo fume 17 can be -- porosity was in the weld and it will not have a l
I
- 18 signiftoant reduction in the load-carrying capability of the i
i 19 material.
i
) 20 So, in my judgment, slag and porosity are rather
- 21 benign. They're rounded, they're not cracks, they are rather
, 22 small innocuous types of indications that really do not have a I
i 23 signifloant effet on the load-carrying capability on the weld,
- 24 as long as they're not gross. Any defect that is gross can be l
l 25 detrimental.
l.
_ _ _ _ _ _ _ _ . . . . , . . - - , . . . _ _ _ - . . - _ ~ . . . _ _ . . . . . _ . , . _ . - . _ _ . _ _ _ _ . . . . _ _ , . _ ____. . - . . . , _ - -
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i 1 l I
20 -
1 Arc strikes. The materials we're talking about .
i 2 again, there are numerous studies on the effect of are 3 strikes. In fact, I will have to say Stone & Webster did l j 4 require the removal of are strikes. !
I i
5 However, we have in the last three or four years c l
6 reviewed the issue of are strikes, particularly on the low !
7 carbon steels. We have done experiments on the material. $
l I
8 One, there is not a very high probability of [
t 9 cracking; and secondly, even if the are strike were to crack, !
[
10 the size of the are strike is relatively small relative to the f f
f 11 thickness of the materials. It's small. We are talking less :
I i
12 than an eighth of an inch normally for total effect of the i i l I
13 sone.
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t i
- 14 Even if it were to crack, which it is not prone to i
(
, t j 15 do, the significance of are strike, in our judgment, has been '
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16 greatly overplayed in the past. -
t i
I 17 MR, CORTLAND: Are you saying an eighth inch orack f l
t 18 is okay?
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I 19 ,,
MR. ELLIS: I'm saying I haven't gone into fracture
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- 20 mechanics, but, one, I would not expect an eighth inch crack
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i l 21 there, because those are readily observable and should not be 22 there, f
- 23 MR. CORTLAND
- If it was there, would it be ,
j . i t !
24 acceptable
- 4 .
\
25 MR. ELLIS. All I can do is give you my opinion of i
i
_ _ _ ._ _ _ _ __ _ _ . = . _ . _ _ _
e 21 1 these materials. I haven't analyzed the stresses. I had my 2 people look at that. But if you would ask me if an eighth !
3 knch orack is acceptable in these materials and these typical 4 kinds of loads, my answer is a very strong yes, sir.
S MR, LIAW: You say Stone & Webster's past practice 6 has been to remove she are strikes. I suppose by welding, I 7 guess? !
, 8 MR. ELLIS: By welding or grinding or other f i
9 processes, yes, sir. But we do not do it now, and we have not i
?
10 done it for -- don't hold me to the time, but not for a !
l 11 considerable period of time. Obviously it would depend upon (
)
i 12 the particular client's attitude, but from a technical i !
13 viewpoint, we do not think the removal of are strikes in most i 1
i l
14 normal applications is an appropriate activity. .
f !
15 Profile discusses whether it's a concave or convex !
! l i 16 weld, fillet weld, and again, as long as you have throat o 't i
17 the weld to carry the load to it, it's a rather insignificant i
18 attribute on illlet welds. ;
i
- 19 I guess in summary on this is that for a non-fat,igue f f
i 20 type of application, which I have been assured that this is [
! i j 21 indeed the case for these, is the kinds of indications that we i f
22 are talking about here are rather insignifloant as far as the f
?
23 load-carrying capability of the structure, in that even if l i i 24 they are saying slag porosity under non-cyclic type of [
[
25 loading, there is very, very little probabili*.y that they l l I I
L__
22 1 would propagate under non-cylic loading, unless you just 2 happen to reduce the cross-section area. Not that you don't ,,
3 have the load-carrying capability.
4 Any questions?
5 CNo response.3 6 CS11de.3 7 Again, I guess I would remind you that the purpose 8 of this review was to determine.are these welds fit.for.
9 service. _That was my charter and that's the criteria ! am 10 trying to follow. Can these welds be determined to be fit for 11 service they are intended for.
12 Fainting effects. The welds which are painted are 13 painted with a prime coat. It's carbon sine-11, which is a 14 very normal coating for nuclear power plants. The thickness 15 is somewhere between 2 and 5 mits.
16 Should there be a repair necessary to the prime " coat 17 before applying the top coat, that repair was made with carbon 18 sinc-191, and the thicknesses were somewhere between 2 and 4 19 mits.
20 The top coat was phenottn-305 with a speckited 21 coating thickness of 4 to 9 mits. This is what we asked for.
22 How do we determine what we have? The site reviewed 23 118 supports at various weld locations on both sid,es. Both 24 metals on both sides of the fillet weld and on the fillet 2S weld, they measured the paint thickness. They measured the te ,
23 1 paint thickness in 1132 locations. 1 l
2 Based on that, a statistical analysis was performed, 3 and the average -- it was determined the average paint 4 thickness was indeed 10 mils, and there's less than 1 percent i
, 5 probability that the paint will be greater than 20 mils 1
6 thickness.
7 So I think that gives us a fairly strong case to ,
1 l
8 what kind of thickness of paint we might be asking the ]
9 ,
inspectors to look through.
10 The third bullet I have there is what weld 11 attributes does one -- can one inspect for through this 12 paint. I think the subsequent information which we will 13 present will assure everyone in this room that the size of the 14 weld can be fairly reliably determined through that sort of I l
15 thickness of paint, both as far as length and throat areas. l l
)
16 One might get in an argument whether one has t o *'m a k e 17 an allowance for paint thickness or not in determining the 18 fillet size. I think based on my understanding of the l
19 situation review of it is that the paint, if it is present, 20 will probably understate the size of the fillet rather than I
1 21 overstate it, j 22 Undercut. Normal acceptance limits is 1/32nd. l 23 MR. CORTLAND: Where did you get 1/32nd from?
I 24 MR. ELLIS: AWS code.
25 MR. CORTLAND: What about the FSARf Unless I am i
4 24 1 reading it wrong, she FSAR quoted the '69 Steel Construction 2 Manual, which in turn quoted the '69 AWS Building and Welding 3 Construction, and that is not 1/32nd.
4 MR. ELLIS: Would anyone care to comment?
5 MR. SMITH: You're going to the VWAC?
6 MR. CORTLAND: That's an inspection you're going to 7 inspect on the VWAC.
8 MR. FAERY: The intention was to inspect to the 9 visual weld acceptance criteria that was issued this year for 10 AWS welding.
11 MR. CORTLAND: The intention is not to inspect to 12 the original construction criteria.
A 13 MR. HANGEL: Point of clarification:
14 Except in the case of ASME welds. There we will use 15 the original criteria.
16 MR. ELLIS: But I think there has been sufficient 17 demonstration that undercut can be determined, even from some 18 of the NRC inspections, can be determined through paint.
19 There's an argument whether undercut indeed may be amplifted 20 by the application of the paint. There is evidence to very 21 strongly suggest if you have paint on the weld and you do have 22 undercut due to the hues of the paint, that indeed it will l
23 look deeper than it actually is.
24 Porosity.
25 1 guess you asked the TRT team to determine if you i
i r
L
25 1 can see porosity through paint. I have reviewed this with my 2 coating specialist, and to cover up a 1/16th pore in porosity 3 would be very difficult with the painting techniques which are 4 currently used. Even the 1/32nd diameter pore would be fairly 5 difficult to cover'up. 1/16th pore would be almost impossible 6 unless you really worked with the damned thing. Even then, 7 there still be a depression of the paint in the bottom of the 8 pore' tha t indeed would be visible, 9 Cracking.
10 There are several types of cracking. One, if it 11 cracked before the paint was applied, it should have been 12 picked up by the inspection program. If it's a large crack, 13 it's a little bit like painting your wall. Even a small crack 14 on the wall, every time I paint over it, I cannot get the 15 paint to cover.up the crack. It's there. I wouldn't quantify 16 the size crack, but there's some cracks that obviously paint 17 will not reach. I think it's a fairly small crack, in my own 18 opinion. Other people ma/ have other opinions. But there are 19 cracks indeed that paint probably can cover up, small though 20 they may be.
21 MR. LIAW: Generally one has to draw the conclusion 22 that you cannot see the crack through the paint.
23 MR. ELLIS: I think' when it ~ came down to it, there 24 are a grouping of cracks that one could not reliably detect 25 through paint,.yes, sir. There are some that you could, if it
l 1
l 26 j l
.1 was a large crack, if it had been cracked after the painting I I
l 2 was applied, it would probably crack. There's probably a 3 group of cracks you cannot see through paint.
4 MR. LIAW: Before you inspect or reinspect to
~
qualify the general quality, you have assumed that you cannot 5
6 make a distinction of the type of crack that could be 7 inspected through the paint. As a result, you have to C conclude that you cannot inspect through paint for cracks.
J 9 MR. ELLIS: That is our assumption, yes, sir.
10 MR. SMITH: 1 think there is a limit, 'where even !
11 visual will not pick up certain cracksJ Like at Wolf Creek, 12 we found that MT picked up some laminar tearing which was 13 rather shallow, but it was not picked up visually.
14 MR. ELLIS: I guess if you really do not and cannot 15 tolerate any cracks, you probably would not invoke the visual 16 acceptance criteria in the code. Like AWS, if they d i d n ' t
17 want any cracks, they probably would not invoke visual 18 criteria, because visual inspection can pick up.certain graded 19 cracks, but there's undoubtedly types of cracks that cannot be 20 detected by the normal inspection. But the-code just assumed 21 that. That's why the design codes allow for a load, that's 22 why they've got the margin in there. Visual inspections, you )
l i
23 cannot ensure you don't have cracks. .
l l
24 MR. SMITH: There is a philosophy you are talking 25 about where you balance your margins vs. what flav. you know. l l
f i
l 27 1 MR. ELLIS: Yes, sir, you are entirely correct.
2 MR. SHAO: Your answer before bothered me here. I !
3 thought all your construction adequacy program or design i
4 programs to make sure the original criteria can be met, not 5 the new ones, meaning original. Now you say the inspection is 6 according to the new criteria, it's not according to the FSAR. ,
1 7 MR. HANSEL: The commitment we made in the Comanche 8 Peak Response Team program is to inspect the adequacy of that I
9 plant in terms of construction: is it constructed safely? And to also there has been a commitment made now for Tugco to I 11 evaluate back against the FSAR. ;
i 12 MR. SHAO: That is very difficult. Your standard, [
j 13 somebody else's standard for whether it is safe may be i 14 different.
7 15 MR. HANSEL: I think, Larry, when we finish you will
- 16 see the inspections that are conducted, the manner in whidh 17 they are conducted and the evaluation of any ~ defects found, ;
18 that the final analysis of all that data will stand on its ;
a 19 own. We will have sufficient data to allow us to draw a 20 '
conclusions as to the adequacy of the construction and is 21 there sufficient margin in those welds --
22 MR. SHAO: Eventually, after you are going to 23 conclude, you are going to say your construction is not 24 according to your commitment --
25 Md. LIAW: They have amended the FAAR by changing l L e----m-.- .-- , - -- - . . - . . - - , - . , - - , . - - . , - - --
28 1
the criteria.
2 MR. SHAO: I'm talking in general now. I'm not 3 talking this particular area.
4 MR. LIAW: I'm saying to you once they amended the 5
FSAR, the new stuff they get is the one they are committed to.
6 MR. SHAO: Have you amended on this one yet?
7 MR. HANSEL: Yes.
8 MR. LIAW: At least you can say they have 9
constructed and inspected their plant in accordance with the 10 FSAR.
11 MR. SHAO: I don't want you to make a general 12 statement saying, well, we don't meet the regular construction 13 criteria, but it's safe.
I don't think that will hold water 14 Unless you have that area that you want to amend them.
15 MR. HANSEL: We will evaluate the plant in terms of 16 the adequacy of the construction. Tugco will also address' 17 their commitments.
18 MR. SHAO:
That part of the program really bothers 19 us.
It's the commitment that we want you to meet. When you 20 say how safe is safe, different people have different 21 standards.
22 MR. HANSEL: Again, I think we will have to atmost 23 take each of those nonconformances or defects on a 24 l
case-by-case basis because it is very difficult. .a s you know, 25 and I do, to evaluate a particular nonconformance on a hanger
4- ,
I v
e
29 1 by itself until we see the data. If we are within the margins l 2 nad the code allowables, then that weld should be 3 satisfactory. We can't state that until we go through the ,
t 4 calculations,- through the analysis, what the defect is, what ;
~
5 is the location is, where it is and how it might affect the I
6 integrity. of that weld. j 7 MR. SHAO: I have spoken my piece. ;
i I
8 MR. HANSEL: I know where you are coming from. ,
9 MR. ELLIS: Any other questions? !
10 MR. CORTLAND: Did you mention lack of fusion? !
i i.
11 MR. ELLIS: You are correct. Lack of fusion is a i
12 defect which is obviously a crack-like indication. !
l 13 MR. CORTLAND: Normally i t. is associated with the
(
14 condition -- I am going to call it roll-over, that the weld i
15 profile is normally rolled over. It's in a di f f icul t irelding 16 position in that the heat has caused the weld metal to r a f'1 17 over. Normally it is associated with roll-over, which can be
~
18 seen through paint and which can be removed. I guess the f 19 corollary, if you would ask is it always associated with ,
i 20 roll-over, my answer is no, but'a large percentage of the "
21 time,'it is. But in those times when it is not, i t is a 22 crack-like indication so the criteria for cracking -- so there
- 23 is another type of crack. It's a sharp, a crack-like w- 24 indication. If you do not see it, in my experience, a ,
t l . 6 l 25 rollover is a prime spot where you indeed may find lack of
,.r g- m T -
7 'ar * *W v
30 m
1 fusion on the fillet time of welds. Obviously, in a groove 2 weld you might find it other places, but on a fillet weld, 3 that is normally where I would expect to find it.
4 MR. LIAW: Among those five attributes, which one of 5 them do you conclude you can see'through the paint and which 6 ones can you not?
7 MR. ELLIS: Size, I think it is clear you can see 8 that through paint. Undercut, as long as -- in fact, the 9 paint may magnify it. . Porosity, there is some porosity that 10 you might not see, but also there is porosity as evidenced by 11 some later test results that you can see. Porosity, in my 12 judgment, is a very, very benign type indication within 13 welds. Porosity can be up to --
static weld conditions --
14 could be up to somewhere between 2 and 5 and percent of the 15 cross-section area and not affect the weld under static 16 conditions. --
17 Cracking. If it is cracked after you apply the 18 paint, the paint would crack and you would see it. If it was 19 a gross crack before painting, you could probably see it, , but 20 in point of fact, there are cracks that one could not see by 21 inspecting through paint.
22 Lack of fusion. Again, if it is associated with 23 rollover, which I believe a significant portion of it is, you n
+
1 24 would be able to remove the rollover and determine whether you 25 have lack of fusion or not when you take the rollover off, the
- ~ ~
s
( x - -
9 se -- e- = m ~ v&
t l
i 31 1 paint off.
2 There are probably some cases where you are going to i
3 have lack of fusion, although there has been no evidence of 4 it, but again, there is a probability there. In some places i
5 you have a lack of fusion that you may not detect through !
t 6 paint. Again, I go back to the code allowables. The design 7 margin is that the visual inspection codes do not ensure you 8 that you have flawless welds. There are some flaws built in 9 and permitted.
?
10 MR. LIAW: Let's not cover the design module yet. I !
11 would pose a question to the technical staff. Do we agree 12 with what he says? "
13 MR. SHAO: I cannot make a comment right now.
14 MR. SMITH: I would like t' o quantify one thing and 15 give some other history. One, I have a feeling that there ,
i 16 might not have been complete communication. To givw you sn ;
17 examp1 , when we were asked to make a response, the question l
18 to us was the staff position on inspection through paint, not 19 particular.to Comanche Peak, but the staff position that would 20 be applied to all regions, all plants, this sort of thing.
21 Therefore, we 'had to also take into account what 22 other experience has been that we knew or has happened in 23 other , plants. We knew of three cases where applicants tried to
- 24 qualify inspection through paints and they wound up with 25 saying they could not, They didn't even come in to us for i
32 m
1 review within their own organizations. They dropped the 2 issue, the project.
3 Basically what it came down to is you take a 4 standard in your VWAC and you say you can accept -- let's say 5 it's a quarter-inch overlap. Let's say a quarter-inch lack of 6 fusion. All right? So the question comes down, when you paint 7 it, can you really evaluate a quarter-inch? Your answer comes 8 down to you really cannot.
9 Now, thicknesses that were involved in the cases 10 were a maximum 5 mils, and the results were that they could ;
11 not consistently meet or determine whether the defect would 12 meet the specific criteria. In other words, if it's over a 13 ,
quarter-inch, could you tell with the paint, and how much 14 could you tell? And they could not do it.
15 So to try and qualify the inspector or the 16 procedures to those absolute numbers that are in the s t and'a r d 17 is really what happened. They could not consistently do it.
18 MR. LIAW: I-guess what you are saying is that other 19 than the size, the other fcur attributes are not really ,
20 "inspectable" through the paint. Is that what you ^are saying? i 21 MR. SMITH: You could not meet the absolute i i
22 criteria, !
i 23 MR. LIAW: You are talking in the context of what
~~~
24 the acceptance criteria are.
25 MR. SMITH: You might say reading between the i
--,- , y ag-- y__,a -
i I
t f
33 i 1 lines. I think the people backed off of it. They felt they i 2 would overcall and wind up with having to do more. If you did !
)
3 the statistical sampling plant, you would wind up with an 4 overkill. Every weld, almost, had to be letter perfect, no t i
5 defects, which is not the way things are. So with the overcall ,
I i
6 on the sampling basis, you would wind up rejectnig the whole [
l 7 population, which is not what you are trying to do. .
8 So if people start saying we want to measure the f I
9 quality according to these standards, the VWAC, it becomes --
10 we also looked at we could not defend it in a court, f
?
11 especially knowing that there were three people who tried to ;
i 12 do it and they wound up saying no. We didn't know of any case i
13 where they had successfully demonstrated. As I say, we were
~
14 I asked for a staff position, which meant anyplace and 15 everyplace, wherever. ;
5 1 16 MR. SHAO: Does Applicant know of any cases thef 17 have used inspections through VWACf ,
t 18 MR. FAERY: The only one I know of is Wolf Creek. l 19 MR. SHAO: They didn't do a lot of sampling. ,
20 MR. FAERY: They did a lot of sampling with [
L 21 welds. They have a lot of unpainted welds which they were able l I I 22 to look at.
23 MR. SMITH: Forty percent, which is more than a 24 sampling. Those that were painted, as a third independent I i
25 party, NRC, we picked out a statistical number. We inspected ,
u w ~ w s w ~ gr y-- myw >- - -- ,w--
4 + eo 3
1 34 i
i them before -- visually through the paint as the inspections ;
2 were done, stripped the paint and then reinspected and redid i 3 both of those before and after stripping, both visually and 4 magnetic particle. ;
5 MR. HANSEL: That was how large a sample, dave?
6 MR. SMITH: Fifty-nine, which was more than an 7 adequate statistical sample. It turns out there are other 8 statistics. I would say 59 would be what you use. !
9 MR. LIAW: At that time the total numbers of welds 10 in question was on the order of several thousand. I guess, r 11 based on 105, look at the population size of welds. Fifty.was 12 the initial sample size, with zero rejects in the accepted 13 population to 100 population as a whole.
14 MR. HANSEL: Let me draw a comparison, I think, ,
15 between Comanche Peak and Wolf Creek. '
16 MR. LIAW: Could we postpone that because right"now [
l i 17 want to have our record to indicate that the s.t a f f are not ;
18 necessarily agreed with what you say with regard to those five ,
19 attributes. I think we agree with the fact that undersized, 20 yes, we agree you could inspect it through the paint, but the 6 21 other four are questionable; correct?
i 22 MR. BARNES: It sounds like a reasonable statement, 23 yes.
24 MR. LIAW: I just wanted that on record.
25 MR. SHAO: Also, I don't think we can make the t
35 1 statement that because there are no fatigue loadings, you 2 don't have to worry about porosity or slag. I wouldn't go for 3 that either.
4 MR. ELLIS: There are probably other things that are 5 more important to me under fatigue conditions, such as lack of 6 fusion and cracking. If I put my pecking order, porosity is 7 probably my lowest concern.
8 MR. LIAW: I agree. Once we have inspected whether 9 or not -- the kind of defect you found, that is one question.
10 Whether or not that particular weld with that kind of defect 11 in there is still safe enough is a separate question in terms
> 12 of AWS terminology. You wait until the engineer " evaluates" 13 it. Let's separate that.
14 MR. ELLIS; Okay. What do we know about the welds 15 at Comanche Peak?
16 [ Slide.) -.
17 The technical review team inspection was performed 18 in' July of 1984, I believe. There were 389 pipe support welds 19 inspected, 89 of which were painted. That inspection revealed 20 that there were four cases of undersized fillets, ranging from 21 1/32nd to 1/16th. There was one case of porosity which I note 22 was seen through paint. There was one case of undercut which 23 also was noted through paint. There were two either 24 incomplete or omitted welds -- i.e., that there ou--t to be a 25 weld and there wasn't one --
and there were two e- sf 9
- -, - - - - , r w, - - - -
, - ,- e
36 1 excessive grinding where apparently the base metal had been 2 encroached upon. '
l 3 Continuing on, that same review team inspected 59 4 raceway support welds.
5 [ Slide 3 6 Again, the support welds were inspected not through 7 paint, as I understand it. There were undersized fillets with j 8 anywhere from a 32nd to 3/32nd in three cases, and misplaced 9 welds in two cases. So based on the TRT inspection which was 10 performed on either paint or not paint, there was no 11 indication that there was a major problem with anything as far 12 as the strength characteristics except the fact that they were 13 undersized fillets and one cases of porosity which was 14 detected through paint.
15 MR. SMITH: On those was there analysis done which
~
16 showed that even with all of the undersized and mi s p l a c e d --
i 17 welds, you still did not violate your code requirements?
18 MR. ELLIS: I don't know what has been done in that 19 area. ,, ;
i 20 MR. HANSEL: Those have not'been evaluated yet. The 1
21 evaluation has not been completed. >
22 MR. LIAW: I have a question here with those welds t
23 with paint on that you have not gone ahead to strip the paint
~
- 24 and verify that indeed those are the only rejectable.
25 MR. FAERY: Those welds were stripped, the welds !
e
.n. - - - , - , ,
. e i
t t
l 37 }
1 where they found the frosting and the undercut. I know they f 2 took the paint off.
3 MR. LIAW: So what is the criteria to determine 4 which welds are to be stripped of paint and which welds are i i
5 not? ;
6 MR. FAERY: The criteria for us, as I understand the i
7 program, the inspector is going to be inspecting for the j r
8 attributes in accordance with the VWAC or ASME criteria. If he ;
' i 9 observes an indication that he cannot totally evaluate --
10 let's say evaluate something that looks like porosity to him f 11 but he cannot totally. evaluate it -- he has the option to take l 12 the paint off and take a look at it closer, which we would
(
r 13 expect him to do. 1 14 MR. LIAW: TRTs and the NRC team, right?
15 MR. FAERY: Yes. I t
i 16 MR. LIAW: I guess I have a question to our own ~ ~
~
l 17 staff. We have mixed facts there. i 18 MR. SHAO: It's not our group. l 1
19 MS. VIETTI; Apparently it was Herb Livermore, who
- 20 is house hunting right now so he is not available for this 21 meeting.
22 MR. SMITH: Were you on the TRT team, Charley? t i
23 MR. SHAO: No, he didn't do this one.
I 24 MS. VIETTI: He didn't perform this one.
i 25 MR. LIAW: I'm not questioning the thing. I would '
s.- . . .
-_~ - -_ _ .__ _ . . _ . --- -- - ._ _ - - - - . - - . .
38 1 just like to understand, Obviously we have mixed facts here. I 2 guess in order for you to draw some kind of statistical 3 inference to understand the basis from which one can determine 4 what can be stripped off and what are not. I guess I will i
5 pursue that with the NRC staff.
6 MR. ELLIS: Again, I don't know where all the hidden 7 rocks are in this, but my' technical advice is 300 welds were 8 inspected in a nonpainted condition; 89 were inspected in a 9 painted condition. Of those 89 which were inspected, either 10 -- let's take the unpainted ones. There was no indication of 1
, 11 generic weld problem. T!. ore was no cracking revealed, there 12 was no major undercutting revealed, there was no significant 13 --
no lack of fusion, no significant problem --
14 MR. LIAW: I would like to see statistically -- you 15 have them both mixed together. Could you separate two l 16 populations, one with paint stripped off and one wi t hou t ? And
, 17 what are the findings?
i
~
18 MR. ELLIS: According to my information, the only 19 two discovered with paint on were porosity and undercut. ,The i 20 other 300 welds which were inspected revealed only undersized
. 21 fillets and incomplete welds or excess grinding.
22 MR. LIAW: So~they are not statistically related.
23 MR. ELLIS: They have not been statistically l
l 24 correlated, to my knowledge.
i 25 MR. LIAW: So that inspection is almost -- I l
l
\ . - _ _ _ _
39 1 wouldn't say useless, but you really cannot draw any 2 conclusion out of it.
3 MR. SMITH: Wait a minute. It is more. Those i
4 numbered welds are more~than any statistical sampling would be 5 required. I i
6 MR. LIAW: Be it as it may, I'm saying the two ;
7 different populations, you are finding entirely different 8 ' things.
9 MR. RICHARDS: I have reviewed the QA/QC SER, and in 10 their report of inspecting these welds, apparently all of the ,
11 attributes that were found were found on the unpainted welds ,
12 because the only ones that they mentioned where they removed 13 the paint was that they had detected the undercu't, one 14 frequency, and porosity, one frequency. They were both
{
r j 15 detected on a painted weld. This being a suspect weld, they 16 had the paint stripped, and then they dimensioned the 17 undercut.
18 Now, the porosity they did not specify, so whether l
'i 19 it was an acceptable condition or not, they didn't say. We ;
20 could only draw s om"e conclusions. But in the meantime, for !
21 each of those --
all of the other attributes that they found 22 were on unpainted welds. F
, 23 MR. LIAW: That seems to be supporting what I said i 24 earlier.
{
l 25 MR. RICHARDS: With the overall sample size, l i
f i
f
~
40 1 including both type supports, 453 welds, all of those 2 attributes fall above a 97 or almost a 98 percent confidence 3 level, except for the undersized.
4 MR. LIAW: What I'm trying to do, in order for us to 5 read the bottom line, whether or not to reinspect it, and I 6 would like to see the results of two populations in order to 7 draw some kind of statistscal correlation based on that 8 result. I don't see it.
9 MR. SMITH: There's one other statistical sampling 10 to be aware of. Of the original inspections, there was 11 something like 20-some-odd thousand NCRs on the welds.
12 MR. RICHARDS: 27,000 NCRs.
13 MR. SMITH: For welds or everything?
14 MR. RicMARDS: Hardware, welds, everything.
15 MR. SMITH: I understand they pulled a statistical 16 sample of 500. **
17 MR. RICHARDS: Those related specifically to support 18 welds.
19 MR. SMITH: To support welds, okay. In that ,
20 statistical sampling that was reported in the Stone & Webster 21 report --
I don't have the exact numbers; I'm sure you have 22 them -- I'm probably taking your thunder, but I'm sorry.
23 MR. ELLIS: That's all right. Great. Move on.
24 You're doing a great job. p.
25 MR. SMITH: Okay. I think it showed that quality, l
i l
L
41 1 the attributes that we're talking about -- quality, like 2 porosity, undercut, cracks, fusions, slag -- they were very,.
3 very small -- in other words, statistically insignificant, as 4 1 recall, the results.
5 The only thing that was of significance was size, 6 and I don't remember if even location or presence was a 7 factor. I don't think it was. It was very insignificant 8 also.
9 MR. FAERY: We didn't study that close enough.
10 MR. SMITH: Okay. The point is, when a request came 11 down to us, we thought the real question is the sizing of 12 welds, and quality was not an issue, because we don't feel 13 that the initial inspection showed it. The TRT inspection 14 didn't show it. And the real question to you is the size, 15 maybe presence and location or some of these things here, 16 incomplete or omitted welds. "
17 We didn't see where quality really was a concern to 18 you, and the only thing that really was a concern was sising.
19 .
MR. LIAW: That's something nice to know. I .
20 appreciate that. I guess in the context of what we try to 21 reach today or with regard to this particular request, I think 22 you have to look at the numbers they presented. That still 23 may be the bottom line with regard to the safety of the 24 plant. We must rely upon that kind of number to come to the 25 conclusion,-to reach the conclusion. I don't deny that.
~ - - _ _ - - . _ .
42 1 I think legitimately those ought to be considered, 2 but I'm not looking at those numbers. I'm just looking at the 3 reinspection, because obviously somebody must have raised a 4 question, and you clearly must have some reasonable doubt with 5 regard-to the initial inspection. That's the reason why you 6 came back on this program to hire Stone & Webster to requalify 7 and reinspect your plant.
8 MR. HANSEL: I think I know where you're coming 9 from. I recommend that we finish the presentation and then 10 throw a discussion of the technical aspects.
11 !s it feasible or not feasible? Let's proceed 12 through and get the full story here.
13 [ Slide 3 14 MR. ELLIS: There have been other independent 15 evaluations which have been performed. The NRC Special Review 16 Team reviewed the weld material control program. The results 17 were, there was no evidence of uncontrolled or improper 18 control of welding materials.
19 The Region I NDE, in April of '83 -- su there have, 20 been several reviews and activities of various reviews which 21 indicate that there was not a fundamental weld problem, based 22 on the evidence which those people reviewed, s
_ 23 Subsequent to that, within the last month, ERC 24 Corporation has, as was suggested earlier, has done extensive 25 review of the NDE related to the supports. They pulled a
43 1 sample of 500, and the result, as suggested earlier, was 2 statistically insignificant. Of the 500 pulled, there were 3 only two with crack-like indications. These were, indeed, 4 rejected and repaired. But again, two out of 500 does not 5 indicate to me that there is a significant weld defect problem 6 with this program. And ERC has concluded that the proper 7 procedures were used for controlling of the low-hydrogen 8 electrodes, that the proper procedures and interpass 9 temperatures en the welding process were controlled, and again 10 they have a well-established control program for the welder 11 qualification training and certification.
I 12 So that's the data upon which we have looked. This 13 data is valid, and I have no reason to believe it not. If 14 that data is valid, then I arrive at the fundamental l
15 conclusion we alluded to here previously.
16 There is, one, not a weld quality program. The Ee is 17 a size problem, mislocation, that needs to be addressed, based 18 on the data that is present, and these attributes can be.
19 reliably looked at through paint. There might be some ,
20 exaggeration; there might be some other things. But with 21 proper consideration, one can establish whether the fillet 22 size, the location, and the other normal things that we're 23 talktng about here as far as weld location in strict 24 parameters can be determined.
25 This cracking is not going to jump out at you, but [
T .
l 44 1 at the same time, there is no evidence of cracking. The 2 welders have been inspected, as to alluded to earlier. Here, 3 they have gone through an extensive training course, 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />,'
4 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of classroom and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of hands-on experience, of 5 inspecting-through paint, and they have been instructed that 6 if there is anything in the paint that makes some suggestion 7 that they cannot establish the attributes they are looking 8 for, they are to require the paint to be removed.
9 If there is anything raising their suspicion, even 10 if-it's beyond the normal things which I believe to be the i
11 problem, which is size and location, if they see something 12 beyond that, obviously they are going to look at it, and 13 they're going to look at it to the extent necessary to assure 14 themselves that there is not a problem with it.
15 So I conclude, given the information that they have, 16 that these welds can be reliably demonstrated, that the we' Ids 17 can perform satisfactorily in service.
18 MR. FAERY: Let me make one other point. We are 19 also saying rejectable porosity, rejectable undercut, is not 20 going to be covered by the paint. There will be.an indication 21 there. You may not be able to totally measure it to say, 22 "Okay, is that 1/32nd or not?" If you can't, then you take 23 the paint off. But i t .s not masked by the paint.
24 MR. ELLIS: I think you suggested that to some of 25 the other people. I believe the paint is going to exaggerate
45 1 that, so we may be looking at welds where the inspector says 2 it's an acceptable undercut, we take it off, it may in point 3 of fact be acceptable, but I think it's an exaggeration 4 criteria, not that we're going to miss something.
5 MR. CORTLAND: I can't quite accept that. The 6 undercut -- paint will give you a bigger reflection, but it's 7 going to tend to fill in the undercut. It may make it easier 8 to see, but you still have to measure it.
1 9 MR. ELLIS: You have to measure it.
10 MR. CO!iTL AND : The paint is not going to make the 11 undercut appear bigger than it is by measurement. I don't 12 think you're claiming that.
13 MR. LIAW: You're not going in there to see if 14 there's something funny, so that you will strip the paint 15 off. I think you ought to go in there with some preset 16 criteria that you want them to inspect to, correct? --
17 MR. FAERY: Yes.
18 MR. LIAW: In this case, you have amended your FSAR 19 and the standard you are going to use in VWAC, too -- VWAC-1, 20 Revision 2. And I think we're talking in that context, rather l
21 than in generalities, saying, " Hey, I have a program. Get an 22 inspector in there. If you see something funny, he is l . I 23 instructed to strip it down.," I think that's too general. ;
-- 24 MR. SMITH: I think there's basically a general l 25 meeting -- or there is some place in here. I think what has i
46 l
1 been said is that sizing, maybe presence and location, are 2 probably the biggest concerns that we have.
3 The other types of defects, which may or may not be i
4 detectable through the paint .or the degree of what you can I 5 actually inspect to, might be debatable. That is not a 6 concern to us.
7 But if we happen to see something that obviously is 8 detectable through the paint, that it would be further 9 investigated. But to say that you can get to the VWAC 10 standards through paint, I think is very difficult to prove.
11
- MR. LIAW:
i I think you're saying it too mildly',
12 MR. SMITH: I'm not going to say " absolutely not,"
13 but I think it would be very difficult to do it. If you're in 14 an adversary type of hearing, I think you would -- we have ,
i 15 statements on record from --
and this is in regards to Wolf -
16 Creek, but I'm sure Miles Davis would make the statement about 17 how much you can see through paint, y
18 And as I say, because other people haven't tried to r I
19 qualify looking for defects through paint, they were not able i
20 to succeed, it makes it very difficult to say that that's what '
21 we're going to make our criterion to. I think if we're saying 22 we're looking for these types of defects -- size, location, ,
23 presence, length -- yes, you certainly can see those through ;
24 paint. We don't have any argument with you on that. f 25 If you are trying to look for the quality, to get it
47
'l to the VWAC criteria. I think you would have a tough time 2 saying that you can.
3 What I think you can say, if you did detect some of 4 these other attributes through paint, you would have a S question on the structural adequacy. But again, that's a 6 statement you can make, but to try and prove it is difficult.
7 In other words, if you saw a lack of-fusion or gross porosity 8 or undercut through paint, whether it be dimensional or the 9 dimensional attributes, you can't get there.
10 To say that you can see some attribute or.not see it 11 through the paint -- I wish I had it -- the concept, I guess, 12 that I .' m trying to say is, you are looking, and whether you 13 will be able to detect something that would be structurally 14 significant, I think you can. In other words, the welder 15 obviously lost control of his welding process, and you would 16 have what you would say is a bad weld, and to try to measu're 17 it and that sort of thing would be very difficult. But you 18 would characterize it as a bad weld, and you would start 19 worrying about the structural adequacy of that weld. .
20 I think you can see it through the paint, okay, but 21 to say that you're going to get down to VWAC criteria, I don't 22 think you can say that.
, 23 MR. HANSEL: Let me kind of recap,, Dave, where !
24 think we are at.
25 One is, we are not out to inspect and to evaluate l
t .
. =
48 1 every weld or every attribute. We are drawing statistically 2 based samples, and from that, we hope to draw conclusions 3 about the plant in general. In this particular case, we're 4 going to be drawing samples of supports, pipe hangers, HVAC 5 hangers, and so forth, and we will be inspecting those welds.
6 We did enough research to satisfy in our own minds 7 that the procedures that were used in the early days and 8 throughout the Itfe of the construction of the plant were good 9 procedures, both for craft and for inspection.
10 We also did considerable research, statistically 11 based, to pull upon the NCRs and the weld data cards to assess 12 those, to see what kinds of problems they had in their welding 13 process vis-a-vis their inspection process. We satisfied 14 ourselves that the major problems were undersized welds --
15 they were the biggest prob 5em -- or misplaced in a few cases, 16 and also maybe missing. -
i 17 MR. SMITH: And that's pretty common.
i 18 MR. HANSEL: That's pretty common for most plants. ,
I 19 With that background information -- and we have l 20 looked at a number of inspector certifications and also welder ,
- t 21 certifications and qualifications, particularly those en board !
l
! 22 today, and a lot of those go back for some time -- we see l
23 nothing there that gives us any great concern, which is 1
i 24 another piece of input for you.
i 25 In our statistical sampling process, we will pull a
. =
49 m .
1 number of samples from Unit-2 that are unpainted. How many of i
2 those will be in the percentage, I don't know. You mentioned 3 40 percent of Wolf Creek. My gut feeling tells me -- we were 4 talking about this last night -- that we're probably in the 5 neighborhood of 35 to 40 percent as well.
6 So I can also draw conclusions from looking at a 7 number of unpainted welds. The experience at Braidwood was ;
8 that we looked at about 2000 welds in Braidwood. At Byron, we 9 looked at some 2400 welds. Statistically, we should come 10 close at Comanche Peak to those numbers.
11 Eo that says, if I assume, let's say, on the low 12 side that 30 percent of the velds in Unit-2 are unpainted, I 13 would be looking at about 600 unpainted welds. Don't hold me 14 to those numbers. I'm just postulating.
15 So I can gather considerable data from that.
16 MR. SMITH: You're saying they're in the same --
17 populations? ;
18 ) HANSEL: Yes, they're in the same populations
- 19 and statistically drawn, randomly selected.
20 MR. LIAW: Under the conditions that between Unit-1 21 and Unit-2, you have essentially the same procedures, the same ,
22 set of welds, and so forth?
23 MR. HANSEL: Yes and no. We have a lot of the same 24 people. The procedures have improved over time and gotten 25 better. So if anything, I would have to say that Unit-2 would
50 1 probably be better than Unit-1. I don't know that for a fact, 2 but I would assume you would get better with time. I know the 3 procedures get better with time.
4 MR. SMITH: When you say the procedures get better 5 --
6 MR. HANSEL: Improve.
7 MR. SMITH: I don't see how it does to the welder's 8 drawing of a bead, because all of the attributes you are 9 talking about are his manual skills, not what's on that piece' 10 of paper.
11 MR. RICHARDS: I might add to that, that in Unit-2, 12 the 110032 weld process specification was also used in Unit-1 13 on the support welding.
14 MR. LIAW: So they have essentially the same 15 procedures?
16 MR. RICHARDS: Weld process specifications for the 17 same qualification.
18 MR. LIAW: Same process, same set of specifications?
1
! 19 MR. RICHARDS: I'm speaking in terms of welder ,
20 performance qualifications.
21 MR. LIAW: How about QA inspectors?
22 MR. CORTLAND: The designs are also the same, !
23 assume, and material selection was also the same?
24 MR. HANSEL: And material controls, yes.
e -
25 MR. LIAW: Oh, by the way, are you going to address m = w e -
51 1 the material, the material question I asked earlier, fillet 2 material question I asked earlier?
3 MR. ELLIS: Restate your question.
4 MR. LIAW: I asked the question in the context of 5 your Vu-graph. You said the welding --
6 MR. ELLIS: Welding material. control?
7 MR. LIAW: I told you that I agree with what you 8 say, with one exception. That is, unless you are assured'that 9 you have a good fillet material control program --
10 MR. ELLIS: Thank you for remind'ing me. I guess 11 there have been two or three people who looked at this.
12 One, the Construction Assessment Team in January and 13 March of '83 reviewed this very issue and concluded there was 14 no generic problem in the welding program, welder 15 qualificat' ion, the NDE, non-destructive examination, and/or 16 training activities. --
17 Going on down, the Special Review Team in April of 18 '84 reviewed the welding material control review, and the 19 result was, there was no evidence of uncontrolled or 20 improperly controlled welding materials.
21 ERC, within the last month, has looked at, one, 't h e 22 electrode control program and concluded that they had proper 23 procedures. The reviewed the welding pr,ccedures and concluded 24 there was proper preheat and interpass temperature control 25 procedures. They thirdly concluded that there were l
l -.
52 1 well-established control programs for welder qualification, 2 training, and certification.
3 So there have been several people who have looked at 4 this area.
5 MR. LIAW: So you have taken that as given.'
6 MR. ELLIS: Yes.
8 MR. HANSEL: We are collectively. Stone & Webster 9 is a subcontract'or to us. ! Just happen to be with ERC, 10 Evaluation Research Corporation.
11 MR. LIAW: You are a subcontractor to Stone &
12 Webster?
i 13 MR. HANSEL: No, TUGCO, Texas Utilities Stone &
14 Webster is a subcontractor to us. We have the 15 responsibility. Stone & Webster is suppor. ting us.
16 MR. LIAW: Here we are talking for almost two hdurs, i
17 and I thought you guys came from Stone & Webster. I'm sorry 18 about that.
19 MR. HANSEL: I don't know where we go from here. We 20 feel we have a good, well-planned program that is well-founded 21 and definable and allows us to draw judgments on the a d e .T u a c y 22 of construction. I don't know what else we can do.
23 MR. SMITH: Okay. I understand the original 24 question to us was a Staff position on inspections made; all 25 right? Our answer, in p >5t , is --
53 1 MR. LIAW: Let me see that. We have reached --
2 number one -- I want to get clarification here. VWAC 3 indicated that you could reinspect your weld up to coating 4 "with concurrence of engineers." When we accepted VWAC with 5 that kind of statement in there, we did not mean that the 6 engineer just looked at it and started to nod his head and put 7 his John Henry on it. That was not the intent.
8 What we meant then was he has to make documentary 9 basis for acceptance, so the NRC inspector can go in there and 10 verify indeed he has done evaluations and agreed with the 11 basis upon which he reached his conclusion. That's point 12 number one.
13 Point number two, generically we don't believe that 14 inspections through paint should be reviewed or accepted on a 15 generic basis. The history of dealing with this issue in the 16 past up to now, the last one being the Wolf Creek and anot'her 17 one behind you is Watts Bar TVA program, has been that we 18 reviewed on a case-by-case basis. We don't believe that a 19 generic position should be established for this or any ,
20 particular sites because of the differences in the 21 qualification program, and difference in how the program has 22 been implemented. It involves different sets of people, both 23 welders and QA inspectors.
~
i 24 So, with that as a preface, I believe generally we 25 agree with what you are saying, that weld attributes, like m
[
e .
54 1 size question, presence, length, that kind of thing, which are I 2 structurally significant -- yes, indeed, you could inspect
^
3 with the coating on there and still be able to draw a 4 conclusion that we would like to have -- remember, in the 3 5 context of the acceptance criteria -- be able to talk about in 6 a certain context.
7 Then for the weld attribute that can be viewed to be 8 related to quality, such as lack of fusion, cracks, porosity 9 in general, or slag inclusion, we don't believe in general you ,
10 could inspect that through paint to certain pre-established 4
11 standards. You get a general idea something might be wrong in 12 that particular weld, but I don't believe you really can 13 measure it to a point where you say it meets the VWAC or AWS.
14 I don't believe so.
15 With that as a general -- I hate to use the 16 guidelines -- but with that as a general framework, we suggest
! 17 a couple of things. I don't know whether or not the project 18 people are ready to notic'e that we have included that in our 19 SER. Should I bring that up for discussion?
- i 20 MR. SMITH: This is pretty much in the SER now. '
21 MR. LIAW: So we suggest two things:
22 In our evaluation, w a- give reasons why we disagree 23 with you, the total approach. We suggest --
l 24 MR. SMITH: We didn't evaluate their approach. It I
1 25 was more the letter from Newman.
l l O
c
- o. e 55 1 MR. LIAW: The inference to the Wolf Creek result, 2 we suggest two things:
3 Numbem'one, in spite of the fact somebody failed, I s
4 think you will have the option to propose a qualification L 5 program for inspections through coating by your inspector, 6 consistent with the guidelines provided above what I stated 7 earlier for certain weld attributes are of. structural )
8 significance. We give some hint that the Staff envisioned 9 that such a qualification program would be very much like the 10 Applicant at Wolf Creek did at that particular site. <
\
11 The second item is random sample inspections be g 12 conducted to the NCIC acceptance criteria by third party 13 qualdfled inspectors, and with our NRC inspectors, so that, 14 these 64 welds with their coating stripped and/or welds which
^
15 have never been coated that are representative of coated welds 16 to be inspected, results of t hi.s reinspection should be --
17 reviewed'And assessed j ointly by the NRR Staff Comanche Peak 18 Project and Region IV Staff.
-19 MR. HANSEL: Let me go back. Are you suggesting a 20 sample --
are you suggesting two samples or sample 649 21 s MR. LIAW: First statement says for certain 22 attributes, which we didn't agree on.
23' MR. HANSEL: Do a qual'ification program of the
~- 24 inspectors?.,
, 'i 25 MR. LIAW: That is right.
1 s E
~
g %-. 4 . . . . .
e e 56 1 MR. HANSEL: What was your second one?
2 MR. LIAW: The second one for the quality 3 attribute. Okay? To look for that kind of thing. Start with 4 64 welds of predetermined population. You have to work that 5 out with the region. I don't know, maybe you have certain 6 ideas that you have questions on certain groups of welds that 7 would consist of a population to start with.
I 8 Then you go in there to strip 64, inspect and verify 9 the quality. We sort of suggest something -- we did not give 10 the acceptance criteria like what your NCIC suggested, with a 11 reject of 64 welds and a sample. We said reassess, which ,
i 12 means if 64 welds have to be inspected with the coating 13 stripped, the result indicated that you don't have rejectable '
14 defects that are related to quality to the number we mentioned
, i 15 earlier. ,
i
. 16 The only thing you-find are the type of attributes 17 or defects associated with certain attributes, I guess,
, 18 undersized, presence, length, that kind of thing. Then we can ;
19 safely reach the conclusion the major problem you have is,that 20 type of thing, that you have with inspection through paint.
i 21 MR. ELLIS: Did you suggest 64 welds to be stripped t 22 --
, j 23 MR. LIAW: 64 to be stripped, or you can substitute
~
24 with welds that have never been painted previously. And you i
25 might ask where this number comes from. You can go back to -
i
57 1 Thomas and what they proposed and our consultant from 2 Statistics has sort'of agreed, too.
3 MR. SMITH: There is another NCIG document, 4 MR. ELLIS: I think we have arrived, sampling at the 5 same program. '
6 MR. LIAW: The only thing I am cautioning you is by 7 third pa . ty qualified inspector and witnessed by NRC 8 inspectors. That's a condition --
9 MR. HANSEL: .On that point, we are third party 10 independent, and we do have inspectors, and we do have the NRC 11 overseeing.some of our work now on a sampling basis. So I 12 think we covered that.
13 MR. LIAW: I am not addressing that to you. I am 14 addressing it to him.
15 The only thing I want to caution you is don't jump 16 to the conclusion about the safety of the plant yet. *-
17 Eventually you will have to do that. I think for this piece 18 of work, to see whether or not you could verify the quality of 19' welds in the plant, in order for you to reach the conclusion 20 that,you are chartered to do or you are tasked to do. Try to 21 separate it out. It's two issues up to that, and then let's 22 maybe get together and see where you might come out. And 23 that's why we suggested the general project has accepted our
-/ 24 technical recommendation, I think.
25 MR. HANSEL: What will be the next step now? Are we
58 1 going to receive another SSER soon with this?
2 MS. VIETTA: Yes. Spott Burrell is preparing an 3 SSER now. He has this type of information in it as a review 4 and guidelines, as to what can be inspected and what 5 additionally would have to be done if you wanted to pursue 6 this.
7 MR. LANSEL: Do you have any idea when we might see 8 that SSER?
9 MS. VIETTA: Spott, I think, can give you a little I
10 bit more feel'for that.
, 11 MR. BURWELL: Very soon.
2 12 MR. HANSEL: Our problem is if we are moving ahead 13 and we are inspecting as we are talking, if I could somehow 14 get this information in advance from the NRC, I would 15 apprecia.te it. If I could get that either in an informal, 16 across-the-table piece of paper, or something officially "
17 through our licensing people, I would like to have that.
18 Because we may end up redoing work.
19 MR. LIAW: I think before we formally send it to you ,
I 20 --
it is not really a formal Staff position in this sense. We 21 simply threw it out for discussion here.
22 I guess the question I am asking you is, do you have 23 a problem that you want some additional clarification with 7
~'
24 what I just said, or do you want to have a caucus?
l l 25 MR. HANSEL: I'd like to caucus briefly. I'd like I
+
a m- +-
59 1 .to borrow that for a minute. I had a hard time following the 2 second item.
3 MS. VIETTA: What we will do is we will include it 4 as part of the record.
5 MR. HANSEL: If we could caucus for just a few 6 minutes and give the recorder a break.
7 [ Recess.3 8 MS. VIETTA: Let us get started.
9 I informed Mr. Hansel that I will be incorporating j 10 this memoranda that we provided him in the meeting as part of
.i 11 the transcript, and we w i.1 1 he formally transmitting this 12 internal memorandum to Texas Utilities.
13 It will also be included in the future SSER 14 supplement. The date is probably within the next couple of 15 weeks that it will be issued.
16 MR. LIAW: Before you respond, let me say something, 17 based on our focus. We do not specify which population from 4
18 which you draw your 64 welds. Really, I don't have that kind l 19 of knowledge to tell you how.
l 20 I want to inform you that that will be Region IV's 21 function. They are on site and they know what you have there, 22 and therefore -- if you proposed to take 64 welds that had j 23 been unpainted from Unit ~ 2, they might disagree with you, s 24 because of the issue that was raised about whether or not you' J
l 25 involved the same set of procedures, same set of people, same I
t
--- - - .: = z .: - .
o .
60 1 set of QC/QA inspectors to do an initial inspection, or the 2 timeframe. This whole thing is in a dynamic process.
3 MR. HANSEL: So the details of that plan would have 4 to be agreed to by the regiont 5 MR. LIAW: Region IV, yes. To me, that is the 6 region's function.
7 MR. HANSEL: All right. Are we ready?
8 MR. LIAW: Yes.
9 MR. HANSEL: First off, we appreciate you sharing
, 10 this information with us. I think as engineers we are all 11 pretty much in agreement on the discussion that has taken 12 place this morning. We feel that the inspections that we are 13 going to conduct, had planned to conduct, would be adequate.
14 However, we will respond very quickly to both of 15 your' recommendations. If we get that transcript, I suspect wo 16 will have a plan put together before the end of this week 7 17 maybe early next week, to get back to you on.
18 One point that I would like to -- a couple of 19 questions, and maybe some points. -
20 On the very first recommendation, that is aimed at, 21 if I read it right, measuring the structural significance and 22 can we in fact evaluate those. And we will put together some 23 type of a plan that will qualify inspectors.
~
24 We have done --
I don't know if it was in Don's 25 presentation. We have had extensive training already of the 4
61 1 inspectors. I gather that you are after some samples here of 2 that recommendation, to do further qualification of the 3 inspectors' skills, and we understand the Wolf Creek program 4 will come up with something very similar to that.
5 MR. BARNES: Who provided this training, Mr. Hansel?
6 MR. HANSEL: Stone & Webster Engineers, who helped
, 7 us put the total program together. That was an extensive l
8 one-day classroom, one-day hands-on with the hardware.
9 MR. ELLIS: NCIG conducted an engineering, quality 10 engineering person' 11 MR. SMITH: Are you talking about inspection 12 certificates?
13 MR. HANSEL: Yes. Detailed classroom training and I
l 14 on-the-job training with the engineers and the inspectors, i
15 both Level II and Level III.
16 MR. FAERY: Also observed by the NRC regional ma'n on 1
17 the site.
16 MR. LIAW: Item No. 1, I would suggest maybe you 19 want to supplement with MP for them. "
20 MR. FAERY: Could you elaborate a little bit?
21 MR. LIAW: You do a qualification program, you might 22 want to surplement with magnetto particle inspection and
, 23 reinspect again to see whether or not you come up with the 24 same results to verify your visual. <
25 MR. HANSE,L: We will take a look at that.
~ . . _ ._ _ _ _ , . .- - . - , . _ . _ . _ . . .-
1 1 +
f I .
~ 62 +
l g
1 MR. LIAW: You know what happened at Wolf Creek.
2 MR. HANSEL: We will consider it i
3 On the second recommendation for the sampling of 64, ;
4 again we will come back with a proposal. My recommendation l i
1 ,
5 initially -- and we will have to refine it -- would se that'we
(
l 4 6 would do a total random selection of any type of support out !
] 7 there that might have this type of welding on it, so that we ;
'l 8 are again statistically based, our total program is based on I i T
9 statistics, so we can talk it out with the region, But at ;
i 10 least right now our program and our thinking would be that i
'11 that would be totally random from all the various supports, l I !
1 -m 12 a r. d w e would pick from that sample. .
j 13 We have that data available to us, number of welds j I
14 by hanger, number of hangers in each population, supports. We [
j 15 will work it out with the region and it will be their decision I l 16 as to how we look at that. And in my.past experience and in
{
r 17 our experience at Comanche Peak, that gives us the best !
18 distribution of time periods, welders, inspectors, processors, ,
19 types of hangers and so forth.
20 One thing that I would want to -- and again we will i l
I 21 work this with the region -- is that if we ended up having to i !
, 22 consider expanding the sample of 64, I would only want to l 1
23 expand if in fact the defect we find is determined to be .
. , I
) 24 safety-significant. That is in keeping with everything else !
t t
j 25 we are doing on the plant. ;
63 1 MR. SMITH: Are you familiar with that --
2 MR. LIAW: That gives me a little bit of a problem 3 here, becsuse the 64 samples really is meant to verify the 4 quality of the welds. If then you start to inject your final 5 acceptance criteria, then you will be talking about a 6 different thing. You get the two things mixed up again.
7 I'm not saying that's inappropriate, I'm not saying 8 that. The final judgment, obviously based upon what you say, 9 but the first step is to verify indeed you have a good quality 10 weld in your plant. If you find lots of rejects, you expand 11 your sample size to further quantify the degree of deficiency, 12 if I may use the word.
13 And after that, you take that deficiency, quantify 14 the degree of deficiency and factor it into your evaluation, 15 to draw your final safety conclusion. That should be the way 16 to go, instead of getting a final safety conclusion -- -
17 MR. HANSEL: I guess my concern is if you take a 18 sample of 64 attachment welds and you have a number of 19 attributes, unless we are very careful in the evaluation of 20 the defects that we find, you could end up in a rather 21 significant expansion looking for very insignificant types of 22 defects.
23 So we will have to develop a plan that is very
, 24 carefully thought out.
25 MR. LIAW: That is correct.
64 1 MR. HANSEL: That will allow us to evaluate the 2 adequacy of the quality.
3 MR. LIAW: I encourage you to do that.
4 MR. HANSEL: That's a very fine point.
5 MR. LIAW: That's correct. That's the reason I say 6 the result of this reinspection should be reviewed at best 7 jointly by the materials engineering branch, Comanche Peak 8 project, and Region IV staff, to indicate that, based on your 9 r e s u l 't , the type of defects or rejectable defects you have 10 found, you will reassess the situation whether or not :s ou 11 should go ahea'd and expand the sample size, or to make an 12 evaluation.
13 And I think I want to reserve a judgment for the 14 time being. You could think ahead of time, in case you find 15 something, what you are going to do about it, and we can talk 16 afterwards. **
17 Is that acceptable position for the Staff, Region 18 IV?
19 MR. RARNES: Sure. ,
20 MR. HOU: Yes.
- 21 MR. MANSEL
- Let me make sure ! understand the next i.
l 22 step. We will get this in the transcript, our plan to 23 implement --
that will be our first opportunity, probably, f 24 Our first opportunity then for discussing our plan 25 will be with Region IVt
65 1 MS. VIETTA: I think it probably will be a good idea 2 to have another session like this with all of the Staff 3 members that are involved in this evaluation.
4 MR. LIAW: The first step, next step for you to 5 take, is to get Region IV agreement to which population you 6 are going to draw the 64 welds from. I think that is the 7 first step for you to take. You agree with what we 8 recommended here. That's the next step for you to take.
9 The result of that inspection will be reassessed and 10 reviewed jointly between Region and Headquarters.
11 MR. HANSEL: I would like to define the rules of the 12 game before we go do the inspection.
13 MR- LIAW: We say inspect to the VWAC standard. We 14 say that.
15 MR. HANSEL: What I'm after is if we are going to 16 select the sample of 64, I have no problem with that. I want 17 to be certain that as to -- I want to be certain as to how we 18 are going to evaluate that data and where we might go from 19 there. It might be easier for me just to remove the paint, on 20 my other samples.
21 MR. LIAW: I don't know. That's your prerogative.
22 I'm not going to dictate to you.
23 MR. HANSEL: We need to evaluate that, TUGCo and .
24 ourselves.
25 MR. LIAW: That's right. I'm only advising you, the A
. _ _ . ._ . -- . - -.--__--. .._ _. --. ~. -_
. o I
66 1 first step you need to take is to get Region IV to agree with 1
2 the population from whkoh you're going to draw your 64 welds, I
y 3 MR. HANSEL: Why don't we take the transcript of the f l
4 meetings which will have this in there, and then we'll get :
L S back in touch with you and let you know what our next step !
- L i l q 6 i s .? All right, Bob? l 4
$ i j 7 l'd like a day or two to think on this. It may be [
t !
l i
, 8 easier to just go with new paint. i i~ i f
4 9 MR. DACKO: Let me clarify one point. These two i
10 proposal you are suggesting are, if, in fact, we pursue -- if i
! 11 we want to inspect for all the attributes, such as undercut h l '
12 and porosity and to demonstrate, we can do that. That is what f 13 these are proposals for, that you're just talking sine and l
? I i
14 location. You've already agreed we can do that through paint, t 15 and no additional qualification is required; is that correct?
i .
16 MR. LIAW: Yes. In the sense the results of the"se [
! 17 64 welds showed that all rejectable -- either undersise i
I 18 length, presence, that kind of thing that we agreed with you
! I
, 19 -- that can be inspected through paint. Then we will cong :
l 20 back and say, " Hey, go ahead. Inspect. Do your reinspection f
I
, 21 of the rest of the welds with paint on them." r [
22 But if you start to show something that is related j 23 to the quality of the weld, ,I think you have a different i 24 ballgame. [
l
)' 25 MR. DACKO: That's what this proposal says. [
t i l 1 :
f
67 1 MR. LIAW: That's right. That's why I did not 2 completely shut the door on our period of reassessment, 3 whether or not to expand the sample sise, or simply make an 4 evaluation, stop and make an evaluation there.
5 That's the reason I'm saying to you, i t '. s v' e r y 6 important to determine which population you're going to draw 7 your 64 welds from.
8 MR. DACKO: I think we discussed on several 9 occasions that --
10 MR. LIAW: You may have, for different populations, 11 two sets of 64 welds One population -- say, all support 12 hangers -- if that's in question, you might say, "That's a 13 population. I'm going to draw 64 weldr. from that." Just 14 separate a set of concerns that relate to supports or piping 15 support welds. That might constitute a different population, 16 and you might draw 64 welds from i t. a t in a random fashinnf*
17 The 64 we'dsi does not ete a n for the whole plant.
18 MR. DACKO: Based on what I've heard today and 19 looking through the previous correspondence, it appears to me 20 that the NRC does not believe, and we do not believe, that we 21 have a problem with --
22 MR. LIAW: 1 understand that.
23 MR. DACKO: I guess 'I'm missing something here. If 24 nobody thinks we have a problem with porosity cracking and so 25 forth, and you already agreed --
68 1 MR. LIAW: No, no. I agree with you, that you could 2 inspect through paint for certain types of weld attributes, 3 but I'm not prepared to agree with you that you don't have a 4 porosity problem, you don *t have a cracking problem, and so 5 ..forth. I didn't say that.
6 I agree with you on that. That's the reason !
7 raised the issue with you, with Bob, about the control, okay.
8 That's good information, the way he responded. That's fine.
9 That's the reason we go out on a sampling basis to verify what to he just said, that you indeed don't have the welding control 11 problems. That's one item that can cause the crack.
12 MR. DACKO: You're saying the 300 unpainted welds 13 that the NRC inspected themselves and found zero -- 389 --
14 MR. LIAW: It eventually comes down to the bottom 15 line, for NRC to take a position, we would take that into 16 account. But right now, based on information I have s e e n --
17 today, I don't see the results of these two sets of 18 inspections, 89 painted welds, and 300-some unpainted welds --
19 the results are not statisttoally -- I don *t think it's .
20 consistent. No statistical correlation.
21 MR. DACKO: Let's ignore the painted ones. Just say 22 300 unpainted ones don *t have a porosity cracking or lack of 23 fusion problem. Let's take that as a sampling. That suggests 24 that that problem does not exist.
! 25 Sising and location may be a problem. Wa need to
69 1 review that.
2 MR. LIAW: This is your plant. You want to satisfy 3 yourself, too, don't yout 4 MR. DACKO: Certainly.
S MR. LIAW: So what's the argument here?
6 MR. DACKO: I think we've satisfied ourselves.
7 MS. VIETTI: I think you have a request in to us. I 8 know from the information that you submitted to Region IV and 9 an August 1st letter, that while it's information that 10 suggests that you want to plan to pursue the inspection 11 through painted welds, and because of that, we reviewed that 12 information, and based on our review, we feel that certain 13 things can be reinspected, such as whether presence, location, 14 length, et cetera and other attributes such as quality, wo 15 must have additional information, additional assurance, such 16 as the 64 stripped welds in order to feel comfortable that' 17 quality attributes are -- if you are inspecting quality 18 attributes -.if you are only inspecting for location and 19 presence, et cetera, we have stated we have no problem with 20 that.
21 But if you are inspecting for quality attributes 22 through painted welds, we are not prepared to support you.
23 MR. DACKO: ! understand that. I guess the question f
. 24 was, do we, in fact, have to inspect for quality attributes if 25 we have --
i
70 1 MR. LIAW: I understand your question.
2 MR. BARNES: I think we should put the question that 3 Mr. Hansel asked: What is the purpose of the 7-C program?
4 MR. LIAW: They are hiring you to make an 5 independent assessment of the construction quality. As part 6 of their proposal, it is to reinspect the welds. The question 7 posed to us is whether or not they could inspect through 8 paint, and we are responding to that question.
i 9 MR. DACKO: I understand.
10 MR. LIAW: In other words, what happened before 11 that? I mean, eventually it would be a factor in the 12 consideration, but somewhat irrelevant or academic at the 13 moment.
14 MR. HANSEL: Unless you have anything further, do we
+ ;
15 have sufficient information to act?
16 MR. DACKO: Yes. **
1 i
17 MR. ELLIS: Could I ask one side question? One point l 18 No. 1, where we are reinspecting through paint, you suggested 19 we may want to expand that to include mag particle testing?
20 MR. LIAW: We say-Applicant can be requested to 21 propose a qualification program for inspections through 22 coating by the inspector, consistent with guidelines provided 23 above.
24 MR. ELLIS: Length, size, location, et cetera, if 25 that's what we're inspecting for, how would mag particles l \
71 1 assist that, if we were to expand that and include mag 2 particles?
3 MR. LIAW: I'm merely suggesting you consider it.
4 MR. ELLIS: I didn't read your letter, so I 5 apologize for that.
6 MR. HANSEL. I guess we have nothing else. .
7 MS. VIETTI. Okay. I discussed with Jack Redding 4
6 of Texas Utilities that we have received some information from 9 Materials Engineering Branch, and he suggested that we should 10 meet, because we had not met on the subject, and I'think the 11 presentation was very helpful today for the Staff to better l
12 understand what exactly your objective is, and hopefully it ;
13 has helped you understand where the Staff is coming from, 14 following their review of the information that we have before 15 us to date.
16 And I think with that, unless you have any c l o s t"n g 17 comments, we can close, and we will resume at 1:00 o' clock on '
,! 1 18 a different subject. '
19 [Whereupon, at 11:10 o' clock, a.m., the meeting,was t
r 20 concluded.)
21 22 23 i
24 i ,
25 a
. o 1
t CERTIFICATE OF OFFICIAL REPORTER 2
3 4
5 This is to certify that the attached proceedings 6 before the Un6ted States Nuclear Regulatory Commesslon in the 7 matter of:
1 8 9 Name of Aroceeding: Meeting Detween NRC Staff and Texas 10 Utilities Generating Company to Discuss the Official Inspection of Painted Support t
Welds 11 Docket No. .
, 12 A t ace ' Bethesda, Maryland 13 cate: Tuesday, September 17, 1985
- 14 15
- 1. were held as herein appears and that this is the original 16 transcript thereof for the file of the United States Nuclear 4
17 Regulatory Commission.
- 18
. . '/
ig (Signature)
, A ,,
g, y, (y ,
(Typed Name of Reporter) Mimie Meldzer 4 20 21 22 23 Ann Riley & Associates. Ltd.
3 24 25 i
.e._ _ _ . . _ . , , . . - - - . , _ _ ,__ . _ _ . - - . . _ _ . , ,,
( , /f l
l i
COMANCHE PEAK i
l
. COMPONENT SUPPORT WELDING RE-EVALUATION JUNE 1985 i
i
Cr i <
INTRODUCTION WELD ATTRIBUTES
- TRT AND OTHER INDEPENDENT REVIEW l
l PAINT EFFECTS i
1 WELDING METALLURGY CPSES RE-EVALUATION CONCLUSION
[ .
l INTRODUCTION TRT INSPECTION
~
PIPE,R ACEW AY,HV A-C SUPPORTS PRESSURE BOUNDRY EXCLUDED
~
INSPECTION THROUGH PAINT a
e
~ - - . . . - - . . - - - - - . - - - . -
4
. l l'
WELD ATTRIBUTES-I '
!
- WELD EXISTENCE & LOCATION i
- LENGTH & SIZE
~
CRACKING l
- UNDERCUT -
l
- FUSION
!;
- OTHER
- SLAG & SP ATTER t 1
POROSITY < i 16
- ARC STRIKES
- PROFILE
- CR ATERS 1
l
- i. _- -
1 PAINT EFFECTS i
. SPECIFICATION l . SAMPLE ANALYSIS (RACEWAYS)
I 10 MIL AVER AGE i -
20 MIL M AX < 1% -
I
! . WELD ATTRIBUTES
-size -
-UNDERCUT
-POROSITY
! -CR ACKING
-FUSION t
t I
I L.____
b I
i TRT INSPECTION l
l 389 PIPE SUPPORT WELDS (89 PAINTnD) ,
) 1 1 i
- UNDERSIZED FILLETS 4X (32---) 16
- POROSITY 1X i
- UNDERCUT 1X I
e INCOMPLETE OR OMITTED~ WELDS 2X
!
- EXCESSIVE GRINDING 2X l .
f TOT AL 10X 1
1 .
l i
/
l i TRT INSPECTION (CONTINUED) l 1
i 59 RACEWAY SUPPORT WELDS i 3 ~
l e UNDERSIZED FILLETS (1 --) 15X i 32 32
! e MISPLACED WELDS 2X
!.' TOTAL 17X i -
J l
l 1
i i
i , ,
l _ _ _ ___ _ _ _ . _ . _ _ _ _ _ _ _ _ - _ _ _ - - _ _ . - _ - - . . _ - - - _ _ - - .
i OTHER INDEPENDENT EVALUATIONS 1
F ;
i e SPECIAL REVIEW TEAM -
APRIL 1984 l
! . REGION I NDE APRIL 1983 ;
i
[
- CAT MARCH 1983 i u
!
- ERC ~
CURRENT i
i
! \
l I !'
l i t i - - -- __ _ -
__.___.-_.m_.._.____....___.m___._
_ _ _ _ _ _ _._. _ m. __._ _ _ .. ____ . _ _ _ . _, -. _ __
l .
i WELDING METALLURGY ,
t' .
l- . B ASE M ATERI AL(A-5 Asm A-36, A-500 GR ADE B,)
8 8 GR ADE B, A-240 ;
l
~
TYPE 304
- -LOW C ARBON
-LOW SULPHUR L . WELD FILLER (E 7018 ELECTRODE I -LOW HYDROGEN.
[ -HE ATED OVEN
! -CONTROLLED ISSUE & STOR AGE l
- WELDS NOT PRONE TO CRACKING i
j L l
i
_ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ , . - . _ ~ ~ . - - _ - - , _ __ ___ , _ . - - - - -- . - _ . ,-------w.
! 'I I
t
-l
! COMANCHE PEAK RE-EVALUATION
) '
l
DETECTABLE e NO EVIDENCE OF GENERIC CRACKING
- WELDING PROCEDURES, CONTROLS,M ATERI ALS,ETC l
- i. INDIC ATE NO GENERIC PROBLEMS l
j
- WELD UNDERSIZE H AS BEEN PRIM ARY DEFECT '
i
{
- REMOV AL OF P AINT 3
i
{
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w: > > ,
CONCLUSION ,
i
- INSPECT THROUGH PAINT
!
- ALLOWANCE FOR PAINT l
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