ML20140F197
| ML20140F197 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/26/1984 |
| From: | Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA) |
| To: | Gilinsky, Palladino, Roberts NRC COMMISSION (OCM) |
| Shared Package | |
| ML20140B849 | List: |
| References | |
| FOIA-84-740 NUDOCS 8603310136 | |
| Download: ML20140F197 (31) | |
Text
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' #p , 'c, UNITED STATES
.i NUCLEAR REGULATORY COMMISSION j- $,,1,.-fsrp[fE}
,i 3
WASHINGTON, D. C. 20555 i
;;* 4:JN 8
% ),'[ [. # March 26, 1984 MEMORANDUM FOR: Chairman Palladino Comissioner Gilinsky Comissioner Roberts Comissioner Asselstine missioner Bernthal n :
I FROM: \ iton Kamerer, Director of Congressional Affairs
SUBJECT:
REVISED QUESTIONS FROM UDALL SUBCOMMITTEE STAFF Today, the staff of the Subcomittee on Energy and the En-vironment provided the attached revised list of Coments related
! to Diablo Canyon.
Attachment:
-As stated
.cc: E00 OPE OGC -
b; maa IE OI ( 8603310136 860206 PDR FOIA DEVINE84-740 PDR ,
*O i
s - l B:DIAEPMAT. eMSS 3/17/84, Rev. 3/1S/84, b/19/54,./20/S4. /22/G4 (. Generic Comments (GC-X) GC-1. ... A statement to'th'e following effect is made repeatedly with respect to the Region V method used to inquire into the NSC ' 'I'-N ~~ findings: "The inspector's approach to resolving this issue was - \- T_p.S.. .;.f. . ' to assess and evalua'te thethe.NRC. validity of.the fin' dings NSC forfinding and Pullman response,4.iN's'.
^
mwt conformance with t he sp eci f i.ed ' .l.D,*- Pull man ' program. " (E.g. 83-37, Item 24.) Thi s i mpli es thet there'^ is a documented Pullman response to.the NSC finding. [E.g. " Th e %" w c. licensee conducted an audit of Pullman during the period.of e1- .e.. Apri.l...2. 'through " June :1 P1978, T i n7. espon, se,"to theNSC ~5Gdi.f'.I. nD.. g7.D %p" -44 pyp @p a .e
..the Pul l man ,, respons. .e .'". : S e e .
.,r....,.
c.E'.2,' gy, This statement ".,. yq h. ... .M does .c. 'n.,ot 'appihF.'.i r.f.
- c. n th'd7~Fi 6a, Draf t 83-37, p .9 37.l'iB3 * .37, '
s ,c)J5 t@e-,gresponse7. .What' i ntervi ews w.-ere conducted with PGLE, Pullman.- an d . '.Wi
. q' e-. e' f.1NSC ,past an.d. present person'nel in the course of preparing'83-377Mdr)f.*
. N ..- w . . . r. . How were such interviews documented? Where i s the documentati on? c.,<*.. i.s kg'* 5 .py &;.;J '.$;.l@GC-2.g'* i 2 i h & 5 Report 5 $b. S !$ $ 4 W . N 5 .: W' W~Y SY M M k! h. 83-37 It is unclear in to ref ers cer corrective tai n instances ' g ;['ac v ' Inspection J ".in response to the NSC audit. as to whether the corrective actions were taken with respect to DA deficiencies that existed prior to the audit; e.g. to what 4/.2.',C? ., . .. [ extent did the corrective, actions i nvol ve activity to insure that
.r W inadequate workmanship did not escape detection as a consequence '.'% ~
M.
. .c , . . of the OA deficiencies that existed prior to the NSC audit.
- .,.}-
n, .~ . : n.' -.~~ - m
. ..ddh./. -
.2 ;, [' GC-3. Inspection Report 83-37 contains several
}/,;/d'?v;Z. ~J90
,,. . ..c.
day welders' log. Does the NRC have the log referencestothe,,Q". in its G-posses'sion? If not, is it readily accessible? Where is it? What
'.1. . .
.I'
".d'eficiencies exist in this log vis-a-vis the ASME. code? '
?'i&.a ,c~ . u 4 h.. +.%<OW.m.p.Mdm;.M:A Q ttm :- v.me W*
. c.wm w. r' %'mMM.'n+WEM:. C'.a N: ~~* '
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%< ;ff'm:'g:7GC-4.
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--gy v .m.I. n.sp ec t i on Rep or t ' 83-37 st a t es i .? e.r.:o .@.'&wxq:vs-.~w).'W .:- . 4v* ~j%
aw
. n- "m- . .a .o . . .
. . .we r. a,e w. con s. t.s.t e
. . . . ,. - n. several. places'th t.
~&
code f',W ;,.:c-4 thato ,n..ssti en.t ":. ,me. an . ".I .n . c o.mp.e,. m.. mr.
.p W uR .Pul
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man, .p r a c t.. .i.c e s.' 1.i. wi an tc.h .".. ,n t.h. e i.t a 7..t,"Aw.i
,EI . .s. ...: .pM...
th,n..-..m..
.s.. AS. ;tti hon..e. ' NR.
a pM.E o. s. i ~. .,. wher.ever ... " consistent" 4s used.that-itxmay.b~e"r.eplaced ....s. by'"in' F"-4 iw. ...e: h.F#. s .21. ,c. W -
. t GC-5. ~ Th, ere i s no. i. n d i c a t i on. of , Reg i on. e~ V.,h avi n g s ou g h t..
t.h. e :.v. ..i.,ew s. g"% _ ... Vw5 ".u Q-~. :l 7.*of' N. .. .SC . e,i t her.
- a .
?. "*" -the f i ndi ng s ',.'t. o el abor.. te 'f.onand concl usi ons or .' t o ' c omm.e o.the.-p.nt 1977. . fi ndi n 4.;,,) ,.
on.'.M.5.-Y.%^
-" . GC-6. .. fer; W i h+'T$.h T @ M-Nd M
- w s 'h.D .'.*.". $ d h f.Q.$'~.!1p ,
-Page 3 of the draft states a sample of 25 stainless" steel
~
welds were selected were sampled to veri f for' y"fi delta eld wel ferrited andand inspection that 100revi radi ewogrMs '
- 4."-@ i.1,'NNi adequacy.
V What is the basis for selectihg these welds?. On what" N ::
p.
- v. . .
-N- . ..
..dates adequate were statistical these wel ds produc~ed?... . sample?
,Di
. - d these wel d s r ep r esen. .t ..an. . ,d.< b.. .
- e. .' p.W:.
_? ; ;#jd
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Cri t eri on ' I , (H;if.. yfsm.s. ; .
. , . ~
iF - h ;..r w,Fi ndi ng p.3, Dr a f t , .p . 2'-S M M ;..Ym
-nal.
s.n3. .3. NSC a-.s.y. ..Audi. . . . t; 3 -3. ,m.(Fi e-e .. pn .-~ ;,:n y. ..,, G.,. .M,p .r,z
. ..y :
K.g.,_ Did the f act of 'OA personnel writing and approving Engineering
. s..
Nwp'.'.br .-.. Specifications, . . . .
%,C.A...f
. . . . n. wperforming welding engineering fun,ctions,i.and
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l approving welding engineering changes ccnstitute a violation of ' Appendix B requirements ~' . s . Criterion II, NSC Audit Finding 4. (Final p.4-5, Draft, p.2-5.): .
- L~.
Is it the NRC conclusion that upper management performed ' .. scheduled reviews of nonconf ormance reports, personnel .- N -; qual i f i ca ti ons, and corrective actions as required by NRC
*2 _ . l, regulations for the time periods addressed'by the NSC audit? Note ' ,,
handwritten notation in draft report: "In conclusion, factual 4; records do not support the NSC finding." The corresponding .-*, p .n. . s.d.y'2-L' ' statement in the final report is: "The inspector, concludes the ,. MfpdQ %e.p historical records of coperate management,, audits do provide efj@Y/Jk QQ~@.?8evi dence' that revi ews*'of . nonconf ormance 'reprots, personnel'$2.Fy.Q. gy/- qualifications and corrective actions were perf ormed. " Note ' - ./ h. *;,: 7..p. un E 'J. comment in final report: "!n addition, Pullman Power Products has1 % - h .
< ', since proved programmatic improvements ..." etc.
What was the 5:.) .
'?.[ ' -
. program prior to the improvements?
improvements were instituted? What uas it after t h e '; '
- f- ?- ,
y ['; ' Criterion V, NSC Audit Finding 1. (Final p. 5, Draft, p.39-40.): . ; NSC stated: "There is no requirement that acti vi ti es affecting ... . . .
.g~
quality shall be prescribed by documented instructions, .
'{ procedures, and drawings." Region V states, apparently in 7 reference to fabrication of piping assemblies and erection of pipe in the pl ant, . that KFP--8 establi shed appropri ate
. . . . ~ ~' . ,
instructions and procedures.
- . . " ' " established procedures ,for pipe, supports. . KFPS-7, however, was;.j;[,a-
' Region V seems to imply that KFPS-7. 3
,,i' .M;[. lnot .
.7.M /. -installation issued until.. oCpipe December procedures .19,73.
prescrebided *.(Were by 'thedocumented. OA procedures f or[4LM':S ..,._ s ,D pEoceduresi ete'.'I hri or ' to "Decemberf. m3fp.M u W.. .f4 the 'draf t.' stat es that 'ESD-264, ',dat ed .9/15/78, . "I M. I.7T6struEtion', provi ded _a specific
- .197. %
M h4 M% r a... ..~. procedure'.}'ito. ,im;sl e, ment prec,i sely; the ~QA {progE kam g w . 7
.KFP .K,%FPS .7. ~e",y+, *T,h e-~.e l at. t,- =,er . . '.st.at emen.t .d.oes n.ot app ear~ --
. . . . = . '7 g'-h>%.~f
+-
al, i.reportLQ2In n: . 8 an. that;tha
.d specific.. procedures f or . implementing.gn ...e
' [','preci sel, y Ith'e' QA pro [r'~am' el ement's of KFP-8 and KFPS-7" . ker'ef.ME:f=-4Ci 7.q: ~
2*~ app'arently'n'ot ? promulgated until'only September ~~15,
" E -- is the basis f or assurance that .1978 wh'at ' ~~~.17h ~
gEh r- i mpl emented 'p"ri o'r? .to September 1978. KFP-8 and. KFPS-7 w ' 'M were adequatel
? j,.$'p.ge ' y h"'"
, p < ~ ; . ~, ;
. . .' m y ' ~.. Ma- , ,;-?
_ :?% . . %.'*;gy: Criterion V, NSC . Audi t Finding 2. (Final p. 5-6, Draft, p '. 4 0-41 ) : re
. . . . . . , . .~
w: ~; .,.. ".' w *
, e ._
4 NSC states that jan'ger packarye review was not described ~in .' Ti.;. N S C.{
., procedures. Region V states that hanger package review was <pW A.., . described in KFPS-2 dated December 3, yj,(', y.
requirements were, incorporated into ESD-254 dated December]30,197 1977. What was Y- ..{: p(7,- L 3, 1973'? . The drhfthe t, basis for reviews conducted prior to'Decembergn?.' but not the final report, states that. M. ESD-253 provided additional detailed information concerning -
~ 6' 4%; hancer drawing controls. 14 hat is t!e d-te of ESD-2537 Is it s..
. N.
~
kly.y. -c . - @ ,t. '
;,iy n a . ,,
-%'. 1,. M ^ i.3-j~L '~ 2
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k
-=s..a.2. e m a h r.n.m m.Y'.-o-'.m m*.i.. m.re-
. r '
- f. -
I .
- o. g NRC's position that hanger package review was described in a
( manner that complied with the Appendi:. B requirements for all periods covered by the NSC audit? '~ NSC states that other activities not described in procedures included preheating for welding, use of Note-O-Grams, use Rej ection m.
*O. M.
- Notices, and maintenance of Field Quali ty Inspector Daily Logs. '_, T q.~
Is it the NRC"s position.1that all-such activities were described M E
~
^ in'proceduras in'a manner that complied with the Appendix B -
'~ f,('s" .
requiremetns for all periods covered by the NSC audit? '
'37 -
p._ . :w v .. .- m., - - -
=.-
. . ~ ..
. . n;... . s.s.: ._ .. a. ....<..g.. * , . . C.. w. xt- s klis;.. . . .. -.2. Cr i ,w". t er i on V .
WJ_t . .--- r. . Draf C w ;.=:-:= g.:r.~
. .. n
- .cv, T NSC Au ..
. di t Fi Mn cd:.1i ng
- s.E*::~,0 % Q, C 3.h -rn.-. (Fi n al=. ~r:a. p'.+.'t 6-8,.g=:":'.;-%g.4,
,' *p . 41-4 2) :: g#.W
.w.ptf-.
gg;y~ w.-h . - p -~ NSC f ound that ;1,sometric.'. package review was not suf fic.#.w described. ' uThe draf t of'83-37 states that " Field procedure ': .. ; - Q - ESD-254 (issued 5/6/75) appears to provide an adequ' ate outline ' C
' .....gui de f or revi ew of isometric drawing packages.". . ,Th e f i. n a..l_. . . . - .. c.-
g,j] '- " report' adds that M a y ,6 ,' 1975 was'the earliest s. v .u 7- .: - - .found for ESD-254 and that"while most piping installations date that ' coul had d b e ',7"'t 7,y.. been completed prior to May 1975, the inspector found that the {~
'2: final complete document review of isometric drawing packages were performed after ESD-254 was in effect. -
Y
.y.
draft states that post heat treatment requirements are Note that
-d" , , ' ' prescribed in ESD-218. ~The draft does not. indicate that ESD-218 9 . was issued in Oct~ober 1977. The final report states that post 7- ~
weld heat treatment 'raqui_rements "were always prescribed by weld .... f-T. .y .U ~ procedure'specificaticns." -The final report does not refer to I I-E... , ' - - . specific procedures in effett prior to ESD-218. What is the .."#
- -e - basis f or the . conc 1usion that post weld heat.trea.tment 2.-, y ~ 7 c.- a " e.::;. ,
~
[hr.1((r'eqUiremedtijere}n,. %.ew: W of "ESD-218 21 n Oct comp! ob er: i ance' wi th App'endi xf B
.19777,p".QWF,=.Ned*W .
, pri or ;to .i-suanc5 MU N, .2.-mY h. N. v . O M.. 7W M. .N. N. M W;". _d --~. .e". Wi t 't hr NR C's.tJ~
. 6 5-N. N.@.
9*. $.,__M_,,,E N .k., t oM,.n=.t m'hE.a.S M'~l$ , t , gm ,.., b i i s ., . aTf hos1.. . . . i n ti6e.. . i.m. e. ' p e.r m e;:gr.c w - C.bythe 'NSC',audi t f' non-conf ormanc. e r ep or tg i n. Fee'qui . . . .. men tF.,i s* femod _p len.c s s e d.. ied' o' :p t ' %:: D. m .M D 9F 73 M.m M-Y@ .N..MNN Ni'iik.hE...t..h.'5.r~d. N@kM-MD.N.b h. _BI_ N, Fem.eIM... _ 9,t.? Q.f .
$e.~,x.h. c. W. ,.AY.,p'en'
.y
.N.y.p.h'PvA.g::':
c5i xY*,M= 5* g gg g g .2_B3-37;stgtesDthat_the.;" interna %y.B.7,g N.E) 4 F implemented "DMId$.~$N.*d 2 ~( C by on-site perso.nnel,-(prior to"1978) was determine'd t.o'b E.5't< i J,5-5
".. W. n~4 am' of, comprehensi ve o'quali f'L. - ~.~ ..
- ' marginal. . quali tyi':.a r edundant , prog' r ty! .'g. -
F 'was performed concur rently." The redundant program appea'rs'to- Dr.% ME':
~,
have been one." directed and condcuted by corporate management MM personnel." Did'the redundant program find the that the internal'T.i.M.E audit program, implemented.by on-site personnel to be of.5..'
" marginal quality?" Did the,corpcrate' audits encompass involve . . . '.i. . .U. . --. 1 1 E. ~
review of weld and welder.. quality, and Q.A. programs app 1'ied toMY: weld and welder' quality? On what dates were the corp' orate audits 9 *
.. . 4 3-:b b1 conducted and.what.were their findings?
- < r.< .G. .: .' M. . r-Q s% .s s...N.
A. -5 . .t Q.. .:-- : ... a. :.u/ . ..=:--9.';.* . .- et-
.s q.-gyt:~
~D*Q.;
7 Regi ons V concluded .that', .f=: -~- - - 5,,: , internal audit program andnotwi~thsanding the failure of the the deficienciesin-the' h D corporate iudit MT4 ' program to discover:these' deficiencies in a they appear nou'to have been corrected until t i mel 1978).,] y ma nn83-37 er.M e . g . 1-d%'. - M'{b -.
, ..pr; ' ., .d. .sQ,;
...? -
v.' .
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e.L ? ;- .*
.h rd. - a o . .K. ,::.-+ ..k",u.C~
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c.:c-W. . %
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,.vrp ,.a. - nw -m --- .r M- , - * .n .h -- . y'*' - * ;"*Wf*'Ot'-^" ;:i.;, dfN,. .-- v: - ' ' "
f; yf.- h . , .-:. - U ..h:-i'.*. " 1*--6#RG' '\*/ "' " % " M ' -
'#~
-~ ; ;r " '. gl:. .g.f # w '.$y"A.:; :.:D.
' ' ~
i
' concludes that "no major breakdown of the Duali ty Assurance program had occurred, nor had any si gnf i ci ant problems gene
' undetected, due to deficiencies identified with the internal auditing program." Is it the NRC position that ther NSC iindings do not indicate that "significant problems Chad 3 gone undetected"
-until 1974 and, to a lesser e:: tent, between 1974 and 1977^
Criterion VI, NSC Audit Finding 9a. (Final p. B-9, Draft, p.-54-55): l NSC stated that a Process Sheet for Isometric 2-14-77 was changed - approximately 19 months after the work was done. Region V states'.. 1.. 2 ~that the process. sheet (which Region V states should Q(f[-c :, N b.een in reference to,2-14-47) that .."no evidence could be shouldhaveik[p.i f ound t'c ,'
-QW p:gt& . h M# indicate "lsignatur es' on ' either"or ~ thatboth ~
there thesehad'
~
documents. beeri" .Does an attempt NRC believe'[ to al .-ter
, . , the NSC finding to have been in error? How does NSC explain the #-
~,
. apparent discrepancy between its findings and those of the NRC7
'-/How does Region V know that the sheets it examined were in fact n', g the same sheets examined by NSC7 ,.
Criterion VI, NSC Audit Finding 9b. (Final p. 9-11. Draft, p.61-64): NSC concluded that FW-1673 was performed without normal 4
, controls. Region V stated in the draft, that "al though i t was ..
not the usual practice" the weld was carried out in accordance with the then existing design change control system. Is it the NRC position that this departure from the usual practice did not ' S .. violate the NRC's DA requirements? ,.!j' What is NSC's response to the .-
,NRC finding?,,O Y' O, .. .f N14r::- Y : .. ,. . ., g-- . .: .-g Q. -
a;..l.- 1;h);.c*.l.
"F.: .=. .' M . ^&;d:'O~.~. Y ' N:f "" :. ';:e %
.g:E ' . .
.$.%?f '" , e.., Criterion .?.*
NSC Audit Finding 10. (Final Draft l,>p.38-39)R _ t *;-
,VI,& Q :'
S 3NSC found h.Y.{.(l:?'that no . pr.&. $*$'W ocedure or - %$:,fp.13-15. requirement .W.h:5v.bbsu.5
.prohibi ts changing ~~O :k55 or WE g--6.hs'd+
M@$kd.COWY [N $ {.[l'.-l.'lIM. i pRegion.V lt'atedEthat" prior'to'1977
$f[h&'xi steno' cont'rol' alteration t'he' 'cfiaki of
~
records r$g#i:S~,~al terati on and: of'kualdoc i t!'y recoIds, 1 0metn insu f."ph*h ' . ~ Ggand docujpents~. fif/j ., Region V'also concluded in the final report}that S f% T'-
.. neither
'T# NSC, nor NRC nor' Pullman audits had "i dent i f i ed any'.M ;f.'.2' T.7J ,
unapproved technical changes or.Other Q' c'-.1-
"~
-would have adversely affected constructionsubstantive' changes.'which @ [$.[D done to reach this conclusion? Note that the concl usi onWhat was ~ ~j. ,i. '
quali t y. " .
~as ' - . ';.c? h';
stated in the draft was less firm; it said: " Pullman's corrective .' 6 '
. action is complete and apperrs to be ef.f.ective. Previous 'E.'.'
inadequacy of management poli,cy or written instructions in .this ..
', . ' f
- g. '
area i s not considered to have resulted in any adverse impact .on' quali ty related acti vi ties. " ~eJ."
- ,. ?
- r. _ '
- s - . .
4.y .
- . . ;;(; q u.
gy- . Criterion VIII, NSC Audit Finding 10. (Final p.14-15. D r a f. t , p . 5 9 ) . ,' . . . _46 z Q
; y, p~e..
qn " NSC stated that ESD-223 did not give adequate instructions for J.h 4 the identification'and control of C1sss I W pe supports. Rcgion~.5'-
~.
.~-
,,j q .
,.m
,es
' . . . , . - * ,, 4* . . L;.
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.s ! . .
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V revieweo ESD-22C and stated that specific revisient we'e dr.ted November 11, 1975 and May 25, 1976. ( procedure revisions contained adquate CA/DC 2 nstructions for the Region V stated that the . control and identification of Class I pipe supports. Is it the f. , NRC position that the instructions were adequate prior to the 1975 and 1976 revisions? What is the basis for confidence in c.__ .1 _ the adequacy of instructions pri or to the 1975 and 1976 revisions .
. in ESD-223? .
.- #.~
Criterion IX, NSC Audit Finding 10b. (Final p.17-18, Draft
~ ..
p.6-7.): - ;-":. -n c. c-.. c.~.7-
.. . . . .:. . :.:. : %.. ;r 2,r.
__- s g&-g.:.x
..i.. . ;T ~~ NSC f ound .that._.from A.ugust.1972 through December 1972 a ninety - 75.
- .t. :z ;
maw: E. 77 day Welders'; Log...was not'irdintained nor did a Weekl y . Qual i fi ed WM. ->7I3 t NMy!. dn: Mar,ic};U~ del ders' -List exisQor . that ' time. .s Region 'V agreed therejas' nU'$[
.%C =-
~i7 weekly Icig butiethat #a"90 day
- og -did exist. Di d ~ Regi on V. seek t(o h.3. .
y;d _ ~ . determine . the reason .f or the discrepant f 2 ndings?.; - - [.: ~
~
. . . : :. : ,. .t. . s . -
-- d.~. .
- 9 .~_ " Criterion-IX, NSC Audi t Finding . loc. _
; ,~'
_p.7-8.): - ?- " "~ - (Final p.18-19, Draft
~
~~' ~
NSC found that the Ninety Day Welders' Log was not suf ficiently
~~ detailed to determine if the wel der was qualfil ed to perform certain procedures. The draft stated that the "90 day qualified welders' log was suf ficiently detailed to determine whether a welder was qualified to perform certain procedures." The draft
,} did not state that the 90 day wel ders' log complied with applicable code requirements. The final report, states, ;
GM~..' S~g depending ~upon the manner in which a sentence is interpreted, fW ,.; S.5 I either that the log complied with the code or, al tern ati vel y, ,[
~.~- that the welder complied with the, code . requirements. Is it.the % .u..:- _,
N. .' NRC position that .f or--the Peri od . cover ed . b.y the NSC audi t~ that '-Nh. M. Y.. -Z.w'+d' [-p
- g. . : .~i .T.. .!.-
7 . < gw; w p ....the.90 .- " T m day' welw
. ,::e- o.:. :aders 4 4,..-bl 7og
-- v.x - 5was =:.c.: .in, comp 1 i ance'.'wi
, : y' 2.w.~.u n . . + -- ..th
#:._. Ww&, .l.5.1;.;;;w.*.ra w.-.5.w. ,wa,-v
.t_ . a-code w re qui . ~. rements% - s:. .x u
4 s -e . %.,,._.,.r". l N., . : . -+ . . Not e a'I so'.'that . Reg ~ Ton .V.~.b a sed i~t s .:concl usi on ..iu pno.part n,s.>., :+;s..f.; ,;. "'ls'G~ p.. t..hseyw : 3 ..i tb.__i s ~w. .... .f.y~. .~:~.:: d i scus si.on on s _ eor.mer.;A. u th. o.r;i z ed,a:re. ..I n sp ec tor..J.'li D cord? r"p-lT/W- v %an'w'.-of ' these,. ~'d i ss scu. _ xist
?. c Wh at ;wa s th e r su,b st an h.,
r-c e ' of.g..'s.uch ~r."7. .
.v-%
*m :u tr; M m.w%..- .
;-S c:.r.m.M:"< d..cg.i. re:v=~
. . . sua Rf:tereg$.j]~b8.l::
[& --di scussi.o,nsM,;U;dLi
.4*- ; S$ neA g%,-c..:::e.a.QRW.W.SY.W:Eck-i;:'.i.:u -An~~-%
%-E *;@ce.--@"U{gp %
- 4. .. .; : ; . .._..; Cri teri oln - I X,-NSC Audi t Fi ndi ng ? '.* -$ M=
-...--r
..P'g~
10d. (Final p.19-20,' Draft. . . . ' --K ='. : Q. ..B. .
~ .
- y h.:..O.h,'... L ~ . :G ';n- . C ~ ~
- --!~. ~~. .. +. n'4.: 5%.': .7 : ' '-' M5s'-W e- --
. - - :.e .= . . . . . . . . . > . -
NSC states that no procedure stated what the Field Quality" 1
- 2. .M. h Assurance Inspector was to use as the primary means to determine' ~~d 'C welder qualification. Regi,on V appears to agree that a procedure '
did not e::ist but that weld ff li er metal wi thdrawal sh e e t s a n d .. . . 0..'. .' welder qualification records.were used to determine wel der -. ~ M '5 - y,, qualification and that 'this method satisfied code requirements? M O-f d:.- Is it the NRC staf f position that, the absence of a specific .- . _, .. .Y. procedure notwithstanding, the method used by i nspectors "to ascertain welder .quali fications complied with
.. code requirements?
~ CA~~~-'U.?"'
MN'.*#{
..,._....- .~
~ . . . . . . -. .:.c. ,. .
3 -.*y'..- Cri to-i or. IX, _PSC . Audit Finding __
,'{.:.:. " .. -
10h,101. (Final p.22-2 , Draft-zg g. u '
.M'd [.[... . . -;s.'t.d(-hi ~. U'E'S
. . . . ...s. -
. . _ S.. :.
O.w - -%r u @" m = * *ib M . " M ", k M' ~. h ... . f
. :5f.ML:=PA.i" 7 7.N.:f W.M +, ^
^~
k p.13-16.): fx The draft focuses on question as to whether auditors
- observations need be recorded on the "prc:ets sheet or the inspectors
- daily work sheet."
the inspector e:: ami n ed the wel der The draft audit does not indicate that sheets. The final does state that the inspector e::amined welder audit sheets but does not indicate the period covered by the e:: amination. The final ~~ version of S3-37 states in 10h that the welder audits were "a Pullman program requirement in e:: cess of the ASME code ' requirements" and twice in 10i that the program recuirerents i
" appeared" in e:: cess of code requirements. The DRAFT did not
.. . J . c
.6 .
' mention that the code .did not require a welder audit. .-
f,p y <.
; . .-1.:.- *3 - fR.p.. . . ..-n \ : .i ._*p.1. [.- . ). . '. ..m ;-l , dpM . v..',.. O.1 '. 2'*. '
J'liQ',Rf'.c;.3 . ~ Draf t 101 (p .15 ) says ".. records of. the 9/70 revision and .11/73 'p):%c.,y,:.v.t . 4,. Q.
'M ~ ' - ' implemented procedure are not available." Final drops this part j,.,.;;-
stating (p . 23) "The November 1973 revi si on app arentl y was i ssued -'_ and implemented beginning in November 1973. .. weldor audit
' sheets indicate that the required welder audits were performed ,,
.beginning November 1, 1973." The following statement appears in the draft but not the final: "The wolder audit sheets e::amined '
indicate by the auditors." the ferrite control measurements were performed on welds Why was this statement dropped? Is the ...,,,. statement accurate? Was there a requirement to make ferrite - control measurements? What is the significance of failing to adhere to ESD-219 if the
.(
ASME code does not require welder audits?
.. n .
Note following statement in draft does not appear in final: .. h..y:.
' ' . ;U . '
[."@, . .' ,(
"Since the record of the 9/73 revision is not available, the .G7N v' O
" inspector _could not determine when the procedure was approved for ,}[h.i and,:thus, was not 'able to corroborate the Pullman X.
(GW.5
$fi W F.e % 20,;.,'implementationthat the September .1973 'revi di*
statement
..M' ..the audi ti ng of welders. ". AThe draf t. and final state..thatf."the h ?:. .
fN S.. M E/> ." inspector'was not able
'7j $.I'" ?.* l Pull man was in" nori-compliance wi th . the procedure f ortd'~c^orrobor aboutY231-*Ig.k*f P(;h[g' 3.
e > T -%.;- T* ;dh.N):mo~n'th'slj.9@C mA..~ ? ;s. .. .
;T
.. .A E eJ.? p ~s V. . ;L:..&.:.s.
' ,5.I5~t@lM-/n'-NIjEKN%f'MN fYm'- ..w .
..c.
o Is the staff's conclusion that neither Item 10h nor Item 10i ' c;&'
-- . , %. . ll,Q~l sit .
Y*~ r .were identifiable items of noncompliance or deviation rest on the"./._ assumption that welders' audits were not required by the ASME code? ~
. g- . %., ts.; :e., .' .
Criterion IX, NSC Audit Finding 10j. (Final p.23-24, Draft. p.16-18.): ""
,-~
~
..- ,s .
. j . ' ' ., . ' ,
7 Note change from draft which relied on the examination of 25 Z h welds to find that "
. .there i s a high probabili ty that other kfg stainless steeel welds install ed in the plant comply with ;f_ ^
- k. ..l g delta-ferrite acceptance criteria." The final report cites a
- j.F ~
g'4- ' " random sample of 25 stainless steel welds" as "an additional '- J. . . " check." Primary reliance for the final report's conclusion that .:r . L., f. . .
"the inspector was not able to cor roborete the.t Ptillrun was in 5 ' .- '
,. . .-2 &.. .
'h
- s' 3. 's , .k-i.
~~
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.: L.:L. ~ . ...M #M,A%a MM
" . A, . Aww[. *'
' * " ^^k U .: *,
--~
a
-noncompliance with this procedure requirement for 12 months" was
(, based on the assumption that stainless steel welding did not begin until early 1973. welding did not begin until If 1973, it is true what that is on-site the relevance stainless of the steel,. examination of the 25 welds since the NSC finding applied to the ~ . " . . . pre 1973 period? ~.1'. - r - .
' .'.ts :,. .".,.
Is there.a documented basis.for the. statement " Based on
- ~
discussions with,PGLE personnel it appears that stainless .
.UM.e;, .
welding on site began in early 19737" steel .g.,;~
- c ---- -
.....r-.
. ~E-t*'-l
..." n M}
.1 5 .
Criterion'IX, NSC Audit' Finding'10k. (Final p.24-25, Draft...,_.4:g.: g +a.y, ., .~,
.c.
P = 1 - 0 .1 '1 = ) =. / * .. ~* W -;..,.u h u. >- - . -
.. . u ~e: . . '~ ; " '" W,, .: -s."r *. . . . 5. a: --R !.
th -cy. $4&l~ES e . .-F. 3&'.M$N~b;.'-$'55$';hWeCh>-W~W, 6.: :g. M.y, .
-.:;,5 9 . .
' *Y *N**I
~n.'.",.,
;r. 4p 42.5.~ . The NSC -f inding -that=" Hangers are not wel ded in accordance
- l**
Q wW ' i th ' Ty.p' s f' - Pacific Did NSC err Gas & F1 electric Company requirements" was not confirmed. , .~ ...
~ steel on the in observing that hangers were welded to structural ,,;g ' ,
=
wrong side of the bracket? What was Pullman's ,,, a response to the NSC finding? Would NSC agree that an error'of ' T .:.~_s f '.' ~. this kind would be made in the audit? Was-an effort made to determine whether the hangers might have been modified following the audit 7 ,
.='
Criterion IX, NSC Audit Finding 10n. (Final p.26-27, Draft p.20-21.) ( . T NSC found'that there was no procedure for preheating weld joints., r. w..,. -a
~
The draft report (p.21) states that a series of weld procedure "' ~ specificatiens.was examined and that each contained " a n . a d e q u a t e v.;.,. f . W.C .:6 '., ' definition of p' reheat,'postweld heat! t.reatment and-interpass i- h
,_.t
-c"%.271,. > ;. , $ temperature. v s "..i;.The v
'dra f t . al so 's'tates. t..h a,t /?.'ESD .218 .(Postwel d ... .'M6.
~
i .
. #'"E K..
j."%-g..C.p ". .M Hea t an d '. Pr eh eat .T.r e. .. a tmenti Pr.of..,ed'ure..) w .. W 'pruscribe'.pr.eheat Pequ. .i remen t s and .yi ndi..a r
... ~ .
c.sa .t .e,. .e.vi sed 12/30/.77.;..to .- r.wrP
- preheatA ~. - -
- 1. E.'appli cabili ty."p. Ansadj acent. handwri tten comment (p. 21)"How 3Sg. ~[.S
.Na.cn ~ asks I.$?.WM~-{. * ' wereIn'ot Idequate'prl'6r' 9 I fto l2/30/777about.
'"' " F ,~ 9 j % $~IA b"/(Q2/30/7771G
'd-Z-or.; )w 45
-.2'. .. - . bq
. <~ . .. _.y.p .yx.:.-.g~ . . .l4.:r.. w. :.,. '?c~.-
- . . , - W~ . - - - ~ ; . . . ' . % . T'H ~C = )*L-%. ::*. .? %, .'.-:&-?-
- ..'c.-9.y.***C
$l._i' M ^ . . . The ... final report: (p.27) contains an additional statementv.to the .: *
~E "' J- J.~ -
effect that prior to early'1978, comp 1iance with'the preheat .I ' -m requirement.was dependent upon' the welder's know :llf the procedure described in the'second paragraph on p. ^ with Appendix B7 What was the basis for the added language? 27. comply Wa's 7'f'b.j there discussion with Pullman or PG&E on this point beyond that ' . ' which 19537 occurred - during the l'nrgection that ended on December 9, . . ' ?. ".~.
, ' v, , ,. . . ; ; .~'
s.. W'. . ~
....,.~....'
. . s. : - P 4. -. : .
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H. .,
- W'* ".
[I,. . J.N.. The penultimate paragraph on this item states " wh i l e .no sep a at e '. 7,.~%' . . $j-z and specific precedure WfE'N 1977,'fpreheating or preheating of weld werejoints existed prior y to December..Oh requirements N-f* ^*~ 'l,_ i -> adequately prescribed by the welding procedure specifications and: J'5 ?
#" ' documented sheet, by signature on the welding block of the process. 2 S"& -
- u. .,.,;. . which specifie'i th= .=pplica' ale welding procedure.".yWas ?.W c; s
?: ~y- .-s
- ..- . . , , ..n...
.a v ., $ k. . .b W b&*4 ~
8~~ m .h*.
..+s... .
. ~'~.. ~ "~~'$$~h5!fl.C4&2.Q.$.. %$m.. s.s,./-: e nz.a..x . ..-mm.'a.wn&& ,
= w. 5.'5 a. u.w.
1 a this in compliance with Appendi:: BT f\ Criterion p.21-26.): IX, NSC Audit Finding 10o. (Final p.C7-00. Draft NSC stated that the initial results of welding auditing (f rom November 5, 1973 to February 1974) indicated the e::istence of 7
~
problems quality. which, if they did exist, raised question about weld . NSC concluded on the basis of a revi ew of these audits that "..there is no confidence that welding done prior to 1974
~*'.
C.M was perf ormed in accordance with welding specification ;.p g. .
, frequirements.".. s -
. ~ . - - .Y.
- '~'
gi. ,
?' :. '~ A h{h~}$!;..&fk ~ kkE N';s: qf:f Q"c'd'The NRC inspector $ T$ - .!
said he had " critically examined the records Nr:Q~ of gl%h'~' 92' ' welder audits performed between November 1, 1973 and April
- 1, ,,...
1974." On the' basis of an examination of 183 audit. records from o. 2 -
' this period, the NRC inspector concluded that the " aggregate of w.
problem areas is not so pervas,ive such that support can be given ' to the NSC conclusion" that there is'no confidence that pre-1974 ' welding had been performed in accord with requirements. 83-37 states that "It i s important to recognice that none of I t'hese were NSC findings, but were instead findings of the Pullman . welder weaknesses audit program, which wac designed to detect prorgram and provide prompt corrective action during the early .. phases of si te welding activity. " The problem is that the welder %,-l {'
',. audits referred to by the Region V inspector (which were found by , i RegionfV under 10h and 10i above to be beyond what was required ' .s .
by the code) were not initiated until November 1973. In .. e"*
, ;,, , addition, the NSC audi t states that in the period "f rom November..j-ff: h V ':. .
s .
' review of Pullman (s audits conducted itsfindingswerebasedona.,k[g.'
..05, 197.3.to' February,1 1974) .'., Theref ore, ".how coul d the audit h ?' '
0.ET'pr~cgram,Upon' whi ch ' R_egi on V reli es' "de'tict wel ding progra'm ' ,' 5-Q:%y;1 mc 8i'w'eaknesses 'an~d. provide p'rompt correctii v4'[ action i d M phases of site'-welding" if the audit program was not initiated . .c.
~
M -1;3 ./ Q95.$3:..; u.. . vt.w a ~ . .
-)unti1.-
%.November.1974]y:j.c.4.4M.e.W-g%y-MW.u
_;, t. 9 -* @, .ny. .; -: m.. : L h.. Vc .+ . . . Ds"n d w 4,..W. . v .gA
.-e .,'.m.M-w
, n: y% 'M Q,"
1 ~'
. In sum,~ j. . .. .t.T . :- : ; .
the NSC finding, based on findings. obtained from'a review i>:
. .: ~
.n... . _ ,
. m :v-
" of audits conducted after November 1, 1973, was that " ...there .a.
is no confidence that welding done prior to early 1974 was done~ $,,.' in accordance with welding specifications." Region V, on the " ' other hand, based on a review of audit reports prepared during b:A essentially the same period as the reports reviewed by NSC Cand " igncring the above noted fi,nding (final, p. 23) that "the , required welder audits were performed beginning November {' . . 1,1973"3 concludes "no suppor.t can be given the Cabove quoted] ** , "?-
. NSC concl usi on. " Region V does not deal with neither (A) the 'i~?
E fact of there having been no welder audits prior to November Si' 1973 nor (B) the question of whether the types of deficiency .dO' k;f g discovered in the initial audits existed- in prior years.
. J-[
- g: -
/.-: -
n.t .. cat the March 19 Commission meeting, statements were apparently made to the eHect that audits other than thoce that oursuant to . ...
.g
, .J".- -
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a'. 4-, , * "** gk'.
, . .e,..-.
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o .. t y fh.. '.W.---
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.h . :. . . . ?- if. -
~- ! "
^
~
,. ~ e the ESD-219 program were conducted prior tc November 1970. If [' so, were the findings of such audits discussed in'83-377 Where?
\
Why were these findings, rather than those in the post November 1973 period, used to refute the NSC findings?] Criterion IX, NSC Audit Finding 100, Item 1. (Final p . 28. Draft .. p.23.): .,... The draft, without ci ting documents, appea'rs to rely on the gas flow being "near the 20 cfm requirement" for its concl usion that ' Opife defective welds might have resulted from inadequate shielding and .;. $W. " purging. The draf t states that excessively how fl ow rat es woul d _. [, :.,.
- ~j.,-have been l manif est in unacceptable porosity which .would ha've been.W..- ~
1~L. Jd etected'by-NDE; the~ draft"does not indicate the extent to which "- . 1"F., .-..Or/ ,1 Je W unacceptable porosity was-found. 'The final does not state that the flow was near the 20 cfm requirment; it does state that "The vast majority of safety related stainless steel welds were - radiographically examined and -the film was reviewed and accepted by a qualified interpreter for code compliance." How many welds were not radiographically examined? How many were examined? Of those that were examined, what percentage exhibited excessive porosity? What was done to determine whether shielding and -' purging deficiencies that might have existed prior to the first - welder audit? What was done to correct for such defi ci enci es? 8 Criterion IX, NSC Audit Finding 100, Item 2. (Final p.23. Draft p.23-24.) y, What'is the significance of 14 out-of 183 audits i dentif ying that ,
- b. :. .
welders did not;have tempil sticks? .-Region V states that in each y 5;..- m et. - . -.. s e...c a s e t h a t ; a _ welder was f ound not to have ,,a -tempil .sti ck / one was }$.L
~
~
provided. :r What'was' done to determin2 the extent - to which ' welders 'If;i Ly;yS-".-#^)?did" not'Wa9e tienipiI ~ ist'i clis- Fi orYo NoOemb'er'1973?'.[Does The ' cade M. ..y :'yh r#W u .: ~! .Vesumption.of , allow interpas's'temperaturerequirementsl,tobemet.by..thei...%.415*h2' welding delayed until the_' welder "can touche the f,--f.$1gp '[,,fW Mel d?"[-The'draf t',f 6ut. not the' f i nal ,' ~ states that'."Tempil sticks b ."if
~
gf ,, were usej;!. by'&el ders i n the ' vast .maj ori tylof c a s e s . " ' ' Wh a t ~ ~ -- F; .T ' consti tutes a " vast majority?" What was done to' determine - r whether there was a tempil . stick problem prior to November 1973? %
- , -2
. . . . ;.3 Criterion IX, NSC Audi t Finding IOo, Item 3.
(Final'p.28. Draft "' " p.24.) m
~
The draft states that in 4 out of 183 instances where amperages' j . . ' -2 were not within the wel' ding procedure spcification limit, the ~ welder corrected his amperage setting. The draft stopped there. ~ J .. n,- - The final adds statements to the effect that defects resulting ~4l.- . i .f
!I f rom improper amperages -woul d be f ound during inspections. The -$ .'.' ".
final also adds a statement that ". . amperage i s not an essentail .~
'9 '~' variable specified by the ASME code.." Does this mean that a . .
welds produced with i t.ip r opar a. .p ct ag a s c oul d s t i l l,, b e -i n '- . . ' ?. . _; . .
._ w '
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. . s.
)fw.
, . . . . . . . . ,...n
.- 5. ,!,-
o ..s* , y
*'.'.*bo%=:
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p . ... . .m.m, m.a.=w .~ .
* . =', j * $ . , . -
... = . s'Y ** '. '.mm=~~=== ff. . . . :. ~ ~ *
- compliance with the code?
What about improper ampo-cgen that mient have been used prior to November 1970-' Criterion IX, NSC Audit Finding 100, Item 4. p.24.) (Final p.2E-29. Draft 83-07 states concludes the " vast majority" of welders used welding procedures and knew where to obtain them. not have them were told to get them. Those that didThose not 'know that did were they could be found were given "an explanation of the location from where they could be obtained." This finding was '
~ based on welder audits conducted after November 1973. -:. - , .,..fRegion V's position with regard to those not members ofWhat
- n. .- " great maj ori ty?" What is Region V's position with regard the i s ';f},.hg.
to the;ggf
" W'y -
availability of procedures and welders' knowledge of where procedures could be obtained in the period prior.to November 1973? Criterion IX, NSC Audit Finding 100, Item 5. p.24.) (Final p.29. Draft NSC found that the oxygen analy er was not available or not operative. Region V concludes that only one of the 183 audits - reviewed " indicated a problem with the oxygen analyzer." What was done by Region V to determine the basis for the significant ( discrpancy between its finding and those of NSC7 What documentation was examined? ~
Criterion IX, NSC Audit Finding 100, Item 6. (Final p . 29. Draft '
..* p.25.) . ...U.
- '*Qh.W rD N
. a::. - ~T..3
.m:..
. n ...c' :. . ,
/ - . . n "
. ;,h .s.-.
~-
~ T ... -NSC 5:..:. ..
" .v.-
_c. ."-oncluded that " Oven rod temperature, was not monitored.by .-r93, the 4: m . qjD~t i@Wel ders. B3-37 states that 14 of 183 audits yi p;a,W 4 3 instances where_ rod oven temperatures were loweridentifiedj.p.*'q$py.[
~
than those which ggli "Withdeaf this man'y' audit 3 -#.'iDE e..;f,,;.
~
the timeg"
.were required. .; ,A(note on the t states:MfN' OE The NRC concludes that "The NSC f i ndi ng that rod oveU,',, ,
temperature was not monitored by the welders is not supported by y'... the audits, although' isolated instances of ovens being below 3 ,} . temperature were identified by the audits. " Is it correct that ' 14 out of 183 constitutes "i sol ated instances?" What is the NRC .,..' position with regard to temperature control during the period prior to the initial welders' audit?
~
Criterion IX, NSC Audit Finding 100, Item 7. (Final p.29. Draft p.25.) 9- w .. , W The NSC stated that "Many welders did not understand their duties '" ' and responsibili ti es. " Region V states that "Of the 183 audits . reived, five welder audits indicated that the welder in question." did not understand their (sic)
- p. . . .
duti es ani recpensi.bi l1 ti es. " The,.. . .
. ?.p'i 1
~
_' ' ' . ~ ~ . -
.a.-. .':. . ' .%. ' $ ?D :.s.; 9 ,.-.-u..-........
~ . . . . . .
- . ~ , ' c .$ !*~.-m.
f*. '
.' . ~ - . - .' .hY.n*?.?kY w
~. r .
I .- , .c *
'e' . .
final, but not the draft, contains a sentence: "The NRC considers that the reason these welder audits were done was to identify (. such instances and provide corrective acti on." The draf t - and final report state that "In each case the welder was
, reinstructed by the QA inspector auditing the welding.." S3-37 does not address the pre-November 1973 period during which audits were not conducted. What mechanism e::isted prior to November 1973 to identify situations where welders did not understa'nd their duties and responsibilities? 'What is the basis for . .
assurance that, prior to November 1973, welders understood their duties and responsibilities? _p..y
. . .. _ . ;.n - . . .. y .:.. : ..u.:(,.-. ~ .- Q ,.. g.;.y ,;.
~ .
, __ . t- -~: m.3.-
'.52. Criterion X '
.. . . - . ~ . . m - .w h;*hhf6hTJ.~p. 26-2B. ) ;G,.:S~NSC ~e .) Audit: Finding 5,4... ... 1. (Fi nal p . 30.-31. reaf t G- re. $?,'.-
.RC *; :i* " a. m. . . .:.a m ... :--.:Q~
+ aP.?jl4$::
. =, - % -. -p/:;MME3M!.~-
~. -
. - .. #-:W cd M a %'i?#.
NSC f ound that the . inspection process is generall.y inauditable 'on ;- ~ - the ground that there were acceptance signitures that did.not permit a determination of whether the individual inspection . . . . requirements were fulfilled. Region V stated that acceptance process sheets identified the procedures necessary to perform a particular inspection and the the accpetance signatures were sufficient documentation of these procedures having been - followed. The final report, but not the draft, states that this - practice was "in accordance with standard industry practice, and in compli ance wi th ASME code requirements. . . " Was this practics ( employed at other plants under construction during this period?
' ' Did NSC consider this practice in compliance with the ASME code? _.
What was Pullman's response?
. . . ~ . . . .- ..
i
' Criterion X, NSC Audit Finding 7.
(
. .?
Draft p.28-29.),.h M . lj ,. .
~
-?.* $
- ligii$~?-Hi::5.s W W W* - :. number ST* ^ '-M NSC 'f ound that a r"l arge b.Yk' ~s .. ...:o&;',
.: . '~Fi nal ~.&-T? _ p. 31.
~.9%~; V~&*$*5 ty?-M"!?"I'visda17efa'mi'rfati on'*ind ~ thereaf ter]1acepeted .on, surf ace NDE, it 9.V:J.W N..'gh e- w.c. . .-
pinspection %'. r-Visual . ~examination but' ~no't ,the draf t .~of , -states:.those 2."The M ' w
~ G
-^ 1nspecji oni"jJhe71nal." report, Q-7 -: ,
'inspectog ' concludes that. the.NSC finding (that the' surface'of the f.$
f ,- welds was not -acceptable for surf ace NDE inspection) was in -
. ,@.'45 error.".What is the basis for these contradictory conclus' ions?. #.~l~
t Did NSC and NRC inspect the same surf aces? , What evidence , exists ] y - to demonstrate that remedial work was not carried out in the time ;-s between the NSC and NRC inspections? .- ' EO.
..~ . .:
. Criterion X, NSC Audit Finding 9. (Final p.31-32. Draft p.28-29.)?.,.
~
. . - . . . .m.
The NRC disagreed with the NSC implied finding that X-inking "R1" W onto a radiograph was not permitted by the code." NRC a l s o ' ', '" '[. . r :. . J. .. 8 ',~ 7- disagreed with NSC that FW-83 contained a surface defect "that is, y -
,- cluestionable f or acceptance under visual standards." Does NSC,,,..'-
~
agree with NRC's findings? . . . y ., . - - re. .3 . - n
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[( Criterion E NSC Audit Finding 10a. (Final p.32-33. Draft p.25-29.) NSC found that " Records of welder qualification prior to 1970 are not available." Thus, the inspector was not able to verify the ~
- validity of the Pullman response to the NSC audi t finding."
Region V found that 20 welders were qualified prior to 1972. Region V also ,found that the 90 day cualified welders log was , started "at the beginning of 1972." The draft report, but not the final, states: "The inspector was not able to determihe when the first production welding was performed or on what system the first weld was accomplished. " The final report, but not the
.j$. .i. .
' draft states: "The inspector concludes that records of welder , , , g.q ,
, / b. .
jqualification prior .to 1972 were available and in acceptable ((qh 1 order." WM.
..-, , . , ,, 2* ..,.;;; ;. 1.- . .
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Does Region V now know when the first production welding. was performed and on ehat system? In light of NRC having found s records for 20 welders, has NSC been asked why they found that ' records were not available? Does Region V believe that the welder qualification records for this period are are complete? How many active welders .are shown on the initial 90 day qualified welders log 7 Is this regarding the 20.-wel ders? log consistent with Region V's findings Criterion XIII, NSC Audit Finding 5. (Final p.05-08. Draft p.31-37.) Note that last paragraph on Draft, p. 37 was drcpped. The dropped
#. paragraph mentions a PGLE auf t of Pullman which identified ,.
programmatic and hardware discrepancies? ..
,;.jf _ these discrepancies? Was What is the nature of .3.Y'N there a, requirement that they be ~ $.y 5u'.y. ~Q
.T*; -' reported to the NRC7 ,.
~
y;;~r"E- : MV have~ a' basi s f or concluding thatWere they reportdd to the NRC7 Doesactions Region.,'p? yf
'i.; " wire taken. appropriate corrective. 7 Note the reference to the inspector having' disc'ssed
[ME 6p gij " p f.W.; T.thi s m'atter with ,. Pullman. and PG&E personnel . What was the.' nature ~ u Ik
-of thesie discussions? 'Dowrittensummariesofthesediscussions.:g}.g ,
'Wty
. .C:- exist? Is 'it Regi on V's ~posi ti on that f or the 'entir;e period e .
covered by the NSC audit, Pullman was in compliance with b y i e,c-?f C 4 applicable NRC requirements pertaining to handling procedures? W. - t -
.,,y Criterion XIV, NSC Audit Finding 1. (Final p.38-39. Draft
- p. 59-60.): . -
NSC stated that the Field Process Sheet was inadequate. Regi on V '-1.dW' reached a contrary conclusion. What is the basis for the ' F. discrepant findings? Is it the NRC staff position that the Field
.I h{ Process Sheet adequately controlled and specified required work $[1""
pg -activities? *' {p.- 0 L,7,, Criterion XV. NSC Audit Report, p. 36: - t .. .- , l *, . - p.*
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NSC found, among other things, that " Systems that circumvent the This finding ws.s nonconf ormance *,ystem have been establi shed. " not addressed in 83-37. What is the NRC's response to this finding? . Criterion XVI, NSC Audit Finding C. (Final p.09. Draft 60-61.): -
. .c z u
NSC stated that
. n. .
..it appeared that a corrective action system had not been operative. Region V cited, examples whero corrective
- actions had been taken in rssponse to audits. Was NSC's c.... . . . . ,, .... .
reference to a corrective actions system intended to encompassA r e .... '.;. A. , .. r,Mi;%..
- . : corrective actions in response to nonconf ormance reports?
E. ? R;y.v.y.-?., ', the samples cited by Region V, suHicient to demonstrate that ea. . .
~ ,-the :,';f,;747 s.M.p .y E..: . . $...$..;.y.~-$
vs. Pullman did have'an .- operative - corrective - action system? ,
- a. . . .
- e. ....; .
- - . r...
-~..-: . ..
- 2 .. ~.
Criterion.XVIII, NSC Audit Finding 3. (Final p. 39-40, Draft p.45 7 ' ;r. ,4
~ . - -46.): 4 NSC states that management audits 'were ineHectual . Region V ,
c.O.'. stated that "there is no basis to suggest these audits were , p '.- Why did NSC and Region V reach such disparate 4- i'neH ectual . " conclusions?
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DIABLO CANYON y i DESIGN VERIFICATION PROGRAM 13' ISSUES RE0llIRING RESOLUTION SCHEDULE AS STATED IN SSER 20 PRIOR TO CPITICALITY/ LOW POWER: 10 - PRIOR TO FULL POWER: u-(0FE ITEM ik PDTP C.ATFGDDTES) ( ADDITIONAL EFFORT PREVTOUSLY RE0lliRFD (SSEP 20) ANALYSES (A) DOCUMENTATION (D) . MODIFICATTOPS (M) TESTS (T) l MAPCP ?6, .108u t
l e. DIABLO CANYON DESIGN VERIFICATION PROGRAM ,( ISSUES RE0llIRING RESOLUTION PRIOR TO CRITICALITY / LOW POWER OPERATION { 01 20 EQUIPMENT QUALIFICATION M RESOLVED 01 25 INTAKE STRUCTllPE LATERIAL FORCES D RESOLVED , 01 29 JET IMPINGEMENT LOADS ON PIPING A,D RESOLVED
- INSIDE CONTAINMENT
('SEE ALSO UNDER FULL POWER) 01 30 RUPTURE RESTRAINTS INSIDE AND D RESOLVED OUTSIDE CONTAINMENT Fi 1
~
AFWS RUFOUT CONTPnl FYSTEM TFST T. RESntvED ( FI 5 MOTOR CAPACITOR DUALIFICATION D RESOLVED
~
ANALYSIS FI 9 MODIFICATION TO AFWS M RESOLVED
, J .' FI 11 PRESSURE / TEMPERATURE REANALYSIS M/D RFSOLVED MODIFICATIONS AND DOCUMENTATION , FI 12 CONFIRMATION OF ENVIRnsMENTAI. D RESOLVED OUALIFICATION DOCUPENTATION FL34 ENVIRONMENTAL QUALIFICATION OF D RESOLVED CABLFS AND WIRES MARCH 26, 39P4
.- ~
Y.' :. .. DIABLO CANYON DESIGN VERIFICATION PROGRAM e (' ISSUES RE0lliRING RESOLUTTON PRIOP TO FULL POWEP 01 2 70 HERTZ CUT OFF FREQUENCY A/D STAFF REVIEW 01 1] ROOF TRUSS MODELING A/D STAFF PEVIEW 01 36 ADDITIONAL PIPING ANALYSIF A/D STAFF REVIEW O! 29 JET IMPTNGFFFNT LOADS ON A STAFF PFVIFV' PIPING INSIDE CONTAINFFFT
- LICENSEE PROVIDED INFORMATION; ADDITIONAL ANALYSIS MAY BF PFolllRED; NO IMPACT ON. CRITICALITY h o
~ - --
..a,v.r -i MAM14 IV1ss in f gy 3 MY >RM P6K1rl
;r o n rew M1 EUU suu
( MeetoM .m ai.a O 3 .
. =
.sp.n.e to auc
- 1. the N.
.:,Pm n-37r2 t .f Pu11.an senseros e.,ress.d 1
- m. mby
.Nw.CAuolia. me.
ra P.to h.ve ..en wertauen in
= a. to h
ethee tse oi.dle
, -{ca_t <(Teacters had been in constructed PSEE Auditin a manner 50422 that semptie ip. 2) ' states:
- s. q[the Commission's regulations.
,k;rg ,~."Several apparently generic deficiencies in merk perf ormed byPunman were p (c - *
- Depar tment. " -
% - . Wha't'* generic deficiencies" had been identified by the Seneral 3 Construction Department? . k C Had these "gererte Weficiencies" heen reported **
.r to The AEC/NRC7
.. 2.- The Seepe Statement of the NBC aCdit encompassed " workmanship 4 2,
- of 'the field-f abricated and installed items." The June 16, 1973 1etter f ree it . Wischew to Mr. Sain, to which the PGLE review cf the NSC audit and Pullaan response thereto were attached, statzd that the NSC audit "did not address itself to the verification of
'T the aseetussey of the installed hardware. Tne NSC audit was
. ,{ , superficial with respect to the hardware...." 4 . Did NSC fulfill its commitesnt to verif y the adequacy of installed hardware 7 If not, what was the reason for its not having done so? ' What was done to eatisfy PGLE's original concern that there be an audit to verif y the adequacy of installed l' hardwa/s? ' + 3., PGEE undertook Audit 90422 to verify the adequacy of
-Y- Pu11aan's OA prograal to review the validity of the N5C findings 2% '
and-to determine the accuracy and appr opriateness of Pullman's
- F@ses' and ~to observe the as-installed condition of components r .
- and' Pu11 man's adherence to applicable specifications, design drawings, and quality standards.'
1 **. 7 Audii" 50422 evalu, ated 's Pu11aan corporate audit conducted in
~
Febr uary 1973. Audit 50422 f ound discrepancies in items tnat had bee inspected by Pulfman auditors e he noted no discrep6ncies. k- - Aud ~ 90422 concluded that "In 110ht of the number of discrepaneles noted, it is apparent that the pullman audit did not ef f ectively evaluate the quality of sneir work." t 4,. . i k..". .
, g * ',neskt%dditional audits were conducted in " light of the finding
- i'
- at' Pullman's " audit did not effectively evaluate the quality of
,. I ~ 'c wor k?" In light of this finding what hardware inspections
's work? How I *
'j'p peere conducted to determirse the adequacy of many discrepancies were noted as the result pditional audits ans inspections senducted in the wake of Audig 227 What
- was done to determine why the deficient senditions ed in l M-3725 and it-:b726 had not been dimenvered in the ecurse of. the original inspeggtion -'process? What whs the reason these deficaent
- i
. .. w ..
h
j' eraus4 , 39:58 y-NBitf9BB 10.004 SP5 b.~. y, sendition'a'had not been not,ed durine the sourse of the er ginal f inspection procese? What was done to determine why the Pullman geeparate audit had not noted the discrepancias poted by Audit af, 304227 t#ty did the Pullman sprporate audit met Wintover the cr' '
.- discrepancies? that was the basis for the Q finding (states page 40) that Pullaan had performed adeouste serporate audits?
**f'. , ,- ' t osaa the basis for thm 53-37 finding tid.6 that Pullman's
. teertal and corporate audits had indicated that no dundamental
.y -program breakdoom had occurred? EE.g. ees 1975-79 findings re
$4*-
pe rupture restrsints pova NCR* a DC1=75-Rt+=008. DC1 79 -MM-009 1=79-RM-003, etc.3, , y3 4.
- g.. 4.',;fTe enhet entent did recommendations listed on page 11 = 12 *ef AuWit 50422 correspond to deficiencies noted in the NB: audit?
y . . ,:. , .. S. A May 29, 1979 menerandue from K. Freed to E. %erwin [f; .
' addresses pipe rupture restraint problems. Why had welder ded,teiencies not be detected and corrected at an earlier date by Pullman's DC/94 program? To what extent are the noted welding .. deficiencies siellar to those.specified by the NSC audit? ;,- .4 .
34'J
. 6., What audits and/or reinspections hangers were conducted to -
determine whether the types of def ects f ound in the pipe rupture %. 's-reistfb aints existed 6sith respect to pipe' hangers? 00 hat is the Deets feh a determination that def ects f ound in pipe rupture -
'4 restraints did not exist with respect to pipe hangers?
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, 3,.. . .:.,; 8 . 'ass ed ..asias M.w.c. M oi m.un == $c-74
, ... .. rn . . .
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-(.F.unsgemca conassronoENCE .~
Mc .
.w .v . . . n ~x - .
h5 ' '.! .d . . n '" M ff [.'4.{ %. ' May 29. 1979 It$f. .' fined ,. . j, ; i % 'M.MthBI,9_CANY0k ItyPTURE.RESTRAlltfl -
- e. . .
. :...g .
l
."Ik Problems outside Pullman's respensibillt)
. I
.. . ; . ;f* .
' ,i ' . . " A) a10!NT Ds518N (Pr{msry Cause) s . .- ;. . .
'M-5-
- 1) Massive weldments 5" deep x 4 5/3' wide at 45' single bevel 4'l '" that would shrink unrestrained about 1/2" in a transverse direction"are totally restrained by hope columns and besse.
- 7. ' 'f'.i.
- gd- - . A11 potential shrinkage is transformed into res15ual stresses -
lF j,. ,.'., thd/or CrtCh8. - W- '
. "E ,1) Lateral reinforcement plates (stiffeners) are welded enactly opposite, both pulling on webs as, thin as 1/2" and 3/4*.
- f. .;"e h '
- 3) PgE !itwi +*=at of netneerin.gJtesearch (D.E.R.} has ack-M.. k ', aswledged joint gn as. T.ne major prcblem by developing ,
ter- '~~.. their investi '
. 4Epna sf =gation aroundA (*6)~-joints classified by
- y,, .. . , . . . . tap. -~ *
. , c.
l ..
- F, 3) Bast MATERfAL (Secondary' Cause)
~ *d ^ ' 1) Almost e11 acra'cks" originated at 1ameller tears 'in base
~;[W - asterial. . .
N material has excessive rolled lastnations. 4 .v" 't) SoNw
'3) PG&E_s'upalled base _'satertai__was inadequately identified prior . ,
to Impl.ementatisei sf..QA vert?,le'a"f. don of-tate n.aterts)."' ~ * *. , g". , -- .fa. . p , y' ' . l,* .I 4) Low matting point alloys formed with cophr'(in A441) and
- g. . '
'.H. .
sulffdes t.ripgered.some tears. , l*N. c) zuerscaturuart ..nuratat asnovAL v# '..,.~ .. 1) 1.arge* Destructive test samples have , ed. .
' chasing cracks.
d; 7
' .... - 3) Some, sections have been essentt511y ,
f -
.9' 3).deProposedrepatr/replacemant. ..-
i & .- t ,4 .. l - d . '4) No consideration is given to how removat stresses igther joints - in same structure. -
. Mr E b .
., ,e m toise m e-teP H e 5 B ND.384 ,
887 "' - m m- l ym.4-y. m.. . . .. . ..m. . . . . .
. . . . . . _ . . . _ . . . . ..._. . . ., ,,m.,,,,_. ,
.a .,,,
~2, .
T' .
- , ..I. Se min one Igy ,23, 1973 H*; esa,ised .BIA8LO CANTON AUPflat AESTRAINTS' s -
&,y".
l .
,, t n= es : u. O:. .t .. .
. e. .. mn-:. ^. -
g.,conftg).'.,,, i
..a: a) asum.m
- .4'e - 1) doint- desien can be 1.oreved by: - '
- 4. -
s
.3, .
, ' .a) naalter e vel.anale..
# ~
' . ,$. ,[ t b) Depb13 htv, g],,1f.possible .
* .L e) Bracing with pusset plates to distribute area ..
gs y-
.: eentracted upon. - *
- i r, . , .2 . .
( .
, 2) 8efore removal a complete repair / replacement plan.should y ..c. . be developed with special attention given to,eti)er join}s
?. in the strweture.
L.
-' !!. ' Probkans within Pullman's Q.A./ Fabrication responsibility . . ,
G*J .
.f.-
M e;. A) PREMEAT fEarly Secondary Causyl * . . .. . . p~1 .
- 1) WELD PROCEDURE - 7/8
- P. .
(: . . J. r- . 11/11/71 -
.* l~ . .
Rev.11/24/73 - Spec. Sli33XN requjres AW$over 01.0 l' 4Preheat carbon over - 50 F.
- - 'e ' Rev.10/15/76
.sna .
Preheat referehces Es0 243 for AWS ' Welding
.- ~
.2 e -
W. @ . '
- 1) q.A. VERIFICATION .
h-y =. ' hi- - k1/11/715 Rev. 2/01/$oc. 4 ESD 8833XR 243 notrequires address detailed preheat "Q.M Inspection Plans"- Rev. 5/06/75 ESD 243 preheat now Q,A. hold point - l-. g. w ..- i.
~ Rev. 4/10/76 ESD 243 setails preheats meeting and exceedlag AWS 01.0-59 -
-f
' f..
' ,,e..
- 3) RN0letDEVIAITONS ,
3 FU 9. , . . 1 *.
<- .a) Pt&E audit observed welders not.us,$gjerrect preheat on
.. .D : 9/17/75 sad on 9/19/75 .L ( .
, .,)_/
. - 3 9t '6)* S/3/77 Q.A. Inspector teret46ted" 4 stfohable doch; l ',,.-g. . e- .
D' 4* *
*e } ht& tion practices.3/15/78 documented preheat of 190 F.."P l -
. .R. 8712).
g g'; . d) ( .R.3798).
/73 documented preheat of 150'F., required 225'F.
t. l gh, A' f.,.
g p. < - - - . l /* aie.vs.: seist . . teie-uu H+as m.eu ens * * "'-' -' -- - - W. .,:
= . _ . . . . . . . .
~
ve = r
. , . . ." . _ m .. . . . . m ._ .o. .. . . , ,
.ns. 'h.'8erwin - - - *
# essa m y 33, 1373 x
-...s. . . . . ..
I
-ffesa$se 'IABLO guff 0N RUPTURE RESTRAINTS * , l' d7 y g.? .. a .. ,
e .
... * . r .
0
~ f }p g* .) ', . : . ' '. ' .
. c,. 21.. (Cent'.d) ..
/
...~ \. 4' 'S F- ". h ) Purpcrted prevalent. aNor Onewelding gross weld andestal welddeject metal has dejects been identi. are not f.,j,'.-
~
..- fied that being a lack of fusion between two SM4W ym- -
M'--: - l ..r. - duced rs Other defects exist but are inherent to the wei 1hf'as p. (for wagle some permity), am not d V- rocou
- d. ,1
- detrimental and are well within acceptable limits. Con-M- 4
. fusion is accurring because pS&E NDE Technicians are
'8' 3 .
~~ E callinglemellar tearing " lack of fusion" which it dist-
', <r-- inctly is not. , -
f - .. a ' n -
.. t-b..c) CONCLUSIONS .
l E',. -
.- . . a
".' tio documented control and inadequate control of requimd
'.h.t preheats were definita problems before 10/15/.76. This
;I
.; likely contributed to cracking adjacent to fillet welds and may have contributed to cracks in heavy joints that
{e- ..r . Originated in hardened heht affected. zones. However.
~
J. ':" the major factor by far in heavy joints was poor joint design. The preheat s'ituation is now under fu11'Q.A. A .,* control pmheat. hold points are Aoing obsteved. ,
~
fg,y, .
. %c19lE'M . . . .
ftn.p. - II 6 10lNT3_REQUIRIfE ACTION p . . .m.. . , ~ p ... 2
- a. ..pr, .".* , .A)
Stop indiscriminate.asterial remov.al ;,, ,. B 9'ifis; Ag )
- Change tional examinations contract.and/or (M.T. and specification re-U.T.) beingto ine19de the addi-imposed.
Q:=.. :.' . ..
.2 . C) Evaluate cracked Joints and develop method of bracing the .
.d- Joint to replace the portion of the joint that**esaminations
.. *W. . .mveal to be cracked.
- 1)
- Srece, pusset or plate to web.
b :. '
- 2) Arrange gusset shrinkage to'tak's load pff &
., f .
,1 crocked area or even to put cracks la .
ton. .
, g'- '
- 9) Hire Welding Engineer .farJiable canyon to agt t@ture testraint repair aroers=. conuos insuis tation
- 5
-( .ef heevy athiithT5Kln Unit Lana. maw.a. n qumty welding -
- q. .
progr . . est A. Eck M. Evans y, w W'T l
- s. d. Freee j
....-___.mm---. . . . , - . - . _ _ . _ _ ___/
i 8 BACKGROUND: DR.MYERhQUESTIONS(DATED 4/10/84)WEREFIRSTRECEIV 11, 1984, SHORTLY BEFORE THE COMMISSION MEETING REGARDING DIABL . TESTING. A LICENSING BOARD NOTIFICATION WAS MADE ON 12, APRIL 1984. MOST OF THE TOPICS REFERENCED BY THE QUESTIONS kTRE DISCUSSED IN TH MEETING ON APRIL 13, 1984. DURING THAT MEETING THE TOPICS WERE ADDRESSED BY THE STAFF AND THE LICENSEE. IN ADDITION, THE LICENSEE HAD PREVIOUSLY m sWmor: SUBMITTED MATERIAL TO TE ATOMIC SAFETY AND LICENSING, BOARD (IN 1983 RELATES TO THESE TOPICS. NRC STAFF EXAMINATION OF TE NSC AUDIT, AND RELATED ACTIONS, WAS PERFORM PRIMARILY TO PROVIDE THE NEW NRC REGIONAL ADMINISTRATOR IN MANAGEMENT AND QUALITY PRACTICES EMPLOYED IN THE EARLY C CANYON. EXAMINATION OF TE NSC AUDIT PROVIDED TE VEHICLE. TE STAFF FOLLOWED THE PATH REPORTED BY THE NSC AUDIT, APPROPRIATELY EXPANDING UPO AREAS OF QUESTION, TO DETERMINE THE VALIDITY OF TE NSC FIhTINGS.THE NRC STAFF DID NOT PERFORM A COMPLETE RECONSTRUCTION OF ALL PULIAN CONSTRUCTION ACTIVITIES AT THE SITE OVER THE BASED YEARS. UPON THE STAFF'S FINDINGS RELATING TO TE NSC AUDIT, A RECONSTRUCTION OF THIS TYPE IS NOT WARRANTED, AND WOULD NOT BE CONSIDERED AN APPROPRIATE EXPENDITURE OF NR RESOURCES AT THIS TIME. CERTAIN ASPECTS OF THE QUESTIONS LISTED BELOW CANNOT BE SPECIFICALLY ANSWERED SINCE TOTAL RECONSTRUCTION OF ALL PERFORMED, AND, AS STATED, IT DOES'NOT APPEAR THAT FURTHER EFFORTS IN THIS AREA ARE MERITED. Aq ._ f
QUESTION 1: TE NSC AUDIT OF PULLMAN APPEARS TO HAVE BEEN UNDERTAKEN IN RESPONSE TO CONCERNS EXPRESSED BY PG&E AS TO WHETER THE DIABLO REACTORS HAD BEEN IN CONSTRUCTED IN A MANNER'THAT COMPLIED WITH THE COMMISSION'S REGULATIONS. PG&E AUDIT B0422 (P. 2) STATES: "SEVERAL APPARENTLY GENERIC DEFICIENCIES IN WORK PERFORMED BY PULLMAN WERE PREVIOUSLY IDENTIFIED BY TE GENERAL CONSTRUCTION DEPARTMENT." WHAT " GENERIC DEFICIENCIES" HAD BEEN IDENTIFIED BY THE GENERAL CONSTRUCTION DEPARTMENT? HAD TESE " GENERIC DEFICIENCIES" BEEN REPORTED TO THE AEC/NRC? I ANSWER 1: AS DISCUSSED IN TE APRIL 13, 1984, COMMISSION MEETING TRANSCRIPT, TE LICENSEE PERFORMED TEIR AUDIT (NO. 80422) TO SAMPLE THE ADEQUACY OF HARDWARE AND OBTAIN AN ASSESSMENT OF PULLMAN ACTIVITIES DUE TO THE (APPARENTLY) IMPENDING LICENSING OF TE PLANT. TE BEST THAT TE STAFF WAS ABLE TO RECONSTRUCT REGARDING TE " GENERIC DEFICIENCIES" (REFERED TO IN AUDIT 80422) RELATE PRIMARILY TO TWO SPECIFIC PROBLEMS AND A MORE CENERALIZED PROBLEM WITH REWORK. TE STAFF HAD BEEN INFORMED OF TESE PROBLEMS. THE FIRST SPECIFIC PROBLEM RELATED TO DEFICIENCIES IN ANCHOR BOLT l INSTALLATIONS DETECTED IN EARLY 1977. EXTENSIVE RESEARCH, TESTING, AND REWORK l
. WAS ASSOCIATED WITH THIS ISSUE TO IMPROVE CONTROLS FOR INSTALLING AND t
INSPECTING ANCHOR BOLTS. THE NRC STAFF WAS INFORMED OF THIS PROBLEM. IN FACT, MUCH OF THE WORK DONE IN THIS AREA WAS UTILIZED BY TE STAFF IN MAKING ASSESSMENTS OF ANCHOR BOLT ADEQUACY AT OTER FACILITIES, IN THAT. TESE PROBLEMS WERE FOUND TO BE SOMEWHAT GENERIC IN THE INDUSTRY. THESE FINDINGS PROVIDED A BASIS FOR THE ISSUANCE OF IE BULLETIN 79-02. TE SECOND SPECIFIC PROBLEM RELATED TO UNDERSIZED SOCKET WELDS ON SCEDULE 160 PIPING. DEFICIENCIES IN THIS AREA LEAD TO TE REINSPECTION OF ALL SCEDULE 160 SOCKET WELDS AND TE ADDITION OF WELDMENT TO THOSE WHICH WERE FOUND TO BE UNDERSIZED. IN 1977, TE LICENSEE ALSO NOTED THAT TE VOLUME OF REWORK BY TE PULLMAN CONTRACTOR WAS INCREASED OVER PREVIOUS PERIODS. THIS INCLUDED NOT ONLY ANCHOR BOLTS, AND SOCKET WELDS, BUT ALSO REWORK RELATED TO RADIOGRAPHS. QUESTION 2: THE. SCOPE STATEMENT OF THE NSC AUDIT ENCOMPASSED " WOR 101ANSHIP OF TE FIELD-FABRICATED AND INSTALLED ITEMS." TE JUNE 16, 1978 LETTER FROM MR. WISCH0W TO MR. BAIN, TO WHICH THE PG&E REVIEW OF TE NSC AUDIT AND PULLMAN RESPONSE THERETO WERE ATTACED, STATED THAT THE NSC AUDIT "DID NOT ADDRESS ITSELF TO THE VERIFICATION OF THE ADEQUACY OF THE INSTALLED HARDWARE. TE NSC AUDIT WAS SUPERFICIAL WITH RESPECT TO TE HARDWARE. . . ." DID NSC FULFILL ITS COMMITMENT TO VERIFY THE ADEQUACY OF INSTALLED HARDWARE 7 IF NOT, WHAT WAS THE REASON FOR ITs NOT HAVING DONE S07 WHAT WAS DONE TO l SATISFY PG&E'S ORIGINAL CONCERN THAT THERE BE AN AUDIT TO VERIFY THE ADEQUACY OF INSTALLED HARDWARE? i l l
ANSWER 2: ( 4 BASED ON OUR REVIEW OF THE SCOPE OF WORK ASSIGNED TO NSC, IT CLEARLY LOOKS AS IF NSC SHOULD HAVE FOCUSED ON INSTALLED HARDWARE. AS EVIDENCED BY TE NSC REPORT THE VAST MAJORITY OF TE NSC EFFORT FOCUSED ON TE " PAPER-TRAIL" ASSOCIATED WITH TE WORK, AND NOT TE WORK ITSELF. AS MENTIONED PREVIOUSLY, TE STAFF DID NOT PERFORM A COMPLETE RECONSTRUCTION OF ALL NSC ACTIONS. TE STAFF DOES NOT KNOW TE PRECISE REASONS NSC DID NOT DIRECT THEIR AUDIT TOWARD HARDWARE. RECONSTRUCTION'WOULD BE LARGELY SPECULATIVE. NEVERTELESS, TE LICENSEE FELT THAT A DIRECT HARDWARE AUDIT SHOULD BE PERFORMED. THE LICENSEE FIRST REQUESTED THAT PULLMAN PERFORM SUCH AN AUDIT AS A PART OF TE FOLLOWUP TO TE NSC AUDIT. THIS FOLLOWUP HARDWARE AUDIT WAS PERFORMED BY A SINGLE INDIVIDUAL. LICENSEE OVERVIEW OF THIS ACTIVITY CONCLUDED THAT THIS AUDIT WAS DEFICIENT.ACCORDINGLY, THE LICENSEE DIRECTED THAT PULLMAN PERFORM A MORE I.XTENSIVE, IN DEPTH AUDIT OF HARDWARE. THIS AUDIT (NO. 71-77-3-78) WAS SATISFACTORILY PERFORMED IN JULY 1978, AND IDENTIFIED 43 ITEMS WHICH WERE APPROPRIATELY ADDRESSED AND RESOLVED TO TE LICENSEE'S SATISFACTION. QUESTIONS 3: PG&E UNDERTOCK AUDIT 80422 TO VERIFY THE ADEQUACY OF PULLMAN'S QA PROGRAM; TO REVIEW TE VALIDITY OF TE NSC FINDINGS AND TO DETERMINE TE ACCURACY AND APPROPRIATENESS OF PULLMAN'S RESPONSE; AND TO OBSERVE TE AS-INSTALLED 1 CONDITION OF COMPONENTS AND PULLMAN'S ADERENCE TO APPLICABLE SPECIFICATION 3, DESIGN DRAWINGS, AND QUALITY STANDARDS. M
, AUDIT 80422 EVALUATED A PULLMAN CORPORATE AUDIT CONDUCTED IN FEBRUARY 1978.
I AUDIT 80422 FOUND DISCREPANCIES IN ITEMS THAT HAD BEEN INSPECTED BY PULLMAN c) AUDITORS WHO NOTED NO DISCREPANCIES. AUDIT 80422 CONCLUDED THAT "IN LIGHT OF THE NUMBER OF DISCREPANCIES NOTED, IT IS APPARENT THAT THE PULLMAN AUDIT DID NOT EFFECTIVELY EVALUATE THE QUALITY OF THEIR WORK." WHAT ADDITIONAL AUDITS WERE CONDUCTED IN LIGHT OF THE FINDING THAT PULLMAN'S
" AUDIT DID NOT EFFECTIVELY EVALUATE THE QUALITY OF THEIR WORK 7" IN LIGHT OF THIS FINDING WHAT HARDWARE INSPECTIONS WERE CONDUCTED TO DETERMINE TE ADEQUACY OF PULLMAN'S WORK? HOW MANY DISCREPANCIES WERE NOTED AS THE RESULT OF ADDITIONAL AUDITS AND INSPECTIONS CONDUCTED IN TE WAKE OF AUDIT 80422?
WHAT WAS DONE TO DETERMINE WHY TE DEFICIENT CONDITIONS NOTED IN M-3725 AND M-3726 HAD NOT BEEN DISCOVERED IN THE COURSE OF TE ORIGINAL INSPECTION PROCESS? WHAT WAS THE REASON THESE DEFICIENT CONDITIONS HAD NOT BEEN NOTED DURING -TE COURSE OF THE ORIGINAL INSPECTION PROCESS? WHAT WAS DONE TO DETERMINE WHY TE PULLMAN CORPORATE AUDIT HAD NOT NOTED TE DISCREPANCIES NOTED BY AUDIT 80422? WHY DID TE PULLMAN CORPORATE AUDIT NOT DISCOVER TE DISCREPANCIES? WHAT WAS TE BASIS FOR THE 83-37 FINDING (STATED ON PAGE 40) THAT PULLMAN HAD PERFORMED ADEQUATE CORPORATE AUDITS? WHAT WAS TE BASIS FOR TE 83-37 FINDING (ID.) THAT PULLMAN'S INTERNAL AND CORPORATE AUDITS HAD INDICATED THAT NO FUNDAMENTAL QA PROGRAM BREAKDOWN HAD OCCURRED? [E.G. SEE 1978-79 FINDINGS RE PIPE RUPTURE RESTRAINTS PER NCR'S DC1-78-RM-008, DCI-78-RM-009, DCI-79-RM-003, ETC.) ANSWER 3: { l
AS STATED IN RESPONSE TO QUESTION 2, ABOVE, TE LICENSEE PROPERLY DETERMINED THAT PULLMAN'S INITIAL AUDIT WAS DEFICIENT. THIS WAS A SECOND FALSE START (TE FIRST BEING NSC'S FAILURE TO FOCUS ON TE HARDWARE). TE UTILITY THEN TOOK ACTION WITH PULLMAN TO GET A THOROUGH HARDWARE AUDIT. THIS PULLMAN AUDIT (NO. 71-77-3-83) ACCOMPLISED TE LICENSEE'S GOAL. PULLMAN IDENTIFIED 43 ITEMS IN THEIR AUDIT. TE KINDS OF DEFICIENCIES FOUND BY TE LICENSEE (IN M-3725 AC M-3726) AND TE PULLMAN AUDIT WERE MOSTLY MINOR IN NATURE AND NOT ATYPICAL OF WHAT IS FOUND ELSEWHERE. IT IS NOT POSSIBLE TO ACCURATELY STATE AT THIS LATE DATE, WHY THE FIRST LINE QC INSPECTORS DID NOT DETECT THESE ANOMOLIES. COMMENT ON WHY TE INITIAL PULLMAN INITIAL AUDIT WAS INADEQUATE WOULD BE LARGELY SPECULATIVE. PERHAPS PULLMAN DIDN'T TAKE TE PG&E REQUEST SERIOUSLY. TE AUDIT WAS CONDUCTED BY A SINGLE AUDITOR. WHAT IS IMPORTANT IS THAT PG&E RECOGNIZED TE ( PROBLEM, TOOK FORCEFUL ACTION WITH PULLMAN !MNAGEMENT, AND A MEANINGFUL HARDWARE AUDIT WAS OBTAINED. AS INDICATED, THE FINDINGS FROM TE LICENSEE AND PULLMAN AUDITS WERE NOT 0F TE SIGNIFICANCE THAT WOULD INDICATE A FUNDAMENTAL QUALITY ASSURANCE PROGRAM BRO XDOWN. AND, AS STATED IN STAFF REPORT 83-37, TE COMBINATION OF PULLMAN CORPORATE AND INTERNAL AUDITS PROVIDED ADEQUATE AUDIT COVERAGE TO MEET 10 CFR 50 APPENDIX B. QUESTION 4: TO WHAT EXTENT DID RECOMMENDATIONS LISTED ON PAGE 11 - 12 0F AUDIT 80422
, CORRESPOND TO DEFICIENCIES NOTED IN TE NSC AUDIT?
ANSWER 4: WHILE THERE IS SOME COMMONALITY IN GENERAL SUBJECT MATTER (E.G. , TE GENERAL TOPICS OF INSPECTORS CERTIFICATION AND REFERENCE TO PROCEDURE KFPS-7) THE LICENSEES RECOMMENDATIONS ON PAGES II AND 12 0F AUDIT 80422 DO NOT HAVE A ONE FOR ONE CORRELATION TO TE NSC FINDINGS. TE NSC AUDIT RELATED PRIMARILY TO PAPER WORK WHILE TE LICENSEE'S AUDIT INCLUDED HARDWARE INSPECTIONS. QUESTIONS 5: A MAY 29, 1979 MEMORANDUM FROM K. FREED TO E. GERWIN ADDRESSES PIPE RUPTURE RESTRAINT PROBLEMS. WHY HAD WELDER DEFICIENCIES NOT BE DETECTED AND CORRECTED AT AN EARLIER DATE BY PULLMAN'S QC/QA PROGRAM 7 TO W)iAT EXTENT ARE THE NOTED WELDING DEFICIENCIES SIMILAR TO THOSE SPECIFIED BY TE NSC AUDIT 7 ANSWER 5: THERE APPEARS TO BE SOME CONFUSION ABOUT TE SIGNIFICANCE OF TE MAY 29, 1979 MEMO. TE PROBLEM WHICH IT DISCUSSES WAS DETECTED MUCH EARLIER THAN DATE OF THE MEMO. TE LICENSEE AND PULLMAN HAD PROPERLY DOCUMENTED TE PROBLEM THROUGH TE QC/QA SYSTEM, AND HAD BEEN EVALUATING TE EXTENT OF THE PROBLEM FOR SEVERAL MONTHS. IT WAS OFFICIALLY REPORTED TO TE NRC AS A 50.55(E) DEFICIENCY ON APRIL 4, 1979. TE MAY 29,1979 MEMO WAS AN INTERNAL PULLMAN DOCUMENT ADDRESSED TO TE PULLMAN QA MANAGER. IT REPRESENTED AN EARLY ATTEMPT BY PULLMAN TO ASSESS THE CAUSES OF PROBLEM. THE MEMO WAS SOMEWHAT PREMATURE IN THIS REGARD SINCE THE LICENSEE WAS CONDUCTING EXTENSIVE EVALUATIONS WHICH
! LASTED OVER AN EXTENTED PERIOD. TESE EVALUATIONS INCLUDED: NONDESTRUCTIVE
1
- EXAMINATIONS; EXAMINATION OF WELD RECORDS; DESTRUCTIVE TESTING; AND FAILURE MODE DETERMINATION. A FINAL REPORT ON THIS SUBJECT WAS ISSUED TO THE NRC IN DECEMBER 1980. THIS TOPIC WAS EAVILY INSPECTED BY TE NRC STAFF AND IS ADDRESSED INJIQTAFF INSPECTION REPORTS.
SY THE ANALYSIS OF TE PROBLEMS DISCLOSED THAT THE CAUSES WERE COMPLEX AND UNIQUE TO THE TYPE.0F WELDING BEING PERFORMED. THE RUPTURE RESTRAINT SITUATION WERE UNIQUI IN THAT TE COMPONENTS INVOLVE HIGH STRENGTH MATERIALS, VERY THICK WELD SECTIONS, AND HIGHLY RESTRAINED JOINT CONFIGURATIONS. NOT NORMALLY FOUND IN NUCLEAR PLANTS. TE COMPONENT FAILURES WERE FIRST DETECTED AS LAMELLAR TEARS OUTSIDE OF TE WELDS THEMSELVES. THE ORIGINAL INSPECTION PROCESS SPECIFIED FOR THESE WEIDS DID NOT ANTICIPATE THIS TYPE OF FAILURE AND WAS NOT SUITABLE FOR TEIR DETECTION. THEREFORE, EVEN THOUGH TE QC INSPECTORS PERFORED THEIR INSPECTIONS PROPERLY THEY WERE NOT ABLE TO DETECT TE FLAWS DUE TO TE INSPECTION TECHNIQUE SPECIFIED. THE PROBLEM WAS ULTIMATELY IDENTIFIED WHEN PERFORMING ROUTINE REPAIRS TO TE RESTRAINTS. A SUITABLE NONDESTRUCTIVE EXAMINATION METHOD WAS SPECIFIED AND APPLIED AS A PART OF TE CORRECTIVE ACTION PROGRAM. TE CONDITIONS RELATED TO TE RESTRAINTS ARE QUITE DIFFERENT THAN THOSE ADDRESSED BY THE NSC AUDIT (WHICH FOCUSED ON PAPERWORK RELATED TO PIPE AND PIPE SUPPORT WELDING). REFER TO QUESTION 6 FOR ADDITIONAL DISCUSSION IN THIS AREA. QUESTION 6:
WHAT AUDITS AND/OR REINSPECTIONS HANGERS WERE CONDUCTED TO DETERMINE WHETHER k TE TYPES OF DEFECTS FOUND IN TE PIPE RUPTURE RESTRAINTS EXISTED WITH RESPECT
- 70. PIPE HANGERS? WHAT IS TE BASIS FOR A DETERMINATION THAT DEFECTS FOUND IN
, PIPE RUPTURE RESTAINTS DID NOT EXIST WITH RESPECT TO PIPE HANGERS?
ANSWER 6: TE PROBLEMS ASSOCIATED WITH RUPTURE RESTRAINT FABRICATION WERE FOUND TO BE DUE PRIMARILY TO TE USE OF HIGH STRENGTH STEEL, IN EAVY THICK SECTIONS, WITH RESTRAINTED JOINT CONFIGURATIONS. THESE ARE NOT THE TYPE OF COND4TIONS ENCOUNTERED IN PIPE HANGER FABRICATION, WHICH TYPICALLY INVOLVES MILD STEEL, SMALLER MATERIAL SECTIONS, WITH LESS CONCERN WITH RESTRAINTED JOINT CONFIGURATIONS. SINCE TE PROBLEMS ASSOCIATED WITH THE FABRICATION OF ThE
, EAVY RESTRAINTS WERE NOT APPLICABLE TO PIPE HANGERS TERE WERE NO SPECIFIC AUDITS OR REINSPECTIONS PERFORMED RELATIVE TO THIS TOPIC. HOWEVER, FOR OTER REASONS (SUCH AS IE BULLETIN 79-14) TERE WERE REINSPECTIONS OF PIPE HANGERS.
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