ML20154R235

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Rept of 850426 Interview W/Tf Westerman Re Actions by Region IV in Response to Affidavits Alleging That Liner Plates for Spent Fuel Tank,Refueling Cavities & Two Transfer Canals Improperly Installed.Incomplete Technical Interview Encl
ML20154R235
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 05/03/1985
From: Mulley G
NRC OFFICE OF INSPECTOR & AUDITOR (OIA)
To:
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ML20154R138 List:
References
NUDOCS 8603280160
Download: ML20154R235 (16)


Text

{{#Wiki_filter:. - - - . ___ _ - _ A U.S. NUCLEAR REGULATORY COMMISSION Of fice of Inspector and Auditor

                   -                                                                  0. . .. i,..i.e n . . .

May 3, 1985 REPORT OF INTERVIEW Thomas F. Westerman, Enforcement Officer, Region IV, NRC, was interviewed concerning actions by Region IV in response to affidavits alleging that the liner plates for the spent fuel tank, refueling casities, and two transfer canals at Comanche Peak Steam Electric Station (SES) had been improperly installed. During the interview, Westerman provided the following informa-tion. On April 4,1984, at the completion of an 0I investigation, the Region IV Office of Inv.estigations (01) Field Office provided Westerman with a copy of an August 24, 1983, transcript of an 01 interview of Arvill Dillingham, Jr. During the August 24, 1983, 01 interview, Dillingham discussed his concerns about alleged falsification of inspection travelers pertaining to.the liner plates. In addition to the August 24,-1983, transcript, Westerman had on file two other affidavits by Dillingham dated March 31, 1983, and June 27, 1983, which documented his concerns with the construction at Comanche Peak SES. Although the issues raised in the first two Dillingham affidavits had pre-viously been investigated by NRC, Westerman provided.the three affidavits to . Region IV Inspector Robert C. Steward for review and research in April 1984. However, also in April 1984, the NRC Comanche Peak Technical Review Team (TRT)

  1. arrived at Region IV to review and attempt to resolve allegations of con-l struction deficiencies at Comanche Peak. Consequently, the TRT assumed responsibility for all allegations at the Comanche Peak SES. The Dillingham affidavits as well as any other allegations concerning the liner plates at Comanche Peak were turned over to the TRT for review and resolution.

L 1 a 8603280160 860320 PDR - ADOCK 05000445 PDR _ A t Reaion IV ,,,,_ 85-10 goril 26,1985 ,, , , George A. Mulley Jr. , Investigator, 01A o,,,,,,,,,,, May 3, 1985 T6aiS DOCUMEasT tS PROPE RTY OF NRC. tF LOANED TO ANOTHER AGENCY IT ANO ITS CONTENTS ARE NOT TO BE OtSTRIBUTED I' OUTSiOE THE RECElvtNG AGENCY WiTHOUT PE RMISSION OF THE OFFICE OF INSPECTOR AND AUDITOR. mw

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1 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2 TECHNICAL REVIEW TEAM 3 4 TECHNICAL INTERVIEW 5 6 Monday, December 10, 1984 7 Granbury, Texas 8 This interview was commenced at 2:30 p.m. 9 ,' 10 PRESENT: 11 MR. JOHN J. ZUDANS Technical Review Team Staff

             .      12       Nuclear Regulatory Commission Washington, D. C. 20555 13 MR. VINCE NOONAN 14       Technical Review Team Staff Nuclear Regulatory Commission 15       Washington, D.,C. 20555
          -         16       MR. JIM MALONSON Technical Review Team Staff 17       Nuclear Regulatory Commission
  ;                          Washington,D. C. 20555
       ,e            18 MR. CLIFF HALE 7

19 Technical Review Team Staff

    '                        Region 4
     !.             20       Nuclear Regulatory Commission Arlington, Texas 21 MR. T. E. CURRY                                   -
            .-      22        Technical Review Team Staff Nuclear Regulatory Commission 23       Idaho Falls, Idaho
                -   .24 C       25

_. , 2 1 PRESENT: (Continued) 5 2 MR. VIC WENCZEL Technical Review Team Staff 3 Nuclear Regulatory Commission Idaho Falls, Idaho I 4

                                                               ~~

MR. VERN WATSO!! , 5 Technical Review Tearn Staff Nuclear Regulatory Corrmission 6 Idaho. Falls, Idaho 7 MS. MEDDIE GREGORY Glen Rose, Texas

        .1       8 MS. DOBIE HATLEY 5'       9       Glen Rose, Texas
10 MS. SUE ANN NEUMEYER Fort Worth, Texas
        !'      11    .

MS. LINDA BARNES 12 Granbury, Texas

       .s -     13
        >       14
       -       15 16                          '
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17 - 18 f: 19 u 20 - _ 21

       .'      22 23 24                                       .

25

I y r-92 g 1- suffer through the NCR's, I think you're going to find thot a i J f 2 in '82'they started doing that to a lot of the inspectors, a  ;

                            ?

j g l. retrain the inspector. Of course, you know that when an

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         ;       g          , inspector is certified he's supposed to $e adequaEcly

(.i , trained. That's why we're asking about Jin because in 1 j 4 fparticularwerememberabouthim. j i  ! a rf e MR. NOONAN: This ct.;ne up in .the hearings, didn't it? t '.

        ; .8           ,
                                , L+r . r MS . GREGORY :   Yes, it did; and also another gentler:an t-<:

in the hearings, Robbie Duncan.- When they.put him ontthe C l 3 9* witness stand and they asked him how you could tell when . u an NCR had been dispositioned which is merely a signature 4  ; at the bottom saying it had been dispositioned, he didn't 8 know.- It was so bad that when they were through questioning l E  : him, Mr. Watkins went on record to ask him if he was still lE r

      ,         .-       l working as a QC Inspector, and he said, no, he was working as a QES Reviewer.         They wanted it off the record that he l'y.A (1 i

sas doing any inspecting. You would have to read the lE i .

                         ,( -testimony.                                                           A E                    ar      MS. HATLEY:     Since then, he's terminated.

I MR. HALE: Okay. Jim, do you want to do on-site g D fabrication, I believe, right? i O MR. MALONSON: I have two categories: One is material [D traceability and.it's related to on-site fabrication because

 '           4 I did sorre material traceability in the other large alle-
5. gation--concern pertaining to traceability.

l p

   ;                                                                             93 1

(Short break taken.) 2 A l2-55 MR. NOONAN: The-issue on the spent

  • fuel-liners, l 3 Whether-it's' safety r' elated, non-safety related; everytime 4 Idturn rarounduI*m_ hearing a different poink of view on this l

5 thing. el-finally got -tired-of -it; *and"I 'fust *put cut' a 6 memo 40 ths97RC ktaf f Melling-them to come-back and*give rne 7 a-formal position on this. The reas'od'I'm laughing is 8 because I think after all these years it seems like each f 8' 9 plant'is different. For some reason or another they have 10 a reason for making it safety related or not safety related. 11 In this plant here I don't know the answer right now. I've

 '     12   had two different opinions, one saying it's safety related, 13  one saying it's not safety related; so I basically took an 14   action here to put it out to the people that are involved 15   in reviewing of this particular item and asked them to come 16   back with a formal position.          I'll give you that;~you can
  ' 0 17    have as nany copics as you' want to'.

IS MS. NEUMEYER: It says fuel pool liner. Is this also

     ~19    including the transfer canals?

20 MR. NOONAN: It includes the transfer canals, yes. 21 MS. GREGORY: My problem with that in that there are 22 reg guides out right now, 1.13. Of courso, you know 1.29 23 puts it in Seismic Category 1. 24 MR. NOONAN: It can be considered f.eismic Category 25 1, but the liner doesn't necessarily have to be safety

I y ' 94 3 related. .But it's either way. I realize that, but 1.13 definitely in

       '. 3          u.e:*r.MS.r GREGORY :

3 p opinion, the way your reg guides read, puts it in safety 4 category because of the possibility of Seakage, I think ycu

      ;                                   rem.1

[ g pall;it, .05 ({ealr), e whatever it is. Anyway, I've gone g p ugh several of your reg guides. I've gone through 10CFR50. I don't know if I gave you the copy that I had 3 3 done :for the stainless steel liners for the ASLB hearings i n art.not,, but it gives you what I thought was pretty con-g g:losive evidence th'at it was safety related. Il MR. NOONAN: It's not. It's not conclusive because c between.two different organizations of the NRC, they both had

         ,u              d,ifferent opinions.      They're both using the same reg guide
     ?

j M ;you're talking about. Certain Utilities, based on their t

     }       5          particular circumstances, can core in and stake it non-fM                  isafety related and we' probably will agree with ther..      What W W- ~-4I= did .in this case: .I went back and I asked them to come j        B          *ack end tell rie.

(

    .        #           Is. 11R. ZUDANS:    It was Friday that this memo was signed I
    ..      3           cut ..- - The reason it doesn't have a date on it is that I 23             pade a copy before it was distributed, and they put the          )

R <iate on at the time they distributed it. D - MR. NOONAN: I'll get it back here, and I'll send you as dadies a copy of what they tell me. E Vac.? MS. HATLEY: Who did you ask to tell you this? I L g. G

. s.- i

,. 95

{ g 7 .t. bet JiR. NOONAN: My peopic. You can see their names on f 2 there. There are particular branches that are responsible 3 for review of that thing. 4 did MS. GREGORY: Wow,T"this will also 4 pertain to ithe 5 ptor cavity . stainless . steel.. liners _ as. well as cmpent cf uel

       ,       .4             W V' y            . wN . MR. NOONAN:        No, it's strictly the spent fuel pool.

8 t!... - MS. GREGORY: Well, the question that we had at the t pa *WASLB hearings is the reactor. cavity.itself.for. refueling

     ';        3            - + system.                                                                                                           -

p.)-57

     +

33

12. MS. NEUMEYER: .Thepdocumentationtthey produced *in my i

3 gymalcallegation was that they haduforced me:to sign of f D apyte 142 travelersp and what we did get them finally to N' produce--they tfere suppcsed to produce Unit One and Unit i f3< Two, and they only produced Unit Two. They came back with {E t

                 ~i some of those plates w'ere installed in the reactor.          So now OP - ere have--surely, if it's in the reactor, there's no question
           ^

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             "$'               that it's safety related.

1,- .1

  }'4                          AG        MR. ZUDAMS:    I think the fabrication methods and the M,

design methods for the liners in the Reactor Building are, M in essence, identical to the way they build the ones in the j Mi spent fuel pool. - j% 0.- 2 3 I i MS. NEUMEYER: What I!m telling you is that. I falsi- {. R) Slee-the: documents. .r.They made me , falsify them, and that's

  . El what's come out in the AELL hearings.             For a long time
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I 96 g there, right up to the last, I think they altrost had ever1-g body cc:nvinced that, yes , indeed, I did have the documenta-

     -                             tion that I needed in order to sign this stuff off, but I 3
  • didn't. I said from day one that I did not know what I 4
                                - was signing off. I did not know what the chit was, that I 6               believed that the chit only had to do with backing strips, 3               whichc came out there at the last to-be true. That's all
             ..    $              . that it pertained to was that. backing strip. It had nothing
                            -*toddo. with the front weld.         Therefore, I signed off the g                front weld; I signed of f everything, without ever. seeing y                its -I was told--I was put in a little room, I was told that g                I.-vould sign it off if it took me three days to do it.      I
              - g                  signed it off. I had gone every route that I could, saying N                Idon't want to sign these of f, I don't believe this is what 3                iets:.for, you're going to put me in prison for 20 years for b                               ,
                 &                 dhng this, it's illegal, and all that stuff.       And still f**                -
                                  .it:y tsupervisor stood there ' and said, "You will sign it off.

E , You will stay here if it takes you three days to get these

            , 89 '                 142. travelers signed off. You will stay here until they're    !
                &                  done, Ms. Neumeyer."     So with that--

1

                %                   t: : MR. NOONAN:   Who was the supervisor?

R MS. MEUMEYER: Dwight Icodard, Ted Blixt; and Pob 3 Sievers was the one that originally told me to do it. That 3B is and was at the time--I know they've had some fast

                &                  corporate shuffles since then, but these were the non in
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97 j charge. Bob Sievers was the one that told rae to go over 3 there, that Dwight Woodard and Ted Blixt would take re over 3 to the Millwright Shop and show me what had to be done, and g they did. ,. g . .- MR. NOONAN: How many documents did you sign off? 4 .that MS. NEUMEYER: They said there were approximately 142 7 cf. them, and later came back and said they thought around i 4 .4121ssomewhere between 112 and,142. But for the hearings d a pg M -on my deposition, when they deposed me, the Utility a s a ' came-up--Dwight Woodard said, when they deposed him, that I i < g had fabricated the whole thing, that it never happened. t Then Sievers came in behind him and Blixt came in behind B him--this is down here in the library; you can read it for

            ,        MI               yourself--and 'they said that, yes, it did happen, that I
            ;            2
           !         5 e
                                 - had signed off, but that I hadn't raised any fuss.            Eut I i                                                    .
           .         E               had, and I think if you could, if you could talk to Billie hW, f- Catness,. Chuck Reaves , Mike Kennr :ly, and C.                       C. Randall, u

3 l. they could tell you that I did raise cain.

                              ~

i S I was upset.

          !#                         Eadidn't just raise cain, I raised hell.

I' ' MR. HALE: This area is one that Tom Curry is going h' to speak to. We're going to have him after Jim. , D us .MR. NOONAN: We're going to cover this? I

  • MR. HALE:

Yes.. I i.' r - MR. NOONAN: I want to go into it. I j ' ccr. , MR. 20DANS: I didn't want to make a big discussion

        .             f.y-
        ;.n I                                                                                                 l w' fh                                      -

a.e V, ,6 i 95 t g of it. I just wcnted to provide you with a memo that at

                         .[                  least we're going to get something straight on our end.

y 3 1. > MS. GREGORY: In other words, this is just a request; t {g .dsey're to answer these questions and--

                          ,5                 s-       MR. NOONAN:   They have to go bacT: and tell me what k
                        ,      6
  • that liner is.

7 i: . MR. ZUDANS: When we say "NRC position", that is how 8 ' me review all the plants on that. This is our position.

                     ,  pfm that's the way we're going to review spent fuel pool W         .' 11ners.                   .'                                           7 3' . B. : . MS. GREGORY:               Well, the one on spent fuel and                   is E            au different NUREG number than that.          I wonder if I could B            get some of those together and send them to you?

N a.x -MR. NOONAN: Sure, e t' E , MS. GREGORY: I know that you've got them, but I would E e feel better mycelf i,f I were to present my case as strongly c , l k9- s Ns I could, a EJ MR. NOONAN: Meddie, send them to me so I can send

                          %v E            them to the right people.

I I 'I  ?.S. GREGORY: All right. E! - MR. HALE: All.right, Jim, let's get you out of the [ 8 way so we can get to Tom. O - MR. MALONSON: I'm dealing with three allegations in 2 here in this category of material traceability, and they i . O cconcern either one or all three of you. I might also say i ,? *

                            ,$. t- -

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                          -cts w, _, . , - -4                 -q

. 0 , , e 106 I MR. CURRY: .-Okaye AQE,41 concerned the gauges used

    .       .y . , -

2 to calibrate- lightings restraint cable. installation-tools 3 were worn-which resulted insipcorrect imptallation.-and

       ...                        !       ,fssuan.ce;ofcan NCR.

Do you rerenber that one? n ,, 5 MR. EALE: That was Eusie's.

    . g -;a 0               MR. ZUDANS: .Actually, we covered this with sorcone
     -                             I         elsc. Let's leave it at that.
   , y , .,q -

0 MR. CURRY : Do you want to go on?

   -                             'I                MR. ZUDANS:     I think we just better go en.

MS. EATLEY: We knew about calibration; you don't have f ,._, u ., . h

      -                            il        to tell us.
   .- e:js                       3                 MR. CURRY: ,dAQ 55-and 78:: 1. Fuel. transfer- canaltliner
   '                                3     ~ 4gcupentatientwast      f alsified. The required weld raciegraphy
                                                             \
       -                            4        was not complete.        Hold points on inspection travelers were 3       signed off improperly.        I cuess we can just take those one
    .. ,n ,; .

4 at a tire. av sno 3- er ,. ii _ First of all, the fuel transfer' canal liner docuncnta-4 tion was falsified. I don't think we're prepared to say e ,, , ,q. I that it was flat-o9t fL sified. We will talk sore more 3 about signoff of 5 sic y,tnts.

     ;, e , ,-
  • 2 MS. NEUMEYER: I can say it was flat-out falsified
            .3.

2 because I'n the one that flat-out falsified it. 3 MR. CURRY: Lut cur investigation and how we deterr..iney I L that it was falsified, I don't think I have enough infor-L. r.ation to say that it was falsified.

  • 4 H.

8 a

_E 167 I MS. NEUMEYER: But I did. 2 MR. CURRY : Let's go on and we'll come back to that in 3 Second: The required weld radiography was just a rinute. 4 not conplete. We did find the weld radiography for"those i 5 welds, and the canal that required radiography--there was 6 a limited number of them--we located that. 7 Eold points on inspection travelers were signed off 8 improperly. Of course, there's a whole series of questions In essence, what 9 that relate to signof5 of hold points. 10 our conclusion was was that we weren't satisfied with the 11 way that they were signed off, call it inproperly or what 12 you will. Whatever actior we take as a result of that,

        - 13       we're still investigating.

14 MR. HALE: I think it's fair to say that we're net 15 through with that. , What allegations I have r.ade about the 16 MS. CREGORY: W 17 stainless steel liners has to do with the knowledge that 18 I have which is with Unit Two cavity only. I didn't know 19 that there were documents that Fue signed off in Unit Cne 20 and in the transfer canal along with Fred Evans, but with 21 your being satisfied with naybe the documentation that are 22 backing up hold point one on there, I found 147 cases where l 23 they had used chits with the QC Inspector date ano sigr.c-t 24 ture that were actually held point two and three and Cif not include hold point one. Fad he intended to includc-25

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            .            .~                           . . - .           .                                                                   -                  -               .   .          -       . . .

y- - . _ _ . . . . . . - - . . . _ . . . . . . .

                          ~
                                                                                                                                                                                             '168 1   hold point one, he wculd have signed it off at the tire he l .                 2    signed off twc and three.                                               So I feel in those particular 5

i i 3 cases that there's not adequate docurentation to show that i: 4 that hcid point one was perforred or docur.ented." i e 5 MS. EATLEY: However, if you would be willing to get us is 6- a copy of Unit One and let us go through it, we would be T 7 happy to document that for you. .,

.                                 8                 MR. CURRY:                           Unit One-                  , ,

i i-

                     ? p9                           MS. HATLEY:                           Unit One Reactor cavity and refueling
                ;   C.           10    canal.               There will be about 1200 to 1500 drawings,'and it
         .           ,           31    would take us about a week, and we can get you a real 4
                     -           12    accurate synopsis of what happened.
                 ' -             13                 HR. CURRY:                           ,3 grin, the subject of falsific'ation of the                                                                      .

14 signatures or whatever on those travelers is the subject of i .- 4. 15 a separate investigation by OI. That's one of the reasons l l why we're not prepared to say that the documents werc i E ! 16 I , .,  ; lg g7 falsified because they are still looking at it. i  ;

                            ,.18                    MS. HATLEY:                           You mentioned that you looked at the~
      .-          .             19     radiography.                                   Did you look at'the film or did you look at 20     the reports?                                   Did you physically see the film?

21 NR. CURRY: We Icoked at both of them. Sore of the 22 team looked at the reports; sor.e of the team. looked at the 23 film-i

!                            l                                                                              .           .

i fE. EATLEY: And reviewed ther with the docurent. 24 l

                             ! 25                   MR. CURRY:                           Yes.         The raterial was there.

i l

                             ,i

_ . . _ . . . . . _ _ . . , . _ . . - . . , _ . , . . . . . . , , , , . . . , . . ~ , . , - ~ ,_# _._.o-..

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                                     -                                                                                                             \

169

                  %> Q[v.        V MS. IIATLEY:     Do you know what percentage they used?

II- l

                 .: :?p:                               -
                                                       -many?

y

                                 .a
                              .f
           -A          '
                                                    ~'

MR. CURRY: How rany radiography--? , l l

                        .*'y
                                -e MS. I!ATLEY:     Yes, and how they were obtained.              Did you
                                                " elect the ones you wanted to see or were they preselected
                         ?
j. g or you?

5- f g g g n: - MR. CURRY: I don't know how they were selected. Thercl: {

l. W & -

g was another individual that went'to look at the film. k . ' g . .g. Q- g Mt _MR. HALE: I thihk I can say with some assurance that l F' .

1
       %                   i,
                           '                . the direction that we proceeded under in all of our assess-                                          l W                 I ment was to select things independently, not sorething--
                         !s,                                                                                                               !

b '

                                                                                                                                          !        1 n            with the exception of those concerns identified to us by
                                          '                                                                                               l        l
       *                       'T individuals such as yourselves, we would go and select                                     I
      "                       8' 4         I something specific; but by and large it was not to be led                                  l         ,

o 1 I ' 1: by anyone. Our interfhce with personnel on site was purely me I.

                   ?
  • because they were on site. Any tirte we did an assessment it was not based upon what someone told us. Ele looked at the documents, we looked at the records, whichever the 6 g. '

case was, and tried to establish an independent view to , r i the extent even that we did not rely on reports generated j by Region 4 or findings generated by Region 4. tio looked  ! independently even of that, so I would say that these l l docur.ents were not selected by somecne for us to look et, i

                  '                                                                                                                 4 but were selected in sor.c fashicn randomly perhaps by the                              !

l l individual who looked at therr. l l

                                                                               - - - - - - - - - - - - --- - -              - - ~              ~~~

t - o r . 1 169 I MS. liATLEY: Do you know what percentage they used? 2 How many? . 3 MR. CURRY: How rany radiography--? ,, 4 MS. HATLEY: Yes, and how they were'obtained. Didyou! 5 select the ones you wanted to see or were they preselected 6 for you? - 7 MR. CURRY: I don't know how they were selected. Therg 8 was another individual that went to look at the film.

                     ' 9                      MR. KALE:             I think I can say with some assurance that 10      the direction that we proceeded under in all of our assess-11      rent was to select things independently, not sorething--                                                                        .

I 12 with the exception of those concerns identified to us by  ! I 13 individuals such as yourselves, we would go and select 14 something specific; but by and large it was not to be led 15 by anyone. Our interface with personnel on site was purely 16 because they were on site. Any tire we did an assessment i 17 it was not based upon what someone told us. We looked at . l 18 the documents, we looked at the records, whichever the  ! I i 19 case was, and tried to establish an independent view to 20 the extent even that we did not rely on reports generated 21 by Region 4 or findincs generated by Region 4. He looked t 22 independently even of that, so I would'say that these 23 docunents were not selected by screene for us to look at, 8 24 but were selected in scr.c fashion randomly perhaps by the 25 individual who looked at ther. i 6 d

e .

                                     )                                          ,

. b ~ I 170 gs , . E;.TLEY : lic would have been someone who was

                            .              2 qualified to know whether or not this particular film was 3                       good or bad?

4 s. MR. HALE: Do you knou what team looked at that,' Ton? I

                           .              5                       Uhich group looked at it? Was it our group that looked at 6.

those radiographs or was it one of the other groups? The 7-L individual's name would be'okay, I think.

8 MR. MALONSON
'I looked at radiographs on a concern i 9 that identified specific weld joints on the lift gate 1 . 10 1 .

frames, and_I physical 19 looked at the radiegraphic record 1 11 and the leader sheets. 12  !!R. 11 ALE: Who selected those records for you? l 13 MR. MALONSON: They weren't selected. I found the. 14 weld joints being referred to and then went and asked for l 15 the film. i 'You're intimately familiar with the assiennent 16 1 of field weld joint's on the spent fuel pool transfer canals, 17 i

                                ,                               and there's no heroics in this, but I spent about seven 18 hours in my hotel room looking at drawings to find the field
                                                                                                                                                                   ~

i i

,                                     19                      weld joints in question. There's a history of that in ene

\ 20 of the mechanical and niping assessments that will bc 21 presented later. This information was presented by another 22 person. It was not presented by-a particular SSTR pertaininh 23 1 to the lift gate frames was not presented by either of you 24 ladies. 25 14S. hATLEY: All of the RT filming that you looked at i I

     - . . . . _ _ , - - ~ .                 _ , . - , , . .--          ,.        . - . _ . - , - . . _ - . _ ,            ~ ~ . . . . . . . . . . . .   ~ , _ - . , _ , , _ . . . ~ . . . .      ,.  . . . - -       . . _ . _ _

j#' *% UNITED STATES - y , y, g NUCLEAR REGULATORY COMMISSION

 &              j OFFICl- OF INVESTIGATIONS FIELD OFFICE. REGION IV
   % ..... /                             '""7d"iGi0' '^ "r"E!I
                                                        .      S   's!' "

April 4, 1984 MEMORANDUM T0: T. F. Westermar. Inspection & Enforcement Officer FROM: H. Brooks Griffin Investigator SUEJECT: RELEASE OF PORTIONS OF DILLINGHAM'S TRANSCRIPT The Regionmatter. Dillingham IV OI Field Office has completed its investigation in the for its reporting needs. Region IV is free to make use of the transcript If you require further infonr,aticr., please call me.

                                                                          -[gk                   /'.

f~ l P 5

                                               ~

yk t (( Attachment 29 h _ w .

           ' "e*g ue ~g'o
     ?                                                                                                                                                           

UNITED STATES jj f M II 3 8 n NUCLEAR REGULATORY COMMISSION h  ; WASHING TON, D. C. 20555 h i(

                                                                         *" * * /

DEC 0 71984 Docket No.: 50-445 ,y" .[ h MEMORANDUM FOR: Olan Parr, Chief Auxiliary Systems Branch, DSI *

  • Robert J. Bosnak, Chief Mechanical Engineering Branch, DE George T. Ankrum,-Chief
                                                      .                                          Quality Assurance Branch, I&E FROM:             Vfncent S. Noonan, Project Director for Comanche Peak Division of Licensing

SUBJECT:

PREPARATION OF A STATEMENT ON THE NRC STAFF'S - POSITION ON THE SPENT FUEL POOL LINER The purpose of this memorandum is to request that Auxiliary Systems Branch prepare a statement of the NRC staff's position on the need for the spent fuel pool liner to be designed and constructed as a seismic Category I structure, and/or a safety-related,10 CFR 50, Appendix B structure. In view of the questions for which we shnuld have answers (see enclosure) ASB will likely need to draw from the expertise of the Mechan'ical Engineering Branch and the Quality Assurance Branch. The statement must , represent the position of all three branches. We plan to use the requested statement to demonstrate to the allegers that the staff's criteria for accepting the Comanche Peak design are identical to the criteria used for acceptir.g designs at all/some of the other plants of the same vintage. The staff's acceptance of the design, construction and inspection comitments for the Comanche Peak spent fuel pool liner has been raised in the hearings. As a result, the statement will likely need to be 3 l offered as an affidavit or testimony in'the next several weeks.  ! We are enclosing a copy of two NRC Inspection Reports, 50-445/77-13 and 50-445/ 79-15. These provide information on the Regions criteria for inspecting the spent fuel pool liner. 1

                                                                                                                                     ~

In addition, we are enclosing a copy of recent testimony (November 26, 1984) by the applicant's employee concerning the quality of the spent fuel liner. The prefiled testimony and pertinent cross examination pages (Tr. 20630-20634) are provided. 5' - y W v i

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                            ,[                                                                                    DEC 0 71984
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1 Please advise me on the members of your staff which are assigned to this task and a schedule for providing this statement. Should you have questions concerning this request, please contact S. B. Burwell on extension 27563.

                                                                                                             /                             :

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                                                                                                 /

t . n, n, roject Director

. for Com che ieak t Division f Licensing

Enclosures:

As stated - cc: P. Hearn E. Sylvester - - R. Kirkwood J. Spraul I e i D 0 9 L 1

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ENCLOSURE QUESTIONS FOR WHICH A RESPONSE IS NEEDED , ,

1. What are the NRC's acceptance criteria for the design, construction and inspection of the spent fuel pool liner?

Comment: We are aware of the SRP (NUREG-0800) acceptance of a non-seismic Category 1 pool liner with qualifications. However, we do not find this in the earlier SRP. What is the background and basis for the

                . change in acceptance criteria in NUREG-75/087 and NUREG-0800; i.e., the acceptance of a non-seismic Category 1 pool liner. Was the change in the acceptance criteria reviewed and approved by the Reactor Regulation Review Committee (RRRC)? What request or event triggered the change?
2. Describe the. relationship between the guidelines in Regulatory Guides 1.13 and 1.29 and the staff's acceptance criteria as given in SRP NUREC-0800.
3. Describe the need for or rationale for requiring the spent fuel pool liner to be classified as a " safety-related" structure, or an "important to safety" structure. And discuss the need to have a QA/QC program for the liner portion of the spent fuel pool.
4. Describe the manner in wilich the Comanche Peak spent fuel pool liner meets the requirements of GDC 2 relative to protection against natural phenomena (earthquakes), and GDC 16 relative to preventing a significant reduction ,in fuel storage coolant inventory under accident conditions.
5. Describe the Comanche Peak FSAR commitments relative to seismic and quality standards for the spent fuel pool liner. In so far as possible, describe the criteria or basis upon which the spent fuel pool was found acceptable ,

in the SER, particularly as it relates to the quality of the spent fuel pool liner.

6. Please identif9 all documentation used in the review of Comanche Peak spent fuel pool liner; e.g., old FSAR pages, SER references, memorandums and reviewer notes.

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UNITED STATES ' [ 'c NUCLEAR REGULATORY CO.WISSICN

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RECION IV

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611 R YAN PLAZA DRIV!. $UIT! 1003 o, *g;((g, /[ AR LINGTON. TZXAS 76011

                             ,g December 20, 1977 In Raply Refer To:                                                                  -

RIV Docket No. 50-445/Rpt. 77-13 50-445/Rpt. 77-13 Texas Utilities Generating Company ATTN: Mr. R. J. Gary Executive Vice President and General flanager 2001 Bryan Tower Dallas, Texas - 75201 Gentlemen: . This refers to the inspection conducted by Mr. R. C. Stewart and other members of our staff during the period November 28 - Decerber 2,1977, of activities authorized by NRC Construction Permit Nos. CPPR-126 and 127 for the Comanche Peak facility, Units No..1 and 2, and to the discussion of our findings with Mr. J. B. George and other members of your staff at the conclusion of the inspection.

  • t Areas examined during the inspection and our findings are discussed in the
          - encicsed insoection report. Within these areas, the inspection consisted of selective examination of proce,dures and representative records, interviews a

with personnel, and observations by the inspectors. t j Within the scope of the inspection, no items of-noncompliance were identified.

  !         One new unresolved item is identified in paragraph 7 of the enclosed report.

J In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,. Title 10, Code. of Federal Regulations, a copy of this letter and the enclosed , inspection report will be placed in the NRC's Public Document Room. If the report contains any information that you believe to be proprietary, it is of the date of- this letter, requesting that such information be withhe public disclosure. The application must include a full statement of the ' reasons why it is claimed that the information is proprietary. The application should be prepared so that any proprietary inforcation identified is contained 1 I

j .- 2 Texas Utili-ies Generating Company December 20, 1977 in an-enclosure-to the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in i this regard within the specified period, the report will be placed in the public Document Room. Should you discuss themhave withar;y you.questions concernin,g this inspection, we will be pleased to Sincerely, o /

                                          -                             f                  e 4
                                                                                 . i.w .        N W. C. Seidl'e, Chief Reactor Co'nstruction and                                       i i

Engineering Support Branch-  :

Enclosure:

IE Inspection Report No. 50-445/77-13 50-446/.77-13 '

  • cc: w/ enclosure ~ b Texai Utilities Generating Company j . ATTN: Mr.. H. C. Schmidt, Project Manager .

i 2001 Bryan Tower .e

Dallas, Texas 75201 4

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                                     ~

U. S. NUCLEAR REGULATORY COFMISSION OFFICE OF INSPECTION AND E?!FORCEMEtlT

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REGION IV Report rio. 50-445/77-13; 50-446/77-13 Docket No. 50-445; 50-446 Category AZ Licensee: Texas Utilities Generating Company 2001 Bryan Tower . Dallas, Texas 75201 Facility Name: Comanche Peak, Units 1 & 2 Inspection at: Comanche Peak Site, Glen Rose, Texas Inspection conducted: November 28 - December 2, lo77 1 O /} 2 Inspectors: ,( g .S_ Yo --e /2.[yo/77 R. C. StewartireaMar) Inspector, PVojects Section Da t'e / (Paragraphs 1, 2, 3, 4, 9 & 10)

                                                                                       =:

W. G. Hubacek, Reactor Inspector, Projects Section

                                                                                                                  / Eft <>/77 Date (Paragraphs 5 & 6)

R. A. Hermann, Reactor Inspector, Engineering Support Date Section (Paragraphs 7 & 8) L. D. Gilbert, Reactor Inspector, Engineering Support

                                                                                                                   /t/1.cb7 Date /

Section (Paragraphs 7 & 8) Other Accompanying Personnel: R. E. Hall, Chief. Engineering Support Section (November 30 and December 2, 1977) Approved: [ /7/10/77 W. A. Crossman, Chief, Projects Section Date

                                                                                                                   / L-f2. 7)

R. E. Hall, Chief. Engineering Support Section Date - ! O

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Inspection Summary Inspection on "ovember 28 - December 2,1977 (Recort No. 50-445/77-13; e 50 U6/77-13)- Areas inspected: Routine, unannounced inspection involving observation of work performance and record review of dome liner and fuel pook liner fabrication; follow on review of safety related piping shop and field fabrication; observation of work performan_ce-and record review of the installatien of the reactor coolant system ' component supports, review , * .- of the QA program implementing procedures for electrical and instrur.ent cables and terminations; and independent reviews concerning construction deficiencies for which the licensee h1s submitted reports in accordance

                     .with 50.55(e). The inspection involved one hundred thirty-nine inspector-                 !'

hours on site by four flRC inspectors. Results: flo items of noncompliance or deviations were identified. 4 e

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  • DETAILS 2,
1. Persons Centacted -

Principal Licensee Emoloyees

                                     *J. B. George, TUSI, Nuclear Construction Manager
                                     *D. N. Chapman, TUGCO, QA Manager
                                     *R. G. Tolson, TUGCO. Site QA Supervisor
                                     *J. T. Merritt, TUSI, Resident Manager
                         -           *C. L. Biggs, TUGCO, QA Lead Eng'ineer        -

R. V. Fleck, TUGC0/G&H, Site QA Supervisor ,

,                                     J. V. Hawkins, TUGCO/G&H, Site QA Representative                                                                     ,

! *D. E. Deviney TUGCO, QA Technician - Other Personnel

                                     *H. O. Kirkland, B&R, Project General'Hanager H. C. Dodd, B&R, Project Manager
                                     *U. D. Douglas, B&R, Assistant Project Manager
                                     *P. L. Bussolini, B&R, Project QA Manager                            -

J. P. Clarke, B&R, Senior QC Engineer j *J. J. Moorhead, G&H, Resident Engineer , The inspectors also interviewed other contractor employees during the l course of the inspection. They included B&R field engineers, B&R QC j inspectors and B&R construction personnel.

  • denotes those present at the exit interview.
2. Licensee Action on Previous Inspection Findings 4

(0 pen) Noncompliance (50-445/77-10; 50-446/77-10): Failure to Remove Weld Surface Defect Prior to Final Acceptance. The licensee's written response, dated November 17, 1977, did not reflect audits. and/or sur-4 I veillance activities being implemented to prevent recurrence of this ! item. This matter remains open pending IE review of supplemental ' l infonration to be provided by the licensee. I

   *                                 (0 pen) Noncompliance (50'-445/77-10; 50-446/77-10): Failure to Provide Welding Procedures at the Location Where the Prescribed Activity is                                                      i i

Performed. The licensee's written response, dated November 17, 1977, did not reflect audits and/or surveillance activities being implemented to prevent recurrence of this item. This matter remains open pending IE review of supplemental information to be provided by the licensee. i Il i j l I

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(Closed) Unresolved Item (50-445/77-11; 50-446/77-11): Indication of an Uncontrolled Welding Design Change. Curing this inspection, the IE - inspector reviewed B&R inter-office memo (TSV-00B7), dated November 30, 1977, which documents the corrective actions initiated to resolve this - matter. The inspector had no further questions regarding this item.

3. Potential Construction Deficiency - Vendor Sucolied Steel Embeds On November 23, 1977, the licensee reported by telephone that tNe site . ,

construction staff discovered that "B" series Cadweld sleeves were welded to eight steel plate embedments in reversed orientation.

                      . During this inspection, the IE inspector reviewed the current status of this discrepancy and found .that the specific steel embeds had not been embedded in concrete and corrective measures were initiated; however, due to insufficient information at this tirre, the question of similar conditions of reversed crientation of "B" series Cadwelds on previously installed embeds can not be answered until an on-going review and evaluation is completed. This matter remains unresolved.
4. Allegation of poor Workmanship The licensee informed the NRC, Region IV office on November 23,1977, by telephone, of a call on November 22, 1977, from an unidentified woman who was apparently concerned with the workmanship at the site regarding the use of "rotofoam" as a temporary spacer being utilized in construction in maintaining the required air space between Category I seiscic structures.

During this inspection, the IE inspector reviewed the subject allegation and found that contrary to the woman's belief, all temporary "rotofoam" blocks have been removed from the subject areas. The B&R-staff have initiated an inspection and docurentation progr.QA/QC inspection am to assure that the required 1" gap between Category I seismic structures is bei,ng maintained in the as-built condition. This matter will remain open pending IE review of the QA/QC inspection results. '

5. Review of 0A Manual provisions for Electrical Construction Activities The inspector reviewed the Brown & Root QA manual to ascertain whether appropriate and adequate procedures were provided to assure that activities related to electrical cables and terminations and electrical components are controlled in accordance with NRC requirements and licensee commitments.

The following procedures and specifications were reviewed: . ACP-3, " Material Receiving Storage and Handling" QCP-1,1, "QC Receiving Inspection" QCP-l.2, "QC Surveillance of Storage, Warehousing and Control" QCP-1.6, "QC Surveillance of Mechanical, Electrical and Instrumen-tation Equipment" 1

a ] QCI-l.6-ll, " Safety. Related Mechanical and Electrical ' Equipment Storage Maintenance" , QCI-1.1-ll, " Receiving Inspection for TUSI/GaH Procured Safety f Related Equipment"

MCP-10. " Storage and Storage Maintenance of Mechanical and Electrical Equipment" j '

ECP-10. " Cable Tray and Hangers" - 1-ECP-19. " Exposed Conduit arid Hangers" ~ Specification No. 2323-ES-100 " Electrical Erection Specification" Specification No. 2323-ES-19. " Cable Tray Specification" } The inspector noted that several work and inspection procedures related j to electrical construction activities are being developed and will be issued in the future. These procedures will be reviewed during subsequent inspections.' _ i No items of noncunpliance or deviations were identified. ] . 6. Electrical Cable and Equipment Storace i i The inspector observed storage of electrical cable which was stored at i the site. Reels of electrical cable were stored outdoors on a concrete pad. The inspector noted-that several QC tags attached to cable reels-

                       - were' becoming faded from exposure to weather and were difficult to read.

A licensee representative stated that new weather-resistant. tags were being procured to replace the faded tags. The inspector also observed storage of several items of electrical equip-ment which were located in warehouses. These items included: three con-tainment spray pump motors, one component cooling water pump motor, two safety inje'etion pumps,'and two motor operated valves. 1 The inspector reviewed receiving records for electrical cable and equip-ment maintenance records for one containment spray pump and two motor j , operated valves. * , No items of noncompliance or deviations here identified. - 1 ! 7. Safety Related Structures f l a. Review of OA Implementing procedures j The inspector reviewed the program for the fabrication, erection, welding and inspection of the stainless steel liners for the

. refueling cavity, transfer canal, spent fuel, storage and cask f

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                                                                                                                                                                       -                                                                                                                     .. -                           -.                         =               _. __ .
                                                                                                                                                                                -s                                                                                                         _

i J loading pits to ascertain if the commitments stated in the PSAR and Gibbs & Hill (G&H) specification 2323-SS-18, Rev. 2 were being implemented. The inspector reviewed Brown & Root (B&R) construction procedure 35-1195-CCP-38, " Stainless Steel Liner . Erections," and B&R QA procedures CP-QCP-2.11. " Inspection of Stainlasr Steel Pool Liner Systems," and CP-QCI-2.ll-1, " Weld  ! Inspection. and Fit-Up of Stainless Steel Liners," to ascertain

                                           '                                                                                                                       if the above stated requirements had' been implemented. Additional QA and work procedures in the areas of weld expendable material                                                                                                                                               ..

contrr,1, welder and weld procedure qualification, NDE and welding ' survoillance were reviewed ,to assess control of these activities. No items of noncompliance or deviations.were identified.

b. Observation of Work Activities (1) Stainless Steel Liners i

The welding of fillet joints for the attachment of leak chase channels and of tacks for the attachment cf backing bars for

;                                                                                                                                                                         the butt weld seams for stainless steel liners was inspected.

Weld procedures and welders were found qualified in accordance with the requirements of the ASME B&PV Code, Section IX. The welding was performed in accordance with WPSs 99020 and 88023

                                                                                                                                                                -         and placed as specified by B&R drawing WRB-10559. Work and inspection activities were performed as prescribed by the procedures discussed in the previous section.                                                                                                 -

Ho items of. noncompliance or deviations were. identified. (2) Reactor Coolant System Component Sucports_ ,

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A limited inspection of the Vertical Columns - C1 as shcwn ' j and described on Westinghouse drawings 1457F2S and 1457F27 i was performed in the site storage yard. The inspector reviewed the PSAR and Westinghouse specification G-952628, i Rev.1. " Fabrication Requirements For the Reactor Coolant i System Component Supports," and. determined the vertical column fabrication requirements were ASME B&PV Code, 1 Section III, Div.1, NF,1974 edition as a minimum. The

inspector was unable to find any documentation in the preliminary data package and certificates of conformance .

or on the components that the articles were fabricated in . accordance with ASME III, NF and that volumetric inspection 4 of the full penetration welds had been performed as prescribed ! by,ASME III, NF, paragraph NF-5212. The licensee is obtaining the complete data package for these items to determine if the " items were fabricated and inspected as prescribed. This item is considered unresolved. I _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ . _ _ . - ______._.___.______.-._.__.m _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ . _ _ . _ _ _._.______...______m. . _ - _ _ _ _ _ _ . _ . _ _ _ _ . _ _

S E i

                                                                      - B. Sa fety Related Pipina (Welding)                                                                                                                                                 '

The inspector observed the welding in the pipe shop of weld #2, 4"-pipe to fitting , SF-l-151R-3 per HPS 88023, Rev. 2. The welders and welding procedure were qualified in accordance with the ASME B&PV Code'. Section' IX. Weld technique, parameters, gases and expendable materials were as prescribed by the WPS. Inspections were as prescribed by B&R QCP-3.4 as noted on Weld Data Card 00893. The inspector reviewed the radiographs of welds 2 and 3, 24"-CC-1-AB-12, componen.t cooling line. The radiography was performed in accordance with procedure CP-NDEP-101, "Radiogra'phic Examination (Piping)," which complies with the requirements of ASME B&PV Code, Sections III and V,1974 edition including Summer 1974 Addenda. The inspector reviewed twelve original radiographs and radiographs of repairs as required. No items of noncompliance or deviations were identified.

9. Unreso1'edv Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. The following item was disclosed during this inspection re-garding fabrication and inspection of reactor coolant system component supports:

Identifier Title Reference

                                                                                                                                                                                                                                       ~

77-13-1

                                                                                    '~

Adequacy of the fabrication and Pa'ragraph 7.b.(2) inspection of reactor coolant system component supports

10. Exit Interview The inspectors met with the licensee representatives (denoted in paragraph
1) at the conclusion of the inspection on December 2,1977. The inspectors summarized the purpose and the scope of the inspection and the findings.

The licensee representatives acknowledged the unresolved item (paragraph 7.b.(2)) concerning lack of documentation regarding the fabrication of the reactor coolant system component supports.

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           %,,y - @ij'[                          611 flYAN PLAZA oRIVE, SUITE 1000 s    ARLINGTON, TEXAS 7G012 In Reply Refer To:

July 2,1979 RIV Docket No. 50-445/Rpt. 79-15 ' 50-446/Rpt. 79-15 - Texas Utilities Generating Company ATTN; Mr. R. J. Gary, Executive Vice President and General Manager 2001 3ryan Tower Dallas, Texas 75201 Gentlemen: This refers to the investigation conducted by Messrs. R. G. Taylor and W. A. Crossman of our staff on May 29 through June 4,1979, of activities authorised by NRC Construction Permits No. CPPR-126 and 127 for the Comanche Peakemployee. Peak facility, Units No.1 and 2, concerning allegations by a former Comanche The investigation and our findings are discussed in the enclosed investigation report. . No items of noncompliance or deviations were identified. Even though no items of noncoupliance with NRC require =ents were identified during this investigation, we did find that true. the allegations vere essentially We also noted during this investigation that a thread of continuity existed between this investigation and others recently conducted relative to alleged problems with site canagement and quality control in certain areas of construction. Although ue feel that the major organizational changes you made in January 1978 have strengthened the QA/QC program at Comanche Peak, we cannot ignorebractices. construction the fact that we are continuing to receive allegations concerning Taken individually these allegations, some of which have been substantiated, do not appear to have any significant adverse impact en the conformance of your plant to NRC commitments. in our meeting with you and Mr. Fikar, in our office on Jun2However, as1979,'uhen 22, we discussed

     .       these allegations are taken collectively, there appears to be a morale problem
hich is evidenced by several of the allegers and may be attributable , in part, to co==unication problens between the workers and supervision. In cur June 22 ceeting, you indicated that you would look into these apparent ec =unication problems along with the adequacy of QA/QC indoctrination of plant supervision ucaknesses anddetect that you workers and take in these appropriate action to correct any areas.

cis sel-/ during subsequent inspections. Pe intend to follow this matter A

t Texas Utilities Generating Company July 2, 1979 In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of'this letter and the enclosed investigation report will be placed in the NRC's Public Document Room. If the

         '              report contains any information that you believe to be proprietary, it is necessary that you submit a teritten application to this office, within 20 days of the date of this letter, requesting that such information be withheld from l                        public disclosute.

The. application must include a full state =ent of the reasons why it is claimed that the information is proprietary. The application should be prepared so that any proprietary infor=ation identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Docu=ent Room., If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. Should you have 'any questions concerning this investigation, we will be pleased to discuss then with you. Sincerely, W. C. Seidl Chief Reactor Construction and Engineering Support Branch

Enclosure:

II Investigation Report No. 50-445/79-15 50-445/79-15 4 cc: u/ enclosure Texas Utilities Generating Company ATTN: Mr. H. C. Schmidt, Project Manager 2001 Bryan Tower Dallas, Texas 75201 i i ' ~ i I

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U. S. NUCLEAR REGULATORY CO.TIISSION '

                 -.                          OFFICE OF INSPECTION AT. O ENFORCDfENT REGION IV Report No. 50-445/79-15; 50-446/79-15 Docket No. 50-445; 50-446                                           Category A2 Licensee:         Texas Utilities Generating Company
                            . 2001 Bryan Tower Dallas, Texas         75201.

Faciitty Name: Comanche Peak, Units 1 & 2 Investigation at: Cc=anche Peak Steam Electric Station, Glen Rose, Tens Investigation conducted: May 29 through June 4, 1979 Inspectors: -

                              ,  R. G. Taylor, Reactor Resident Inspector, Project Sections G[2/[75 Date ev                  '
                       ..        W. A. Cross =an, Chief, Projects Section                         6[Z/ h .

Date Approved: WN +7-G[2 / b - W. A. Crossman, Chief, Proj ects Section Date . Investigation Su nary: - Investigation on May 29 through June 4, 1979 (Recort No. 50-445/79-15; 50-466/79-15) Areas Investi::ated: Special investigation of allegation received regarding improper and potentially very poor welding of inter-place seans in the Unit 1 Refueling Fuel Handling Pool, spent fuel pools, and transfer canal of the common facility Euilding. The investigation involved twenty-eight inspector-hours by the Reactor Resident Inspector (RRI) and the Chief, Projects Section.

  ..       Results: The alle3ations vere neither specifically confirmed nor refuted.

The allegations, if confir=ed, would have no safety significance. No items of nonec=pliance or deviations were identified. l 1

                    ,J
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l . . INTRODUCTION 1 Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 are under construction in Somervell County, Texas, near the town of Glen Rose, Texas. Texas Utilities Generating Company is the Construction Permit holder with Broun and Root, Inc. as the constructor and Gibbs and Hill, Inc. as the Architect / Engineer. . REASON FOR THE INVESTIGATION The Region IV Reactor Construction and Engineering Support Branch received a telephone call from a former'CPSES employee who reported several allegations indicating a pctential breakdown in the CPSES Quality Assurance program and a possible threat to the health and safety of the public. The substance of the allegations also appeared in an edition of the Fort Worth Star-Telegram published on May 30, 1979.

SUMMARY

OF FACTS The Region IV Reactor Construction and Engineering Support Branch received a telephone call on May 25, 1979, from a party who identified himself as a former CPS'ES employe~e who had worked as a Boilermaker welder. The call was taken jointly by the Branch Chief and the Section Chiefs of the Projects Section ~and the Engineering Support Section who in turn provided the infor-cation to the ~a ssigned Resident Reactor Inspector at CPSES on May 29, 1979. The allegations were reviewed with the alleger in an interview which took place on May 30, 1979, at his home. Each of the following allegations relate to welding of stainless steel liners in the Unit 1 Reactor Containment Building or in the common Fuel Handling Building:

1. Allegation No. 11/

Welding and weld repcirs on the liners were difficult because water fro:a concreting activities had run down the leak chase channels and out past the baching strip into the weld area. Welds finally completed were very poor; some velds had been slugged with weld rod and others were so.thir that if buffed a second time with' 120 grit, they would not have passed

 ,,              PT (Penetrant Test).
2. Alle2ation No. 2 There are problems with the gate guide (refers to a gate in the Reactor Containment separating the refueling pool f r.;;n a s aill storage pool and the transfer canal).

p.- r.1:enen .s . ov a rr- tha allegaticas as receited. Cl a ri fi ca t i:nn r.M :. i':e i jtc the alleger durin3 the interview of :!ay 30, IM9, are indicated by p4r. 4:!.u. .

a. The gate guide between the large and small pool was welded in the shop. When the gate guide was installed in the pit, the end bevel was cut off so it could be fit-up. When the guide was installed, it was3/16" only not rebeveled and made.

fillet veld was where a fillet weld of 3/8" was required,

b. The gate guide had to be welded to both sides of the liner. When
      -                welding   the back side, the welder had to crawl down between.the rebar to get to the weld.

The position was so crowded that the welder could not make a good weld. Also, the welder couldn't see what he was welding very well. c. Six inches of the chase channels were lef t off the gate guide and added after the gate guide was installed. The rebar was so thick in the areas where welding was performed that "you could hardly get your finger through, much less the welding torch." Consequently, the welds were not'made properly.

3. Allegation No. 3 Welders have no experience.

make a test veld. They finally They spend as much as 80 hours trying to learn how to make a weld that wi.1 pass the qualifying test what they're doing. and then when they get into the field they do.1't know

4. Allegation No. 4 There is " lots" of QC coverup. QC is " buying-off" on welds over the phone.

One-QC inspector bought off a seam before he ever saw the seam and it was not a good weld because water was coming through while the veld was being made. atory to(The buy-off involved was joint preparation and cleanliness prepar-welding).

5. Allegation No. 5 Brown and' Root is not following procedures in welding the liner plate.

(The procedures referred to are welding procedures and specifically refer i to use of up-hand required a down-hand welding technique being used versus the procedurally technique).

6. Allegation ro. 6
    -          Some of the tcp seams 18" above water level on the fuel pool had backing strips tack welded to the liner plate. There are places where the plate did not cover the backing strip. H.e would           not guarantee the weld. The veld was probably 60% rust, air, concrete, etc.

D 4 CONCLUSIONS Review of the CPSES Final Safety Analysis Report, Project Specifications and Engineering Drawings, as they pertain to the liner fabrication and 3.ustallation, . have led oftoFacts Summary the following above. conclusions relative to each allegation stated in the considerations are necessary:To better understand these conclusions, the following The liner systems are not installed to prevent or mitigate the conse-quences of any of the postulated design basis accidents, but rather are installed to prevent an excessive burden on the liquid waste collection and disposal syst6m and to allow the wall and floor area to be more easily decontaminated after pool usage. The liners as a functioning element are, therefore, not considered safety related and are not normally inc.luded in the NRC inspection program. The liners, as passive elements and parts of the building structure, are usually classified into seismic Category I since if one or more of the liner plates were to become detached from the wall, serious damage could be done to stored fuel assemblies. The plates are,

               . therefore, secured to the concrete supporting structure with a system of weld studs attached to the back of the plate and embedded into the
                   <oncrete.
     .                            The weld stud system is not a factor in these allegations.
1. Allegatio'n No.1 The RRI, based on the interview with the alleger and with other welders,

__.. has.become reasonably sure that there were difficulties encountered by the welders with water, moisture and in some instances with concrete on the weld surfaces and that in some instances, the welds may not be com-pletely sound internally. These welds, however, serve no strength purpose and need only to be smooth and leak free, factors which are established by visual inspection, dye penetrant examinations, and by vacuum box tests of the joint after it is complete. The allegation, while probably true, has no safety consequence.

2. Allegations No. 2.a, b, & c These collective allegations, while probably true in a substantial sense, also have no safety consequence. The veld joints in. question only need to case be of smooth
c. The and leak free in the- case of a. and b. and leak free 'in the welds do not serve to lend strength to the .=tructure.
3. Allecation No. 3 The project specifications for all welding, including the pool liners, require that velders be qualified under the requirements of the American Society of Mechancial Engineers, Boiler and Pressure '.*essel Code, Section IX or a comparable requirement such as those of the American k'elding Society. Section IX of the ASME requires that a werder must perform a weld process involved and the as-welded coupon must pass specified tests when ccaplete. No time limits are specified or implied as a requirement in Section IX for making the qualification test coupon weld.

The RRI has verified previously that'the site welder qualification pro-gram is in full compliance with Section IX.

4. Allegation No. 4
                 'The RRI' examined the circumstances surrounding the specific portion of the   allegation and discussed the matter with the QC inspector directly involved. It appears that this man, on occasion, was depending on the inspections performed by a fellow inspector and so recorded on the
                  ' appropriate weld data card. The joint was cov'ered over with tape after it had been inspected for cleanliness and fit-up and the inspector re-leased it over t.ne phone based on the record card entries. Water in the leak chase channels appears to have been a constant problem. 'The QC inspector may have made a judgement error in not re-examining the joint, but  nottime.

at that withstanding, the joint had been inspected and found satisfactory because of theThe lackREI did not investigate the alleged " lots" of QC coverup of specifics.

5. Alle2ation No. 5 As noted in the Summary of Facts, the general allegation of failing to follow procedures was subsequently refined in the interview with the alleger to relate specifically to an occasion where the alleger was directed by his supervision to weld down-hand rather than up-hand as required by the welding procedures.

ASME Section IX indicates that such a change. is in the category of a non-essential variable and, therefore,

             , is not a prohibited change in the procedure, if recorded. It appears                  ,

that the change was not recorded. Interviews with other welders on the sa ae activity failed to reveal any similar experiences and supervision has denied directing the alleger to perform out-of procedure. The RRI, there-fore, has no mechanism by which to confirm the allegation. Again, assuming that the alleger did weld down-hand instead of up-hand for whatever reason, the consequences of such an action are essentially meaningless as related  ; to a weld, since such a change has no effect on the finished weld of the type involved. l

6. Alle2ation No. 6 The particular welds in question are even less consequential than the other

' seam welds in a functional sense. These welds, which are above the water line of in the easy pools, do not need to be leak free, just smooth for the' purposes decontaminat'.n. quence. The allegation, while perhaps true, has no conse-

                                          ' w,                                                                                               -

DETAILS

1. Feysens contacted Alleger The alleger, hereaf ter identified as Individual "A," is a former employee x

b of Brown and Root, Inc. (the site general contractor). The person iden-tified himself as a for=er welder assigned to the millwright / boilermaker s unit of the construction force. Principal Licensee Emoloyee Site Quality Assurance Supervisor ' Brown and Root, Inc. Project Construction Manager Milluright/ Boilermaker Superintendent Individual "B," a welder currently working as a pipefitter but who was a Boilermaker

                                                  ,                  Individual                                                                "C," a welder currently working as a pipefitter but Oho was a Boilermaker Individual                                                                "D,"

a quality control inspector who was assigned to inspection

                                .                                                        of pool liners
2. Backtround of Allegations Individual "A" contacted the Region IV of fice at approximately 9:25 a.m.

on Friday, May 25, 1979, to express concerns about the welding activities which had taken place on the spent fuel pools, cask loading pool and the transfer canal in the com=on Fuel Handling Building for both Units as well as that work accomplished in the Unit 1 refueling pool and temporary stora3e pool installed in the Reactor Containment Building. The RRI was notified of these allegations on Tuesday, May 29,1979, (May 28 a holiday) and initiated an immediate investigation. The first point of contact was the licensee's site Quality Assurance supervisor who informed the RRI that he was aware of the allegations, since his company had been apprised of them by a newspaper reporter e= ployed by the Fort Worth Star-Telegram. The site supervisor also infor=ed the RRI that another welder, Individual "B," had expressed similar concerns to the Project Construction Manager

                                                             'on May 23, 1979, and that concerns had been forwarded to site Quality                                                     s Assurance for investigation. The RHI was provided an informal memorandum giving the results of the investigation dated May 23, 1979.

t

e. .

h t

Individual "A" also contacted the Project Construction Manager on May 24, 1979, and expressed Individual "B" and which essentially the same concerns as those expressed by May 25, 1979. in turn he expressed to the Region IV office ~on It appears that Individual "A" and his supervision, up through of the Project disagreement andConstruction Individual Manager, had reached a substantial point . at the site as of May 24,~1979. "A" voluntarily terminated his employment The voluntary termination ds a matter of record in Individual "A's" employment file.

3. Investigation The RRI initiated the site phase of the investigation by extensively
                     . reviewing the CPSES Final Safety Analysis Repnrt in order to ascertain the safety classification of the various pools and pool liners involved in the allegation and to review the functional descriptions. Reference to Section 3.2, " Classification of Structures, Components and Systems,"

in the FSAR does not indicate the liners as being safety related although the buildings in which they exist are shown to be in seis=ic Category I. Paragraph 3.8.3.7.1 provided a commitment to test the liner seams via a vacuumthe behind boxliner for seams. leak tightness and briefly described a leak chase system Paragraph 3.8.4.1.3 provided a brief additional description of the function of the liners. Figures 9.3-9 and 11.2-4 revealed that the extensive leak chase system has lead-out piping which leads to a building sump and hence into the liquid radioactive waste collection and disposal system. The RRI then obtained Project Specification 2323-SS-18, Revision 3,

                     " Stainless Steel liners," to ascertain what requirements the design engineer had established for the liners. The RRI noted the following significant items from the specification:

a. The design engineer invoked the general quality assurance requirements of 10 CFR 50, Appendix B on the fabrication and installation work. b. The design engineer provided three full pages of detail requirements relative to the system of studs to be welded to the reverse or concrete backed side of the liners. c. The design engineer made reference to the inter plate seam welds only by requiring ASME, Section that IX. the welding procedures and welders be qualified to Criteria for finished welds require that, " Surfaces of all welds shall be smooth and free of any irregularities such as

 .                          serrations, ridges, crevices, or pinholes which may make it subsequently difficult to achieve an effective washdown of the liner surface." Under testing the design engineer provided the following, "All seam uelds                ;

shall lenth." also be tested by vacuum box for leak, tightness for their entire  ; No other quality requirements were imposed on the seam welds. I

d.

                    -           The RRI then obtained the design engineer's drawings S-0831 through S-0834, SI-0560, MI-0581, all of which provide' details of liner fabrication and installation. In addition, the RRI obtained vendor design detail drawings for the gate guide installed in the Containment Building between the refueling pool and the temporary storage pool.

These drawings, taken collectively, showed that the design engineer had designed a system wherein the liner plates and the gate guide would be supported by and anchored to the surroanding concrete walls by a very extensive system of "T" headed sides of the plates and gate guide frame. studs. welded to the concrete The seam welds are entirely from plate-to-plate and provide no attachment into the basic building structure. The RRI concluded on the basis of the above information that the liner system in the had been designed such that resistance to seismic effect was vested "T" headed stud installation and that the seam kelds were necessary only to provide a very low leakage path for the pool water and that what leakage of might occur would be drained to an appropriately designed method disposal. The RRI interviewed Individual "A" on May 30, 1979, in conjunction with the

  • Region IV Reactor Construction and Engineering Branch, Projects Section ~

Chief, in order to gain additional information relative to each of the allegations received over the telephone on May 25, 1979. The additional information and clarifications were as noted in the Summary of Facts included in this report. In addition, Individual "A" acknowledged that he had only very recently become aware that the stud system existed for holdihg the plates in place' and was, in fact, unaware that the leak

         ---          chase channels were piped to a collection point for controlled collection and dispos'al of any leakage which might occur.

The RRI interviewed Individual "B" in the presence of the licensee's site QA supervisor, also on May 30, 1979. (This arrangment was allowed since Individual "B" only came to the attention of the RRI through the assistance of the licensee's representative.) The allegations of Individual "A" were reviewed in detail with Individual "B" who essentially confirmed Allegations 1, 3 and 6, but indicated he had not worked in the Allegation 2 area and further indicated that he had no complaints about lack of effective QC nor had he been instructed not to follow welding procedures. The RRI interviewed Individual "C" on May 31, 1979, with the same results as those obtained in the interview with Individual "B." Individual "C" indicated that he perhaps was one' of the persons referred to by Individual "A" in Allegation 3. He also indicated that he had very limited welding experience before coming to work at CPSES and none in "Heliarc" weld process. He vas given some forty hours of very informal training and then used fifty-t<o hours to make his weld test coupon, a duration that he now considers to be excessive. He now thinks that he is a good welder.

                                                            -S-

The RRI interviewed Individual "D" on May 30, 1979,'and again' June 1, 1979, to develop any facts relative to the specific allegation of " buying-off" joints over the phone. Individual "D" categorically denied that he, or to his knowledge any other QC inspector assigned to this work area, had ever

             " bought-off" a designated inspection point without making the required inspection. On June 1,1979, Individual "D" indicated that there had been very few occasions when he had given consent to the welders to weld up a seam that, by the inspection reports, had been previously inspected for fit-up and cleanliness. He also indicated that he and others had repeatedly stopped work on welding of seams where it came to their attention that water or moisture,was interfering with good welding.                                 l The RRI interviewed the Boil'rmaker Superintendent on June 4, 1979, relative
            'to his knowledge and/or participation in any of the allegations. ' He cate-gorically denied ever directing welders to make welds where water or moisture was present, but acknowledged that it was a constant problem. He indicated that he finally received engineering permission to drill holes through the liner at the ends of the leak chase. channels so that air could be blown through to dry out the channels and that this action helped a great deal.

He indicated that he had continuely attempted to impress the welders with the importance of making good seam welds. ,

4. RRI's Assessment of the Liners The RRI observed some of the welding work on the refueling pool in the Unit No.1 containment during the latter part of 1978 and the early part of 1979 incidental to making inspection of other activities in the same work area.  !

The welding appeared to be normal and the dye penetrant examinations appeared to be properly accomplished. The finished surfaces examined have been uni-for~cily smooth and appear sound. The RRI also examined some unfinished areas in the Unit 2 spent fuel pool and can appreciate the difficulties that may be encountered in removing some of the concrete laitance from the vertical weld jaint areas. l l 4 9

4 20574 4 i 1 November 21, 1984 . i h' '- UNITED STATES OF AMERICA I 1

  • NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

s

                                                                                     }                                     .
,                                    TEXAS UTILITIES GENERATING                     )

COM PANY, et al. Docket Nos. 50-445-2 and i .

                                                         ~~                         )                     50-446-2
                                                                                    )

(Comanche Peak Steam Electric ) (Application for ' . Station, Units 1 and 2) _) i Operating Licenses) ) PREFILED TESTIMONY OF C. THOMAS BRANDT REGARDING CASE'S sFURTHER " EVIDENCE" OF A QUALITY CONTROL -

                                              .         BREAKDOWN IN THE CONSTRUCTION, INSTALLATION AND INSPECTION OF THE STAINLESS STEEL PLATE                        LINER Ql.        ,Mr. Brandt,
        '-                                                     have you had an opportunity to review the memo-
                       ~ "  '

randum concerning the stainless steel liner plate

                                                    ~

filed b'y the Citizens Association 'for Sound Energy on November 15 , 19847 l a A1. Yes. ' Q2. Mr. Brandt, directing your attention to. page tEo of that i memorandum, CASE contends that applicants incorrectly assert that the' liner plate is not sa fety-related. Do you i see that passage? A2. Yes. It is set out in the first three paragraphs, on the page. 03. Is that contention correct? 4 f O. f sig e , y -ea w4 . - ee- --,,,.-e----

  • y y--.--

. 20575 , "A3. No. CASE's contention shows a lack of understanding of my testimony and the procedures applicable' to the fabrication r '. ,..

 .-                           and installation of the stainless steel liner plate. As I testified before, the fabrication and installation of the stainless steel liner have been designated safety-related                           r activities by the architect engineer. I eould like to note
                      -                                                                                          g my testimony on this. point appears at page 45,315 of the
                                                                       ~
                        ~

transcript of this proceeding. Therefore, CASE is factu-ally incorrect w' hen it asserts that applicants have testi- 'I fled that the liner plate is not safety related. What I

                                                                                              ~

testified to, and what CASE appears not to understand,- is that the welds in question are non-structural; this point is different from, and unrelated to, the fact that the [ fabrication and installation of the liner plate are _ _ , , _,,,, safety-related activities. The significance of the welds being non-structural is that the architect-engineer did not impose stringent- I L requirements such as those imposed by the ASME code, for the fabrication, installation, inspection and testing of the liner and the welding associated with these activities. The architect-engineer's only concern was that_the . elds I 3 not leak. Accordingly, welding on the liner place is not \ now, nor ha's it even been, under the jurisdiction of the

      .                   ASME Code.

only two matters. remotely tie the liner plate to ASME activities, but { neither of these matters' apply ASME fabri-cation and installation requirements to the-liner plate. J

                                                                              ~

l

 ,,          ,                                                   ~3~

20576 First, the specification for the liner plate requires that welders who work on, and welding procedures used in connec-() tion with, the liner plate be qua'lified in accordance with

         .                         Section IX of the ASME Code.      This Section, however, is limited to the qualifications of procedures and welders, and it is not a fabrication code. Accordingly, the Code's fabrication requirements simply do not apply to the liner plate.

Second, as an administrative matter, the inspection group originally assigned to perform these inspections was the ASME group. In February 1982, responsibility for these inspections was transferred to the non-ASME inspection group; this transfer was also an administrative matter. Again, I want to emphasize that these assignments-were

                               .Qnrelated to the applicability of the ASME Code require-ments to the fabrication and installation of the liner p la 't e .                                         -
04. Mr. Brandt, directing your attention to pages ' two and three of CASE 's memorandum, CASE asserts that the correct traveler form.was used for weld no. 988, and that you either were wrong in testifying that all travelers were initiated on the wrong form or that you knew that some travelers were initiated'on the correct form and your testimony aas deceptive. Do you see these allegations?

A4. Yes, I do. C5. Is CASE correct? } V

20577 ( AS. No. First, my testimony was that I could find no evidence that the correct traveler form was esed before April 18, . ('e-1979. My review of the travelers in11 cates that the cor-- rect form was used after that date. Second, all of my testimony, as I have stated several times, is limited to the travelers for the Unit 2 refueling cavity, which is located inside the Unit 2 reactor buiiding. All thirteen hundred travelers at+ issue in this proceeding are for that cavity. I would like to point out that I made tf.is point on pages 15,921-923, 15,927 of the transcript of this pro-ceeding. Traveller 988 cited by CASE is not for a w' eld in this cavity. I-t is for a weld in the Unic 2 fuel transfer canal, which is located inside the fuel building. This is ( , not only a completely different cavity; it is for a cavity f

                           . located in a completely different building. Thus, CASE's allegation is pr'emised on a , traveler that was not     even j

included in the travelers that were.the subject of my testimony. -

06. Directing your attention to page 3 of Exhibit I to CASE's memorandum, CASE alleges that certain welds lack QC veri-fication of the fit-up and cleanliness of the outside 1

welds. In support of this allegation, CASE identifies a total of 147 welds which it claims lack QC verification of the fit-up and cleanliness of outside welds. Do you see those. allegations? ~ A6. Ye s I do. i 07 F. ave you reviewed the travelers for these welds? A7. Yes.

i 20578

                                .Q8.

What were the results of your review? AB. In each instance. I found that g~g there was either a chit

      \; ...

and/or a traveler documenting QC verification of theup fit _ - and cleanliness of the outside weld. Accordingly, CASE's allegation is

      ~                                                        factually wrong.
                          ' 09.

CASE asserts on page three of Exhibit 1, "it is evident t that the chits (attached to the 147 travelers] ere not w intended to verify step 1, but was [ sic] intended t o verify Step 3 and/or 2 only." A9. Is this correct? No. The chits themselves reflect that they document QC

                           '           verification of the fit-up and cleanliness of the out side weld.

Q10. 4 CASE also alleges on page 3 that 170 other weld s lack QC verification for fit-up and cleanliness of the outsid e weld. A10. Did you review the documentation for th'es~e weld s  ? Yes.-

Oll.

What were the results of your review? All. With the exception of weld 326, . [ I found that there,was a. chit and/or traveler substantiating the QC inspectionof the fit-up and cleanliness of the concrete sid welds. Thus, e of these with the exception of weld 326 gation is CASE's alle-f actually wrong.'

  , ,                  Q12.

Have you determined why there was no documentati on verify-ing the cleanliness and fit-up of the outside weld for traveler 326? A12. Yes, I have. e

                  **"                                                                                         9 a

se

                             ,,                 ,         n,     w- - , -.   ,           y - ~             g-       m e-,w   e  ,      -p-   w      -og,-
                                                                                                    -6 20579
                                -Q13.

Why was documentation of the QC verification fo not found during your review? r this weld A13. . , The weld has not been made. It

                                                    ~

and is a weld between an angle the top plate of the cavity,

         .,                                         1984, which as of November 20, had not yet been fit-up.

Q14. CASE next states on page four of Exhibit 1 that five welds lacked OC verification of fit-up and cleanliness for the

                              '                   outside welds prior to welding which allegedly renders their conditions indeterminate, contrary to procedure and I                                                10 C.F.R. Part 50, Appendix 3, criteria V.              - Do you agree with this characterization?                                                                      ~

A14. I cannot agree with CASE's position. [ I do agree with CASE's contention that,

                                              't u r e s ,

because of the dates of the signa-t the chits attached to these travelers do not

                                        - definitely                 establish that                                                                                                               ,
                                                      .-                                          the five cleanliness and fit-up inspections were performed prior the time the b acking strip was tack-welded to the plates.

procedures, This is a violation of site and I have directed that an NCR be written .to address this deficiency. While I agree that there i is a paper problem with these five travelers, I cannot agree that , the deficiency is tech-nically signific' ant. , The fit-up of the plates associated with the travelers identified by CASE was reverified and i documented and the cleanliness of the inside joint was verified and documented prior to making the inside weld s. Under these circumstances, the verification of the fit-up and cleanliness of the plates prior t'o tack-welding the

                                                                                                                                                                                                 }

m m oe a # #

         --    ,---,,-y,,..-              ,-,, -                      -- - , , ,      - - - ,    ,      y          ,.,.--,y       ,.                            ,w        ,,p    a,   , , , . --
     '                                                                                                                          i 20580 backing strip to the plates is not a technical concern.                                 ~

The only purpose of verifying the cleanlin t * (" ess of the plates " prior.to tack-welding the backing strip to the' l p ates was ^

         ~                           to assure that the backing strip could be securely t acked on and would not become dislodged inside thea le k channel.                                                         c.hase The sole purpose for the inspectIion is t o ensure that the backing strip remains in p' lac the inside fit-up.                            e until the time of The reason for verifying fit-up prior to tack-welding the backing strip to th e plates was to prevent difficult rework which would be requir ed after the attachment of the leak chase channel if the origi                 nal fit-up
                                                                                                             ~

between the plates was out of tolerance In any event, if r the backing strip had dislodged or if th e fit-up have been

   \                            . improper those deficiencies would have been                  e not d when the cleanliness and fit-up inspections were perfo inside welds.                                                rmed for the 015.

On page five of Exhibit 1, CASE identifies a number of welds which were done using welding proc d e ure 88023 and. claims that the correct procedure ing procedure 88025. for those welds was- weld-A15. No. Do you agree with this assertion? The welds CASE identified are embed to plat e welds. All selds made on the linsr plates betw plates are groove welds een embeds and in shich the deposited weld metal ' thickness (joint thickness) is 1875" plate). (the thickness of the The proper procedure for making this w e ld in 1978 wa s W PS 880 2 3, which was cualified for thickness ranges

                             .0625" through .750".

Prior to October 15, 1979, WPs 83025 h e e -*S . M % * * '

20581 -

                            ~

was qualified for welds with thicknesses of 0.75" through 3.5". On October 15, 1979, WPS 88025 was revised and the f'N thickness range was ' expanded from 0.75" through 3

    \ /                                                                                                  y 5" to 0.185" through 3.50".

Af ter this date either WPS 88023 or WPs 88025 could have been followed when making the welds to which ' CASE refers. Therefore, CASE is wrong in contending that the wrong procedure was used in making the referenced welds. To confirm my observations on this point, copies of WPS 88023, WPS 88025 and 1977 ASME IX, QW 202.2 are append-ed to 'my testimony as attachments 1, 2 and 3 respectively. Q16. On page six of Exhibit 1, CASE identified 243 travelers which CASE claims lack QC verification for Step 5, fit-up and cleanliness of the inside welds. Have you reviewed the traveler packages for these welds? A16. . Yes. - Q17. What was the result,of your review? A17. It is difficult to understand CASE's allegations with respect to the various welds included on the lists on page 6 of Exhibit 1 to CASE's memorandum. Initially, it is important to note that CASE's list includes five-line , travelers and eight-line travelers. With respect to the ftve-line t ra v e l'e r s , for example weld 6, the fifth line is

      ,,                            for the final V.T.       inspection, not for a fit-up and clean-                    -.
       ,                            liness inspection.        Thus, CASE's allegations for the five-line travelers does not make any sense.                In any event,
                      .                                                                                                                                                                                                   20582 where the fifth line of the five-line traveler is unsigned                                           ,

it simply means that weld is in process, and it does not,

   -]                        reflect any paper or technical deficiency.                                                          .

The eight-line travelers on the list categories. fall into several First, many of the travelers are for welds that are welded on one side only (welds 875, 896, 901, 908, 909, 910, 912, 682, 713, 714, 779, 7'83, 784, 785, 797, 798, and 799). For these welds CASE's allegation is wrong because there is welding on only one side of the liner; consequently, there are no fit-up or cleanliness inspec-I tions to be performed on the second side of the liner ' Second, CASE is correct with respect to a small group of i . eight-line travelers (welds 12, 51, 59, 65,66, 72, 73, 90, 43, 107, 147, 203, -709, 851, and 907), and I have directed i that._ an NCR be written identifying the welds for which the inside fit-up and cleanliness inspections have not been " documented. Finally, my axamination of all of the remain-ing eight-line travelers on CASE's is list reveals.that CASE factually wrong because the inside fit-up and cleanli- ! ness inspections were performed and documented. 017. On pages 7-8 of Exhibit 1 CASE lists twenty-seven (27)  ; welds which CASE contends are missing the  : final V.T. of the  ! inside weld. Have you reviewed this alleca tion? 1 A17 Yes. 218. What  ! conclusions have you drawn as a  ! result of that review?  ! , 1 i I

20583 - A18.

                                 'This is another example of CASE's l the fabrication and inspection proceack              ss.

of understandin fg CASE is correct Q noting that a final visual inspection has not b in ed een perform-for these welds, but the final visual inspection has not been performed because the welding /inspecti not been completed.. on process has tha t My review of the travelers indicates

                    -                 no holdpoints have been bypassed and no on                               violati exists for any of these welds.

Q19. Fir. Brandt, , CASE also lists twenty-two (22) welds ' on page 8 for which WFMLs are not in the package. Have you had an opportunity to review this allegation? A19. Yes. However, the absence of WFMLs in these traveler pack-

 /                          ages does not constitute a violation of proc d' i                          deficiency.                                                       e ure or a There'is simply no requirement specifyi                   ng that a_cgpy of the applicable WFML is to be keptni each   ,
                                                                                                  ~

traveler. I might also add, there is no requirement for filler metal traceability on any of thes 020. e welds.. On pages 9-15 of Exhibit 1, CASE alleges that WFMLs are referenced on' travelers indicating that done, but new welding was the weldingthere is no QC verification or involv is done. ement when Assuming this significance doe. to be true, what , s this al' legation have? A20. Although I have not , i reviewed all the travelers listed by i

                                                                                                                               \

CASE on pages 9-15, i I have reviewed enough to lead me to believe that this is another '.itance where CASE does not unders.tand the requirements and/or the sequence. fabrication In all-travelers I reviewed, no inspection hold-

                                                                                                  .-.                  ~
                                                                                                                               )
                                                                                                .                                                                                20584 points have been bypassed.

If CASE is attempting to infer that QC must perform some type of " verification" each day (.7%v welding is performed, this simply is not the case. All required inspections are procedurally described, and there is no requirement for " verification" each day welding is performed.

                       "                                 From the sample I reviewed, I am unable to detect any violation.                                               .

021. Mr. Brandt, turning your attention to pages 16-20 of Exhibit 1, CASE lists numerous welds for which welding was done, -but no QC verification or involvement is shown, and that WFMLs are attached to, but not references on, the ~ travelers. What significance, if any, is there to this allegation.

    ,'             A21.        Mone.

Once again, as I discussed above, this is apparently

                       . . . .anoth_er instance where CASE is attempting to assert                      that verification of welding must be performed on each day that welding occurs.

Of the travelers that I reviewed in connection with this allegation', process, all welds were still in-i.e., they had not yet received final inspection. CASE's observation that WFMLs are attached to, but not referenced on, the travelers is correct; however, the alle-gation is without significance. This information is not I required by specification, and serves no quality function. ) The millwrights are procedurally required to enter this information but they simply have not done so as of this date.

                                                                                         --                                             -- - --     -y - - - - .

Ac.- ,,a .L_ J .-.aJ , 20585 - Q22. Mr. Brandt, CASE identifies S NCRs on page 21 of Exhibit I which describe welds for which vacuum box testing was

    ,g tj                                   improperly noted as not applicable.

Is there significance to this observation? No. A22. It was an error made by the inspector, but was proper-ly reported and dispositioned on an NCR. - Q23. On page 22, 4 CASE lists fifty-seven (57) welds which it, alleges are deficient because final V.T. has been- performed without vacuum bo'x and/or liquid penetrant examination bein~g performed. Have.you reviewed this allegation? A23. Yes, I have. . Q24. What was the result of your review? A24.

   /'

CASE apparently misunderstands the inspection testing sequence. i The final V.T. precedes the vacuum box testing and the liquid penetrant examination.

                ~[                                                                                           As these welds are clearly still in process, no holdpoints have been bypassed and no violetion exists.

Q25.

       '                         On the bottom of page 22, CASE notes "the final V.T.

of the inside welds were signed off on the following welds by other inspectors." What i s the significance, if any, of this observation? A25. I am not quite s'ure to whom CASE is . referring by the use of

      ..                        the phrase "other inspectors."

I assume CASE is referring

    ~.;                         to the fact that the final V.T. has been performed by
inspectors other than those who performed the P. T.

V.B. test. and/or If this is. CASE's allegation, i it is without

                      , , , . ,          ee * *   ="#*88*

e ,, -

                                                                                .e.   ,         ,   , , , .     ,.      , ---..      ,,

4 p 20586 merit because there is no requirement 'that the same inspec-ter perform V.T. and P.T. and/or vacuum, box testing. No ' (} violation exists. - 026. Mr. Brandt, .on page 23 of Exhibit 1, CASE lists 131 welds shich it alleges are deficient because the " completion of weld inspection block on attachment 1 signed off as completed prior to the completion on welds prior to [ sic] vacuum box testing and/or P.T. inspection being performed." Have yo,u reviewed this allegation? A26. Yes, I have. C27. What did your review indicate? _ A27. The welds

            ~

listed fall into several different categories. ' (~ For a number of welds which CASE asser~ts that " completion i , wof weld inspection block on attachment I signed off as

                                    .. completed prior to the completion on welds prior to [ sic]

vacuum box testing and/or P.T. inspection being performed," CAS: is incorrect as the travelers clearly indicate that the wel*' is still in process. Welds 5, 7, and 8 are examples of this category. As the welds are incomplete,-no violation exists. For a small group of wclds, (seld numbers 1240, 1242, 1245, 1248, 1182, 1209, and l'210), CASE is correct and I have direct'ed that an NCR be written identi-fying the condition as nonconforming. For all other welds ] ,, ,) R { listed on page 23, CASE is incorrect because the referenced I tests are net recuireb.: the re fo re, no violation exists. i

    ;.
  • 20587 Q28.

CASE alleges on page twenty-four of Exhibit 1 that "[m)any g7g NCR's were written for welds that James Cole had e N/A'd

      . ..#:                          vacuum box test on.

The vacuum b'ex test has been reestab-lished on all but the ones below." Have you had an oppor-tunity to review this allegation and the travelers involved with this allegation? A28. Ye s, I have. 4 029. What was the result of your review? A29. Apparently CASE alleges that' vacuum box was required for these welds. CASE lists.eighty-eight (88) welds which it believe are deficient. As a result of my review, I have determined that with one excpetion (weld 932) that CASE's allegation is incorrect. All other wieds are not pressure boundary welds and therefore do not require' vacuum box

                                                            ~

testing, and the step is properly marked not applicable ("N/A") on the traveler. I have directed that an NCR be written for weld 932 noting that the vacuum box test for that weld was improperly marked "N/A." 030. Mr. 3randt, CASE alleges on. the bottom of page twenty-four of Exhibit 1, that " PT t e s t has been performed on these welds but vacuum box has not".

!                                                                                             Have you had an opportunity to review this allegation'and the related travelers                                    .

i A30. Yes I have.  ! Q31. What l ' .' ._/ were the result of your review of these travelers? A31. CASE lists an additional forty-eight (48) welds for which vacuum box has not been performed. j For-four (4) of these selds (welds 1230, 1232, 1235, and 1238), CASE is correct '

w eee- e e
          -                --   ,         , , . .,.                             -c,,      .n.  .
                                                                                                                 ..,,.'              ,,..pg.y -

4 . . 20588 ,. and I have directed that an NCR be prepared d condition. escribing this For all other welds listed here, CASE is incorrect; the step has properly been marked no't applicable 032. as these welds do not require vacuum box testi ng. Mr. Brandt, directing your attention to Exhibit 1, page twenty-five of

                             -                                 in particular to CASE's di'scussion of NCR M 83                                    -

D1847 dated 7/7/83. - .

                                                                                    . CASE states that in 1983 and a hold tag applied                                                "The NCR was written tiened yet,                                                         It has not been disposi-151.                    and'there is no copy of this NCR in traveler There is no RPS in package for weld 154
                                     . signed off by Don Vogt, 154 was S.M. McCoy, for steps 2, 3, and 4.

Jim Cole inspected 151 on 4/20/80 and 153 what is the significance, on 4/24/80." f if any, of these allegations 7 A32. -First, CASE is incorrect in stating that " ' _ - - - - - - - - been dispositioned yet." ...it has not In fact, ' CASE describ'es the disposition of this NCR on page 25 of Exhibi original NCRs are not t 1. . Second, filed with traveler packages, nor does the lack of a copy of the NCR in package 151 consti-tute a violation of any code, standard, procedure. specification, or Third, CASE's observation thut package 154 is correct, no RPS is in but it is without significance for tso reasons: first, secon'd, the the repair is not-yet complete and , repair, when completed, s nog weld 154, will be of weld 151 and accordingly s copy package 151, not 154. of the RPS will be in Fourth, with respect to CASE's observation that

                                                                        " Jim Cole inspected seld 151 on 4/20/80                                ,

[actually 4/2/90] and 153 on 4/24/80 " CAS E is apparentiv -

               . m.
                           ,            -, - - ,-      ,           .-g.

_ _ . _ -- . c. _ . . _ y , w .y . - - - -

              .    ,_                                     -.        e      . -~ _         __          .            _                _-                  _
                   .                                                                                                                      20589 speculating on Mr.

Cole's ability as an inspector. There '

  • is no indication that' weld 153 was impr
      ,_                                                                                                              operly inspected.                                  ~

The NCR clearly states that k- the backing bar had"been ground I through. No evidence exists which indicates thatthe back-ing bar was not intact when Mr. Cole performed his inspec-tion .on 4/24/80, and, as CASE notes, the incident (gr through the backing bar) was properly repo t ing. r ed as nonform-In the other incident described, i.e., the failure of the backi,ng bar to continue for the full length of the weld at the intersection of welds 166 and 153, CASE again seems to allege that this weld was imprope'rly insp ected by Mr. Cole, Although not extremely clear from the face of the document, what Mr. Halcomb,

 ,-                                                                                                 the originator of the NCR, was attempting to indicate by attaching the Chit for first fit-up of weld 154, i

was that the " deficient" backing strip

  • was from weld 154, not from weld 151. Therefore, Mr. Cole ,

clearly was not ) involved with this deficiency. The defi-i cient condition becomes clearer after looking at the ing. raw-d Weld 151 is a vertical weld which attache s_a' plate-(A35) to a gate guide. Although the vertical weld contin-ues on down the gate guide, it is numbered differently for ' each plate it at.taches. Welds 151, 155, 157. and-159 all form the vertical weld which attaches a gate guid e to ' plates A35, 335, M35 and M35, respectively. This weld - (although'4 weld numbers) was fit up on 5/17/79. The back-ing strip for this weld (weld numbers 151, 155, 157, a . .d 159) was continuous for the 'ength of th.e weld. r Th e fact s v, e-~, wr-nm---- e r,cv r- - e a m g - ,- , y s- +---- ~ s - - - - e s.-y e

                                                                                      .             =
                             . . .                                                                                    20590       #
                               ~

that the backing strip for weld 154 lacked 3/8" fr om running the full length of the weld was properly reported .

     ,\.n) on an NCR, and is attributable to inspector errQr.

Q33. On page 26 of Exhibit 1, CASE refers to a numbering discrepancy which was reported on NCR M-83-00907. What

                                ,          significance, if any, is there for this allegation?

A33. . This allegation is co~rrect, however without significance. In this case the construction group which issued the trayelers, assigned separate veld numbers for the welds attaching the backing strip and leak chase to the gate , guide. Although clearly indicated on the traveler, the mi11 wrights were not timely in assignment of these weld i ' numbers to the marked-up drawing which they were proce-

                                  ,    Murally required to maintain.

This conditi n was properly

                                    , identified by QC on an NCR and the situation was corrected.

In no way was this an inspection deficiency. Q34. Mr. Brandt, on page 27 of Exhibit 1, CASE identifies two nonconformance reports, NCR M84-Ol969 and NCR M84-00498. Have you had a chance to review CASE's allegation regardi ng these NCRs? i A34. Quite frankly, I am unable to find that CASE alleges anything with regard to these two NCRs. problems, Both identified i and both were properly dispositioned in accord-

    - s                              ance with site procedures.

CASE's note regarding the ) absence of a copy of the NCR in all of the packages is not  ; a violation of any recuirement. As I stated earlier, the original UCR is filed in a 4 location separate from the e

                  .                                                 ~18             .

20591 traveler package. All Packages do contain the' corrected PT report and reference NCR M-84-00948. Other than the defi- - O ciency which was reported on these two NCRs, I am not aware

               '                     of any deficiency in the way they were processed or dispo-sitioned.

e e G 4 e e 4

      ,~
                 *"    =*=.%

e 9

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           ,        ._                             ,     . .              _    ,       -- -.-i

1 i 20592 1 UNITED STATES'OF AMERICA r NUCLEAR REGULATORY C.OMMISSION ( ,j. BEFCRE THE ATOMIC SAFETY AND LICENSING ROAR In the Matter of ,

                                                                                                )
                                                                                                )

TEXAS COM UTILITIES PANY, et al. ELECTRIC ) Docket Nos. 50-445-2 and

                                                                  -                            )
                                                                                               }

50-446-2

                                 *(Comanche Peak Steam Electric                                )      (Application for -

Station, Units 1 and 2) ) Operating Licenses) CERTIFICATE OF SERVICE I hereby Testimony of C. certify Thomas that copies Brandt of the foregoing "Prefil ed . of a Quality Control Breakdown in the Construction,Regarding CASE's Installation "delivery captioned or deposit matter were served upon the following e- pa

         ,                      postage prepaid,                             in the United States mail,* firstersonsclass,                           by hand-this 20th day of November, 1984:

(' Peter B. Bloch, Esq. i Chairman, Atomic Safety and

  • Chairman, Atomic Safety and Licensing Doard Licensing Appeal Panel U. S.

Nuclear Regulatory

                          . - U. S. - Nuclear
  • Regulatory '

Commission Commission Washington, D. C . - 20555 Washington, D. C. 20555 Dr. Walter H. Jordan Mr. William L. Clements E81 West Guter Drive Docketing & Services Branch U. Oak Ridge, Tennessee 37830 S.' Nuclear Regulatory Commission Herbert Grossman, Esq. Washington, D.C. 20555 U. 'S . Nuclear Regulatory Commission Stuart A. Treby, Esq. Washington, D .' C . Office 20555 LegalofDirector the Executive

                             *M r. Robert D. Mar-in                                          U. S.

Nuclear Regulatory Regional Administrator Commission Region IV Washington, D. C. 20555. U.S. Nuclear Regulatory Commission

  • Chairman, Atomic Safety and Gil Ryan Plaza Drive Licensing Board Panel Suite 1000 U.S. Nuclear Regulatory Arlington, Texas 76011 Commission Washington, D. C . 20555
                                         .s * * * -
             - . - , , - -                -- -- _ _ . -                          -                                                               --y         ,, ,

t a "O J 2-20593

                               *Renea Hicks, Esq.

i Assistant Attorney General Anthony 7.. Roisman, Esq. .' '. Environmental Protection Executive Director - Division Trial 2000 Lawyers for Public Justice P. O. Box 1254.8 P. Street, N.W. Capitol Station Suite 600 Austin, Texas 78711 Washington, D. C. 20036

                             *Mrs. Juanita Ellis
  • Ellen Ginsberg, Esq.

President, CASE Atomic Safety and Licensing 1426 South Polk Street Board ' Panel Dallas, Texas U. S.

                               ~

75224 Nuclear Regulatory Commission Washington, D. C. 20555

                                                                                                                           /

N /

                                                                       '44 ru c e ' L . 'Down ey cc:       Homer C. Schmidt                                             .

John W. Beck Robert Wooldridge, Esq. i e e O . v w: . I e I

20594

  ~

arm vetLD #wCCtCweit.vo, - W 1? Y) :. 4n..

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APPLICA3LE COD 2isi SUPPORTING POS ts) ASME Tee. iY _ ">- C a t?na s.., ess.:. Sec. IiI yg c-- i . , ..-- .. :

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D.; PREH2A7 - i ?;i.Ti .!'I' .0 r.2AT T3 EA7:4 5777 '- C000 4 g.} ,j j, PREHE AT TZMP., 'F T' ' 71 H--e - f* -}# N 9I ./ 1[dhtM7A.S MANCI. F I' " -W . TC'?*3AT:.;RE 'I ? "- - b l Tc.. :I/A . Q * . . _ , . \. j

                                                                                                               ~

Acc;Tiot. alt:3 su,'PL.! .. :iTAH't 72cu!.c .1::ra l. Pricr to f:r checked theitsstart oxyger. of welding, cent 2n . th 2nittn ;2s fr:n the ;crge trea shall te 2'; or Scicw bef:re widi- .:s;en ::::2r.: cf the exiting gas us ; he

. 7.::: in: 2.2i:eFili). cur;2 shall te . aintained fcr
- : ..2.

at least t o (2) pas:es (gi.e., 2. All weld joints shall te fr:e of < :isture, ext:e, ,rease, oil 2nd ;retective coatings. All slag and/or surfac: deisc s : hall ce re cve: as prescribed frem each weld bead pricr to the c:ntinuatica of weidng. , (1) Purge reiuire .ent snail te deicted ..han be: king strip is u-ilf:ed.

     ~'
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FREvt.aA;;c-RAP ne w.L .

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                                ;-                                                                             JO!NT DESIGNr.'liLO $1 QUINCE                                                        '

20595 r ,  % "* wy/gj; wswq M7 cwxw y((A gs.g I I

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           <~ . -                         emeu                                                                                                                                                                                s.

w y OhD h 4y d_. h - A.,, nu Y- N6 j rW  : h, K\ WELD PARAMETERS PASS PSCCEss FILLia MET AL l .C As/F LUX

                                                               , g gg

{ ELsCTRICAL DATA ,TRavgt W.

'                                                                                                       g. A ss i rves M ir., sLcn type               AMetaAct        vCLiz                   IPM GTA                                                                                                                                                                                                  y ,e 1                                    1/16"               See flote 7 Arg:n '

i or 15 CFH DCSP GTA 100 Max. 11 Max. - 3/8" 3/32" See Note 7 Argen 15 CFH DCSP 2-3 GTA 100 Max. 11 Max. - 3/8" 1/16" See Note 7 Argon 15 CFM DCSP GIA 115 Max.11 Max. - 3/8" l 3/32" See Note 7 Argon 15 CFM OCSP

;&Cri GTA 115 Max.11 Max. -

3/8" 3/32" See ;;ote 7 Argon 15 CFH CCSP i

f. g 1 pon Can ?!n to 7 i ce a e, 140 Max. 11 Max -
                                                                                                                                                                                                                                            '3/8" 1C r?u             neC0                  1,81 vs , 11 e. , ,                          -
  • 3 son i PMfMEAT goor j _ iur:Reas Ttup. SAcx Co uC:NC METHCO D 60cF - 350cc , courAct was to wor un. N/A 53NetE c$ MULTIPLE ARC Clea*n CRIFICE oR CUP $J:3 t /o n v4 SINCLE C A MULTIPLE PA:5 MU I< 01 e l . wg(g pgggggggggg _ UOwa tad SPECl AL INSTRUCTIONS 1.
;                            2.           Preheat shall be established prior to the start of weidir.g.

The interpass te:ceratura (abeve 1503F) shall be checked ustr.g :amper ture ' incicating crayens or an accreved ecual.

3. The number of weld beads n2y vary with section thickness.  ;

4. The starts and stocs of all tack welds snail be ta:ered by.;rinding s tha i 5. the initial pass can be properly consume the tack. ' '

6. Tack welds which are used at the root cf fcir.:s shall be c: alete cer.e:ratien. ;

The non-c:nsumable electrcce for the Gas Tur.gsten Arc pec ess snail cerf:m l to AWS AS.12 Class EWTh-1 (1% Th:riated Tungsten) or Class E' nth-1 (2'; Theriated Tungsten).

7. The type of bare wire selec ed for the base metal t:
            ..                         follows:                                                                                                                                        he welded shall be as
             '                                                          BASE METAL TYPE                                                               EARE WIRE                  -')   EE i SED 304 or 301.L to 2G4 cr 30al                                                                     iASC5 or EE20d C 316 cr 316L :o 315 cr 316L                                                                      ER316 er ER31st 304 or 30*L to 315 cr 316L                                                                      EP.316 or ER316L i                                                                                                                                                                                                                                                                l l
i l

1

               ..  .           .. ..                  .....          .     . . _ . -                                                                                                                                                                            l m-              7-         '
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                                                                                                                                                                        - :c:r:s. Tt n :

0808V204pe.,; t . . . PROCEDURE QUALIFICATIOtJ RE RO _ , ree. 1 of 4

                               .,     Jtsteris! Spec. - SA-312 TP304 -                                                                                                                                      .

20596 P No. O Gr. No. to SA-312 TP304 Weiding Processes l to ? No._ 6 Gr. .'.o. _ I

                                                                                              !.1._f*iGas                                     Tur. ester. Irc_

Manual or Automatic 2. _';/ .h:ceu A and 0.D. _ E30" 'a I I I.". nua l nickness Rsnge 2. *!/A

1. -
                                                                                                                                                                                                                                                                               ~
2. '! / A Tots! Qustified Thickness Range O_ W" N'1
                                                                                                                                                         . CW
                 .                                                    FILLER 5tETAL WELDINC PAR.OtETERS F.No.                I._ 6                                                  _ 2, _N/A A.No.                1. _ 8                                                                                                            Joint Type _

SFA $ pee. ~ 2. _ fi ' A Po.ition Sincle '!ee Groove *.41d 4 1. ___5. 9 _ 2. IUA _ 6G Ur:ttard AWS CI.us. 1._ ER303 cs: Ling

                                                                                                                ~2.                  fi/ A -                                                       Constrabale                        Ir: sert (ivne x)

Filter Si.ce 1._3/32"  !'rchest 600F , 2. IUA Trsde Name I. ARCOS IPT Range G0oF - 350eF-

2. fuA P'.iHT tione Describe Filter afersi if stu( included in Seitaun IX Passes / Side I._ MultieIe 2,_ I;/A No.of Arc: 1._ S1nele 1/8" x 5/32" Arcos Consur able insert Current 2._ N/A I._0 CSP Amps 2._ N/A FLUXOR AT'.!OSPHERE 1. 70-100 2._ N/A Volts I. 8-10 i Travet Speed 1. 1"-2" IDM
2. - ?UA Trade N:me 1. -

2._ N / A 0,:it!stion 2. _ H/A ' Shiciding Cu 1. _ 'rt Sn 1. 3/8" Ftar. i 2. fi / '- 2. _ H/A i Flow Rate  !. 16CFH 31 1 2._ P:/A Sesd Type 1. Strincer _2. fi/A Purge 1. I EC ea .'.si n_ ,;, .y ; .

                   ~

1 TENSILI TC5T Specimen No. D mmions

  • h.idth .

A,eJ L 'l,' mmste Unit l Thiexness - Character of F&re

                                                                                                                                                                            , (3,                   steess psi j                                                                                                                                                                                                                                             And t.ocation OW 462. I(b)!1 : 0.724                                                                                                i 0.203                                .1505 i                 13,100
                                                                                                 ,                                                                                               87,000
                                                                                                                                                          .                                                                         i Weld-O'.! 40.1(bh2
7. 714 0.205 .147d l i, 13.?00 c0.200 Peld CUIDED DE.'.D TESTS Type sad
r. Tare No. Result I i S P' *"d
                                                                                              '                                                                                              Fere No.                                               ge3ut

_ QW-462.3(a) Face Sa tisfact:ry l QW-462.3(a) P. cot Sa tis factory QW-462.3(a) Face Sa tisfactory _ QW..tS2.3(a) Ecot

                                                                                                                                                                                           -                                             Sa tis fact:r.i                       _.
           *   '                W:Ider's Nsme _ Jfrrny E. Mite C:ock No. 2314 hho by virtue of these tests meets v.elJer perior-.ance requirements Test Conducted by stamp No.__ AAC Soutb.es tern L2: Ort: cries                                                                                                     kboratory              Test        .No._29559-60 per_          rir. Con form,                                                                                      Aedress                Scuston, Texas
                        ,                                                                                                                                   _ rhte                         2-20-15 he certify that the statements in :!n> re:ord are c:rre: :nJ ttist                                                                                                                                                   .

acccrdance with the requirements ni Seerson IN of the ASME the test welds C2de. prepared, me!ded and te..eJ in ! eigned - 3E CIIII l' E30 I . II C-

  • OI.nuiseturer; Date- A ' "I
  • 70 y_ -

f -- " t,&

                                    =_       _

w - - _ . _,y . _ _ _ _ _ _ . _ . - _ , _ , , . _ _ _ _ , , , . . _ _ _ _ _ . ,,m_. _,,,_.y._ y , , , . , , , , , . . _ . . . , , _ _ _ . ,r.. _r_,_._

                                 /
                  */                        .Ef0' tin O~i:OC:LinC.                                                          oum s,. rc <.u                              -

v.a r . escse. m A 2.e.,. SUPPLEMENTAL TESTS ' I fe.x 2 or 4 TOlJCHNESS TEST TYPE- PER SIZE e PER 20597

             !m-                        . SP -Ctst E.'4 tor.wT1scA11oN TEST               .%0TCH rgg MUY W.LBS                                                                                                                     9

,  %. TOIP LocATro.y stiLS LAT.F.tF  % SIIEAK D.itent 3.or P A E.\ x N r, c 6t t.m q

                                                                                                        .                                                                                                                                     i I

< \. HARDNESS YEST TYPE PER.

                                          .% O.                             hEL D stkTAL HFAT \FFECTcD 70NE                                                 BASE sthTAL i                                                                                                                                                                                                                                    .

i f.- FILLET WELD TEST FIC V

                                                        ,        MCRO Tt3T RCSULTS                                             l FRACTURE TEST RCSLLTS CHEMICAL ANALYSIS %                                         METHOD           L'st Chanicti                                 PER r*EI'1 M 71 1

tLest. e u. P s si er si uo ce WELD L O33 1.76 ri N _ Q___ g 42 19.89 9.45 .29 .059 0. 0 Accrexir.2te Celta Ferrite Content: 9" (S .9 41ar Div > er :M -, - ADDITION AL TESTS . of the A5i'i Section III C de) Celta-ferrite tests were conducted en -he cc:pleted weld at 12:00, 3:00, 6:00, and 9:00 o' clock wi'th a severn ferrite indicator. All posittens

             ..                         recorded a 7.5 to 10" delta-ferrite centent.

I 1 - he ::rtify th..! the it::e: rents in tis tscurd are co:Tect sad 1.'at t:::

PQR No. $.EO9.A200 ?? 3 tests were cos:J:.;eted ni 3::ctJ;.:ce ..a.

and the recuire ne:its of 'I/ A i

                                                                                                                               $ia;*lCd                 .eSe k $I.)Y.             '
                                                                                                                                                                                  . (

Uste _ * 'T ~7 9 f a E.v ,,, - ,. .*W/w p

                                                                                            .g*.
    -r~                 - - , .              - . -        --w+-    w we - e    --t    rw-            e          ,--e     --        --w                        --          w----      y     -, < - - - - -          - + - -     -e i   -e

_, ._ _ - ^ i f ON[7D s ;C C . l .I[,, Hou: sten.7ExAs SUPPLEME JTAL TESTS 020 A204 Rev.' P r..

                     ,,          TOUCHNESS TEST                                  TYPE-3 .:             4   )

PER.  ! SIZE 20598 FER S Pt:ClitEN TEST NnTCit i ~.'-. IDr.NT!!1CA110N TDtl' LCCATios FNFRGY FT.L35 MILS LAT.E.V 3 31 TEAR DKor hI H.H r

       \.                                                                                                                                                                        tREAK             NO 8 RE4K I

Y

                                                                                                 .                                             .       \

HARDNESS TEST TYPE PER-

                                      .N o.      !

WE:.0 METAL HEAT AFFECTCD /ONE , BASE . META L , l i FILLET WELD TEST FIG

    .                                                    MACRO TEST RESCLTI l

FR ACTUn' 2 TEST XLSCLTS CHDIICAL ANALYSIS . StETHOD -

          "                                                                                                                                   - PER-

! ELEM. C u. P 3 $; i, Ni uo gg

                               % ELD l                                                                                                    _ _ _                        _ _                _            g L sASF ADDITION AL TESTS Bend tests were examined at 10X ragnific2:!cn                                                                          r aftar' be'.cing te teet the acceptance critaria of "Interm Repictory Guide 1.21."

exceeding 1/64" were present. ft fiss;res Radiographic Report of !! alder Qualificaticn:

      -     -                    00009, was run in ac:orcance with 2cetieri                                                     Radiograpnic reper: '!CRI                    ,

acceptance criteria of Section VIII, Oivisicn 1 was herein net.IX,1970, The par We certify th.it the statements in this ree.srd are correct :::d tS PQR No. C 71M00 Dav. 3 . t the tes:1.cre :endected isf :: cord:nce *ub and :he er pitements of - " 'I Sige.ed 3EC. *! 5 A O "J . I.*;C . oaue - * ~7 7 C '

                                            -                     E i
                                                                                                                    ** . ///N ..                       . ,. u s                                                .

e e

              - =,                ---                     ,           ,e      r          - - - - . -              -     -.          ,...-%.,---..m.m               .    ,.      ,,  .,y--   ,,.r..       ~ . - - -

p i

  ,               , , /                  $~.[O'(([.I                   ..       C        [.Ye.              xou::o4.ieaAs                          .

020SM204 Rev.. SUPPLEMENTAL TESTS P, . 4 .t 4 l r TOUCHNESS TEST . TYPE PER SIZE /Er( 20599 SPIT 14t E!4 TYST .%f)TCit sul hTit irAlloN TIMt? LOCAT!uN F.N > KG Y >T L D S tills L AT. EX P 't silF. Aft D W w>ltJIT

         ,3 BREsx                No turag t        t                                                                                                                                                  -                                          1 1

4 I

                  , ,         HARDNESS TEST                                          TYPE-                                                                                                            (

l'ER NO.  % F.I.D st>.TAl. 4 i ItFAT WFF:LTr3 /oSE B ASE MkTAL ' l l , Two Practice (2)E. specicens were sansitization testad in accordance with ASMT A262-(. micrecracking.Specimens were examined ac 20X cagnificatien for presence of No fissures were present. 1 The following parameter excerpts have besn ex:racted from the actual param utilized withir qualification of said pr:cecure and are by the PSAR.  ; ADDITIONAL TESTS Ef:ERGY I::-i!T D:l;GE GTAU Prccess ~ '; Amperage 80 ' ' Voltage 90 - 10 8 Travel Speed (in. per/ min. ) 2.0 - 1.0 Kilojoules/ inch -- 24.000 min. Note: 43.200 r.ax. Parameters range and do noted not are indicative of ,ne maxieum and minimun energy inout utilized during qualificaticanecessarily ref t act the -aximum/cinimum amperage /vol:a he certify that th PQR No SC8 ,e20- gt :ements eV. 3 in tes rc:urd are correct md : : the tests were cortdue:ed in :::o:c:nec -aa and the re t;;ter.e:::s of *!/ A ~ S!;.:d__ I ~9! A 'OOT. ";C . On t e __ S' ]* ?? a f/

                                                                                                                       ~

f.'. O . . '

                                                                                                                               /

_m __,A__+_m_, . = _ - - _ - "i--------**-* 1

s s. - ' *

                     /                                         C3 .e.         s /C Yi *.> r .*3 . .r > !.. :J                                   e .n          wousto*,              rmr.s sca ns.
               /'

i g r.m j e g ,3., PROCEDURE QUALIFICAT ON RECORD - ha 1 of 3 '

                 ,                     ' Ma terial Spec.                     SA-312 TP 304                                                                                                                                                      20600
                                         ? No.              R to -       92-117 TD v4 Gr. No.~-         1 to t No.                              A Cr. No.             I_ Tnickne:s ano 0.u..h. ?E*' '4ii Tir i t < .,,

Welding Procenes 1. (;as Tiinte*an a- , r, Manual or Automatic r 2. Chialdad V3=1 2. c

                                                                                        !.            b'snum1                                                    2.      92 m>> i Thickness Rsnae                                 I.

(s!

2. -

Tot:1 Qualified Thickness Range O.e:2c" - h e'# 0 : n" -

                                                                                                                                                                                                                               ~~

FILLER METAL WELDING PARN.!ENRS F No. 1. 6 3 _ 2. Joint Type A.No. I. 8 2. - 8 91 mal e. 'l a = r:r w.. v a ld Position EG Ucuaed SFA $pec. 1. 5.0 2. -- 4 2acking '!c a s AWSChu. 1. - ER308 2. E309-16 I. Prehest - 60*F Filler Size 3/32" 2. 3/32"!il/S" Trade Name 1. Arcos IPT Range An*F i:0*C PWHT '!a n a

2. Arcos Passes / Side 1. e i ti c l e 2.- Multirla Describe Filler Metal it not incituied in Section IX N/A No.of Arcs 1. Sinele 2._ Sinn!e Current I.- CCSP 2. DCR0 Arnps I. 29 05 _.2. 70 09 FLtJX OR ATMOSPHERE Volts B-10 I. 2.- 16-27
   ,                                , Trac.: Name              I.          -

II/a Travel Speed I. 34 I E'4 '

2. 2.5 .0 I5

_ 2. o,c;Irmijon Shieldina Cas I. A"a"" '!/ A g,  :/16" usw . 2,_ g/1ca w, i 2. Send Type Flow Rate 1.

1. 5 "i""*" _2._._Steines-
  • 19 CFM *'f a -__2.. '!/ S ~
           .                         Purge                    !. 10 C CV i a _ 2.                                      *f /a                                                          -
                                                       -                                                                                         TENSILE TEST
                                          . Specimen No.                                   **# **

Width Area { tillimste L' nit Charseter of Failure

                                                                                                  ! Thickneu
  • Streu psi And Lo : tion

{ OW *62.IIbi il _ .73? .146 .1069 c.?:n " c1_ or.n u.3 t s I OW 462. lib) id .711 .Ic6 .1141 in _160 te .an Weld GL".DED BEND TESTS Type and Resuji yPe and Firare No. F 3ure No. Result f'?> 4A7 7f2) Face c=*f sir-- v fN 462.3/a) R:ot $3'#5f!Ctarv l w 462.3(a) rar. e2 4,<,,*--y (N 462. 3(2 ) ocot ' Satis'!ct:rv Welder's Name Ji- v Hi e Clock No. 2314-hho by virtue of these tests meets welder performance nquirements. St:mp No. AIC i Test Conducted by Laboratory Test No. 17 23

       ~

Sm'thwae*=-a ' = M-s a rb e Addreu 997 P 3.* '1 e s 4 w e- - ~Y per wancy wm5 Mek- _ Date_  ?'s r . iW We c:rtify that the state.-.ents ia (?:u record an c:rrect and that the test weids prepared, se!ded and tested seccidance with the requ.irements of Section IX of the ASME Code.' cj l Siped --- a  % :-a*

  • a-t.is Let)
                                              'f-an 7f D, , e w            /T CJ                    iG2MN                                                 .

i i

                      -. , - - - -           , - - - .                --a.-,            . , . . . . , . _          , , . ,          , , , - , ,                               , , . ,                       , - , - _ . . . - , . , , - , ,                    .,,,,.n.,_,a-,           ,

j b[O'((.0 . Oddin . eu2:=u.TexA: . Os $7 sir., ,, i SUPPLEMENTAL TESTS __ I Pqe p. g

                       ^                                                                                                                                                                                                           -_

TOL'GHNESS TEST TYPE PER 20601 SIZE PER SP> raw EN TEST $0TCit s foENTillCA110N T0.4 P FNFROY FT.L85 MILS LAT.EXP  % SHEAR H.HT LOCATtON I, ' BREAX .% 0 D R >:A E

                                                                                                                                                                                         ~

HARDNESS TEST TYPE PER PsO. h>.1D vtTAL HtL4T ATFELTCO ZONE B ASE MkTAL i l FILLET WELD TEST FIC

       /

M ACRO TLST i.CSL L TS i FR ACTURE TEST RcSULT3 CHEMICAL ANALYSIS 5 METHOD 'det Ch*~ic2I PER ASI'd E?!O-74 ELEw. _g_ wa P s si c, wi wa C2 n fl wELo . 079 1. go Q___ g 7n to.7o o 14 - oc-ecn 0.0 SASF { a g g re y (c.s

  • a 931*3 c a ,r**a ra *s-. . 7 f*e-see s1.,. r*ii s e. s- o e t -.. . 7f.?? l ADDITIONAL TESTS of tr.e AI.':E 5ecticn III'Coce).  ;

Bend :ests were examine:! at 10X cagnification af ter ' er.  : ding to c.eet the acceptance criteria of " Interim Regula ory Juide 1.31." present. ;o fissures were  ;

                                                                                                                                                                                                                                       \
0.adiographic Report of '<.'aidar Ocaiificaticn: P.2dicgra: hic rec:rt '<'CP.T C0020was l
           .                       run criteria in accordance of Secticr:wit.'1 Sec-icn IX,1974, P:ragr:;i C4-id2. The ac:e;;ance VIII, Di.isien I was herein r et.

he ce tsf} th.st the siste. .ents i. tna record art torte:t ud that' the tests were condu:ted i, ac:ct::2. ice wili PQR No. 050315105 :s v. * *: ' 2 and the rew rements or Sqned _ 9 eo.4n 7, een- fr-e,, , e 1'- p e - V ~

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_ _1 . _ . . ,s,;j VffD. . . _ . . . j *, ,,,

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                                    ,                                                                                                                                                                                                                                                                 i
!                                s'                                                                                                                                                                                                                     ranQ : ~

Mousron.Tt

        .            -       #                                                                                                                                                                                                                                                                      -\
                                               .{

0303*.;;}c pg SUPPLEMENTAL TESTS _ i TOUGHNESS TEST s 74s 7 sf

                               .<~                                                                                      TYPE                                                                                                                                                                          ,

SIEE . _ PER~ _ SMft%EN TEST NOTCH l PFR- 20602 IDENTil1CA110N TI:MP

.                                                                                                          LOCAT10 N             E.9ERGY FT.L55 AtiLS LAT.ExP 4

1 1 ^ 5 51 TEAR SREAK Mobi h.uT _ S .", 3 R E A i

 ,                                                                                                   i                                                                                                     j                       .-                                      I j
                    .                                                                                                                                                                                                                                                                                 i i                                                                                                                                                                                                                                                                        1                           i i

t j . t . I

                                                                                                                                                                                                                                                                                                 ^
 \                                      HARDNESS TEST-i
 ,                                                                                                                     TYPE _                                                                                                                                                                      .

I NO. _ l'ER _- -.i k WLD MLTAL HEAT AFFtLTCD 7.oNE _ i B ASE METAt.

                                     ]_                    <                                                                                                                                                        f                         -

l 1

-FILLET WELD TEST -

t FIC __ MACRO TEST RE5L'LT3 - 1 i

          /                                                                                                                                          !

1

          -                        =

FR ACTL'RE TEST R C51,'LTS ' 4 - - - - - a~ C' HEMICAL ANALYSIS ~r~ r

                                                                       ~

AIETHOD_ tiet Chemic? 1 ~ RE M. < C V9 I 5e _ PER_ ASTM E350-72

                                                                                                                              !       Ni i

i wtLD l.013 - - 1.61 .35 9.38 h_t_ _ g__ u .07 19.95

 !                                               "I! ec crir ?te Cel                                                                                                                                                 .05?S             4.'n ta Ferrite Cen ent:                                  10'; ISchte"le" Discr!

ADDtTIONAL TESTS 1 E of tr.e ASEE Section ce Peitre III CeceJ ?ill-L 1. Ber.d tests were exa.ined at 10X magr.ificatica aftt - 2. acceptance present. criteria of " Interim Reguia: cry Guida 131 "r ber. din . .

                                                                                                                                                                                                                       !Io fissures were Celta-Ferrite tests were ccnducted                                                                                          12                    at t.telve used     Positien and the folicwing results notad:the                                                                            .

erritascopa MTE.'725 was length of the p ~ All Del ta-Ferrite *:u-ter

                                                                            ~

Ali positicr.s ar.gec tetween 9.5 and 11.5 We PQR No. certify that the staternents in this record a n~SC11'ta ~=v 1 re_ cortect and tr.st' snd the en,uirements at. he N/Atests weree:r: condve:ed see om- es 5gned_ Da t e -- O ** Er wn 5 Roe- I c. i __ g_ y

 !                                                                                                                                                                                                           7^               %# #           ~"

e. 'l - _ - -- ,7 . . . . . _z...-..- _ -

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_ .,.. .... .- ~ -

                                                                                   - ~ _ . . - . _ _ _ - - .                     _ . . - .   , . . ,         . . . _ , _ . , - . . . . _ - . . . _ . . - . . .  .                         . . - . . - _ . . , - . _ . -
    '         ~
                                                  " Brovm &Tho!Jnc.

SUPPLEMENTAL TESTS ou. c . . xu -

                                                                                                                                                                                                      ' Lib                ae  ;

. . P ,. 3 .t 3 TOUCHNESS TEST TYPE- _ PER SIZE PER 20603 . sri-flM EN TEST NITCil

           / ,   .

IDF.NTillfA110N T!3IP LOCATIO N F.st kGY FT LE) Lt!Ls LAT.EXP DROF%M.HT

          \ ;.-                                                                                                                                                                  5 SHEAR .         BREAC           ho 3Rt;AK 4

t I HARDNESS TEST TYPE PER

;                                                     NO.                  wE4.D kitTAt.                                                   HEAT AFFECTCD /' 0.sE                                  8Ast MLTAL            ,

I i: FILLET WELD TEST FIG I M ACRO TEST RESULTs FR ACTid E TE.5T RESUL;3 3 4 ADDITIONAi. TESTS 1. Two.(2) spect.~ ens were sensitizaticn tested in sccordance with ASTM A252-70, Practice E. Saecimens were examined at 20X magnification for presence of microcracking. flo fissures v.ere present. In additien, - Westinghouse Cactment WCAP - 8673 stst:s that anergy input of 80 KJ/ inch 4 for base metal thickness of 3/4" resf.ted in r.o ser.sitization of the base metal. i i i l We certify g t_t,he >ts,te .e:sts in th.s record an cert:ct an PQR No. - Ou aII" '9V- I  :..as stir tats *ct ;70.ht:eJ an ac:st::nce .ith - as:d the regi. ire nents of - a i

                                                                                                                                                    $iped            Er-.n & ?C00. I"C.

C :te - ~ S0 ~ $ By L VNOA J - o l

                                                                                                                                                                               *         ^

r - e

  • rea r4 l . .- _ *[CY.8 } D n. ,3*6 0 C81 .yi' O. ee:: :. trxes 0802AS105 Rev.d SUFFLE.YENTAL TE3TS pg. 3 .e 3 TOUCHNESS TEST TYPE pen 20604 SIZE PER srt riMLtd TEST NiTCil lggymy 3 7,g,35l stiLS LAT.sxP 7 SHEAR DROP wt H.H T
    /                 IDt NTillrA110N       TI'M P        LOCAT!oN t                                  l                                                 BREAK                 6 0 S M t'A K Q.                                                    *
                                                                              'i                                                                        .

I* 1 i I f MARONESS TEST TYPE PER N O.  % ELD is tTAt. IIF.AT Arl'ECTCD /ONE B ASE M ETA L FILLET WELD TEST FIC [ M ACRC TkST RCit.LTs I FR ACTL*R E TEST R CSL LTS ADDITION AL TESTS

1. Del.ta Ferrite tasts were conducted en the c:mpleted weld test pad at six equidistant locations at the center ine with a severn ferrite indicator. .

All positions recorded the fol10wirg delta-ferrite content: Greater than 7.5, les: than 10". i

2. Lo (2) spect=ers A262-70, Practice E.were sensiti:ctica t::sted in accordance wi-h Asm Specimans were exacined dt 20X magnification fer presence of microcracking. _ tio fissures were presen:. In cdditien, Westinghouse dec:. ment ',;;AP-5G73 s:::es t. Mat erer;y ir. ut of EC Y.J/ inch for base metal thickness of 3/'" resulted in r.o sensiti:stien of the base ce tal . i
    ..                                                                                                                                                                                                  i t
     .                                                                                                                                                                                                 1 he certify th..

PQR No. n

  • the
                                         * : : itstements
                                                ' l
  • D a'r - in 2 :his record are and cortect r.J th:t the rests were es.-docted in a::ord: ace *at:
he regirements of ' b' C S;,ned Decun ', be t, '- , (

0# Date 8y MC)pp~

                                                                                                                                                                                                       ]

I m . {

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                                      /. _ . -"

C.'.) p Ja Q. f.- sC.r,. t

_ -q~(3; yu
                                    ,                                       e :                        .

ron t'e. mrov. . ai.s .

                                                                                                                                                                                                                                                                                                  ~

s 050SAA114 pey. 4 PROCEDU E QUALIFICATION RECORD Pm 1 of 3

                         .m                  mterSISpee._

i SA-240 Tvoe 30 1 P No. R _ o __ M-220_IV:n 204!. 20605 Welding !roceses Cr.No. 1 te r No. 't Cr 1

1. Ga s Tur.cs enArc .No.- _ hekness 2. _ *!/A and o.D. _l-3 /4" ola ta Manual or Autorr.a6e I. !*.anua l
     .      T'                               nickness Range                                                                                                                              2. - i!/A
           -                                                                                                       I. -                                                                                                                                                                              -
2. 'l/ A '

Total Qualified Thickr.ess Range 0. !875" thru 3. ~ i.'e",,,,, g FILLER METAL . F No. WELDING PARAMETERS 1._6 A.No. _2._N/A j I8 2._N/A Joint Type _ SFA Spec. 1. 5. 9 Position - Doubh Vee Gemve Wld 2G i AWS class. _ 2. ti/A uscLing'

                                                                                                                                                                                                                                                                                                       ~ .'

I._ER308 & 30SL 2. 'i/A~ None Fil!er size  !.3/32" 8 1/8" 2. i./ A Preheat ~ 600F - ~ i _ Trade Name I.1/32" Acces: 1/3" Elrdvi$, IPT Ranse. 110'F throuch 3cC0F " ' ' 2.N/A l'WHT _ Iforte Describe Fi!!ct Etal if not included in Section IX P:sses/ Side I.Mult'nl* _2._ H / A No.of Arcs 1. Si nnl e* Current 1._ N/A

  • I.DCEP
                                                                                                                                                                               . Amps                            1.100 i'O                              _2. 3 FLUX OR ATMOSPHERE                                                                                                                                                                      _2. N/A i

Yolts 1.11 _2. H/A

                                         -Trade Name                I. -
2. N/A Trnvel Speed 1.2J-4 't IDM j

Shielding Gas I. Arcon - Oscilhtio:s _ 2. !!/ 4

1. _ 'I ' f. I.3/ " '**v Flow Rate _2. N /A
!                                                                 1.20 CR m m.                                            2._ '! / a Se.ad Type I. S h f9=*                             _2. '! / 3 P.rE, d

I.20 C:M Min. .

i 2._ N !. .

3 TENS!LE TEST

          .                    ~
                                          ' Specimen Ko.                                                        Dimensions                                                   ut m258 Width     i nickness                   Arc 2 Totsi                             Ultimate Unit                   '

Stress psi Character of Fsiire __ Losd LS. And Locatiers GW-462.1(a) 31 1.002 1.61a 1.617 .121.700 80.487 uC'J-462.1(a) 82.1.005 Meld Metal 1.a01 1 435' _ 1

                                                                                                                                                                 " ' '#4                                  28 A                                         * ** 1 d        "a"'

__ CUIDED BEND TESTS Type and Fig.are No. Result y ,F,, ,, Result OW-462.2(a) Side Satisfac-6ry j l. C'J-42.2(a) Side Satisfacterv uCW-462.2(a) Side i Satisfact:ry - C'.'

      .                                                                                                                                                                                      '62.2f a) Side                                          Sat'sfacterv                                             i l

Welder's Name _ Curtis Ma rcuis

                                                                                                                                                                                                                                                                                             ~!
;                                     Who by virtue of these tests meets weiderp.:rformance                                                                 5. 5. 'o . 260-64-7775            ter;uirerne-ts. .-                            Ses=, No._                   A *.J i

Test Conducted by_ Paterials E.cgte.eer' .g L:.:. Laboratory Test .';o. ~ per- *a. r. . W.<!: n. .udres: 02:e 3100 C11rten Oe.. F h s:: . .e,.2s - i

                        ,                                                                                                                                                                      Ma r n j , 1H?,,

We certify that the statements *n this record :re co: ::t ar'd that - ' sccordance with the r;quittm: .:s of S : tion LX cf the .!d.'.'C C:Je. the rest melds prepared, welded

                                                                                                                                                                                                                                                                      .v.J :ss:$5 Signed --                                             E0 5 E000.                         'PC.

('la..upeturer; o,,, 9- a e - 7Y y *~ o

                                                                                                                                                       . y
                                                                                                                                                                     /K(T&                                               %

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4

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                                                                                                                    - = -                                                                   ,

B g,

                                            ,,,/I.,M.. ..gj F,                    .     #d.! 1,%o       ; 82 .:,:"3 HOU: TION. TE X A$
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                                                                                                                                                                                                                                      <. a was.one:.      __M4    rr.v;t 5 :r., .:

4

                                                                                                                                                                                                        ^J,,'      . . .W            R Eva$10N- 3 WELDING CODE                                                                                                                                                                                     pact i os 2
                                   ~~AS$1E B & PV                                                                                                                                                                                   SUPPORTING PQR(S) 20606 SECTION lx WELDING PROCEDURE SPECIFICATION
  • 0 5 0 3.u 1 1 1. Rev. -

I. '. ) WELDING PROCESS (ES)

1. N **"* '** ..

1, -_ TYPE "--"C

                                     -                                          2.      e/s                                                                                                               -

TYPE '? ' A BASE META LS ive,-4031 P No. 8 _ Gr. No. 1_.to P Nor E FObii.E .0 HE AT TREATMc N T iCW-4071 - Gr. Pio. I tv .: M l Tnickness Range .147 d' 9 3 53 IN Temr nt. re - Mh Pi,e o,a Ran,e n %.o . Range for Fit:et. T.%All in. ue - w 4 O.J. '.'.0.I f.;"Li' ifs IN ' FILLER MET ~sLS (CW--8081

  • C t.'. IOW- 10J)

F No. I. 6 '.,n: ate.r 1 Gas ! *

                                                                                     . 2.                       'i/ 5 A No.1. -                9                                                                                    ree. .. Como.                                    IM

_2 " 'ft SFA Spec. No, l. S- 0 5. febn- Gas Flow Rate 1% 2.- ".E' E *;f OJ1 *~~^' '4 CFM (mm.) i AWS Cisss. No.1

                                                                -W*                           - 2.             *
  • Site of Electroce 1. * * -
                                                                                                                                          '* an : Shie:mog Gu Cor*.::,s. tion - -" 'Flow
                                                                                                                                                                                                                                          --           R9 _te- CFM (min.)

2.- d. . Size of Feller 1. P/ ' ' '/* ' ' Electroce - Flus Cr us- '; ' S lt:. F L ECTT.iCA1. CH AR ACTEf11STICS (CW-.109) Consumaele insert - . -. . .- iC . sinnt 1)'M - 2.- N/A ntal n,a*0c ... '"- fr-'- ri3

                                                                                                                                                                                                                        -.2             -

v::t: itan..a ~1 - ! !. s- - _2._ '!/2 _r

                                               .                                                                                   - ] . er m:i E!ee S.ie:T<pe                                              16"-l/B"/r Th.i -- 9 POSITION ICW- 805)                                 ,,

welcie; Pes : en _ A1 TECam:Odi :C //--. 10 We c.ng Pre. pen.on '

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Or i .x ,r Gas Ou, Site 1/** - I/2 ._ IN Preheat Terr.o *p 3 l.i.: J r 117.*trons creante.1 Wel&rg surfsces snali ce w.re trushen j i n:.:rcass . Temp. R ange -

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g Prenest Maint - . '. 3 2 1

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JCit47 C ES G?, (OW-C# _ 2. -- * /A Groove Ce. -r. I ' : .' e */ o r " ".-  : Tede :1..:. L ::tt:nce ';/ A _iN ) i '

nt Type Cd - '# "' . . . . : ,. ;r .,. c :,. 4, t _ IN  !

Cl- " / *. ._ . N.n'".c Ba:A:9; Matt Tvoe 51-i h r 20 h'SJ E'a /?" h. :;:,: - *: -

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pe ce 2.- '" i . RE!. TAR KS *This PQR i:.cl;2cr $.. ; le .an*.2

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erygen con:ent. It :ut,t of'ewidtr: .1:v the exitinf- .:.u <h.11 he : hee 2d for

           '                  Main:ain purge fora: 'es.: :va la                                                                 er b. iert velei:.. r1n :r . ence.

i Vas tinghous e su;f.ied c.. .po . .- yers G .v. . ::." and ne fill). t.hree layers (i.e. , rc : .ind :ve i lisi.  :=w ire ;.rc.e . air.h... :a for a: least i P i C.f P[. R / Tf 3rd/4.7PROV*.'.$ L.l ' ' " 'l /fp. d-) n e ,C; E, 4.we.e.:, - s t.T E (0 R *7'; F:: . Cc. ,s: i

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                    . ~ " * * ' ' \ * *.'

4 "

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             =

WELDIN:- "CCHNIQUE SHETT P NO. 4 -_. _ -.___ - .a _ GnouP 1 TO P NO - 8 ,, - , . . . ,.- -=-.,., -=- . . . c. . . . : . .. . . t . . .. . . v.

  • GROUP _1 os c:g35 W

THK. RANGE-- I ' I O '" ' M #

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ngvisiou _3 4 TvPicAt .oNr orsic~s PE=wirf Po C' 2 08 2 hs. . s rs 9.... .-rmm noor oPzNmc o e _1/14-ilih. '

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                                                           "                                                                                 t*AS LAYEp                                    SIZE                                                                                                                     ELECTntCAL DATA PhotE55                 f fN.)                  #^ICl#II                    r T'E lr L".s ci n A T) E TfPfl C FM                                                             l hAVEL ""*
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mAuct 1-3iGTA or 1"+/32

                                                                                                                                                            .                                                                                                                     gin ,

See Nets 5 nrgon 15 j5 . - OCSP 50-150 I 3-14 N/A 3/8 ' GTA 1/8 See Note 5 Argon-s 15 i5 DCSP 50-150 Alt <GTA or 3/32t See :~o:e 5 S-14 i N/A 3/S i g i f,r g o n , 15 i ::/A DCS? 50-150 8-14 ' N/A f 3& GTA 1/3 t  ! 3/8

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*ste 5 -Arg:n' r
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thichness v*f 2ny faslejdap**!':ri h,.yar shnll not extccd 1/ i PREME AT TEv'* f' r; i,;mai; _..___._.___._. _ ._.. , NTE AP ASS TE*.ip 38 t'.9n' t a t *

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                   ,     PREME AT M Al*JT. ~                                              'O                                                                                                                                "'*

h C.* ".T AC T T 'uE TO WOR *: !. 5 * * * ' ' e a.,. . ! on t:.,e 5.zE Tv**csTEN E LiCT Si2E 4. TvPE 3 i. .C'-I/3 . t / ~' - ' /' in ! . .N E.m. 1.er <.-EL ,..o. .. P. . carastoai p ...ra i ., i

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.

! 1. Prchen tempara:ure and i.terpass indicatingtempersectscir.yct .' bbec.: 1D

  • T) :, hill bc :h< Sed usi .3
2.
2. Tack welds shall e:picy t'c pars ::ics for :h:ran r;r" Crx.t aq.:11.
                                                                                                                                                                                                ;>a:           .

Tack welds shall be complete fusion; :a. by grinding so that the int:ial pu . sr.ar:s an ' stops sha.*; be ::pered 4 All velding shall utili:c :ringe r be.: . pre,pcily con. mc th :s n.  !

5. .

3.are wire selec:ed for she base :.cial :o .e valded shall be as foI i i

             ~

BASE METAL TYTE 1, .

                                   .                      ;04 or 304L to 304 or 3                                                                                                4.f._*ill?. 70 E 'MD

! L

         ~

316 or 316L to 31o or 311:*. FR235 or ER305L 303. or 30!.L to 315 or *1.*. EiOlo or T:.31ol Eh316 er E?.3*6*, . I Ter Ves:inghouse supplied ?.e..::or C:olan: i 6. base :e:a1 Cype 3G cr 3Ci; :: 316 er EfL.Piping, ER305 vill be used f:: Pur;c re uire en: n.:y La deh:ed for c:M: 7

he ?r:;e : '

a' eld in: En: ncer. voici or when spc:ified by ) Prehea: : sin:c.::ce sh.;'.1 :.s ecn:1 e.: I 8. veld in s:ill air. d tri ; v.r! !in; :nly; : :'. c:n:lc d  ! J I V:ris:icn in the join:  ! is single or double w eldcu ..na the tantgec.utries sh:v..:bave is permit cd previded the j; .: tolerances. .psting caintsinad within the spe-::: led 3 e

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l l - 1 h//7) i vb rv. _\ 1 HOUSTON. TEXAS U

                                                                                                                                                                      ;                                               880 5         -

WELDING *ROCEDURE SOE(.tTIOATION . 50608 CHM (fN, .

w. .,
                                -                                                                                                                                                         O R EV.

CURREPeT REVISiOP.S ARE IN i DATE o-: ORIGINATOR

                                                                                                                     -                                                                                                                   s 1                                                                                    _            3.      Bro.t-ki                            PAP 789VAp*

1 tMo [L T (LLi.o C ' J. l^- Bra-tedi_ 1 g V t.dl.0a- n-

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R EVISION NO. CESCRIBE TilC CHA7;GE 1 _ ficted POR revini.:n. detai}.:, nr.inv Revir.ed thickness rar.:;c, joint rcierenec :o c::*..c.' .alues s s;eeds. of amps and volts and deleted

                                                                                                                                                                             ~

2 ketypad in c, . fore. Idled the folic. int; infor:stion: filh -t :J c. '- cla.w isic.ut- . . ,

. u and dir.rutur, cle: trode - flur.

trailin; =hi *.i.e. rA.t :tiiatensnee, jo! .: description,

                                                                                                                                       . . * . :un
                                          -                                     type, initial                                                                              :. n size and type, head ce t! o.t . c n i '. ' . .
  • 0-n.. int r, us a le .nir.g ac:k : cuping vision. i.J d e......u. i.nd :a rc.'t .; h in . ::::ced Tih re .

s...p ..J k'es tinghe .:c r.'  ; ire- vol: val :es . t.dl;; 3 :n: :or k' P vulds. Added prchc..: s n:O rt .c. , ; .3ni. reo: spaci.~,, cup size r:n.es .

                                                                                                                   .e u 4 7 .- : 2 E .

Kevised :.._J.: -4 ru;:.; 4.

h:ed ? 3 r e vi.= i :n .

tion. .idd:J layer thickness li:ita-

  ~./
  • REVISION
  • MUST BE AP7 ROVED GY THE PA 0 3 1435 CE3iCf4EE
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                                       /M O MOG o r,C.                                                    souSToN. TEX AS
                                                                                                                                                                         --7 . _                                  WPS!POR HQ.

t 2 *.~ 7 - 20 __ 0 %?.u t 1: CHANGE NOTICE PROC E D'_'R E OU 2.*. TI.' ATION RF.CO RD 20609-OUALIFYING wit. DIN'a ?RDCEDURE ?J'ECIFsCATION Q Qi, ESSENTIAL VARIABLES CANNOT BE CHANGEO

                                                                                                                      ' CURRFNT REvissONS AR E INDICATED S
             '                         WPS.?OR                                   REV.

pg . Cr TE OR t'il% ATOR p..- - r. _ . _t . .  :. , APPR OV A L *

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                                                                                                                                                                                        -                                                            , . .gg WPSPQR. REVIstON NO.                                                                                                                                                                  .

DESCR:PJ THE CHANGE

                                'PQR                                    1 Deletien of Ica: 'ni a: pars: c:ers and ..ddition of k*cstinghouse 4

2 L'CA?-85 7? re fe ren ts. PQR 2

                                                                                   ?.etyr d .*n'r.ev f$rs.
                                                    -                                                                                  Added :he f e; *.cri :;: infor:stien:

j kPS r.u:" ranno thi:kneess e r , j c i .: sis.:ch i dir.er.sirnt , 0.t. range qualified-!

                                           -                    ~-

electrode-f;:: t:a:!fie<i ;str prc::* r. clee: rode size . Phil! type,: i. :i: 0cit.b ., cencunablo it...crt, .eelding pretressica, orifice or :ns cu virc..::.nge, p :r:;c flev rate, bead t.ridth, or single laia:". "; C:.an:.cd "rittes/ side" to "r.ulti electr de". Oelet.. ler e.f tires" tc "cultiple or single "hsckine", and " h: forence te "A: :.; hare trade nione", l pe r f:- ..:nr e req *.: t ro:.r .r =".

                                                                                                                                "c:. virtue cf :hs:t .ec:s eee:s sc *. der              -
                                                                                  "N/A". Inf.rr. sri: ;: . leuwiCh:nrel                                 r
li;er trade naec :o is er.!cred under '" e.o: v12 t h" r nd ' .dir. s ' '.;d :r d"SIA" i: .d *r "escilla: ion" osci!Intion.

C' - inde r J 1 20 Cili c;n. : e. 2 . hu t.:ir.:.,, .;:n i ' r .; rec fic. rc:e f rc:

                              ~4P S                                3 Dele:ed ref.:ren s t:                            s .:p - u r k
                                                                           ..    : ain u :..:nce ..nc 'e ; : . .:e ra :.e.gin: 7 R r. 1 act d pee.Jng, pre'.ca-PQR                                  3
                                                                                'Chr.n o "thickr..rs                       .

s cual.fied" : "l-peri:ed vel . 5g  : thicinust". l..:i ..: e:a; and type, pcen.::s ....: bru .x;.-i gir.;:

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ns on .

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1 i

  • flEvts Ow: uu:7 CE APPROVE t

D BY THE We % AGER OF LL ATEril ALS ENGINEER . M hr . * *'" _ MWg- -

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         , T 3aSE FAETALS 407. 403:                                                                                                                                                          _-                                                                                                                                       . .          . .

O 9 No O Gr. No I

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tLLER MST45 iCW-404 .
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} # No 1 6

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s No 1__ E -  ;. , u .. . ./,. .. .. 2 ,:....:.Le C. .~ * .? 1 ; c , ., _ _ ,. . _ _ . _ , , _ _ _ 3ea sat: N o . I .1:.~- .

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2 . S ".A.. AWSsoClass Site E.ce:::,,ce No 1 SI 1. I3N . . 3ME2 ..I.I.1. - it,* ,. i ;- . 4: . . , .. . _ _ _ .. _ . _._ C r rs

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R E VISIOti NO. ~ D E SCR!*.it tr4 E OF AN G E 1 Dele t i. :: vf ; i n it:; u t ;. :: ..:.vtc:: :. .ind t.ddi :ler.

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QW.201.1-QW 24.2 SECTION IX - PAllT QW WELDING i the necessary Procer%re Qualification Record (s) (PQR). QW.202 Type of Tests Requires.

20614 I

QW 202.1 MechanicalTests.The type and numb ! of test specimens that must be tested to qualify i s77 welding procedure are given in QW451.except tha

$78 QW 201.2 Procedure Qualifesrion Record (PQR),

where qualification is for Atlet welds only, the . h, De specisc facts including the base metal spe. ci5 cation Type and Grade (or chemical analysis and requirements are given in QW.202.2 and, where mechanical properties), and the essential variables qualineation is for stud welds only, the requirements are given in QW.202.3. All mechanical tests shall

(as listed in QW.252 through QW.282) used in qualifying a WPS shall be recorded in a form called meet the requirements prescribed in QW 150. QW.
160.QW-170.or QW.180 as applicable. .

I Procedure Qualification Record (PQR). This form 1 . shallalso record the test results. It is_recuired that the essential and nonessential QW 202.2 Base Metals -Groove and FIHet 4 Except for vessels or parts ofvessels constructed of P vahables or : WPS boroUowed in weldmit the test!! (excluding P.ll A Subgroup l'and 2) metals, WPS

                                                    ~

coupons. He WPS identdcanon (including case and qualiscation tests for groove and Met welds may revistos number) shall be listed on the PQR. These made on groove welds using reduced.section sension . documents shall be ceruned by the manufacturer or contractor and shah be available for examination by specimens and guided-bend specimens. De groov the Authorized laspector. A suggested format is weld tesu shall qualify the WPS for use with groo j welds within the range of essential variables listed, i given in QW483. This PQR format may be changed Groove. weld tests shan also qualify for use with Met ! to 6t the needs of each manufacturer or contractor. * !d i A change in any essential variable shall require _! s in aH thicknou- armetal sizen or nh .g i requalification, to be recorded in another PQR. A and diameters of nine ne tube _within the other

                                                                                       !1n.saminti applicable essential variables. Where a

! change in any nonessential variables does not require WPS qua tAcation of Met welds only is required, tests . requali5 cation. A change from one welding process to another welding process is considered a change inshah be made in accordance with QW 180.T I shall qualify the Allet WPS for use only with Met e an essentialvariable. welds in au thicknesses of metal, sizes of Met welds, ! s and diameters ofpipe or tube, for use within the other ! remaining applicable essential variables.

                   . - - QW 20lJ C^'s of Welding Processes or                            For vessels, or parts of vessels.<onstructed of P l!

! (eacluding Procedurus. More than one process or procedure may P ilA Subgroup I and 2) metals, WPS be used in a single production joint. Each welding qualiacation tests for groove welds shall be made on ' { process or procedure shall be qualified either sepa- groove welds using reduced.section tension speci- { mens and guided. bend specimens. The Groove. weld rately or in combination with other processes or l tests shau qualify the WPS for use only with groove procetures (within the thickness limits specified in QW.202.2, QW403, and QW451) for the base metal welds within the range of essential variables listed. - thickness and for the denosited wefd metal truckness WPS qualification tests for Met welds shan be made ) {

                         " rance for wh at The nme- m erocedures to be in inccordance with QW 180. The tests shall qual used in the productioiiFjoint. For'multiprocess or        the fillet WPS for use only with fillet welds in ai!               -

j multiprocedure applications, the qualised thickness thicknesses of metal..sizas of nilet welds, and diame. of each process or procedure shall not be additive in ters of pipe or tube, for use within the other remaima 1 applicable essential variables. determining the maximurn thickness of the pro. duction joint to be welded. One or more processes or. Groove weld procedure qualineations shall encom-procedures may be deleted from a production joint pass thickness ranges te be used in productien, for i

             '            qualified by a combination ofprocesses or procedures both the base metsis to bejoined or repaired and the provided each remaining process or procedure has          deposited weld metal to be used, except as aUowed in l

) been,in the spect5c combination welding process or (1) below for both the base metal and the deposited ' ) . weld metal. procedure qualineation, qualified (within the thick-l (/) For welding procedure quali6 cations made 1 ness limits specised in QW.202.2. QW-403, and QW. l 451) for the deposited wc!d metal thickness range for the SMAW. SAW. GTAW. GMAW, or PAW with ' cach of the processes or procedures to be used in the welding processe.s. using weld layer (s) of % in. (13

j. productionjoint.

mm) or less in thickness. there is no limit on the nunimum depth of deposited weld metal for reps.:t er i ' 22 L W e am a ~t 3 i i .. . . 1

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c'~ Ro ss 21189.0.. BRT

                                                                         = F A tvu r4 A Ti o r4 20630 1                    JUDGE BLOCH:   What's the difference?

2 - THE WITNESS: (??; Section NP you can construct

     *'                            3        something to. Section NF of the code gives you design 4

criteria, procurement criteria, installation criteria, and 5 inspection criteria. ,Section 9 does not do that. 6 JUDGE BLOCH: Okay. 7 BY MR. ROISMAN:

                               '8              Q       I'm going to show you what appears to be the QA 9

portion of the FSAR for Comanche Peak, and ask you if you 10 could identify in it -- show us the chart that you were 11 referring to that lists the stainless steel liner plates

                .              12          as "nonsafety." I don't think this is a trick question, I 13 7'                                      fust want the witness to do that so we will'have it pinned 14 down.-

15 MR. WATKINS: I do want to be sure this is the 16 current FSAR. 17 MR. ROISMAN: Okay. I think that's fair. 18 MR. WATKINS: I would like to ask or ask the 19 Chairman to ask whether the witness knows this is a 20 current copy of the FSAR. It's not an exhibit in this 21 phase of the proceeding.

  • 22 JUDGE BLOCH: Can the witness verify for us 23 whether or not this is a current copy of the FSAR?

24 THE WITNESS: No , I cannot. 25 MR. ROISMAN: Mr. Chairman, I assume it's 9 i

21189.0 , BRT 20631 1 possible to tell because there are amendment dates that 2 are on there. (2 The witness could tell us at least through kM 3 what date that's relevant. We are going through a whole 4 period of time here so there would be some relevance in at 5 least pinning that much down, even if we don't know that

                  ".6     we have the 1984 version.

7 JUDGE BLOCH: Mr. Watkins, how can we get a 8 stipulation as td having the current copy? 9 MR. WATKINS: I'm not objecting to questions 10 based on this document. We would like the opportunity to

                'll review that we know to be the current FSAR, so long as 12 it's understood that Mr. Brandt's answers are on the basis 13 of what this document is and I would like the pages of 14      this document on which he's questioned bound into the 15      record.                                                  '

16 JUDGE BLOCH: Any objection, Mr. Roisman? . 17 MR. ROISMAN: I don't have any objection to 18 having it bound in. I don't have an extra copy of it at 19 this moment. 20 JUDGE BLOCH: We'll arrange to have it bound in 21 as an exhibit with the understanding that Mr. Watkins will 22 correct it if he finds it's not the currents FSAR. 23 JUDGE GROSSMAN: Is it the current FSAR you want 24 anyway here? 25 MR. ROISMAN: It is the current. We have been

21189.O' BRT 20632 1 led to believe that this is. I can't independently verify 2 that. . 3 JUDGE BLOCH: Judge Grossman's que,stion was do 4 you want the current one or the earlier one that might 9 S' have been applicable when the liner plates were nade? 6 MR. ROISMAN': We are interested in both. We 7 want to know what it is now and what it was back then. 8 JUDGE BLOCH: The liner plates are still being 9 made? 10 MR. ROISMAN: There's still some fabrication on 11 them, is my understanding.

           ,                  12                     JUDGE GROSSMAN:   I haven't seen that.             Are there r                     13        dates on each page there?

14 MR. ROISMAN: Yes. It tells you " amendment as 15 of"'and then it gives a date which presumably are the most ' 16 current amendments. I believe the dates Mr. Brandt is-17 looking at appear to be 1981 -- well, no, there's some '82. 18 It just depends on when the amendment took place. s 19 JUDGE GROSSMAN: My recollection is that the 20 liner plates we are talking about, a lot of them were in 21 1981, those travelers. , .- 22 MR. ROISMAN: That's correct. Why don't we do 23 this. I had thought it was a quicker process. When we 24 take a break I'll take Mr.'Brandt -- 25 JUDGE BLOCH: We'll use that as a-basis for l m-. 3

y ,

   .            e a             s 21189.0 20633 BRT 1  questions and then Mr. Watkins will correct it if it turns 2  out to be wrong.
    /7)

NI 3 MR. ROISMAN: Mr. Brandt seems to be still 4 looking and rather than have us all sit and look, he can 5 do that at a break and I'll just move on to something else

                                                          ~

6 and he can do that later. . . 7 MR. WATKINS: I want to make sure he has enou'gh 8 time to review.

                                                                                              ~

9 JUDGE BLOCH: How much time do you need to 10 review that? 11- THE WITNESS: I don't know. The table is 50-something 12 pages long. 13 MR. ROISMAN: He indicated earlier, I think in 14 answer to a question about the appropriate table of the FSAR, 15 that this stainless steel liner was listed as "non-safety," 16 and I'm asking him to identify where that is in there. 17 MR. WATKINS: To correct the testimony, that it 18 was "non-ASME." 19 JUDGE BLOCH: Non-ASME. 20 MR. ROISMAN: I believe it was non-safety. I 21 don't know what his current testimony is but -- 22 THE WITNESS:

    ....                                              What I intended was n6n-ASME.       My 23     prefiled testimony clearly states that it is
     ~' )

24 safety-related, and it is considered safety-related by the 25 designer. L

r' ,

  , * * =

21189.~0 BRT 20634 k 1 JUDGE BLOCH: Why don't we accept Mr. Roisman's 2 suggestion and hold the study of that document for the 3 next break and we can prolong that break if Mr. Br&ndt 4 needs it. 5 MR. ROISMAN: Okay. 6 JUDGE PLOC : That would seem to be something 7 that could be handled by stipulation of counsel, frankly.

                                                                                              ~

8 I mean, that table either says it or it doesn't. 9 . MR . ROISMAN: I hope that's correct. 10 JUDGE BLOCH: I think we have shifted the. burden f 11 to Mr. Watkins reading it during the break. It seems we

           .           12    can have a stipulation of counsel as to what that table f                13    says or doesn't say.       It doesn't seem to me that we need 14    testimony as to whether it is or is not ASME in the table.

15 MR. WATKINS: I'll have to consult with my

                     '16     expert during the break, your Honor.

17 JUDGE BLOCH: Okay. 18 BY MR. ROISMAN: 19 0 I would like to take a look at weld 62, 63, and 20 64. If you have them there, I'll have them here and then 21 we can talk about them. 22 JUDGE BLOCH: The witness is looking for the 23 documents about that weld. This refers to the second set i ../ 24 of testimony and second filing? This is for your further 25 evidence submittal? N}}