ML20198L395
| ML20198L395 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/12/1984 |
| From: | Richards C NRC |
| To: | |
| Shared Package | |
| ML20197J316 | List:
|
| References | |
| FOIA-85-59 NUDOCS 8606040277 | |
| Download: ML20198L395 (200) | |
Text
I, Draft 3 10/12/84 AH-11, etc. /CP5 SSER
- 1. Allegation Group: Mechanical and Piping Category 43 Flper weldlag cad:4ieas fc :P
- 4"*( d- -i*
p..I t enar
- 2. Allegation Number: AM-11, AW-40, AW-42, AQW-80, AW-81, and AW-82
- 3. Characterization: It is alleged that:
(a) AM Incorrect fitup and poor welding technique resulted in thinweldsjoiningstainlesssteellinerplahfor t
fuel pools in the fuel building and reactor building for Unit 1.
(b) AW One seam is largely rust and concrete (c) AW Poor welding conditions for field installation of the stainless steel liners in the spent fuel pools of the fu'el handing facility. ,
(d) AQW Liner plate weld seams do not match drawing locations on floor around Unit I reactor vessel.
(e) AW The stainless steel floor plate liners in the spent fuel pool and transfer canal are supposed to overlap the angle at the bottom edge of wall to floor. There '
were areas of no overlap and weld was built up to meet.
(f) AW A single block, related to the leak chase channels under the floor liner of the fuel pools or fuel transfer canal is defective and could affect leak detection.
O [" =
g 60 g 7 860527 FO1 j
- 4. Assessment of Safety Significance: The TRT review for the evaluation of the above allegations included a study of the applicable specifications, drawings, procedures, documentation, regulatory guides, NRC Region IV investigation reports (irs) and NRC memos. The TRT also performed visual inspections of the fuel pool liners. The visual inspection was general for the overall liner 1'nstalaltion and a more expertise examination of approximately 20% of the welding in the spent fuel pool, reactor fuel pool, and fuel transfer canal. The areas of weld inspection covered the floor plate liners, those portions of the wall liners which were easily accessible from the F
floor, and areas adjacent to the sparger spray system which runs horizontally, about half way up two walls of the fuel pools. The liner installations are complete and the details of the leak chase channel network, and floor inbeds are not accessible for visual examination. The following is a briet lescription of the liner details: The wall liner plates are joined by f.ull penetrations butt welding using a backing strip. A C3x4.1 S.S channel is welded over the back side of every seam to provide a leak chase, where any leakage through a liner seam weld will be collected. The completed sections of wall ifners become the form for the pouring of concrete wall structure of the fuel pools. The concrete floor is poured prior to floor liner installation. The leak chase grooves in the floor are molded during the pouring of concrete usin? "blockouts". Also 3/8" x 2" bar strips are imbedded to be flush with the surface of the concrete floor. These imbeds form the lattice. work to which the
floor liner plates are fillet welded. Both the wall liner plates and floor imbeds are anchored in the concrete using nelson studs. The design features of the fuel pool liners include a system of drains where each drain connects to a sectional group of leak chase channels or grooves to provide an early detection system for leakage from a given number of seam welds. It also provides a means to recycle the captured leakage.
Gibb & Hill (G&H) specification 2323-55-18, Rev. 3 " stainless steel liners," and B&R's Quality Assurance Instruction QI-QAP-11.4, Rev. O, t
" welding inspection of stainless steel liners," cover the requirements for the fuel pool liners. Material is specified as ASTM grades of type 304L. Liner sheets are seal welded by inert gas-shielded (gas tungsten-arc) welding. Welding procedure qualifications and welders performances are required to be qualified in accordance with ASME B&PV _
l Code,Section IX. The required inspections are visual, liquid dye penetrant, and radiographed where specified by drawing. It also requires the entire length of all seal welds to be vacuum box leak tested. The liner system was also water leak tested. Surfaces of welds are required to be smooth and free of irregularities and may be ground to obtain this smooth finish. A weld reinforcement of 3/32" maximum and a weld undercut of 1/32" below minimum wall tolerance is pennitted. The G&H drawings 2323-5-0831 through 0834 show the liner l is fabricated predominantly from 3/16" and 1/4" sheet and assembled using fillet and full penetration groove welds.
O l-The TRT's visual inspection revealed that the placement of floor plate was not necessarily uniform. There were some areas where the gap between floor plates was such that the fillet welds washed together and one area gave the appearance of a butt weld. All wall liner butt welds were ground flush and most of the floor fillet welds were cosmetic ground. The inspection could not determine excessive butt gaps or where tightly butted joints would cause insufficient penetration. The examination did establish that gas tungsten-arc (GTA) welding, if not exclusively used, had been extensively used.
This conclusion was based on the appearance of unground welds. No F
butt welds were observed to have reinforcenent exceeding the 3/32" maximum. Seam weld undercut may exceed 1/32" in some locations. A more' cursory examination was made of liner welds in the fuel pools of "
Unit 2 and in all cases the general appearance of welding was smooth, clean, and sc"nd.
The TRT review included seismic and regulatory requirements that apply to the fuel pool liners.
The U. S. NRC Memorandum, dated February 6,1979:
For: R. T. Carlson, Chief, Reactor Construction and Engineering Support Branch, RI
. From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE
j
Subject:
Classification of Spent Fuel Liner Plates (A1TSF12193141)
(AITSF30382H1)
States . . . " fuel pool liners are not required to be designed and errected to seismic Category I requirements."
No where in the codes, specifications or Regulatory Guides are the liners for fuel pools specifically addressed. The U. S. NRC Regulatory Guide 1.29 classifies the spent fuel storage pool structure, including the fuel racks to seismic Category 1 design t
requirements. The liners become a permanant attachment, integral to the fuel pool structure. However, the liners serve no structural integrity. The U.S. NRC memorandum also states, " . . . The primary function is to provide a leak tight barrier and a surface suitable for decontamination, rather than to serve as a critical safety structure." The fuel pools are lined with stainless steel plate to provide durability, life expectancy and the stability of
- properties in an irradiated environment. The memorandum further states, " . . . The probability of large leaks occurring and being undetected over a period of time such that a potential hazard might be incurred is acceptably low." The fuel pool liners are, therefore, j classified as seismic Category II which refers to those portions of systems or components whose continued functioning is not required, but whose failure could reduce the funcWoning of any Category I
( system or component to an unacceptable level (as defined in Regulatory l
l Guide 1.29). The Regulatory Guide 1.29 also stated that l
the pertinent quality assurance requirements of Appendix B to
10 CFR Part 50 should be applied to all activities affecting the safety-related functions of those portions of structures, systems.,
and components which are classified as seismic Category II. The pertinent quality assurance requirements are defined and implemented by B&R's Instruction No. QI-QAP-11.1-4, Revision 0 and gives reference to B&R's CP-NDEP Manual.
The following is more specific to the allegations.
(a) AM-11 This allegation is concerned that:
(1) The fitup of 3/16" and 1/4" thick stainless steel liner plates '
for butt welding was supposed to result in a joint gap of 3/16" to 3/8" to facilitate making a full penetration weld but tightly butted joints were encountered. These joints were partial penetration welded by laying weld filler wire on the joint line and fusing it in.
(2) Gapped butt joints were incorrectly welded by either building up weld metal in the middle of the gap and then bridging the gap at the top with a thin weld or by~ laying weld rod in the gap and welding over it.
B&R Procedure CCP-38, Revision 4 (dated January 5,1984), Stainless Steel Liner Erection, was also reviewed. The 3/16" to 3/8" joint gap for fitup of stainless steel plates for butt welding, which is identified in paragraph 4.3.3 of CCP-38 and was a requirement
only for au'.omatic welding. Narrower weld gaps were identified as acceptable for manual welding. Howeve',
r the TRT notes that tightly butted joints would preclude making full penetration welds in the 3/16" and 1/4" thick liner plants using the manual GTAW process. All of the fuel pool liner welding were performed using the manual GTAW process.
(b) AW-40 This allegation is concerned with water from poured concrete.
It was stated that the water had entered leak chase channels and run past backing strips into weld joint areas. The '
allegation does not identify any specific weld or area.
However, the TRT's visual examination did detect two questional spots of corrosion. Both were on the north wall liner of Unit I spent fuel pool. A buildup of corrosion products was observed on a horizontal seam weld located about half way up the wall. The corrosion products were located between the midsupport for~ the pipe and the nearest light pole. The second questionable spot was in a horizontal seam below the sparger about level with the top of the fuel storage rack. It was located about opposite the northeast corner of the rack. There was no buildup of corrosion products but there was a light rust colored stain that appeard to have been caused by -
water leaking from a small spot in the weld seam. There was, however, no obvious hole or pore in the weld.
(c) AW Inasmuch as both Unit I and 2 fuel pools are complete, the current TRT visual examination could neither substantiate or refute the allegation regarding welding conditions, fitup, and welding technique during liner fabrication. However, reported by the NRC Region IV in IR 79-15 dated May 21, 1979, concluded that the allegation may be substantially true. In addition, DC/DDA 2946, Revision 1, dated November 13, 1978, documents a modification accomplished to drain leak chase channels containing water interfering with welding, supporting the NRC Region IV findings. At least to the extent of this evidence, welding conditions were not ideal, t
(d) AQW This allegation has similarities to allegations I
M-11 and AW-81. During the,TRT examination of liner welds, some lack of conformancy was noted; 1.e., variations in l
fitup gap, and certain areas giving the appearance of butt joint in lieu of an overlap. However, the TRT examination of the welds could find no evidence that the welds were not sound or that an adequate seal was not achieved. The RT's evaluation for safety significance is based -
on their visual examination of liner welds, the requirements that apply to the designed purpose of the liners and the final acceptance of the required NDE e aminations and leak tests. ,
(e) AW This allegation is similar to AQW-80 except that it applies to the floor plate where it mates with the wall plate. The floor plate is supposed to overlap and be fillet welded to the leg of angle attached at the o
-g_
bottom edge of the wall liner. The TRT did observe some apparent butt joints in this area. Where this conditinn exists, the TRT was unable to determine whether there was any weld buildup to compensate for an excessive fitup gap. The TRT's evaluation of safety significance is based on the same evidence as AQW-80-above.
(f) AQ Since the details of the leak chase channel network are not accessible for visual examination and due to the lack of specificity, the TRT review has attempted to -
identify the alleged " defective block" and evaluate the t
affect to the functional aspect of the leak chase system as well as safety significance, regardless of its location and extent of defect. The review of details shown in G8H drawings 2323-5-0831 through -0834 and B&R drawing WRB-10559 determined that only two items in the construction of the leak chase channels and floor grooves could apply to the alleged block:
(1) Blockouts - which were used to form the leak c'hase channels during the pouring of the concrete floor of the fuel pools. After the setting of concrete, the blockouts were removed and any chipping or.
damage to the chase was repaired.
(2) 3/8" x 2" Imbedded Bar which is shown to be imbedded and
~ flush to the surface of the concrete pool floor and anchored m using Nelson studs. The bars are centered between the leak chase grooves and form a grid framework to which the floor liner plates are fillet welded.
The review of documentation discovered a CPSES Design Change Authorization (DCA) No. 5687 where a 3/8" x 2" imbedded strip identified "F-15" was omitted. The DCA solution was: " Plates P186 and W135 shall be butt welded together and laid as one unit."
The location of this deviation. is at the junction of the fuel transfer canal and the cask pit entrance.
The TRT reviewed the drawings and determined that the functional purpose of the chase channels was not affected (to detect leakage ,
through the pool liner and to locate the leakage within a sectional area using the system of drains where a section of chase grooves t
empty into a single drain).
The TRT also reviewed transcripts where issues pertaining to the fuel pool liners were discussed from Sept.10 through Sept. 21, 1984.
These discussions question the adequacy of inspections and governing procedures, and the adherence to the procedures. For the most part, the activities which took place from the back side of the liners were discussed (the side which becomes the interface to the concrete).
i.e., tack welding the backing strip in place to accomplish the wall liner plate to plate fitup, and the attachment of the leak chase channels which are fillet welded and form the enclosure around the backing strip. The purpose of the leak channels does not include the intent to be a secondary seal to the plate to plate seal weld.
Therefore, there are no regulatory requirements for documentation of
)
I l
visual examinations for cleanliness of attachment locations to the back surface of the liners. The requirements which are established in accordance with the pertinent portions of Appendix B to the 10 CFR 50, and defined in B&R's Quality Instruction QA-QAP-ll.1-4, apply only to the plate to plate " seal" weld. Normally these requirements include visual examinations for cleanliness, fitup, and the completed weld; a liquid penetrant examination of the completed weld and a liquid film vacuum box " bubble" test for leakage. All of these examinations are performed to the front (exposed) surface. The fact that the backing strip is no longer visable from the back side is of no consequence.
t Over and above any regulatory requirement the drawings specified certain areas to be radiographed. Some of these areas did not receive the radiography but were dispositioned by NCR to be examined using the magnetic particle method. There were other areas that were examined by the Mass Spectrometer Leak Testing method. As mentioned earlier in this report, the pools were also " water" leak tested. QC personnel was permanently assigned to the areas of fabrication and installation of the fuel pool liners to monitor the activities. The allegations and transcribed discussions lack specificity to the extent that traceability to a specific occurrence cannot be positively shown.
However, documentation of nonconformances, conditions that were not ideal, and certain deviations to procedural sequence of operation were reviewed. -
- 5. Conclusion and Staff Positions: The TRT concludes that the basic requirement of seal welds to be leak tight has been obtained, and
3 that the applicable seismic and regulatory requirements have been satisfied. Due to the lack of specificity, the TRT cannot fully substantiate the allegations. Considering the possibility of substantial truth in the allegations, the TRT review finds no safety significance or generic implications. However, TUEC action is required for corrective measures of the questionable rust spots in the welds described and located in Item 4. )
AW-40, page 7 of this report.
- 6. Actions Required: TUEC shall inspect and evaluate the two suspicious spots in liner welds identified by the TRT. Should
, leak paths be verified, appropriate measures should be taken, t
both for repair of these spots and verification that additional such areas do not exist in the liners of the spent fuel pool, refueling cavity, transfer canals and cask loading pits within -
the Reactor Building and Fuel Building of Units 1 and 2.
- 8. Attachments: None
- 9. Reference Documents:
(a) G&I Sr :ification No. 2323-SS-18, Revision 3, April 6, 1979 i
" Stainless Steel Liners," issued for B&R Construction (b) G&I drawings:
(1) 2323-S-0831, "F.B. Spent Fuel Pool Liner Details" (2) 2323-S-0832, "F.B. Spent Fuel Pool Liner Details" l (3) 2323-S-0833, "F.B. Spent Fuel Pool Liner Details" 1
(4) 2323-S-0834, "F.B. Spent Fuel Pool Liner Details" l (c) B&R drawing WRB-10559, Sheet 1, " Fuel pool liners Imbeds -
Weld Identification No's" i
(d) B&R Procedures:
(1) QI-QAP-11.1-4, December 26, 1979, " Welding Inspection of Stainless Steel Liners" (deleted in error on January 15, 1982 and reissued.with no changes on Janaury 26,1982)
(2) CCP-38, Revision 4, dated January 5,1984, " Stainless Steel Liner Erection" (e) DC/DDA 2946 Revision 1, November 13, 1978 (f) Comanche Peak Steam Electric Station / Final Safety Analysis Report (CPSES/FSAR), Section 17.2, " Quality Assurance Requirements, and Section 3.2, " Design of Structures."
t (g) U.S. NRC memorandum, dated January 25, 1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: D. B. Vassallo, Assistant Director for Light Water Reactors, Division of Project Management, IE
Subject:
Classification of Spent Fuel Pool Liner Plates (AITS F1219H1) (AITS F30382H1)
(h) U.S. NRC memorandum, dated February 6,1979
. From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: R. T. Carlson, Chief, Reactor Construction and' Engineering Support Branch, RI
Subject:
Classificattan of Spent Fuel Pool Liner Plates (AITS F12193H1) (AITS F30382H1)
~
i
(i) U.S. NRC Regulatory Guide 1.29, Revision 3, September 1978,
" Seismic Design Classification" (j) Region IV Report 50-445/79-15; 50-446/79-15 (k) Allegation Source:
(1) AM-11 --- 84-006, 3/7/84, A-4 Testimony Pages 51, 52-55 (2) AW-40 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15 (3) AW-42 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15 (4) AQW-80 --- A-49, 8/8/84, and A-4, 8/24/84 (5) AW-81 --- A-4, 8/24/84 (6) AW-82 --- A-4, 8/24/84 -
- 10. This statement prepared by: MN Name Date Reviewed by: ,
Group Leader Date Approved by:
Project Director Date
. t 9
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l l
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, O . raft 3 10/12/64 7 AM-II, etc. /CP5 SSER
- 1. Allegation Group: Mechanical and Piping Category 43 Peer welda) c..(Ai,n3 $ ; ' -{w e( d . S e
, p..I t ener
- 2. Allegation Number: AM-11, AW-40, AW-42, AQW-80, AW-81, and AW-82
- 3. Characterization: It is alleged that:
(a) AM Incorrect fitup and poor welding technique resulted in thinweldsjoiningstainlesssteellinerplahsfor t
fuel pools in the fuel building and reactor building for Unit 1.
(b) AW One seam is largely rust and concrete (c) AW Poor welding conditions for field installation of the stainless steel liners in the spent fuel pools of the fuel handing facility. ,
(d) AQW Liner plate weld seams do not match drawing locations on floor around Unit I reactor vessel.
(e) AW The stainless steel floor plate liners in the spent fuel pool and transfer canal are supposed to overlap the angle at the bottom edge of wall to floor. There
~
were areas of no overlap and weld was built up to meet.
(f) AW A single block, related to the leak chase channels under the floor liner of the fuel pools or fuel transfer canal is defective and could affect leak detection.
L .
4 The TRT's visual inspection revealed that the placement of floor plate was not necessarily uniform. There were some areas where the cap between floor plates was such that the fillet welds washed together and one area gave the appearance of a butt weld. All wall liner butt welds were ground flush and most of.the floor fillet welds were cosmetic ground. The inspection could not determine excessive butt gaps or where tightly butted joints would cause insufficient penetration. The examination did establish that gas tungsten-arc (GTA) welding, if not exclusively used, had been extensively used.
This conclusion was based on the appearance of unground welds. No t
butt welds were observed to have reinforcement exceeding the 3/32" maximum. Seam weld undercut may exceed 1/32" in some locations. A more cursory examination was made of liner welds in the fuel pools of Unit 2 and in all cases the general appearance of welding was smooth,
~
clean, an'd sound.
The TRT~ review included seismic and regulatory requirements that apply to the fuel pool liners.
The U. S. NRC Memorandum, dated February 6,1979:
For: R. T. Carlson, Chief, Reactor Construction and Engineering Support Branch, RI l
l From: G. W. Reinmuth,- Assistant Director, Division of Reactor Construction Inspection, IE ,
l
. e - --
Subject:
Classification of Spent fuel Liner Plates (AIT5F12193141)
(AITSF30382H])
States . . . " fuel pool liners are not required to be designed and errected to seismic Category I requirements."
o where.in the codes, specifications or Regulatory Guides are the liners for fuel pools specifically addressed. The U. S. NRC ,
Regulatory Guide 1.29 classifies the spent fuel storage pool structure, including &efuelrackstoseismicCategory1 design g ~ --
~ -
4 requirements. /The liners become a permanant attachment, the fuel pool-4tructure. However, the liners serve no structural,)
i 45 integrity The U.S. NRC memorandum also states, " . . . The primary function is to provide a leak tight barrier and a surface suitable for deconta'mination, rather than to serve as a critical safety structure."/The fuel pools are lined with stainless stee
- plate to provide durability, life expectancy and the stability of,/
~ _-
- properties in an irradiated environment. The memorandum further states, " . . . The probability of large leaks occurring and being undetected over a period of time suMat a potential hazard might be incurred is acceptably . low." he fuel pool liners are, therefore, classified as seismic Category II refers to--thoseyrtQtms-et_
systems-or--sevenents whc5c -uvuti
_.-..------- .nued-functioning- is- not- required, but-wh61N enuld raduce the funct4cntng'o anfCate ' ~
systent-or--eponeni. te en unecceptchl: len hs defined in Regulatory 7 ~_ -_
Guide 1.29)[he Regulatory Guide 1.29 also stated that M J the pertinent quality assurance requirements of Appendix B to L
6 10 CFR Part 50 should be applied to all activities af fecting the safety-related functions of those portions of structures, systems.,
and components which are classified as seismic Category II. The pertinent quality assurance requirements are defined and implemented by B&R's Instruction No. QI-QAP-11.1-4, Revision 0 and gives i reference to B&R's CP-NDEP Manual.
The following is more specific to the allegations.
(a) AM-11 This allegation is concerned that:
i (1) The fitup of 3/16" and 1/4" thick stainless steel liner plates for butt welding was supposed to result in a joint gap of 3/16" to 3/8" to facilitate making a full penetration weld but tightly butted joints were encountered. These joints were partial penetration welded by laying weld filler wire on the joint line and fusing it in.
(2) Gapped butt joints were incorrectly welded by either building up weld metal in the middle of the gap and then bridging the gap at the top with a thin weld or by laying weld rod in the gap and welding over it.
~
B&R Procedure CCP-38, Revision 4 (dated January 5,1984), Stainless Steel Liner Erection, was also reviewed. The 3/16" to 3/8" joint gap for fitup of stainless steel plates for butt welding, which is id entified in paragraph 4.3.3 of CCP-38 and was a requirement L .
only for automatic welding. Narrower weld gaps wrre identified as acceptable for manual welding. However, the TRT notes that tightly butted joints would preclude making full penetration welds in the 3/16" and 1/4" thick liner plants using the manual GTAW process. All of the fuel pool liner welding were performed using the manual GTAW process.
(b) AW-40 This allegation is concerned with water from poured concrete.
It was stated that the water had entered leak chase channels 9'
and run past backing strips into weld joint areas. The allegation does not identify any specific weld or area.
However, the TRT's visual examination did detect two questional spots of corrosion. Both were on the north wall liner of Unit I spent fuel pool. A buildup of corrosion products was observed on a horizontal seam weld loctted about half way up the wall. The corrosion products were located between the midsupport for the pipe and the nearest light pole. The second questionable spot was in a horizontal seam below the sparger about level with the top of the fuel storage rack. It was located about opposite the northeast corner of the rack. There I
was no buildup of corrosion products but there was a light rust colored stain that appeard to have been caused by water leaking from a small spot in'the weld seam. There was, however, no obvious hole or pore in the weld.
b
.p.
(c) AW Inasmuch as both Unit I and 2 futi pools are complete, I
the current TRT visual examination could ntither substantiate or refute the allegation regarding welding conditions, fitup, and welding technique during liner f abrication. However, reported by the NRC Region IV in IR 79-15 dated May 21, 1979, concluded that the allegation may be substantially true. In addition, DC/DDA 2946, Revision 1, dated November 13, 1978, documents a modification accomplished to drain leak chase channels containing water interfering with welding,
, supporting the NRC Region IV findings. At least to the
- extent of this evidence, welding conditions were not ideal.
i (d) AQW Th'is allegation has similarities to allegations M-11 and AW-81. During the TRT examination of liner welds, some lack of conformancy was noted; i.e., variations in fitup gap, and certain areas giving the appearance of butt joint in lieu of an overlap. However, the TRT l examination of the welds could find no evidence that the welds were not sound or that an adequate seal was not achieved. The TRT's evaluation for safety significance is based on their visual examination of liner welds, the requirements that apply to the designed purpose of the liners and the final acceptance of the required NDE examinations and leak tests.
(e) AW This allegation is similar to AQW-80 except that it applies to the floor plate where it mates with the -
wall plate. The floor plate is supposed to overlap and be fillet welded to the leg of angle attached at the
.o.
bottor:. edge of the wall liner. The TRT did observe somc apparent butt joints in this area. Where this conditinn exists, the TRT was unable to detennine whether there was any weld buildup to compensate for ar. excessive fitup gap. The TRT's evaluation of safety significance is based on the same evidence as AQW-80 above.
(f) AQ Since the details of the leak chase channel network are not accessible for visual examination and due to the lack of specificity, the TRT review has attempted to identify the alleged " defective block" and evaluate the t
affect to the functional aspect of the leak chase system as well as safety significance, regardless of its location and extent of defect. The review of detail's .
shown in G&H drawings 2323-5-0831 through -0834 and B&R ,
drawing WRB-10559 determined that only two items in the construction of the leak chase channels and floor grooves could apply to the alleged block:
(1) Blockouts - which were used to form the leak chase channels during the pouring of the concrete floor of the fuel pools. After the setting of concrete,
! the blockouts were removed and any chipping or damage to the chase was repaired.
(2) 3/8" x 2" Imbedded Bar which is shown to be imbedded and l
flush to the surface of the concrete pool floor and anchored using Nelson studs. The bars are centered between the leak l
chase grooves and form a grid framework to which the floor liner plates are fillet welded.
a The review of documentation discovered a CPSES Design Change Authorization (DCA) No. 5687 where a 3/8" x 2" imbedded strip identified "F-15" was omitted. The DCA soluticn was: " Plates P186 and W135 shall be butt welded together and laid as one unit."
The location of this deviation is at the junction of the fuel transfer canal and the cask pit entrance.
The TRT reviewed the drawings and determined that the functional purpose of the chase channels was not affected (to detect leakage through the pool liner and to locate the leakage within a sectional area using the system of drains where a section of chase grooves empty into a single drain).
The TRT also reviewed transcripts where issues pertaining to the fuel pool liners were discussed from Sept.10 through Sept. 21, 1984.
These discussions question the adequacy of inspections and governing procedures, and the adherence to the procedures. For the most part, the activities which took place from the back side of the liners were discussed (the side which becomes the interface to the concrete).
l 1.e., tack welding the backing strip in place to accomplish the wall I
liner plate to plate fitup, and the attachment of the leak chase channels which are fillet welded and form the enclosure around the backing strip. The purpose of the leak channels does not include the
- intent to be a secondary seal to the plate to plate seal weld.
t Therefore, there are no regulatory requirements for documentation of l
l r i
l l
- 1 1 '-
visual examinations for cicanliness nf attachment locations to the back surface of the liners. The requirements which are established in accordance with the pertinent portions of Appendix B to the 10 CFR 50, and defined in B&R's Quality Instruction QA-QAP-11.1-4, apply only to the plate to plate " seal" weld. Normally these requirements include i
visual examinations for cleanliness, fitup, and the completed weld; a ,
liquid penetrant examination of the completed weld end a liquid film vacuum box " bubble" test for leakage. All of these examinations are performed to the front (exposed) surface. The fact that the backing strip is'no longer visable fran the back side is of no consequence.
i Over and above any regulatory requirement the drawings specified certain areas to be radiographed. Some of these areas did not receive the radiography but were dispositioned by NCR to be examined using the magnetic particle method. There were other areas that were examined by the Mass Spectrometer Leak Testing method. -As mentioned earlier in i
this report, the pools were also " water" leak tested. QC personnel was permanently assigned to the areas of fabrication and installation of the fuel pool liners to monitor the activities. The allegations and transcribed discussions lack specificity to the extent that traceability to a specific occurrence cannot be positively shown.
However, documentation of nonconformances, conditions that were not ideal, and certain deviations to procedural sequence of operation were reviewed.
- 5. Conclusion and Staff Positions: The TRT concludes that the basic requirement of seal welds to be leak tight has been obtained, and
[ _ _ _ _ _ _ _ _ _ _ _ _ - _ - -
)
that the applicable seismic and regulatory reovirements have been satisfied. Due to the lock of specificity, thc TRT cannot fully substentiate the allegations. Considering the possibility of substantial truth in the allegations, the TRT review finds no safety significance or generic implications. However, TUEC action is required for corrective measures of the questionable rust spots in the welds described and located in Item 4. )
AW-40, page 7 of this report.
- 6. Actions Required: TUEC shall inspect and evaluate the two suspicious spots in liner welds identified by the TRT. Should leak paths be verified, appropriate measures should be taken, both for repair of these spots and verification that additional if such areas do not exist in the liners of the spent fuel pool, refueling cavity, transfer canals and cask loading pits within the Reactor Building and Fuel Building of Units 1 and 2.
- 8. Attachments: None
- 9. Reference Documents:
(a) G&I Specification No. 2323-SS-18, Revision 3, April 6, 1979
" Stainless Steel Liners," issued for B&P, Construction l
l (b) G&I drawings:
(1) 2323-5-0831, "F.B. Spent Fuel Pool Liner Details" (2) 2323-S-0832, "F.B. Spent Fuel Pool Liner Details" (3) 2323-S-0833, "F.B. Spent Fuel Pool Liner Details"
. (4) 2323-S-0834, "F.B. Spent Fuel Pool Liner Details" (c) B&R drawing WRB-10559, Sheet 1, " Fuel pool liners Imbeds -
i Weld Identification No's" l
l-(d) B&R Procedures:
(1) QI-QAP-11.1-4, December 26, 1979, " Welding Inspection of Stainless Steel Liners" (deleted in error on January 15, 1982 and reissued with no changes on Janaury 26,1982)
(2) CCP-38, Revision 4, dated January 5, 1984, "Stainles's Steel Liner Erection" (e) DC/DDA 2946, Revision 1, November 13, 1978 (f) Comanche Peak Steam Electric Station / Final Safety Analysis Report (CPSES/FSAR), Section 17.2, " Quality Assurance Requirements, and Section 3.2, " Design of Structures."
t (g) U.S. NRC memorandum, dated January 25, 1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: D. B. Vassallo, Assistant Director for Light Water Reactors, Division of Project Management, IE
Subject:
Classification of Spent Fuel Pool Liner Plates l
(AITS F1219H1) (AITS F30382H1) f (h) U.S. NRC memorandum, dated February 6,1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: R. T. Carlson, Chief, Reactor Construction and 1
, Engineering Support Branch, RI
Subject:
Classification of Spent Fuel Pool Liner Plates (AITS F12193H1) (AITS F30382H1)
S
(i) U.S. NRC Regulatory Guide 1.?9, Revision 3, September 1978, "Scismic Design Classification" (j) Region IV Report 50-445/79-15; 50-446/79-15 (k) Allegation Source:
(1) AM-11 --- 84-006, 3/7/84, A-4 Testimony Pages 51, 52-55 (2) AW-40 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15 (3) AW-42 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15 (4) AQW-80 --- A-49, 8/8/84, and A-4, 8/24/84 (5) AW-81 --- A-4, 8/24/84 (6) AW-82 --- A-4, 8/24/84 t
- 10. This statement prepared by: d[
Name Date Reviewed by:
Group Leader Date-Approved by:
Project Director Date e
O e O
t # , , , . . ,., ijg g AIG : 1, e t c . ( DC I"., )
- 1. Allegation Group: Mechanical and Piping Category No. 43j Poor Welding Conditions for Spent Fuel Storage Pool Liner
- 2. Allegation Number: AM-11, AW-40, AW-42, AQW-80, AW-81, and AW-82
- 3. Characterization: It is alleged that:
(a) AM Incorrect fitup and poor welding technique resulted in thin welds joining stainless steel liner plates for fuel pools in the fuel building and reactor building for Unit 1.
(b) AW One weld seam in the spent fuel pool liner is largely rust and concrete.
(c) AW Poor welding conditions existed for field installation of the stainless steel liners in the spent fuel pools of the fuel handing facility.
(d) AQW Liner plate weld seams do not match drawing locations on the flooring around the Unit I reactor vessel pool.
l (e) AW The stainless steel floor plate liners in the spent fuel pool and transfer canal are supposed to overlap the angle member at the bottom edge of the wall-to-floor joint. There were areas of no overlap and the weld was built up to bridge a gap.
(f) AW-82 . A single block related to the leak chase cnannels under the floor liner of the fuel pools or fuel transfer canal is defective and could affect leak detection.
F0W yoy
\
- 4. Assessment of Safety Significance: The TRT review for the evaluation of the above allegations included a study of the applicable specifications, drawings, procedures, documentation, regulatory guides, NRC Region IV inspection reports (irs) and NRC memos. The TRT review included seismic and regulatory requirements that apply to the fuel pool liners.
The TRT also performed visual inspections of the fuel pool liners.
The visual inspection was general for the overall liner installation and included a more detailed examination of approximately 20% of the' s/
weld in the spent fuel poolsf and fuel transfer canals. The areas of a weld inspection covered the floor plate liners, those portions of the wall liners which were easily accessible from the floor, and areas adjacent to the sparger spray system which runs horizontally, about half-way up two walls of each of the spent fuel pools. The liner installations are complete and the details of the leak chase channel networks, and floor imbedments are not accessible for visual examination.
The TRT's visual inspection revealed that the placement of floor plath r was not necessarily uniform. There were some areas where the gap between floor plates was such that the fillet welds washed together and one area gave the appearance of a butt weld. All wall liner butt welds were ground flush aitti most of the floor fillet welds were
cosmetic ground. The inspection could not deternine excessive butt gaps or where tightly butted joints would cause insufficient penetration. The examination did establish that gas tungsten-arc (GTA) welding,1f not exclusively used, had been extensively used.
This conclusion was based on the appearance of unground welds. 143 butt welds were observed to have reinforcement exceeding the 3/32" maximum. Seam weld undercut may exceed the specified 1/32" maximum in
~
some locations. A more cursory examination was made of liner welds in the fuel pools of Unit 2 and in all cases the general appearance of welding was smooth, clean, and sound.
(a) AM-11 This allegation is concerned that:
(1) The fitup of 3/16" and 1/4" thick stainless steel liner plates for butt welding was supposed to result in a joint gap of 3/16" to 3/8" to facilitate reking a full penetration
. weld, but welders encountered tightly butted joints. These joints were partial-penetration welded by laying weld filler wire on the joint line and fusing it in.
(2) Gapped butt joints were incorrectly welded by either building up weld metal in the middle of the gap and then bridging the gap at the top with a thin weld or by laying weld rod in the gap and welding over it.
e e
- - _ _ . . _ . _ - _ _ _ _ . ._ ^
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4 B&R Procedure CCP-38, Revision 4 (dated January 5,1984),
Stainless Steel Liner Erection specifiedthat3/16"to37)"
joint gap for fitup of stainless steel plates for butt welding was a requirement only for automatic welding. Narrower weld gaps were acceptable for manual welding. However, the TRT notes that tightly butted joints would preclude making full penetration welds in the 3/16" and 1/4" thick liner plates using the specified manual GTAW process. All of the fuel pool liner iding was apparently performed using the manual GTAW process.
(b )' AW-40 The allegation states that water from poured concrete had entered leak chase channels and run past backing strips into weld joint areas. The allegation does not identify any specific weld or i
area. However, the TRT's visual examination did detect two questionable spots of corrosion. Both were on the north
{
wall liner of Unit I spent fuel pool. A buildup of corrosion products was observed on a horizontal seam weld located about half way up.the wall. The corrosion l products were located between the midsupport for the pipe and the nearest light pole. The second questionable spot observed by the TRT was in a horizontal seam below the sparger about level with the top of the fuel storage rack. It was located opposite the northeast corner of the rack. There-was no buildup of corrosion products but there was a light .
rust colored stain that appeard to have been caused by water leaking from a small spot in the weld seam. However, the TRT could find no obvious hole or pore in the weld. l
. l
(c) AW-42 Inasmuch as both Unit 1 and 2 spent fuel pools are complete.
TRT visual examination could neither substantiate nor refute the allegation regarding poor welding conditions, incorrect fitup, and poor welding technique during liner fabrication. However, NRC Region IV IR 79-15 dated May 21, 1979, concluded that the allegation may be substantially true. In addition, DC/DDA 2946, Revision 1, dated November 13, 1978, documents a modification made to drain leak chase channels containing water interfering with welding, a modification supporting the NRC Region IV findings. At least to the extent of this evidence, welding conditions were not ideal. -
(d) AQW-80 This allegation has similarities to allegations AM-11 and AW-81.
During the TRT examination of liner welds, some lack of conformancy was noted; i.e., possible variations in fitup gap, and certain areas giving the appearance of butt joint in lieu of an overlap. However, the TRT examination of the welds could find no evidence that the welds were not sound or that an adequate seal was not achieved. The TRT's evaluation for safety significance is based on its visual examination of liner welds, the requirements that apply to the design purpose of the liners and the final acceptance of the required NDE examinations and leak tests.
O 3ema
(e) AW This allegation is similar to AQW-80 except that it applies to the floor plate where it mates with the wall plate. The floor plate is supposed to overlap and be fillet welded to the leg of the angle attached at the bottom edge of the wall liner. The TRT did observe some apparent butt joints in'this area. Where this condition exists, the TRT was unable to deterinine whether there was any weld buildup t.o compensate for an excessive fitup gap. The TRT's evaluation of safety significance is based on the same evidence as AQW-80 above.
(f) AW-82 Since the details of the leak chase ch'annel network are not accessible for visual examination and because the allegation lacks specificity, the TRT review has attempted to identify ~ the alleged " defective block" and evaluate the affect on the function of the leak chase system as well as its safety significance, regardless of the location and extent of the defect. A review of details shown in G&H drawings 2323-5-0831 through -0834 and B&R drawing WRB-10559 determined that only two items in the construction of the leak chase channels and floor grooves could apply to the alleged block:
(1) Blockouts - These are wood blocks used to form the leak chase channels during the pouring of the concrete floor of the fuel pools. After the-setting of concrete, the blockouts were removed and any chipping or damage to the chase was repaired.
l
(2) 3/8" x 2" . Imbedded Bars - These are bars imbedded in and flush with the. surface of the concrete pool floor and anchored using Nelson studs. The bars are centered between the leak chase grooves and fann a grid framework tr which ,
the floor liner plates are fillet welded.
In its review of documentation, the TRT discovered CPSES Design Change Authorization (DCA) No. 5687 where a 3/8" x 2" imbedded 4
strip identified as "F-15" was omitted. The DCA solution was that: " Plates P186 and W135 shall be butt welded together and laid as one unit." The location of this deviation is at the '
junction of the fuel transfer canal and the cask pit entrance.
The TRT reviewed the drawings and detennined that the functional purpose of the chase channels (to detect leakage through the pool liner and to locate the leakage within a sectional a.rea using the system of drains where a section of chase grooves empty into a l
single drain) was not affected.
The TRT also reviewed ASLB testimony where issues pertaining to the fuel pool liners were discussed from Sept.10 through Sept.
21, 1984. These discussions question the adequacy of inspections and governing procedures, and adherence to the procedures. For the most part, the activities which took place from the back side of the liners (the side which becomes the boundary to the concrete) were discussed in the testimony, i.e., tack welding the
m.
.a. -
V backing strip in place to accomplish the wall liner plate-to-
, plate fitup, and the attachment of the leak chase channels which are fillet welded and form the enclosure around the backing
- strip. The purpose of the leak channels does not include the 70 j' [l ' t
! intent to be a secondary seal to the plate-to-plate seal weld.
7 hgerefore, there are no regulatory requirements for documentation D b of visual examinations for cleanliness of attachment locations to (Qt d -
Y
- h. thebacksurfaceofthelinersyb requirements which are k y established in accordfince with the pertinent portions of Appendix fl 1 B to the 10 CFR 50, and defined in B&R's Quality Instruction QA-QAP-ll.1-4, apply only to the plate to plate " seal" weld.
-e y phese requirements include visual examinations for cleanliness, fitup, and the completed weld; a liquid penetrant examination of the completed weld and a liquid film vacuum box
" bubble" test for leakage. All of these examinations are perfonned at' the ' front (exposed) surface. _ The fact that the 7
. backing stri ra longer visible from the back side is of no consequence. Over and above any regulatory requirement thp_ _
X
/ O (rawings specified certain areas .to be radiographe SI letter e
'E 6 !
TUQ-041 dated September 4,1975 to B&R permitted the substitution 5
/*~g k of magnetic particle inspection AW o'es \ in lieu of rad vertical' containment liner we,lds in the =cter cavy 4.t'(The TRT
, notes that magnetic particle inspection is not applicable to the'
/ y liner material, which 'is type 304L austenitic stainless steel.
l e$F y It is probable that liquid penetrant inspection was actually
,g ,
used. There were other areas that were examined by the Mass As mentioned earlier in. this +
Spectrometer Leak TestingJ'~ hod.
4' msy wM A
d . $ ~h > l Q C -u4 -s -
SSER, the pools were also " water" leak tested. QC personnel were permanently assigned to the areas of fabrication and installation of the fuel pool liners to monitor the activities. The allegations and transcribed discussions lack specificity to the extent that trat.eability to a specific occurrence cannot be positively shown.
However, documentation of nonconformances, conditions that were not ideal, and certain deviations to procedural sequence of operation were reviewed.
- 5. Conclusion and Staff Positions: The TRT's review established that considerable difficulty was encountered in fabrication and "t
installation of the liners. Documentation in'part substantiated the allega owever, the primary function of the stainless steeb q # O,' liners is to provide a leak tight barrier and a surface which' may be
/ easily decontaminated. The TRT concludes that these basic I b }
[V requirements have.been met. The TRT also established, on the basis of i y a U.S. NRC Memorandum entitle Classification of Spent Fuel Liner
/ f.
Plate dM February .6,1979, that fuel pool liners are not requir
/p , jttbe designed and erected to Seismic Category I requirements. The 1' . fy.t ninA. n
.A (d TRT, therefore, concludes 19se allegations hav @e.ao safety significance Y p s-er generic implications. !
P g4
/) ,
w&um sw % urns, f 6 Actions Recuired: TUEC shall inspect and evaluate the two suspicious spots in liner welds identified by the TRT. Should leak paths bep verified, appropriate measures should be t en, '
q vv s s r h .
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f
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/ ls4 \ v (} v 4 0-v '
'e A .
- f both to repair these spots and to verify that additional areas of this kind do not exist in the liners of the spent fuel pool, refueling cavity, transfer canals and cask loading pits within the Reactor Building and Fuel Building of Units 1 and 2. !-h i ; 3
- i - * " ' - N r
cc.4 1cied pi ivi 6. ;tt 9 ~ + a' 51 pm-;r (
- 8. Attachments: None.
- 9. Reference Documents:
- 1. G&I Specification No. 2323-55-18, Revision 3, April 6, 1979
~
{-
" Stainless Steel Liners," issued for B&R Construction
- 2. G&I drawings:
(1) 2323-S-0831, "F.B. Spent Fuel Pool Liner Details."
(2) 2323-5-0832, "F.B. Spent Fuel Pool Liner Details." .
(3) 2323-5-0833, "F.B. Spent Fuel Pool Liner Details.."
(4) 2323-S-0834, "F.B. Spent Fuel Pool Liner Details."
- 3. B&R drawing WRB-10559, Sheet 1, " Fuel pool liners Imbeds -
Weld Identification No's."
- 4.
- B&R Procedures:
(1) QI-QAP-11.1-4, December 26, 1979, " Welding Inspection of Stainless Steel Liners" (deleted in error on January 15, 1982 and reissued with no changes on Janaury 26,1982).
(2) CCP-38, Revision 4, dated January 5, 1984, " Stainless Steel Liner Erection."
l' l
ql
. 5. DC/DDA 2946 Revision 1, November 13, 1978.
- 6. Comanche Peak Steam Electric Station / Final Safety Analysis Report (CPSES/FSAR), Section 17.2, " Quality Assurance Requirements, and Section 3.2 " Design of Structures "
- 7. U.S. NRC memorandum, dated January 25, 1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE ,
To: D. B. Vassallo, Assistant Director for Light Water .
)
Reactors, Division of Project Management, IE l
Subject:
Classification of Spent Fuel Pool Liner Plates j (AITS F1219H1) (AITS F30382H1).
'8. U.S. NRC memorandum, dated February 6,1979
~
From: G. W. Reinmuth Assistant Director, Division of Reactor Construction Inspection, IE. - '
To: R. T. Carlson, Chief, Reactor Construction and Engineering Support Branch, RI
Subject:
Classification of Spent Fuel Pool Liner Plates (AITSF12193H1)(AITSF30382H1).
- 9. U.S. NRC Regulatory Guide 1.29, Revision 3, September 1978,
" Seismic Design Classification."
- 10. Region IV Report 50-445/79-15; 50-446/79-15.
- 11. Allegation Source:
(1) AM-11 --- 84-006, 3/7/84, A-4 Testimony Pages 51, 52-55.
(2) AW-40 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15.
(3) AW-42 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15.
(4) AQW-80 --- A-49, 8/8/84, and A-4, 8/24/84.
e e.
(5) AW-81 --- A-4, 8/24/84 (6) AW-82 --- A-4, 8/24/84.
~
- 10. This statement pr.epared by:
E. G. Thompson Date C. Richards,
. TRT Technical Reviewers t
T Reviewed by:
L. C. Shao, Date Group Leader A'pproved by:
l V. Noonan, Date Project Director I
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Admi ni str ati ve Wr'iteup integrated into SEER ___________
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Workpackage File Complete __ __________.
Wortpackage Returned to Group Leader __________
F0lA-85-59 L L //O
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AM-11, etc. (DCP5)
SSER
- 1. Allegation Group: Mechanical and Piping Category No. 43j Poor Welding Conditions for Spent Fuel Storage Pool Liner
- 2. Allegation Number: AM-11, AW-40, AW-42, AQW-80, AW-81, and AW-82
- 3. Characterization: It is alleged that:
(a) AM Incorrect fitup and poor welding technique resulted in thin welds joining stainless steel liner plates for fuel pools in the fuel building and reactor building for Unit 1.
(b) AW One weld seam in the spent fuel pool liner is largely rust and concrete.
(c) AW Poor welding conditions existed for field installation
~
of the stainless steel liners in the spent fuel pools of the fuel handing facility.
(d). AQW Liner plate weld seams do not match drawing locations on the flooring around the Unit I reactor vessel pool.
(e) AW The stainless steel fl.cor plate liners in the spent fuel pool and transfer canal are supposed to overlap the angle member at the bottom edge of the wall-to-floor joint. There were areas of no overlap and the weld was built up to bridge a gap. -
(f) AW A single block related to the leak chase channels under the floor liner of the fuel pools or fuel transfer canal is defective and could affect leak detection.
L .
2
~
- 4. Assessment of Safety Significance: The TRT review for the evaluation of the above allegations included a study of the applicable specifications, drawings, procedures, documentation, regulatory guides, NRC Region IV inspection reports (irs) and NRC memos. The TRT review included seismic and regulatory requirements that apply to the fuel pool liners.
The TRT also performed visual inspections of the fuel pool liners.
The visual inspection was general for the overall liner installation and included a more detailed examination of approximately 20% of the
/
weld in the spent fuel pools;fand fuel transfer canals. The areas of 1-weld inspection covered the floor plate liners, those portions of the wall liners which were easily accessible from the floor, and areas adjacent to the sparger spray system which runs horizontally, about half way up two walls of each of the spent fuel pools. The liner installations are complete and the details of the leak chase channel networks, and floor imbedments are not accessible for visual examination.
The TRT's visual inspection revealed that the placement of floor plate ][ r was not necessarily uniform. There were some areas where the gap between floor plates was such that the fillet welds washed together and one area gave the appearance of a butt weld. All wall liner butt welds were ground flush and most of the floor fillet welds were L
cosmetic ground. The inspection could not determine excessive butt gaps or where tightly butted joints would cause insufficient penetration. The examination did establish that gas tungsten-arc (GTA) welding, i.f not exclusively used, had been extensively used.
This conclusion was based on the appearance of unground welds. No butt welds were observed to have reinforcement exceeding the 3/32" maximum. Seam weld undercut may exceed the specified 1/32" maximum in some locations. A more cursory examination was made of liner welds in the fuel pools of Unit 2 and in all cases the general appearance of welding was smooth, clean, and sound.
(a) AM-11 This allegation is concerned that:
(1) The fitup of 3/16" and 1/4" thick stainless steel liner plates for butt welding was supposed to result in a joint
~
gap of 3/16" to 3/8" to facilitate making a full penetration weld, but welders encountered tightly butted joints. These joints were partial-penetration welded by laying weld filler wire on the joint line and fusing it in.
-(2) Gapped butt joints were incorrectly welded by either building up weld metal in the middle of the gap and then bridging the gap at the top with a thin weld or by laying weld rod in the gap and welding over it.
B&R Procedure CCP-38, Revision 4 (dated January 5,1984),
Stainless Steel Liner Erectio specified that 3/16" to 3/8" 4
joint gap for fitup of stainless steel plates for butt welding was a requirement only for automatic welding. Narrower weld gaps were acceptable for manual welding. However, the TRT notes that tightly butt'ed joints would preclude making full penetration welds in the 3/16" and 1/4" thick liner plates using the specified manual GTAW process. All of the fuel pool liner welding was apparently perfonned using the manual GTAW process.
(b) AW-40 The allegation states that water from poured concrete had entered leak chase channels and run past backing strips into weld joint areas. The ' allegation does not identify any specific weld or area. However, the TRT's visual examination did detect two questionable spots of corrosion. Both were on the north wa'11 liner of Unit 1 spent fuel pool. A buildup of corrosion products was observed on a horizontal seam weld located about half way up the wall. The corrosion pro' ducts were located between the midsupport for the pipe and the nearest light pole. The second questionable spot observed by the TRT was in a horizontal seam below the sparger about level with the top of the fuel storage rack. It was located opposite the northeast corner of the rack. There was no buildup of corrosion products but there was a light rust colored stain that appeard to have been caused by water leeking from a small spot in the weld seam. However, the TRT could find no obvious hole or pore in the weld.
L
1 (c) AW-42 Inasmuch as both Unit I and 2 spent fuel pools are complete.
TRT visual examination could neither substantiate nor refute the allegation regarding poor welding conditions, incorrect fitup, and poor ; welding technique during liner fabrication. However, NRC Region IV IR 79-15 dated May 21, 1979, concluded that the allegation may be substantially true. In addition, DC/DDA 2946, Revision 1, dated November 13, 1978, documents a modification made to drain leak chase channels containing water interfering with welding, a modification supporting the NRC Region IV findings. At least to the extent of this evidence, welding i
conditions were not ideal.
i (d) AQW-80 This allegation has similarities to allegations AM-11 and AW-81.
During the TRT examination of liner welds, sdme lack of conformancy was noted; 1.e., possible variations in fitup gap, and certain areas giving the appearance of butt joint in lieu of an overlap. However, the TRT examination of the welds could find no evidence that the welds were not sound or that an adequate seal was not achieved. The TRT's evaluation for safety significance is based on its visual examination of liner welds, the requirements that apply to the design purpose of the liners and the final acceptance of the required NDE examinations and leak tests. .
(e) AW This allegation is similar to AQW-80 except that it applies to the floor plate where it mates with the wall plate. The floor plate is supposed to overlap and be fillet welded to the leg of the angle attached at the bottom edge of the wall liner. The TRT did observe some apparent but't joints in this area. Where this condition exists, the TRT was unable to determine whether there was any weld buildup to compensate for an excessive fitup gap. The TRT's evaluation of safety significance is based on the same evidence as AQW-80 above.
(f) AW-82 Since the details of the leak chase channel network are not accessible for visual examination and because the allegation lacks specificity, the TRT review has attempted to identify the l
alleged "de'fective block" and evaluate the affect on the function of the leak chase system as well as its safety significance, regardless of the location and extent of the defect. A review of details shown in G&H drawings 2323-5-0831 through -0834 and B&R drawing WRB-10559 determined that only two items in the construction of the leak chase channels and floor grooves could apply to the alleged block:
(1) Blockouts - These are wood blocks used to form the leak chase channels during the pouring of the concsete floor of the fuel pools. After the setting of concrete, the blockouts were removed and any chipping or damage to the chase was repaired, l
(2) 3/8" x 2" Imbedded Bars - These are bars imbedded in and flush with the surface of the concrete pool floor and anchored using Nelson studs. The bars are centered between the leak chase grooves and form a grid framework to which the floor liner plates are fillet welded.
In its review of documentation, the TRT discovered CPSES Design Change Authorization (DCA) No. 5687 where a 3/8" x 2" imbedded strip identified as "F-15" was omitted. The DCA solution was that: " Plates P186 and W135 shall be butt welded together and laid as one unit." The location of this deviation is at the junction of the fuel transfer canal and the cask pit entrance.
The TRT reviewed the drawings and determined that the functional purpose of the chase channels (to detect leakage through the pool i liner and to locate the leakage within a sectional area using the system of drains where a section of chase grooves empty into a single drain) was not affected.
l The TRT also reviewed ASLB testimony where issues pertaining to the fuel pool liners were discussed from Sept.10 through Sept.
21, 1984. These discussions question the adequacy of inspections l and governing procedures, and adherence to the procedures. For the most part, the activities which took place from the back side of the liners (the side which becomes the boundary to the -
concrete) were discussed in the testimony, i.e., tack welding the i
j backing strip in place to accomplish the wall liner plate-to- l plate fitup, and the attachment of the leak chase channels which are fillet welded and form the enclosure around the backing strip. The purpose of the leak channels does not include the j intent to be a secondary seal to the plate-to-plate seal weld.
Therefore, th'ere are no regulatory requirements for documentation of visual examinations for cleanliness of attachment locations to I
the back surface of the liners. The requirements which are established in accordance with the pertinent portions of Appendix
) B to the 10 CFR 50, and defined in B&R's Quality Instruction QA-QAP-ll.1-4, apply only to the plate to plate " seal" weld.
l Normally these requirements include visual examinations -for cleanliness, fitup, and the completed weld; a liquid penetrant examination of the completed weld and a liquid film vacuum box
" bubble" test for leakage. All of these examinations are i performedatthefront(exposed) surface. The fact that the 1
l backing stri is no longer visible from the back side is of no consequence. Over and above any regulatory requirement the /
l ^
! drawings specified certain areas to be radiographed. TUSI letter i
TUQ-041 dated September 4,1975 to B&R pemitted the substitution of magnetic particle inspection in lieu of radiography for vertical containment liner welds in the reactor cavity. (The TRT notes that magnetic particle inspection is not applicable to the
. liner material, which is type 304L austenitic stainless steel.
It is probable that liquid penetrant inspection was actually .
, used. There were other areas that were examined by the Mass Spectrometer Leak Testing method. As mentioned earlier in this L
6 SSER, the pools were also " water" leak tested. QC personnel were permanently assigned to the areas of fabrication and installation of the fuel pool liners to monitor the activities. The allegations
- and transcribed discussions lack specificity to the extent that traceability to a specific occurrence cannot be positively shown.
However, documentation of nonconformances, conditions that were not ideal, and certain deviations to procedural sequence of operation were reviewed.
- 5. Conclusion and Staff Positions: The TRT's review established that considerable difficulty was encountered in fabrication and installation of the liners. Documentation in part substantiated the allegations. However, the primary function of the stainless steel liners is to provide a leak tight barrier and a surface which may be easily decontaminated. The TRT concludes that these basic l
requirements have been met. The TRT also established, on the basis of a U.S. NRC Memorandum entitle Classification of Spent Fuel Liner n Plate M February 6,1979, that fuel pool liners are not required to be designed and erected to Seismic Category I requirements. The PfAM TRT, therefore, concludes itse allegations hav(e\LdW me safety significance s-er generic implications. !
P
)sp YK hr&, EGbY 'k fW^3
- 6. Actions Required: TUEC shall inspect and evaluate the two A
suspicious spots in liner welds identified by the TRT. Should leak paths be verified, appropriate measures should be taken, i
m _ _ -__
both to repair these spots and to verify that additional areas of this kind do not exist in the liners of the spent fuel pool, refueling cavity, transfer canals and cask loading pits within the Reactor
- Building and Fuel Building of Units 1 and 2. Thi; ::t4r" ^ 2 7 ' 5- N i
cC.T@lsicu ps aus i.v C II2 i"~^"* "# 5 % yu ns ,^ Q
- 8. Attachments: None.
- 9. Reference Documents:
- 1. G&I Specification No. 2323-SS-18, Revision 3 April 6, 1979
" Stainless Steel Liners," issued for B&R Construction ,
- 2. G&I drawings:
(1) 2323-S-0831, "F.B. Spent Fuel Pool Liner Detatis."
(2) 2323-S-0832, "F.B. Spent Fuel Pool Liner Details."
(3) 2323-5-0833, "F.B. Spent Fuel Pool Liner Details."
(4) 2323-S-0834, "F.B. Spent Fuel Pool Liner Details."
- 3. 88R drawing WRB-10559, Sheet 1, " Fuel pool liners Imbeds -
Weld Identification No's."
- 4. B&R Procedures:
(1) QI-QAP-11.1-4, December 26, 1979, " Welding Inspection of Stainless Steel Liners" (deleted in error on January 15, 1982 and reissued with no changes on Janaury 26,1982).
(2) CCP-38, Revision 4, dated January 5, 1984, " Stainless Steel Liner Erection."
[ _ _ _ _ _ _ . _.._ _ _. _ _ _ _ _ _
- 5. DC/DDA 2946, Revision 1, November 13, 1978.
- 6. Comanche Peak Steam Electric Station / Final Safety Analysis Report (CPSES/FSAR), Section 17.2, " Quality Assurance Requirements, and Section 3.2, " Design of Structures."
- 7. U.S. NRC memorandum, dated January 25, 1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: D. B. Vassallo, Assistant Director for Light Water Reactors, Division of Project Management, IE
Subject:
Classification of Spent Fuel Pool Liner Plates (AITSF1219H1)(AITSF30382H1).
- 8. U.S. NRC memorandum, dated February 6,1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: R. T. Carlson, Chief, Reactor C'onstruction and.
Engineering Support Branch, RI
Subject:
Classification of Spent Fuel Pool Liner Plates (AITSF12193H1)(AITSF30382H1).
- 9. U.S. NRC Regulatory Guide 1.29, Revision 3. September 1978,
" Seismic Design Classification."
- 10. Region IV Report 50-445/79-15; 50-446/79-15.
- 11. Allegation Source:
(1) AM-Il --- 84-006, 3/7/84 A-4 Testimony Pages 51, 52-55.
(2) AW-40 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15.
(3) AW-42 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15.
(4) AQW-80 --- A-49, 8/8/84, and A-4, 8/24/84.
i I
i l
b
~
(5) AW-81 --- A-4, 8/24/84.
(6) AW-82 --- A-4, 8/24/84.
- 10. This statement prepared by: ___
"~
E. G. Thompson Date C. Richards, TRT Technical Reviewers Reviewed by:
L. C. Shao, Date Group' Leader l
1 I
l Approved by:
V. Noonan, Date Project Director 4
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AM-11, etc. (DCP5) yrd SSER,
- 1. Allegation Group: Mechanical and Piping Category No. 43, Poor Welding Conditions for Spent huel Storage Pool Liner
- 2. Allegation Number: AM-11 AW-40, AW-42, AQW-80, AW-81, and AW-82
- 3. Characterization: It is alleged that:
% - (a) AM Incorrect fitup and poor welding technique resulted in
~
thin welds joining stainless steel liner plates for fuel pools in the fuel building and reactor building for Unit 1.
(b) AW One weld seam in the spent fuel pool liner is largely rust and concrete.
(c) AW Poor welding conditions existed for field installation of the stainless steel liners in the spent fuel ~ pools of the fuel handing facility.
,- - (d) AQW Liner plate weld seams do not match drawing locations on the flooring around the Unit I reactor vessel pool, g - (e) AW The stainless steel floor plate liners in the spent fuel pool and transfer canal are supposed to overlap the angle member at the bottom edge of the wall-to-floor joint. There were areas of no overlap fand the weld was built up to bridge a gap.
l
- (f) AW A single block related to the leak chase channels I
under the floor liner of the fuel pools or fuel transfer canal is defective and could affect leak
~
detection. f L . .. LNA
r .
- 4. Assessment of Safety Significance: The TRT review for the evaluation of the above allegations included a study of the applicable specifications, drawings, procedures, documentation, regulatory guides, NRC Region IV inspection reports (irs) and NRC memos. The TRT review included seismic and reaulatory requirements that apply to the
~ / 7?.~ sf,r- c,,y, Q a cl re e er'cer- acf4rm cf.v, Q o J/rvdfuelpooldiiners. -r-. wT en cJ'y w/I F
- /2 ovfme ".p gOe , ', ='= *= A s go f,
5._y The TRT also perfonned visual inspect ons,of the fuel pool liriers.
1 c r Poor OS'^tc hTksvisua.1 inspection =[ ;;;;d fJ the ovWall liner installat,ig ,
- gwM and included a more detailed examin tion
= wpA- % y,v-\ % w.ke %
approximately 5 f th I h t+
pf , y
, welds in the spent' fuel pools and fuel transfer canalg. The areas ,of
- weld inspection covered the floor plate liners, those portions of the 1 # E.i wall liners which were easily accessible from the floor, and areas
} o %' / y jsssf adjacent.to the sparger spray system which runs horizontallyg about l halfpay up two walls of each of the spent fuel pools. The liner installations are complete and the details of the leak chase channel networks and floor imbedments are not accessible for vis~ual
'7 examination. M- (W 1
{ g f,,swk
- J}- [a %g ',6P
& % y* \', w q ' yJNG Y mW a c The TRT's visual inspection revealed that the placement of' floor plates was not necessarily uniform. There were some areas where the gap between floor plates was such that the fillet welds washed together and one area gave the appearance of a butt weld. All wall liner butt seam welds were ground flush or concave and most of the floor fillet welds were cosmetic ground. he inspection could D
A ll
- h
- T A 7 g- . - / " ' ' " '
0 " . , ,. ,. ,7 g 5, t Wy af d s (fy" of /
.y gg, q Whhs, doc 1M Mon. Uhr*~M CC RCIVM'M -
determine excessive
.a aa tightly butted joints would gaps or, ^
hmaA bh 9.+u ua.e 5:sf'icirt ;; nct::tknt[e examination did establish g
gas tungsten-arc jjfh) weldinr,f if not exclusively used, had been extensively used. This conclusion was based on the appea'rance of unground welds. No butt welds were observed to have reinforcement exceeding the 3/32" maximum. Seam weld concavity may exceed 1/32" in some locations due to grinding of weld surfaces. A more cursory examination was made of liner welds in the fuel pools of Unit 2 and in all cases the general appearance of welding was smooth, clean, and sound.
(a) AM-11 This allegation is concerned that:
, (1) The fitup of 3/16" and 1/4" thick stainless steel liner plates for butt welding was supposed to result in a joint gap of 3/16" to 3/8" to facilitate making a full penetration weld, but welders encountered tightly butted joints. These joints were partial-penetration welded by laying weld filler
\ .
j wire on the joint line and fusing it in.
(2) Gapped butt joints were incorrectly welded by either building up weld metal in the middle of the gap and then j y ic, , r M C7 il >*.
/ 7 Xe.
1 bridging the gap at the top with a thin weldfor by laying weld rod in the ga'p and welding over it.
f U g "- b 3 M 'md wk M Mr- 6 M*
.I ,; f&
.1 e t JL w L& L w.h u%a.
(' N [ 0 BM CCE-33._ Rcvisicr ' (dahd anua M 984),
L g Stai ss Stee t4mrspe / 10 - /8 j nt
},[.N ga fitup of stainlesp eel olate .m s
'n req em --tic weld er wel" japs e +. i kable for mani
[Ill\ q' 1 =1dtg. . . _ _ _ , [heTRT otes that j
'j '
f tightly butted joinh/da= preclude making full p on ,
l welds i the 3/16" and 1/4" thick liner plates usi the /
sp fied manual GTAW process. All of the fuel p lin weld n was,apparentl{ performed using the manual GTAW ocess.
Rc & f .e n ~ 5 ' A- % . M -r o 7 o .,. . -
g;
~
er 7? m r f c h -- X s
~
T s preparing a suninary of its findings on allega ion 2 -11 to rd to t ege wh c ine an i tarvt .
\Q % % ?.-- S ' E*
- G s si u- w rR r c ' '
) ->~* m . w e-s M G,/ rr =l dr . .'c, , , u,
.{' M (b) AW-40
' ~
? The allegation states that water from poured concrete had entered leak chase channels and run past backing strips into weld joint areas. The allegation does not identify any specific weld or. .
area. ":y:~',gheTRT'svisualexaminationdiddetecttwo 0 questionable spots of corrosion.
9 Both were on the north
,, , : ap wall liner of Unit 1 spent fuel pool. A buildup of
/
@', corrosion products was observed on a horizontal seam T weld located about half way up the wall. The corrosion products were located between the midsupport for the pipe and the nearest light pole. The second questionable spot observed by the TRT was in a horizontal seam below the sparger.
about level with the top of the fuel storage rack. It was 1
located opposite the northeast corner of the rack. There was no buildup of corrosion products but there was a light rust colored stain that appeard to have been caused by water leaking from a small spot in the weld seam.' However, the TRT could find no obvious hole or po jin t a weld. @ E A
),,',, W . S C. 99 9' 4 S 's e 4 to < m.h4 A .~ u, y . .
Arrangements are to be made for the TRT to review its findings on allegation AW-40 with the alleger. ygig is. km:sd j ihe, r % :h- W % q.(,.
- (c) AW-42
% .[ Inasmuch as both Unit I and 2 spent fuel pools are c letep TRT visual examination could neither substantiate.por refute thei
. + e WM d.as.W.J.s eu?d&6bihyvW7 f
.\ /, j, -.
allegation regarding poor veldingconditions],Qncecc.ctrii.up"p
, e' , s c,, ~-- . . ~ ~ r- , . , .. - .. .e -
! c and poor welding technique during liner fabrication , However,
\ u l' .
s n [f5 NRC Region IV IR 79-15 dated May 21, 1979, concluded that.the w
{ 3
/ allegation may be substantially true, d ~additio , DC/DDA 4946, 1% gc,.h"'. cant &-, _.,/ s.
! d e Revision 1, dated November 13, 1978, documents, a-. modification ;
i
^\ " . s o(
i p g made to drain leak chase channels containing water interfering k.
V -
sunnnr+4na
_with weldin M -~44'4e +4an + h unf n;;;' e- r $ r; 4 s4 ~
Q N
g' Jing A1;;;;t to 1 ding g
[ i g e -- e.*-ui= Nva*Y % ' ' this evidence rq Q .. (conditionswerenotideal.
t3 -
f kc 's R,. ,.s. r - ., ,3 p.d e .a 27 /~ s / /7~. i7 n i-4 7 ,7w w e +
s Mc A 's -
f A . ,t ', t,,-7., w -~
n., ; -
L l ,
7a A r~ J f w. s. .s s -
! < Arrangements are to be made for the TRT to review its findings on 1 l
allegation AW-42 with the alleger. )
s.
. , b .
Qg l . W % 4" $ L *
} 'f l
. - - - + . , , - - , - - - - - ---er,.- - - - -
-d,--
- r. -
pe M -
'\0C-
"oA*. c b co GC 4.s ,
(d) oI? O.Rh 14. M csv,M eb-*E~) ., nc AQW-80 3 s.or~ ud This allegation has similarities to allegations AM-11 and AW-81.
During the TRT examination of liner welds, some lack of 31 o informancy')was noted; i.e., possible variations in f tup gap, p . @,. , , and certain areas giving the ,a pe rance of/ butt , joint in lieu of) ..
vi5 dd wA b. oht- o( nG ee%NA p an overlap. However, the[TRT examinationlf the welds;
_ ~ _ - ; -
could find pm p
/ \#' "
t t'--) no evidenc3.that the we'Tds wef'eiotw,,sound or that af adequate b dd"d.
IM 6T V ' Ig /,
- 4 do '
p., ' geal was not achieved. [Th; int'_q~=u %/ W 's1"=+4c #.~,fsafety ^ "'h a d ,. /
ivs p b g
[g5d 6h)4 +- "(,, a=4fierEh b;;ed un its v1soisi examinai.ivn of Tiner welds, "'Ok
,' , 'l n J %vf u <. k.
yyiTrhquirements
'I - that apply to-thedesign purpose of t e b
, e T %
]
e,.u <"y
- g. s , , . ... . . . n and_ the final acceptance-of-the required MOLexaminatia ._ nd W
ke@s.
~
4 un .- -]
h W e.s -
c; 6-<.
The TRT is preparing a sumary of its findings on allegation
)\ AQW-80 to forward to the alleger, who decline.d an interview.
(e) AW-81
- O S This allegation is similar to AQW-80 except that it applies to f the floor plate where it mates with the wall plate. The floor p plate is supposed to overlap and be fillet welded to the leg of 5 Th e
( the angle attached at - the y co bottomn A.dge of the wall . liner.%e 2 TRT q "~' '
q F did observe some fapparent butt HC jointslin MMthis
@area.W.sabe.re this T u d ,9 V condition exists, the TRT was unable to determine whether there a was any weld buildup to compensate for an excessive fitup gap.
D; T",T':; evel .C, . %'+> ia=4'ic=e is. based-en-thosame l
evidence a= a m ;; . -- - 'Do M
- z -
, 1 sk
.uf' w ,- n , - - - - - - , . , _ , - , - - - - - - , - - - - - -r-,-n----------------,,-,,.--,.w --
mw-, -
The TRT is preparing a sumary of its findings on allegation AW-81 to forward to the alleger, who declined an interview.
(f) AW-82 - fM Y Since the details of the leak chase channel network are not accessible for visual examination and because the allegation lacks specificity, the TRT review has attempted to identify the alleged " defective block" and evaluate the affect on the function of the leak chase system as well as its safety significance, regardless of the location and extent of the defect. A review of details shown in G&H drawings 2323-5-0831 through -0834 and B&R drawing WRB-10559 deterinined that only two items in the construction of the leak chase channels and floor grooves could app ~ly to the-alleged block: - --
N (1) Blockouts - These are wood blocks used to forin the leak chase channels during the pouring of the concrete floor '
- of the fuel pools r h setgns fjoggteu gg dd i je '(,, the blackout (were removed)and any chipping or
- damage to the chase 6 h reaafred N \d N *'
g/./
[. N-regv & b e ~y- 4 3r t U L % % % k 5
o TI (2) 3/8" x 2" Imbedded Bars - These are bars imbedded in and
'{g $,h;; '(' '- flush with the surface of the concrete pool floor and I
. anchored using Nelson studs. The bars are centered between the leak chase grooves and fom a grid framework to which
~
the floor liner plates are fillet welded.
r s y g &, /, ~ * ' is & *] ' p ro b .
Qu Initsreviewofdocumentation,theTRTdiscoveredCPSESDesign)((#h j Change Authorization (DCA) No. 5687 where a 3/8" x 2" imbedded ,*' {'(~j f strip identified as "F-15" was omitted. The DCA solution was D' E y l that: " Plates P186 and W135 shall be butt welded together and
/ , laid as one unit." The location of this deviation is at the
~f) [f junc[ ion of the fuel transfer canal and the cask pit entrance. ,
fd '? I The TRT reviewed the drawings and determined that the functional purpose of the chase channels (to detect leakage through the pool liner and to locate the leakage within a sectional area using th'e '
/ /.
system of drains where a section of chase grooves empty into a '
\,
single drain) was not affected. DuAdf , g_(;,
,, 7-
-L f 4 /o e c c E /a g 7 ) :,. g g, , n. ., s . - ;r ' 7f. .
fu C 3< * ~ 7~ /> r > e a d-, c. t 5 . o e, _ , s. oy<**er,-lKi -
The TRT also reviewed ASLB testimony where issues pertaining to the fuel pool liners were discussed from Sept. 10 through Sept.
21, 1984. These discussions qDestion the adequacy of inspections and governing procedures, and adherence to the procedures. For the most part, the activities which took place from the back side of the liners (the side which becomes the boundary to the concrete) were discussed in the testimony, i.e., tack welding the backing strip in place to accomplish the wall liner plate-to-plate fitup, and the attachment of the leak chase channels which are fillet welded and fonn the enclosure around the backing stri . e purpose of the leak channels does not include the-M 3
T. > 0 .
g got g,k, ~
to be a secondary seal to the plate-to-plate seal weld- /
vnw U^ ,
g g j )er M P'Misualh>
f A
-1 aminations .I e'! 'i L,Tu qos for(cieanliness otherefore IctAI%" .
g o attachment nstylocatio/
f g,m' W .
EM *a a s.u M-g & cw3 %y
-th(, bag,k3cfacs.oh The requirements which are
/
4(p ib ished in accordance with the pertinent portions of Appendix i 8 B to the 10 CFR 50, and defined in B&R's Quality Instruction QA-QAP-ll.1-4, apply _only to_.the n1 ate to a1 * * " seal" weld.
s
[,,,/ /
Nonnally these requirements include. visual examinations for' A
<.9 1 jh/, f I cleanliness, fitup, and the completed weld; a liquid penetrant
(/ ([ ,, examination of the completed weld and a liquid film vacuum box
" bubble" test for leakage. All of these examinations are
]
( perfonned at the front (exposed) surface.jhe fact that 5e j . - - - -
r- I
\ backing strip is no longer visible from the back' side *? c' r.gf D I o,o c,- ;4 . i M M ^ dd '"
7m y-Wy m .
I (v M h.g er and above
- any a4,2m s eregulatory uA Nirement[the drawinasYpeci
- . . /
\ce.rt arehtoberadiographed I letter 'TUQ-041 dptfed Septembe 4,1975 to B&R permitted the substitution pf' magnetic
\'3 .l' particle insp tion in lieu of radiography for ver/ tical 3 (U%, "\pJ.% -
W- d h liner /
5 9 "r'.
V' .i -
s i dsinthereactorcavi.t/.d<.e(TheTRTnotes%
uA+ www1W ,
9 0 T>t"- ,,4 (.s # \ that magnetic particle spection is]not' applicable? t o the liner
- ps
- 9G, i eh, e-l'[\ 4,-i(material,whichistype304 ustenftic stainless steel.) 7, .; .
./'
- gu ,3, There were other areas that xamined by the Mass . .} ; ( '
,i ,\\ c. , "" ' *h# : Spectrometer Leak Testi method. A ntioned earlier in this - - -
t .r wp
\' + ' ' - SSER, the pools also " water" leak te ed. QC personnel were
{8CV. g i
permanently igned to the areas of fabricat on and installation l fy e/
of the
/
el pool liners to monitor the activitie frEallegations
!f g')/ I [ an ranscribed discussions lack specificity to the tent that ,/
traceabili to specific welds cannot be positively sho '
,( \< 4 '- ,
\ < 'g, .
i However, documentation of nonconformances, conditioWthat re i
t{k
, in- g - - -..- ... . -.- ... . . . . . . . ...- -
VgAJQ Q g g ? %\ m sab
~ \cbo h 'D cpi .S **
.-e-s .M 94Ae
' , <o " ,,b , (g rT " '# ,c , .f, )
d [ : k' b fO f 9
/ yl f - # 10-
'd ,. p' W V hes KA L%?
no[ ideal, rtain deviations to procedural of
/p operation were reviewed -
}' y /'i(The TR is preparing a summary of its findings n allegation s
o' ',. 6 3
, *'S M , 't l, g AW-82 to fo ard to the alleger, who decli d an interview.
A . V' '
g
/
- 5. Conclusion and Staff Posi r.
ons: The TR s review established 41..L4that jad Pr./d/ <*
s fcinsiderabledifficulty3asen un red in fabrication ^an
,' . , ~. . pi 3. c in *.. ;1ation of th,e liners,,- cu . ntation in part subs t b
'C ,,
allegations. However, t pr,imary fu tion of the stainlbgitteel
, 1[-
1*** f i' liners is to provid ' / leak tight barrie and a surface p 'p)(gay b _,
' p b# -
f/ easily decontam ated.)TheTRTconcludest t these basi C k,d 4 _ - . _ . .
x _y d$,, f % . requiremen) _have been met;.y[e TRT also estab ished, on thel
,7
,L ~a"U.S.IRCMemorandumentitled"Classificationof pent Fuel Pool poc z, N #:
/
Litter Plates," dated February 6,1979, that fuel poo liners are not h,
i
'.' ,. .- ,s
/ . * ?.
required to be designed and erected to Seismic Category &/
- - -~ "m y t,
- c'
<* ,p
- Ma , f requirements. [The TRT, therefore, concludes that although some of the 2 l C '" * - - ~~- -
~ #
- allegations are valid, they have no safety significance.
Q r-L.r,' ,w4l4 is .2 ~J/ts ~r7 '~ & '
/**I lf** ,
- 6. Actions Required: None. /g' i:' p
- 8. Attachments: None.
4 y . . _ . - , , , - - . -
r .
- 9. Reference Documents:
- 1. G&H Specification No. 2323-55-18, Revision 3, April 6,1979
" Stainless Steel Liners," issued for B&R Construction
- 2. G&H drawings:
(1) 2323-5-0831, "F.B. Spent Fuel Pool Liner Details."
(2) 2323-5-0832, "F.B. Spent Fuel Pool Liner Details."
(3) 2323-S-0833 "F.B. Spent Fuel Pool Liner Details."
(4) 2323-5-0834, "F.B. Spent Fuel Pool Liner Details."
- 3. B&R drawing WRB-10559, Sheet 1, " Fuel pool liners Imbeds -
Weld Identification No's."
- 4. B&R Procedures:
(1) QI-QAP-11.1-4, December 26, 1979, " Welding Inspection of Stainless Steel Liners" (deleted in error on January 15, 1982 and' reissued with no changes on Janaury 26,1982).
(2) CCP-38, Revision 4, dated January 5, 1984, " Stainless Steel Liner Erection."
- 5. DC/DDA 2946, Revision 1. November 13, 1978.-
- 6. Comanche Peak Steam Electric Station / Final Safety Analysis Report (CPSES/FSAR), Section 17.2, " Quality Assurance Requirements, and Section 3.2, " Design of Structures."
- 7. U.S. NRC memorandum, dated January 25, 1979
- From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: D. B. Vassallo, Assistant Director for Light Water
^
Reactors, Division of Project Management IE
Subject:
Classification of Spent Fuel Pool Liner Plates .
(AITS F1219H1) (AITS F30382H1).
..+--s.m-. .-,-. --.-.e -,e.-,-..h mw,w,w-w_-- - . .- . . - - - , - ..-. e,. .-..--w,,.-w - - - - - , - - - -
r .
- 8. U.S. NRC memorandum, dated February 6,1979 From: G. W. Reinmuth, Assistant Director, Division of .
Reactor Construction Inspection, IE To: R. T. Carlson, Chief, Reactor Construction and Engineering Support Branch, RI
Subject:
Classification of Spent Fuel Pool Liner Plates (AITSF12193H1)(AITSF30382H1).
- 9. U.S. NRC Regulatory Guide 1.29, Revision 3, September 1978,
" Seismic Design Classification."
- 10. Region IV Report 50-445/79-15; 50-446/79-15.
- 11. Allegation Source:
(1) AM-11 --- 84-006, 3/7/84, A-4 Testimony Pages 51, 52-55.
(2) AW-40 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15.
(3) AW-42 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15.
s (4) AQW-80.--- A-49, 8/8/84, and A-4, 8/24/84.
(5) AW-81 --- A-4, 8/24/84.
(6) AW-82 --- A-4, 8/24/84.
- 10. This statement prepared by:
i E. G. Thompson Date l C. Richards, TRT Technical Reviewers ,
Reviewed by:
L. C. Shao, Date Group Leader Approved by:
. V. Noonan, . Date Project Director 1
_rm-. _- - -. __,-...._.w m. .__ , _ - - ~ , - - - - , - - , _ _ . _ - - - . _ _ - _ _ _ _ _ _ _ - _ . , . . , . . - - . - - . - - - - - - -- , ~
Oraft 6 3/5/85 AM-11, etc. (DCPS)
SSER
- 1. Allegation Group: Mechanical and Piping Category No. 43, Poor Welding Conditions for Spent Fuel Storage Pool Liner
- 2. Allegation Number: AM-11, AW-40, AW-42, AQW-80, AW-81, and AW-82
- 3. Characterization: It is alleged that:
(a) AM Incorrect fitup and poor welding technique resulted in thin welds joining stainless steel liner plates for fuel pools in the fuel building and reactor building for Unit 1.
(b) AW One weld seam in the spent fuel pool liner is largely rust and concrete.
(c) AW Poor welding conditions existed for field installation of the stainless steel liners in the spent fuel pools
~
of the fuel handing facility.
~
(d) AQW Liner plate weld seams do not match drawing locations on the flooring around the Unit i reactor vessel pool.
(e) AW The stainless steel floor plate liners in the spent fuel pool and transfer, canal are supposed to overlap the angle member at the bottom edge of the wall-to-floor joint. There were areas of no overlap and the weld was built up to bridge a gap.
(f) AW A single block related to the leak chase channels -
under the floor liner of the fuel pools or fuel transfer canal is defective and could affect leak detection.
F.C!4-85BC u3
- 4. Assessment of Safety Significance:jhc TitT re;ic;. fer t% :;;; i. i un I of a egations included a study of the applica e spec tions, drawings, procedures, documentatio regulatory guides, NRC Regio inspection reports (I and NRC memos. The TRT review included seismic an gulator equirements to determine those requirements that apply to th ine or the fuel pool, transfer canal,andreactoiref ing cavity. These r rements are: (a)The ASME B&PV Code s forth Seismic Category I requireme for the structur the fuel pools and makes reference only to the exte th_ _ the Seismic Category 1 requirements do not apply to the liners: _
. (h The U.S. NRC Regulatory Guide 1.29 classifies the spent fuel storage pool structure, including the fuel racks to be Seismic Category I design requirements. The regulatory guide also states that the pertinent quality assurance requirements of Appendix B to the 10 CFR 50 should be applied to all activities affecting the safety-related functions of those portions and functions of structure, systems,andcomponentswhichareclassifiedasSeismicII;f)cBy!
U.S. NRC Memorandum dated February 6, 1979_, states "... fuel pool r liners are not required to be designed and erected to Seismic Category I requirements." The memorandum further states "...The primary function of the liners is to provide a leak tight barrier and a surface suitable for decontamination, rather than to serve as a critical safety structure."; and, "...The probability of large leaks occurring and being undetected over a period of time such that a potential hazard might be incurred is acceptably low."; (d} The
- },,vr N & c m->ws,,,,,,, ,g- _ ,, w i
SA h M 6 F O r-l i drP da wa.5muuI.4r#N 5y Na--Ios dm'
@2;.7,' - M neif4eattu 2321-51n.ev n g
4tainless steel liners," and B&R's Quality Assurance Instructd QI -11.4, Rev. O, " welding inspection of stainless step ners,"
cover t
.=
requirements for the fuel pool liners. Mat al is specified as STM grades of type 304L. Liner sh ts shall be seal welded by inert as-shielded (gastungsten-rc) welding. Welding procedure qualific tions and welders p formances are required to be for 71 9ss ge m .ove woMi-5 m W oc.ss n W -W qualified 4Mac, corda ^~ e with ASME --p^ V Code, Section IXf ^ . qdi S p .
= v w oectione a re " i :: :1 ,\ ' i qu i d $ m per. traat. M r:di gr:phed hcre soac m ed by dr M aa- T equices the satir; inngth Of all u4
'[esteo.
a-m:.=___e:.- % ) %
Surfaces of welds are required to Q alde te be vacue= 50:/ .:k --
be smooth and free irregula ities and may be ground to obtain this ,
smooth finish. weld reinforce. nt of 3/32" maximum and a weld undercut of 32" below minimum wa 1 tolerance is permitted. The G8H I drawings 23-5-0831 through -0834 s w the liner is fabricated
\
predo nantly from 3/16" and 1/4" shee and assembled using fillet and ,
penetration groove welds, (i AS - w 7 -
x- [
The TRT's review of requirements has determin m s - - -
that the pool liners
\
,7 ;u e/sES/rsn d2- (
3 ,.
are/c,lassified as Seismic Category g and that/) e only regulating%,; ,
requirements that apply to the fabrication (more sp cifically welding) \
}
and erection of stainless steel liners are:
( % na/nc ronf r_amante i in_a_ccordance with Appendix B to the 10 7,
- 50. h ym t-N The QA/QC pects concer ing t W issues relatly t the J t
l
< ar addre:::d ir, dio T /" ' QA/QC SSE .
h t
. w
+
>r M
.A
(2) /The requ"rements spec fied by the G8 andB&Rsp'ificatifns, procedur s, and dr ing OTE: TRT's review of s procedure CCP-38 found the y requir t to be 3/16" minimum and 3/8" maxi . The
,x .
welding shall as Tungsten Arc We g (GTAW). The B&R 80 2 3 war e,- e Weld Process Specifica n 99020psed for the liner Ha- x.a:~ onw s w .s welding is for th W proce and shows the minimum fit-up ga o be 3/16". These requ nts are consistent the G&H specifications. 1/,3 Jac r+7S of M lf En r etid: 5::S for bett:r =d:rsteading of the TP,T': re ri-h;
= I m- .iid as=ess.. ,J.5 in usia r epu r i. , uiu iviivwinv ur i=T-d-ecripti= sf liner dei..il5 is piu,lded: The wall liner plates are joined by full penetrations butt welding using a backing strip. A C3x4.1 S.S channel is welded over the back side of'every seam to provide a leak chase, where any leakage through a liner seam weld will be coll'ected. The completed sections of wall liners become the form for the pouring of concrete wall structure of the fuel pools. The concrete floor is poured prior to floor liner installation. The leak chase gr'ooves in the floor are molded during the pouring of concrete j using "blockouts." Also 3/8" x 2". bar strips aro imbedded te-be flush d+ttr the surface of the concrete floor. These imbeds form the lattic work to which the floor liner plates are fillet welded. Both the wall liner plates and floor imbeds are anchored in the concrete using nelson studs. The design features of the fuel pool liners include a system of drains where each drain connects to a sectional group of leak chase channels or grooves to provide an early detection system
for leakage from a given number of seam welds. It also provides a means to recycle the captured leakage. 3 wy ?dr,ca L m4 . %
- y f -
4,5 p _TRT else p-fe... J __vjsual inspections',af was tha fe=' p:1 lir,ar y d g6 1< r n ra n of - p general ;hul i...;Ftie.. Tec the overall liner installation wes-pt ' .xd, and a more detailed examination of approximately 20% of the welds in the spent fuel pools and fuel transfer canal. The areas of weld inspection covered the floor plate liners, those portions of the
'wa~11 liners which were easily accessible from the floor, and areas adjacent to the sparger spray system which runs horizontally, about half way up two walls of each of the spent fuel pools. The liner installations are complete and the details of the leak chase channel networks and floor imbedments are not accessible for visual examination.
The TRT's visuat ' inspection revealed that the placement of floor plates was not necessarily uniform. There were some areas where the gap between floor plates was such that the fillet welds washed together and one area gave the appearance of a butt weld. All wall my T & /> ~ * ** rd ' *
- liner butt seam welds were ground flushfor[c$ncave)Im+ pst of the floor fillet welds were cosmetic ground. The inspection could not determine if the fit-up gap was excessive or if it was tighly butted (tightly butted joints could cause insufficient penetration). The examination did establish that gas tungsten-arc welding (GTAW), if not exclusively used, had been extensively used. This conclusion was based on the appearance of unground welds. No butt welds were
6-rs r.er 4 observed to have reinforcement exceeding the 3/32" maximum.I Seam weld '% isw mes % concavity,moy wed 1/32"41n some locations due to grinding of weld 1' s t opp +e w e d r,4. fconcenty .m ay4=me e s ee d 19s , surfaces A more cursory examination was made of liner welds in the \' fuel pools of Unit 2 and in all cases the general appearance of welding was smooth, clean, and sound. f~ns 4, y [R/~f Raww en d.9s s ess-~~t fjoe /,2 7: 4 M4ya77N.c (a) AM-11 1 This allegation is concerned that: (1) The fitup of 3/16" and 1/4" thick stainless steel liner plates for butt welding was supposed to result in a joint gap of 3/16" to 3/8" to facilitate making a full penetration weld, but welders encountered tightly butted joints. These joints were partial-penetration welded by laying weld filler wire on the joint line and fusing it in. (2) Gapped ' butt joints were incorrectly welded by either building up weld metal in the middle of the gap and then bridging the gap at the top with a thin (less than full penetration) weld or by laying weld rod in the gap and welding over it. The TRT inspection of the liner welds reasonably supports that all of the welding was performed using the GTAW process. The ! inspection could not confirm the preweld, fut-up gag conditions to have been tighly butted, excessively gapped, or to have been bridged over. The overall surface appearance of the , completed welds. lhe TRT notes that using the GTAW process, tightly butted L
i joint could preclude making a full penetration weld in the 3/16" thickness, and more probable in the 1/4" thickness stainless steel material specified for the line f 1,, a - r The TRT is preparing a sumary of its findings on allegation AM-11 to forward to the alleger, who declined an interview. (b) AW-40 The allegation states that water from poured concrete had entered leak chase channels and run past backing strips into weld joint areas. The allegation does not identify any specific weld or area. -; u ..;n n iva 44C i tect tws. p ,#$ (,questiona
/ spots of corrosion. Bothwereonthynorth
/
wall liner of Llh t 1 spent fuel pool. Abuilduhof
/
corrosion products . observed on a horizontal seam weld located about half upthewa)T. The corrosion products were located between her midsupport for the pipe and the nearest light pole. The s'econd questionable spot
/ \
observed by the TRT was i a horizontaBseam below the sparger about level with the f opofthefuelstora\gerack. It was located opposite the northeast corner of the rack. There was no buildup of corrosion products but there was a 1 ght rust co,1 d stain. The TRT could not determine the source ca, g these stains. No obvioughole or, pore could 4found n d Oweld. The RT-f bds no saf so
;u ver d ,a ose xa a
[y ] sign'f$cance n....c ., ,9 ./ ung%.atb. t " e /oL.,he g , ce er . t
74 a!!*y*e .u a s c e ra a t d 7.o a r r * ~p a - - 7)~., r.,, -, L rr.,rary
< v e te a r? ' a ~ id c,: d h ixa a,4 7a -i s,c ,7. e A e /,,, ~ c.a c , ,, _,4 dP.3ES .omW 4 er /~rea-esre.d s~ a reus m ,aars.y wj';g ;-4, rg
_Arrann--- at: tre +n he made f a r- +M "I t: ; n i n **- c4 sin y y artice. ?S "; -; ; the :" 7-(c) AW-42 The allegation shows considerable concern regarding poor welding conditions during the construction of the fuel pools and fabrication of liners, i.e., seepage slury fiom the pouring of concrete causing interference to welding operations. The TRT's ws# 1 dinspectionofthecompletedlinersdidnotrevealanyevidenceof conditions that existed during the construction phase. However, the review of documentation revealed numerous NCRs. There were several cases where the QA inspector (s) wrote about interferring conditions as being source giving cause for the defect. Some of gr s these conditions werc(/)wefdcr,ha,dgogesc,h,)through a maze of /, [,,', rebar to make the weld faM r seeping from locations where concrete had been ou,r,egn,d , , cogtami,ngi,nyomponeg,fJ. 1,i ,egs,, _ ,. being fabricated,Q ,ter in leak chase channels interferring with 4 r> u. i. welding, addg<a o many.4 >oactivities ree d..ee,o ee a-causing sr -w ow interfere g y wa n o3*_A Design
}
Change /DesignDeviationAuthorization(DC/DDA)No.2946,REv.1., ' dated November 13, 1978, authorizes 1/2" holes to be drilled in a leak chase channel to drain and/or dry out residual moisture causing interference to welding. Afterwards the holes were repair welded using the GTAW process and groundflush to
= surrounding surface. The conclusions reported in NRC Region IV's IR 79-15 dated May 21,1979, states that the allegations .
. regarding poor welding conditions may be substantially true. The TRTs review did find documented evidence of conditions that were
_9_ pn. A I f notfideal. However, the TRT cannot conscientiously take the position that these conditions were worse than normal for +rp,< = / construction #c tNI [itede. t T^T nuies uioi ;i is n:--! ta he:: :; ; univresecoLI. conditiens iho; ;s uependeni vii the cH11< and aya rtise e' the craft . =a0 4 a-- i ; : d 00 te ::p ___ with *ad datamiae reselett:na Uian will p.evide ; completed-ped"et tha+ '711 : ,,ith the --inir r quirements-47';;en ieu~ sby th: ::d:: :nd :;;;i'!::tiert. The TRT review cannot find any safety significance resulting from these reported and alleged conditions. MMS6 r "( -A-r ;;;;i.ta are tv Le maae rv. ihe T",T te revie" it #4a ' s mr ; l
#e all e; tie;; .'l, C .. : .:. t :t ',:r.
Mg, (d) AQW-80 The concerns of this allegation are that weld seams do not match drawing locations on the floor around the Unit I reactor vessel , pool. The TRT review of the drawings determined that the liner weld seams must mate with the 2" wide bar imbeds which provide a backing plate for the weld. The TRT notes that the weld seam could vary across the width of the imbed without consequence or safety significance. The TRT's inspection of liner w&lds did notice that weld runs from plate to plate joints were" not consistent but did not consider these variations to be excessive. The TRT also observed variations such as the appearance of a butt j u h n i r., s w . s t) joint in lieu of an overlap (fillet type) joint. The review of documentation found several NCRs covering M conditions.
TRT's inspection of liner welds and review of documentation-
" cannot find evidence of poor welds or that the welds were not zm a,.r- a 9 soundorthattherequiredsealwasnot. achieved.I The final 7%
/ of rh /i ~ e r- s is 6.s a d e.,
acceptance of visual, liquid penetrant A vacuum box leak j a ,s A v e w w aree A ii rasr; testingj :: 9 e -eui t ::d ghe TRT could not determine any evidence that the completed liner installation was not in accordance with the requirements as defined early in this reportj a ,, d d o = s -~ - r d-t -- ' o,. f re/r. 77 sy F.e , ee- r 7c., d aw c e ,-- s off 7% i e/47 5m . The TRT is preparing a sumary of its findings on allegation AQW-80 to forward to the alleger, who declined an interview. (e) AW-81
& g//q d r /f dow r et *** W This allegation is similar to AQW-80 except that I it :ppH:: t;r novr to
/ the floor plate ,ph=r-up rt..ro..rtes 4t m:t y O . the wall plate. The floor plate is supposed to overlap and be fillet welded to the leg of the angle attached at the bottom edge of the wall liner. The TRT did observe some apparent butt , joints in this area. There were several NCRs written which covered these conditions. Where these conditions existed, the TRT was unable to determine whether there was any weld buildup to compensate for an excessive fitup gap, m v pra-.; a marrwtw.1.ce> u cojrra r-i. i. ovooo
- nr1 u ni .
Based on the inspection of welds, the review of documents and the
# 71, . r*
final acceptance examinations, the TRT determined these A . . , a re, eie < d u. rs.a r n o r t,; -,, a n. d conditions not to be safety significant.
, The TRT is preparing a summary of its, findings on allegation AW-81 to forward to the alleger, who declined an interview.
(f) AW-82 The alleger is concerned about a defective block under the floor liner in one of the fuel pools or transfer canals that could affect leak detection. Since the details of the leak chase channel network are not accessible for visual, examination and because the allegation lacks specificity, the TRT review has attempted to' identify the alleged " defective block" and evaluate the affect on the function of the leak chase system as well as its safety significance, regardless of the location and extent of the defect. A review of details shown in G8H drawings 2323-5-0831 through -0834 and B&R drawing WRB-10559 detennined that only two items in the construction of the leak chase channels and floor grooves could apply to the alleged block: - - - - - - je,,ps of-ra,;. i a-r n is reedre d&<~,;n i#r n na (1) Blockouts /Thx J -d thi used to form the leak %. chase channels during the pouring of the concrete floor j of the fuel pools. The B&R procedure CCP-38 states that ' after tihe setting of concrete, the blockouts shall be removed and any chipping or damage to the chase repaired, and that the chase grooves be coated with a sealant film. A final visual examination was required for these operations. It is not reasonable to believe that a blockout was left in place, or if defective, to cause subsequent affect to the requirements. ' ~ #p,,,,/,n sr.J Jor stodesudd !J (2) 3/8" x 2" Imbedded Bars T.tioss=sse:tssas imbedded ' =d flush with the surface of the concrete pool floor,and
. anchored using Nelson studs. The bars are centered between the leak chase grooves and form a grid framework to which the floor liner plates are fillet welded.
L
In its review of documentation, the TRT discovered CPSES Design Change Authorization (DCA) No. 5687 where a 3/8" x 2" imbedded strip identified as "F-15" was omitted. The DCA solution was that: " Plates P186 and W135 shall be butt welded together and laid as one unit." The location of this deviation is at the
. junction of the fuel transfer canal and the cask pit entrance. -
The TRT reviewed the drawings and the functiona,l "o.ss r+ rA
- f "* 7" f, ~
purpose of the chase channels to #(as sagu,s.si., detect a, leakage through the pool liner and to locate the leakage within a sectional area using the system of drains where a section of chase grooves empty into a singledrain). Since the design drawings locate the chase groove to run parallel on each side of the imbedded bar to which the plates are normally welded, they would therefore, remain to be parallel to each side of the butted plate to plate seam weld (relating to DCA No. 5687).' Therefore, any leakage that might occur through the weld joint would be collected and detected in the same manner as it would if the imbedded bar were in plafe. The TRT could find no safety significance regarding this DCA. I Z~t ~
-r .
l The TRT & reviewed ASLB testimony where issues pertaining to the fuel pool liners were discussed from Sept.10 through Sept. 21,1984. These discussions question the adequacy of inspections and governing procedures, and adherence to the procedures, st part, the activities which took place fro back side of the liners ide which becomes' e boundary to the
. ./
concrete) were discussed' n timony, i.e., tack welding the bac ce to accomplish the wall liner - L ft
plata fituo. and the stt:r' r-t c# +ka 1-' :hgeh:rr.:1 ; ,;h-
^ fillet' elded and To.E. th; nr1 neure arnnnd -the-taning These testimonial issues and the implementation of requirements in accordance with' Appendix B to the 10 CFR 50 are covered in the TRT's QA/QC SSER.
s\ d Go G htce la>,N The-TRLreviaw of F151 Snecification Nod 323-SS-18M gr# ge dra s (ref. "T.5. 5po.it F :' Den 1 Iiner Detai1:") nui.eu 1 at rannirement for welding the nelson studs +n t'.: l iners 5 ' h nrevidad the 2n:h:rs ir, the sunu.cie strture. shall ha rdance with AWS D1.1 (nn+ = atiered 4-th: ::rli ii>^ g of s). The G&H drawings call for these wald: t.
'radiogr:phed. Dur4ng the review of d"cu- ntati:n, Ll.c TRiw.
NEthr-TUSI lattar TUO-041 dated September ed toJ11R which normitt d the sub5titui.ivu of magnetic particle ection in ileu vi s odiuvraphjrtor vertical- liner welda in the r ..tcr ::vi+g. The TRT notes that since the liner material is 7 N Type 7u4L au=LincticQsteel (non-ferris),"magnetic
/
varticle_exactnation cannot - be, valid._ Tha iQisu netept(hat t elds wEre liquid penet ; ti es tite KS r accordance. above any specified requirements RT noted that there were areas which w ed by the mass spectrometer leak testing metho . Also that th " water fil ed"
./
leartested.
, A Tginihas \@RC memorandum dehd Jer.x;y 17-nr Mnce S Nnaar #rc;- Olar. O. "an.
The TRT's pos 'on r a seismic category requirement /for the fuel pool 1 ners is: (1) The' liners ere not designed by TUEC to be a eismic Category I fab cation and the requiremen established by TUEC for their fab cation does not su ort seismic Category
\
I requirements. (2) Since the liners provide o stru tural support to the concrete pool structure, an at a seal weld failure would not be safety significant eca e (a) the concrete pool structure is designed seismic tegory I structure and has the capability contain the wat , (b) there are redundant syste to replenish water in eat volume, (c) the liners pp vide an early detection system for leakage and
/ 74 feakem,n y,*
the capab lity to recycle this leakage #ew, and (d) any such s_s, g . leaka through the liners would not release any l'avels of
\
1 ra ation through the pool structure or outside conta'inment $ v o be harmful to personnel. The fuel pool liners need not !
+b be seismic Category I. s'2
/(
i - l
/ The TRT is preparing a sumary of its findings on allegation
~ I AW-82 to forward to the alleger, who declined an interview.
. 5. Conclusion and Staff Positions: The f the ions
'~
f an4 i::" g arding the concerns about the f l ,, fj oncluded tha significance. 9 .
- 6. Actions Required: None.
- 8. Attachments: None.
- 9. Reference Documents:
- 1. G&H Specification No. 2323-55-18, Revision 3, April 6, 1979
" Stainless Steel Liners," issued for B&R Construction ,
- 2. G&H drawings:
(1) 2323-S-0831, "F.B. Spent Fuel Pool Liner Details." - N (2) 2323-S-0832, "F.B. Spent Fuel Pool Liner Details." t (3) 2323-S-0833, "F.B. Spent Fuel Pool Liner Details." l (4) 2323-S-0834, "F.B. Spent Fuel Pool Liner Details."
- 3. B&R drawing WRB-10559, Sheet 1, " Fuel pool liners Imbeds -
Weld Identification No's."
- 4. B&R Procedures:
(1) QI-QAP-11.1-4, December 26, 1979, " Welding Inspection of Stainless Steel Liners" (deleted in error on January 15, 1982 and reissued with no changes on Janaury 26,1982). ' (2) CCP-38, Revision 4, dated January 5, 1984, " Stainless Steel Liner Erection."
- 5. DC/DDA 2946, Revision 1, November 13, 1978.
- 6. Comanche Peak Steam Electric Station / Final Safety Analysis Report (CPSES/FSAR), Section 17.2, " Quality Assurance Requirements, and Section 3.2, " Design of Structures."
l
- 7. U.S. NRC memorandum, dated January 25, 1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: D. B. Vassallo, Assistant Director for Light Water Reactors, Division of Project Management, IE
Subject:
Classification of Spent Fuel Pool Liner Plates (AITS F1219H1) (AITS F30382H1).
- 8. U.S. NRC memorandum, dated February 6,1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: R. T. Carlson, Chief, Reactor Construction and Engineering Support Branch, RI
Subject:
Classification of Spent Fuel Pool Liner Plates (AITS F12193H1) (AITS F30382H1).
- 9. U.S. NRC Regulatory Guide 1.29, Revision 3, September 1978,
~
" Seismic Design Classification."
- 10. Region IV Report 50'-445/79-15; 50-446/79-15.
- 11. Allegation Source:
(1) AM-11 --- 84-006, 3/7/84, A-4 Testimony Pages 51, 52-55. (2) AW-40 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15. (3) AW-42 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15. (4) AQW-80 --- A-49, 8/8/84, and A-4, 8/24/84. (5) AW-81 --- A-4, 8/24/84. (6) AW-82 --- A-4, 8/24/84. - _ g .- -
- 10. This statement prepared by:
E. G. Thompson Date C. Richards, TRT Technical Reviewers Reviewed by: L. C. Shao, Date Group Leader Approved by: V. Noonan. Date Project Director e 6 l l l
i .. 5 g
,?-
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- r. c c. . . . .. t ,:. n ri r.. - ( 44ri- '
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- 1. t4.. il i ar rir.
~1 I r.rir.12 t e Revis1on Number 4 5 Final 1 2 .
r ..+ her Tech. Ed tor . Erouc Leader J. r s.,1, .r d n T. T r. ., r.1 4 + n fidmi ni str ati ve Writeup integrated into SEER ___________ Pot enti al Violations to Region IV___________ l Workpa.ckage File Complete ______________ i Wortpackage Returned to Group Leader __________
~
4 l F0lA-85-59 ijd
3[s~ (o Draft'( 7199/85 AM-11, etc. (DCP5) SSER
- 1. Allegation. Group: Mechanical and Piping Category No. 43, Poor Welding Conditions for Spent Fuel Storage Pool Liner
- 2. Allegation Number: AM-11, AW-40, AW-42, AQW-80, AW-81, and AW-82
- 3. Characterization: It is alleged that:
(a) AM Incorrect fitup and poor welding technique resulted in thin welds joining stainless steel liner plates for fuel pools in the fuel building and reactor building for Unit 1. (b) AW One weld seam in the spent fuel pool liner is largely rust and concrete. (c) AW Poor welding conditions existed for field installation of the stainless steel liners in the spent fuel pools of the fuel handing faciltty. (d) AQW Liner plate weld seams do not match drawing loca~tions on the flooring around the Unit I reactor vessel pool.
, (e) AW The stainless steel floor plate liners in the spent fuel pool and transfer canal are supposed to overlap .
the angle member at the bottom edge of the wall-to-floor joint. There were areas of no overlap and the weld was built up to bridge a gap. (f) AW A single block related to the leak chase channels under the floor liner of the fuel pools or fuel transfer canal is defective and could affect leak detection.
.h
- 4. Assessment of Safety Significance: The TRT review for the evaluation of the above allegations included a study of the applicable specifications, drawings, procedures, documentation, regulatory guides, NRC Region IV inspection reports (irs) and NRC memos. The TRT
% dererm;~ ka reesire m e -Cr review included seismic and regulatory requirementsdthat apply to the Aws pc/4
/ &* >'s f* r r+
fuel pool,14eer-s.. - ce n ok a ,, a' r e o c.n refa af,4,5 anity \
~~
-- )
%gy j
$ s , f"2 4 dry'h The TRT also performed visual inspections of the fuel pool liners.
71y y -De[generat visual inspection ::r ;_..m oi for the overall liner installation was /pr/cr-and ' W a more detailed examination of approximately 20% of the welds- the spent fuel pools and fuel transfer cana[' The areas of weld inspection covered the floor plate liners, those portions of the wall liners which were easily accessible from the floor, and areas adjacent to the sparger spray system which runs horizontally, about
- half way up two walls of each of the spent fuel pools. The liner installations are complete and the details of the leak chase channel network and floor imbedments are not accessible for visual l examination.
l The TRT's visual inspection revealed that the placement of floor plates was nut necessarily uniform. There were some areas where the gap between floor plates was such that the fillet welds washed together and one area gave the appearance of a butt weld. All wall liner butt seam welds were ground flush or concave and most of the floor fillet welds were cosmetic ground. The inspection could not 1
j $43 a) wa s a cc ess m er N IT a'* S @ AW'7 S" detennine!: p ysed;; L;; gap cr J.:n(tightly butted cou N joints /w causeinsufficientpenetration),Theexaminationdidestablishthat
.- (&mw),
gas tungsten-arcp, welding if not exclusively used, had been extensively used. This conclusion was based on the appearance of unground welds. No butt welds were observed to have reinforcement exceeding the 3/32" maximum. Seam weld concavity raay exceed 1/32" in some locations due to grinding of weld surfaces. A more cursory examination was made of liner welds in the fuel pools of Unit 2 and in all cases the general appearance of welding was smooth, clean, and sound. (a) AM-11 This allegation is concerned that: (1) The fitup of 3/16" and 1/4" thick stainless steel liner plates for butt welding was supposed to result in a joint Fp of'3/16" to 3/8" to facilitate making a full penetration weld, but welders encountered tightly butted joints. These joints were partial-penetration welded by laying weld filler l wire on the joint line and fusing it in. (2) Gapped butt joints were incorrectly welded by either building up weld metal in the middle of the gap and then bridging the gap at the top with ld orabythinfw(e/ess laying 7% weld rod in the gap and welding over it.
~
43 9'yr sj ~ Procedure CCP-38, Revision 4 (dated January 5, 1984), Stainle Steel Liner Erection specifies that 3/1 " o 3/8" joint gap for fitup stainless steel plates fo utt welding was a requirement only for omatic weld . Narrower weld gaps were acceptable for manual weldin However, the TRT notes that tightly butted joints uld preclu making full penetration welds in the 3 and 1/4" thick liner p es using the specifi nual GTAW process. All of the fuel p liner w ing was apparently performed using the manual GTAW p ss. . The TRT is preparing a summary of its findings on allegation AM-ll to forward to the alleger, who declined an interview. (b) AW-40 The allegation states that water from poured concrete had entered leak chase channels and run past backing strips into weld joint areas. The allegation does not identify any specific weld or area. 't.:. g the TRT's visual examination did detect two questionable spots of corrosion. Both were on the north wall liner of Unit 1 spent fuel pool. A buildup of 1 . corrosion products was observed on a horizontal seam weld located about half way up the wall. The corrosion - products were located between the midsupport for the pipe and the nearest light pole. The second questionable spot observed by the TRT was in a horizontal seam below the sparger ! about level with the top of the fuel storage rack. It was l
[. ~. O located opposite the northeast corner of the rack. There was no buildup of corrosion products but there was a light
74 rR T~<.eu M - o r te r-r - ,~ 77<-
rust colored stain;th:t appe="d te Sn ; t,;;r, ::esed by Source- ca us e'n y 76u. s m*~ s - m +ne lamkinn frem 3 cm3 11 : pet j- th= yald : 3- , , , , , , , , , ,
;,t,,
ca.1d 4<- fou ~ d en. no obvious hole or pore /in the weld. L 7A rfi <$ no4 y?? M h,% ,. rs A Th u sh72.f A s a cto ss r- eye-, ,,.- 7. % w n u - r 4<- ) e r -.p;J. Arrangements are to be made for the TRT to review its findings on allegation AW-40 with the alleger. (c) AW-42 I much as both Unit 1 and 2 spent fuel pools are com ete, fY / TRT vis 1 examination could neither substantiate or refute the
&O / allegation r arding poor welding conditions ncorrect fitup, and poor welding te nique during line abrication. However, NRC Region IV IR 79-15 da May , 1979, concluded that the allegation may be substanti y . In addition, DCfDDA 2946, Revision 1, dated Nove r 13, 1978, doc nts a modification made to drain lea hase channels containing wa r interfering with welding modification supporting the NRC Reg 1 IV findings At least to the extent of this evidence, weld g co tions were not ideal.
Arrangements are to be made for the TRT to review its findings on allegation AW-42 with the alleger.
v i (d) A0W-80 - t hie alleaation has e4=41erities to allageticr.; #1-11 -and au_sd., 7 llu he TDT e r <n:tien of liner ;;;1d;, ;;;; 1;;'cof 71.a rRr as o o sw<d
' fitup gap, r- - "
- t , petrib% variations i) #
nd certain areas ving the appearance of t joint in lieu of a smrac tvem a r ri ;.5 % e s,h; s . an overlap)7%..elb:v:r, wt TRT exami on of the welds could find no evidence th'at the welds we not sound or that an adequate seal was not achieved. e TRT's e uation for safety ed on its visual examin on of liner welds, significance is the requir ts that apply to the design purpos f the liners
..f~
inal acceptance of the required NDE examination nd b 7 . b,i and
,f ,_ tests.
The TRT is preparing a summary of its findings on allegation AQW-80 to forward to the alleger, who declined an interview. (e) AW-81 This allegation is similar to AQW-80 except that it applies to the floor plate where it mates with the wall plate. The floor plate is supposed to overlap and be fillet welded to the leg of I the angle attached at the bottom edge of the wall liner. The TRT I did observe some apparent butt joints in thisthisese Where area] rAon w E t conditionsexist/ItheTRTwasunabletodeterminewhetherthere
?
was any weld buildup to compensate for an excessive fitup gap. e;
"? "'0 Oval"2tiO" Of- 00f0ty einnif 402"C? i0 b;3Cd On th0 !?me !
- Ovidence at ^Q" beve. 8 5" d - & '~ WM 8 " O .
7s n, W .p eaa--. n s - d 76 ><, L ./ .ccop - +
, i
(*< n - , , 7,S s , 7L nt' 7 a6 kr-. A cf & a C #~ #' "
- C
- r n, a s.p r, m-1.
The TRT is preparing a sumary of its findings on allegation AW-81 to forward to the alleger, who declined an interview. TAs e//ay - n s~e s r ~ < </ e d-r . a'f-e7;r e d / < A. u ~ *'*'~ Th. / /ovv-f /s .= - r- io ' , L . : , = ' m o pr 71-prud povis # (f) AM-82 T' M C'~'/ " **
- b r /* * " a'* 7- < 77S -
Since the details of the leak chase channel network are not accessible for visual examination and because the allegation lacks specificity, the TRT review has attempted to identify the alleged " defective block" and evaluate the affect on the function of the leak chase system as well as its safety significance, regardless of the location and extent of the defect. A review of details shown in G&H drawings 2323-5-0831 through -0834 and B&R drawing WRB-10559 determined that only two items in the construction of the leak chase channels and floor grooves could apply to the alleged block: (1) Blockouts - These are wood blocks used to form the leak chase channels' during the pouring of the concrete floor o1R /noe
- de A C'c/> - fe 57. r. , y% . f
- of the' fuel pools.I(Tha fter the setting of concrete, j
the blockouts/we/,.//ee6a removed and any chipping or damage to the chase y repairedj ,e - o' N'.T r0 e 4,3 4 7 n o <
- 5 f2 coe 7 d cui r/s a. S u / o ,. T 7C/~ ; A/ f?" *'rs e n d' en ~*i~ = S ara s re e u,' c/ ,7Co 71g' e s Zt h ~er ren s e e s-a ru G* !* ~
n-r o w&co sr .u s i.ists,.,saa., ,y a, +,1.,7;: p 7;ar s,ne.u...sas.v. rz # -_ g . l (2) 3/8" x 2" Imbedded Bars - These are bars imbedded in and - l *t-l flush with the surface of the concrete pool floor and 1 4 anchored using Nelson studs. The bars are centered between 'g the leak chase grooves and form a grid framework to which the floor liner plates are fillet welded. 1 I
In its review of documentation, the TRT discovered CpSES Design Change Authorization (DCA) No. 5687 where a 3/8" x 2" imbedded strip identified as "F-15" was omitted. The DCA solution was that: " Plates P186 and W135 shall be butt welded together and laid as one unit." The location of this deviation is at the junction of the fuel transfer canal and the cask pit entrance. e*' d The TRT reviewed the drawings and d:ti-k;d that4the functional purpose of the chase channels (to detect leakage through the pool liner and to locate the leakage within a sectional area using the system of drains where a section of chase grooves empty into a single drain),r:: not : f'--t=d.
/824 Y The TRT also reviewed ASLB testimony where issues pertaining to the fuel pool liners were discussed from Sept. 10 through Sept.
21, 1984. These discussions question the adequacy of inspections and governing procedures, and adherence to the procedures. For the most part, the activities which took place from the back side of the liners (the side which becomes the boundary to the concrete) were discussed in the testimony, i.e., tack welding the backing strip in place to accomplish the wall liner plate-to-plate fitup, and the attachment of the leak chase channels which are fillet welded and fonn the enclosure around the backing - n s7;, e.~D Is w < s a ~ s' ytw' i ~M-r= W strip. /T..:p purp::: 5.a f the kd :h:rn:h deer act 4-cle& the - of regyn-e w 7s tw acce,-da~ce wiff f)p/ y j3 477 4 to dH J'o intent to be a eecendary : ;l tc the pl&te-tc pht :::1 weld. ar e cave e o' s, > 7% TM 's $st/6d. SSa~^? .
-Therefore. th;rh ata nn rannlatney reg"4ppyqn_t:,fer d::ur ntation i:f th :1 exe-inauena for cleenliness of ettaduncut locatlud5'to
e _g. . . i h e of-t W iners _ The requirements whi are hed in accordance with the pertinent por ons of Appendix
/estab .
B to the 10 50, and defined in B&R's Qu ity Instruction [ pd[ QA-QAP-ll .1-4, app nly to the plate o plate " seal" weld. y< Normally these.requiremen incl visual examinations for y .\ '(vj cleanliness, fitup, and the mp ted weld; a liquid penetrant examination of the com eted weld and a quid film vacuum box
\v [ ', ,N.f ' .
y '. " bubble" test for eakage. All of these exami ions are y\ [,[ performed a he front (exposed) surface. The fact th the {d ' ' I g ba:iin strip is no longer visible from the back side is of n 9'y z r / sequence.
/
}? .
f f'# 7 s0ver and above any regulatory requirement the drawings specif fmi cer n areas to be radiographed. TUSI letter TUQ-041 d
~
ed September 1975 to B&R permitted the substitution magnetic
- particle inspec on in lieu of radiography for rtical containmen liner we in the reactor cavi . (The TRT notes that magnetic particle insp ion is not applicable to the liner material, which is type 304L aust iticstainlesssteel.)
There were other areas that were'exami by the Mass l / Spectrometer Leak Testing method. As mentio earlier in this SSER, the pools were als " water" leak tested. QC rsonnel were
/
permanently assigped to the areas of fabrication and ins llation l of the fuel pool liners to monitor the activities. The alle tions and transcribed discussions lack specificity to the extent that ' traceah ity to specific welds cannot be positively shown. H er, documentation of nonconformances, conditions that were
/
l
~.
w __ not ideal, and certain ~a ti'5Hs to pro operati ere reviewed. The TRT is. preparing a summary of its findings on allegation AW-82 to forward to the alleger, who declined an interview. l 5 nelusion and Staff Positions: The TRT's review establis that consi able difficuljy was encountered in fabricatio and installation f the liners. Documentation in ar substantiated the allegations. How r, the primary functio Vof the stainless steel liners is to provide a ak tight ba r and a surface which may be easily decontaminated. The R concludes that these basic requirements have been rr . The RT also established, on the basis of a U.S. NRC Memora m entitled " Class' ication of Spent Fuel Pool r Liner Plate dated February 6,1979, tha fuel pool liners are not requi to be designed and erected to Seismic tegory I requirements. The TRT, therefore, concludes that al ough some of the 4 ~~ allegations are valid. they hamafety signiittance~.
- 6. Actions Required: None.
- 8. Attachments: None.
- 9. Reference Documents:
- 1. G&H Specification No. 2323-S5-18. Revision 3, April 6, 1979
" Stainless Steel Liners," issued for B&R Construction
- 2. G&H drawings:
(1). 2323-S-0831 "F.B. Spent Fuel Pool Liner Details." (2) 2323-S-0832, "F.B. Spent Fuel Pool Liner Details." (3) 2323-S-0833, "F.B. Spent Fuel Pool Liner Details." (4) 2323-S-0834, "F.B. Spent Fuel Pool Liner Details."
- 3. B&R drawing WRB-10559, Sheet 1, " Fuel pool liners Imbeds -
Weld Identification No's."
- 4. B&R Procedures:
(1) QI-QAP-11.1-4. Decchioer 26,1979, " Welding Inspection of Stain! ass Steel Liners" (deleted in error on January 15, 1982 and reissued with no changes on Janaury 26,1982). (2) CCP-38, Revision 4, dated January 5,1984, " Stainless Steel L'iner Erection."
- 5. DC/DDA 2946, Revision 1,flovember 13, 1978.
- 6. Comanche Peak Steam Electric Station / Final Safety Analysis Report (CPSES/FSAR), Section 17.2, " Quality Assurance Requirements, and Section 3.2, " Design of Structures."
- 7. U.S. NRC memorandum, dated January 25, 1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: D. B. Vassallo, Assistant Director for Light Water Reactors, Division of Project Management, IE
Subject:
Classification of Spent Fuel Pool Liner Plates (AITS F1219H1) (AITS F30382H1). \ .
. ".e
- 8. U.S. NRC memorandum, dated February 6, 1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: R. T. Carlson, Chief, Reactor Construction and EngineefingSupportBranch,R,I
Subject:
Classification of Spent Fuel Pool Liner Plates (AITS F12193H1) (AITS F30382H1).
- 9. U.S. NRC Regulatory Guide 1.29, Revision 3, September 1978,
" Seismic Design Classification."
- 10. Region IV Report 50-445/79-15; 50-446/79-15.
- 11. Allegation Source:
(1) AM-11 --- 84-006, 3/7/84, A-4 Testimony Pages 51, 52-55. (2) AW-40 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15. (3) AW-42 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15. (4) AQW-80 --- A-49, 8/8/84, and A-4, 8/24/84. (5) AW-81 --- A-4, 8/24/84. (6) AW-82 --- A-4, 8/24/84.
- 10. This statement prepared by:
E. G. Thompson Date C. Richards, TRT Technical Reviewers Reviewed by: L. C. Shao, Date Group Leader Approved-by: V. Noonan, Date Project Director p -
. , . . . .O
b - gg.11, etc. t DCP5 Draft 7 - 3/20/85 SSER
- 1. Allegation Group: Mechanical and Piping Category No. 43, Poor Welding Conditions for Spent Fuel Storage Pool Liner 2.
- 2. Allegation Number: AM-11, AW-40, AW-42, AQW-80, AW-81, and AW-82
- 3. Characterization: It is alleged that: .
(a) AM Incorrect fitup and poor welding technique resulted in thin welds joining stainless steel liner plates for fuel pools in the fuel building and reactor building for Unit 1. (b) AW One weld seam in the spent fuel pool liner is largely rust and concrete. (c) AW Poor welding conditions existed for field installation of the stainless steel liners in the spent fuel pools of the fuel handing facility. (d) AQW Liner plate weld seams do not match drawing locations t on the flooring around the Unit I reactor vessel pov'. l l (e) AW The stainless steel floor plate liners in the spent fuel pool and transfer canal are supposed to overlap the angle member at the bottom edge of the d wall-to-floor joint. There were areas of no overlap and the weld was built up to bridge a gap. (f) AW A single block related to the leak chase channels under the floor liner of the fuel pools or fuel transfer canal is defective and could affect leak detection. b Nh
f . 4.0 Assessment of Safety Significance: To provide a better clarification of the alleged concerns and issues, and their review and assessment, this section is divided under the following subtitles: 4.1 Scope, ce 4.2 Applicable Requirements, 4.3 0/'scription of Details, 4.4 Fabrication Technique, 4.5 TRT Visual Inspection, 4.6 TRT Review of Documentation, 4.7 TRT Review and Assessment Specific to Allegations, and 4.8 Additional Findings and Assessment.
4.1 Scope
This TRT review and assessment is regarding the allege,d osu t.j ed concerns and issues about the g stainless steel liners for the spent h b\ bu M useW fuel pools,Wtransfer canal, and reactor refueling c'avitie3 In p y y%" Ypsc*f
@ & addition to that which is alleged, the concerns have given birth to gor 3 g
c _ ,a . N A .st w W M sv h.a issues that question the adequacy ofdCPSES) failure safety analysis report ( FSAR), the requirements which were implemented, the N_ fabrication processes, and3 acceptance criteria to assure that the
<& eb liners will not sbc h:rful tithe safe operation of the plant. The TRT objective is to report their finding of fact, review the concerns, and to make an assessment of safety significance.
4.2 Applicable Requirements: The following regulatory sources which
..sniur '
either impose or exclude requirements for the, liners were reviewed andarelistedindfcendingorder: (a) CPSES/FSAR does not list the liners for the spent fuel pools, transfer canal, and reactor refueling cavity, as "Q" items. The CPSES/FSAR does not make mention of these liners. i
i g Se (b) ASME B&PV Code sets forth the requirements for concrete structure l of the fuel pools and clasifies the structure to be seismic J Category I. The Code makes mention of the fuel pool liners only to exclude them from these requirements. (c) The U.S. NRC Regulatory Guide 1.29 classifies the spent fuel g I storage pool structure, including the fuel racks to be Seismic t) N't ()O % Category I design requirements. The regulatory guide also states l Y) o, y [ 8 M that the pertinent quality assurance requirements of Appendix B
; # to the 10 CFR 50 should be applied to all activities affecting the safety-related functions of those portions and functions of structure, systems, ar.d componer.ts which are classified as Seismic II.
(d) The U.S. NRC Memorandum dated February 6,1979, states "... fuel pool liners are not required to be designed and erected to V b
/ S The memorandum further states l
g'g'f,MeismicCategoryIrequirements."
"The primary function of the liners is to provide a leak tight i
g( u barrier and a surfac st:i u.!4 'cr decontamination, rather than No- // to serve as a critical safety structure."; and, "The probability of large leaks occurring and being undetected over a period of l
. Y'? time such that a potential hazard might be incurred is acceptably l low."
- 7. n, r w' '![ Q -. (-r# S .4 . * ?~'
3
- 1. Materials shall be ASTM grade, Type 304L stainless steel, l
3/16-inch and 1/4-inch thickness. D. ,. - - . - - . - - - , - - - _ , , , - - . , - - , , , . ---,.-.n _,c,,-, -. ., . - _ _. ,,- ,- - - - - - -
e w 4-
> 2. Liner plates shall be seal welded by inert-gas-shielded (gas tungsten-arc) welding (GTAW), using fillet and full penetration groove welds.
sy ec1 mum
- 3. Welding procedurejer'"f : tid and welders' performances shall be qualified in accordance with ASME B&PV Code Section IX.
- 4. Plate-te-plate fitup gap using backing str p for manual GTAW shall be:
(a) other than prequalified joints - minimum 1/16-inch, (b) for prequalified joints as shown in prequalified details - 1/16-inch + 1/4-inch (without backing strip - 1/16-inch + 1/16-inch), (c) "high-low"mismatchbetweenabuttingendprfpsshall
"+ exceed 1/8-inch.
(d) If root opening (gap) exceeds its applicable requirements,oneorbothendprfpsshallbebuttered until gap is within acceptable tolerances.
- 5. Surfaces shall be smooth and free from irregularities and may be ground to a smooth finish.
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- 6. Stud welding (ASTM A108 Nelson studs) shall be automatically 7
w
' - controlled equipment which shows dacceptable undercut.
i . V gp MSA5# cO. Lack of 360' fillet may be corrected by additional manual GTAW. Installation, inspection and acceptance of anchor studs. shall conform to the applicable requirements of the A AWS D1.1 Structurg Welding Code.
- 7. All seams welds shall be dye penetrant tested, and shall also be tested by vacuum box for leak tightness for their entire length. Also, all liner systems shall be filled with water and monitored for 48 hours for leakage. An optional test may be performed for locating leakage by filling the leak chase system (see 4.3 Description of Details) with helium and scanning the welds with an instrument sensitive to and capable of signaling the presence of helium that permeates through the. weld. Any leakage shall be repaired and testing repeated until successful completion. No test I is considered complete until accepted by Engineering. The '
l TRT notes that no acceptance criteria was specified for the dye penetrant test until January 3, 1985 by DCA to the . procedure (see section 5. " Conclusion and Staff Position). Note: The QA/QC aspects regarding the issues relating to l the liners are covered in the TRT's QA/QC SSER. 7 f d L Gh*9 # ed\9'- l l 1
4.3 Description of Details: The wall liner plates are joined by full penetration [buttweld* usi g a backing strip. A C3x4.1 S.S 54 \, ' channel. is welded evegthe 2ack side of every seam to provide a leak chase, where any leakage through a liner seam weld will be collected. _The :.upiered ::: tion: ef w:11 lir.er; bec0 : the ferir, forthopa"ringe of rnnerata "e!' structur: of the fuel peels. Jh: : ncret: 'h;r i;
,ggge.o nr4nr +n noc: % r t g j=+4mr. The leak chase grooves in the floor are molded [.N th; esch+.ef concrete,u;ing -
% 3e n ?
GL - ;- -. . - Also 3/8" x 2",bar strips are imbedded to be flush with the surface of the concrete floor. These imbeds fann h lattidwork to which the floor liner plates are fillet welded. Both the wall liner plates and floor imbeds are anchored in the concrete using w e \ 1. A L IA4. \a ux s aa . nelson studsg The design features of the fuel pool liners include a system of drains where each drain connects to a sectional group of leak chase channels or grooves to provide an early detection system for leakage from a given number of seam welds. It also provides a means to recycle the captured leakage. 4.4 Fabrication Technique: Each liner system, for the spent fuel pools and reactor refueling cavities, was fabricated and erected to be a single " box" like unit (excluding the floor plate). The fabrication was performed outside the buildings where th: prec::: e. tU we re n expA > Ad
=-pi's the plate-to-plate fitups by itack welding the backing strips in place and fillet welding the leak chase "U" channels as defined in 4.3. The inside of each liner unit was heavily braced and which supported the erected linersg f +"M !:: n;;e:tery for the
i a 4r;;in- to providedrigid " backup" strength $#$$Ynercrit;since t
- I. i c s .n f
/~ " , they also served as the fonn for the concrete peur ;[. the pcd ( pe. structure The Nelson studs, wh;ch-acre' located on 12-inch centers L -~Y a u d s eco m e a m4e<< o' \ (certain details required much closer centers),bere s'e!d:d to the inga e. cne ran s 1;n.rs ec. . J. : 7 s aftar_tha lia r_ unit wac locat;d ;. plecc. " 1 -i. m, ..dd 705 ibl0 {z rg" to Tire %; lid ai.udreiace +ho nav+ stan rif a c ti oi ty WAC D CGGC7ctC puur. IhC 00nc 6t6 OtrSCt9* ^^^- ~ C th0-
"^'--- ^ ^ " "
ddghe features of the leak chase channels form a
" tongue and groove" type mating with the structure. W -- , the '
rh 4,,o .s e e e.- l.!-_- s haenma essentiallg an intregal attachment to the concrete structure. The plate-to-plate groove welding on the exposed side of the liners was completed after the concrete had set and the bracing removed. The floor plates were the final installations as described in 4.3 Note: The transfer canal liner was similarly fabricated except that the wall liners were fabricated in two half sections and welded to a single unit after they had been located in place. 2 Ow .y \ . 4.5 A general observation of the,overall liner installation and a more detailed examination of approximately 20% of the welds in the spent m.h. fuel pools and fuel transfer canal 3 The areas of weld inspection covered the floor plate liners, those portions of the wall liners which were easily accessible ~from the floor, and areas adjacent to the sparger spray system which runs horizontally, about half way up two walls of each of the spent fuel pools. The liner installations are complete and the details of the leak chase channel networks and floor imbedments are not accessible for visual examination.
~
6-I The TRT's visual inspection revealed that the placement of floor plates was not necessarily uniform. There were some areas where the gap between floor plates was such that the fillet welds washed together and one area gave the appearance of a butt weld. All wall liner beM seam welds were ground flush (or slightly concave) to the liner surface. Most of the floor fillet welds were cosmetic ground. The inspection could not determine if the fit-up gap was excessive or if it was tighly butted (tightly butted joints could cause u dd- - insufficient, penetration). The examination did establish that gas tungsten-arc welding (GTAW), if not exclusively used, had been extensively used. This conclusion was based on the appearance of unground welds. No butt welds were observed to have reinforcement exceeding the 3/32-inch maximum. The TRT did not dimension seam weld concavity. However, in some locations due to grinding of weld surfaces it appeared that concavity may exceed 1/32-inch. A more cursory examination was made of liner welds in the fuel pools of Unit 2 and in all cases the general appearance of welding was smooth, - clean, and sound. The TRT did detect two questionable spots of corrosion. Both were on j the north wall liner of Unit 1 spent fuel pool. A buildup of l corrosion products was observed on a horizontal seam weld located about half way up the wall. The corrosion products were located between the midsupport for the pipe and the nearest light pole. The second i questionable spot observed by the TRT was in a horizontal seam below the r sparger about level with the top of the fuel storage rack. It was located l l i
e . 1 l
)
opposite the northeast corner of the rack. There was no buildup of corrosion products but there was a light rust colored stain. The TRT could not determine the source causing these stains. No obvious hole or pore could be found in the weld. The TRT also observed certain inconsistancies in joint configuration; i.e., an area where the joint appeared to be a butt type in lieu of an overlaped, fillet welded (ve p/e pejoons ; m. are 17/co) " ' " " jointA -Oth;r inccesistracies er wktt Thi I, c0e!d net confide,- these 'iad I p -tr he m ssive er t?.Vi P ny ef %y
-signific ::: ' .xample OC/00As No. ES & 97007 4.6 TRT's Review of Documentation was initially to review all possible sources of codes and other regulatory documents to determine the requirementsth:t i::: ;;cci'itally impos 4 : d applicable to the o ~"
liners. ch: rev hred " M iwevides the besis CPSES/FSARl+e:: m aoes n o r : : : - m i., se. Y' fe either adopt 4ng-or not7doptimrany7dditionabrequirements, [ex.r
- i,*~<.,,,,ru n n s ,,e o i; ,., p ,. n.,;, a ,,,,.,,n,.,
penvided_by_the Codes and-other regulatory source where those ) e rr y p;.. A, r-e rep ry s ~ irsis per 7xa /, ,,e r.s . ranuiraments are nnL:pec;ficelly addressed-to-be-applicable to the/ ' liness.,, & TRT el;c eviewed the NRC Regulatory Guide 1.29 which is ,
.u .2 3 -ss re dated subsecce"t to tM CPSES/FSAR but prior to th@ G&H specification '- M j
so %* . W9 for the fabrication and erection of the fuel pool liners. Regulatory 4a
,1 h c J Guide 1.29 defines the clasification of seismic categories, and also statesthatthepertfnantportions4ofApendix8to10CFR50should n,,
be applied to the linersgwtrit:ir establishes 3 QA/QC requirements for the control of the fabrication processes and documentation. The TRT reviewed the G&H specification and B&R specifications and procedures and he trace of requirements through the procedures weg consistant. These applicable requirements are as identified in 4.2. T VNoiwe*k6 "# b h T* -
TheTRTalsoreviewedB&R'sweldingprocessspecificationkWPS)99020 for machine GTAW, WPS 88023 for manual GTAW welding which was used for the liner applications; and WPS 10071 which was used for stud welding using the automatically controlled welding equipment, and WPS 18013 which was used wFere stud weld repair was required. These WPSs are consistant with the applicable requirements for liner welding. . the TRT performed a general review of welding documentation, numerous a d NCRs /ma,,ny DCAs, ete: where certain observations 4het appeared to ! have 4eme relevance to the allegations,Me-e not e G&H and B&R drawings were reviewed for detail requirements. These drawings are listed in section 9(2) and (3) of this report. The review includes the Region IV report 79-15 and related testimonies; and to date the TRT has remained current with their review of NRC memorandums. These memorandums are M ; Lully regarding s w s y o'er+r -,n, m 4the level of safety relationship that should be established (if any) fa *Fe liner systems. 4.7 TRT's Review and Assessment Specific to the Allegations: (a) AM-11 This allegation is concerned that:
s
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(1) -The fitup of 3/16dInd 1/4" thick stainless steel liner plates for butt elding was'sdppoYed to result in a joint gap of 3[16" to 3/8" to facilitate making a full penetration weld, but welders encountered tightly butted joints. These
, joints were partial-penetration welded by laying weld filler wire on the joint line and fusing it in.
(2) Gapped butt joints were incorrectly welded by either
," , building up weld metal in the middle of the gap and then .
bridgingt5egapatthetopwithathin(lessthanfull penetration) weld or by laying weld rod in the gap and welding over it.
', vrsO The TRT p inspection of ,the liner welds reasonably supports that
~
all of the welding was drformed using the GTAV process. The s , inspection 45uldnotconfirmthepreweld,f)t-upgapconditions to have been tigh y butted, excessively gapped, or to have been n, n y bridged overfThe overall surface appearance of the completed}
^ ~
d
$4 p e's 'th'a't'u s In'gThe"YNAW"p' roc es s ,7ti gh tl y butted joint could preclude making a full penetration weld in the 3/16" thickness, and more probable in the 1/4" thickness stainless N gt o MW steelmateria)specifiedfortheliners. (The ester,uun 4,for the worst case using GTAW and for 1/4-inch thick liner material,
~
a 95% M ability to produce 65% penetra hion.) However, the TRT did conduct an interview with an individual who is currently employed with B&R, and had been a fitup man for -the liner 9 W
- fabrications for more than 1 year. He stated that all the fitups that he was responsible for were gapped; but he could not (at present) recall what the gap requirement was. He also stated that he did not recall having 1 seen any t(fightly butted fitups.
3 _ e h11 that o.ea"ir: : t Sectier '. (c)4(4 r The TRTwor
- ster4.7 w&:h:: d--- raosunk 9.1ce) ecd) "ravir e , n iy shows that buttering is permitted where gaps exceed the specified requirement.
The TRT review cannot substantiate the concerns regarding this allegation; nor does the review determine any safety significance. . 7 WcMM q The TDT 4 pt:Pri79 2 st=:ry af it5 findin95 en allegaWon
=Q ^
#er:rd to th: :11eger " e d: Hneu f
(b) AW-40 The allegation states that water from poured concrete had entered leak chase channels and run past backing strips into weld joint areas. The allegation does not identify any specific weld or i area. During a personally conducted interview with a B&R
~L dVMM employee,yiachdirfcasualdiscussionswithB&R'swelding engineer and QA personnel, the TRT learned:
(1) During the concrete pour of the pools' cavity structure, there were certain areas where spillage of concrete ran down pbAes the exposed side of the linerg. 'n -ee Mer: p rtic : af-
._ ^ ~ " " ' ~ - - - - - _
13 - i
-n _
f 5. . ;;ge"it b;;;r: indnad in : := rnorb y f grooves 2: r; t9 01 ate-to-ola e scrdi had not baan ( s k ~~ ] yh concra re -m *>r gNIT1flebCG; C Seenana n# t:t;r f;eg,d t '2: :- . g Je <fra frL.-
= rter the 'r9 chn g between the nlat6 and hackinn c+rin r g ,M (2) During the liner fabrication activites, the overhead (roof) structures of the buildings that contain the liner system were not in place. This was to facilitate the locating of liner units described in 4.4 " Fabrication Technique."
Plastic had been stretched across the span of these , fils )h sni di d mirJ<d ne w's 4 4 openings. However,jeverytima 4 + @:d , .-::ter poured into the pool areas and ran down the exposed sidesof the liners. Where the seam welding was not performed, the water entered the leak chase system by seeping between the liner plafe and backing strip.
,,g,,Lg s b A ' M k h e.
Thereare(eNa1NCpdescribingweldingpreparationsbeing contaminated with concrete and/or water. In every case, appropriate measures were documented to clee; ar' . c"iew acceptable welds. More specific cases are addressed in allegations (c)AW-42and(d)AQW-80. The visual inspection of the liners detect two questionable spots of corrosion as described in the final paragraph of 4.5, "TRT's l Visual Inspection."
b The TRT determined the concerns of this allegation not3 be safety significant. However, a more decisive examination method should be considered to determine the exact causes for the two questionable spots of corrosion to preclude the possibility of leakage. The alleger was contacted to arrange a meeting to review the TRT's evaluation and finding. The alleger indicated he has no concerns with CPSES and is not interested in a review meeting - with the TRT. (c)AW-42 The allegation shows considerable concern regarding poor welding conditions during the construction of the fuel pools and fabrication of liners, i.e., seepage slur) from the pouring of
~
concrete causing interference to welding operations. The TRT's visual inspection of the completed liners did not reveal any evidence of conditions that existed during the construction phase. However, the rev %: c f n:uranta+ ion revealed numerous NCRs. There were several cases where the QA inspector (s) wrote g _g_ about interfe ing conditions n hin;;hp giving or 5 the defect. Some of these c;nditiers were: m N w..,def<cr.be.dec wsa-(1) 1 Welder had to reach through a maze of rebar to make the weld. This was relating to a stud weld that did not have a 360* fillet. The existance of rebar was an unavoidable , condition. The stud welding was performed after the liner
~
d
, }/p [rta df /* r fY '# " r'~
units ,were located and the rebar! p ::dyj W en e 4_414us. During an interview with a B&R employee, he recalled having to occasionally provide clearance for the welder by using a come-along to pull rebar aside. (2) Water seeping from locations where concrete had been pou. red and contaminating components of liners being fabricated. (3) Water in leak chase channels interfe ng with welding. - This source of water described in Item (b) of AW-40 is also
~
reasonable to believe. (4) To many activities causing interference. The conditions already described are considered by the TRT to be not unusual to the industry and for construction activities conducted in environments which are open to the elements. The B&R employee who was interviewed and other B&R personnel (during casual discussions)~could not recall any additional co-diH ens that could be considered " poor". More than one B&R employee mentioned that on occasion individual employees were indisposed to perform work as directed due to personal reasons, thereby enhancing any existing " poor" condition. 17 m rar wro rr,. r
/ Als:, = noeinn rhen; /D :ign Deviation-Authorization-7
/DC/DDAg No. 2946, Rev.1, dated November 13, 1978, authorizes 1/2" holes to be drilled in a leak chase channel to drain and/or dry out residual moisture causing
E interference to welding. Afterwards the holes were repair i welded using the GTAW process and groundflush to surrounding I - surface. The conclusions reported in NRC Region IV's IR 79-15 dated May 21, 1979, states that the allegations regarding poor welding conditions may be substantially true. The TRT's review did find documented evidence of conditions ; that were not necessarily ideal. However, the TRT cannot conscientiously take the position that these conditions were , worse than normal for typical construction industry. The - TRT review cannot find any safety significance resulting from these reported and alleged conditions. l The alleger was contacted to arrange a meeting to review the TRT's evaluation and finding. The alleger indicated he has no concerns with CPSES and is not interested in a review meeting with the TRT. 8 i (d) AQW-80 The concerns of this allegation are that weld seams do not match drawing locations on the floor around the Unit i reactor vessel l pool. The TRT review of the drawings determined that the liner I ' weld seams must mate with the 2" wide bar imbeds which provide a backing plate for the weld. The TRT notes that the weld seam could vary across the width of the imbed without consequence or safety significance. The TRT's inspection of liner welds did notice that weld runs from plate to plate joints were not
)
~
consistent but did not consider these variations to be excessive. The TRT also observed variations such as the appearance of a butt joint in lieu of an overlap (fillet type) joint (Identical to covering The review of documentation found Eve AW-81). su veh4 67 such conditions. vtSN TRT's, inspection of liner welds and review of documentation cannot find evidence of poor welds or that the welds were not The TRT noted sound or that the required seal was not achieved, that at least one area, which had been contaminated with concrete [see description of source Ref. AW-40, Item (a)], could not be adequately cleaned and an acceptable weld could not be achieved. i This condition was resolved by grinding the descrepant weld flush to the liner plate, cutting a " patch" from liner material to completely cover the descrepant weld, and the patch fillet welded This all the way around and to the liner plate surface. condition was documented'by an NCR and the resolution authorized by a DC/DDA. The final acceptance of the liners is based on the wl The TRT could visual, liquid penetrant, , vacuum box leak testing. not determine any evidence that the , completed li.ner installation was not in accordance with the requirements as defined early in
~
this report, and does not detennine any safety significance to the concerns of this allegation. O h7 INS preparing a summary of its findings on allegation
,yQ T V(M w
AQW-80 to forward to the alleger, td@e%n-4MWeW" W h
f (e) AW-8 This allegation is similar to AQW-80 except that the alleger is concerned about the floor plate fitup that mates to the wall plate. The floor plate is supposed to overlap and be fillet welded to the leg of the angle attached at the bottom edge of the wall liner. .The TRT did observe some apparent butt joints in WW%T this area. There were al N written which covered these conditions. Where these conditions existed, the TRT was unable to determine whether there was any weld buildup to compensate for an excessive fitup gap. However, buttering is permitted (see 4.2(e),4(d),andexampleDC/DDA 795 & 3221). Based on the inspection of welds, the review of documents and the final acceptance examinations, the TRT determined that these conditions 7 were resolved without violation, and t M safety significant. he TRT is preparing a summary of its findihgs on allegation { AW-81 to forward to' the alleger, whv declined an 4ci.ei v ied (f) AW-82 The alleger is concerned about a defecthe block under the floor liner in one of the fuel pools or transfer canals that could affect leak detection. Since the details of the leak chase channel network are not accessible for visual examination and
.i T. because the allegation lacks specificity, the TRT review has ,
attempted to identify the all.eged " defective block" and evaluate the affect on the function of the leak chase system as well as L
L its safety significance, regardless of the location and extent of the defect. A review of details shown in G&H drawings 2323-5-0831 through -0834 and B&R drawing WRB-10559 determined that only two items in the construction of the leak chase channels and floor grooves could apply to the alleged block: 1 (1) Blockouts - Lengths of material cut to the required dimension for the leak chase grooves, and used to fonn the leak chase channels during the pouring of the concrete floor of the fuel pools. The B&R procedure CCP-38 states that after the setting of concrete, the blockouts shall be _r_emoved v and any chipping or damage to the chase repaired, 7nfthat the chase grooves be coated with a sealant film. A final visual examination was required for these operations. It is not, reasonable to believe that a blockout was left in place, or if defective, to Msubsequengaffect tc td-requirements. (2) 3/8" x 2" Imbedded Bars - Stair' n: + 3: bcr stock which is imbedded flush with the surface of the concrete pool floor, and anchored using Nelson studs. The bars are centered between the leak chase grooves and form a grid framework to which the floor liner plates are fillet welded. In its review of documentation, the TRT discovered CPSES Design Change Authorization (DCA) No. 5687 where a 3/8" x 2" imbedded strip identified as "F-15" was omitted. The DCA l
o solution was that: " Plates P186 and W135 shall be butt welded together and laid as one unit." The location of this deviation is at the junction of the fuel transfer canal and the cask pit entrance. The TRT reviewed the drawings and the functional purpose of the chas'e channels as described in 4.3, " Description of Details" (to detect leakage through the pool liner and to locate the leakage within a sectional area using the system - l of drains where a section of chase grooves empty into a single drain). Since the design drawings locate the chase groove to run parallel on each side of the imbedded bar to WMch-the plates are nonnally welded, they would therefore, remain to be parallel to each side of the butted plate to plate seam weld (relatingtoDCANo.5687). Therefore, any leakage that might occur through the weld joint would be collected and detected in the same
- c-mannerasit'wouldiftheimbeddedbarwereinplafe. The TRT could find no safety significance regarding this DCA.
(3) During the recordeo TR1 interview with the alleger in
' ow Gran ury, Texas, dated, March 5, 1985, the alleger described the " block" to be an area where the leak chase grooves were d<.h6b interrupted. This area served as a dam to prevent leakage o
from one leak chase section and drain to g te th8 adjacent _section. The leak chase grooves are now sealed beneath the floor plate which precludes visual examination. However, the TRT notes that B&R's procedure CCP-38 provides the
-, .- , - , - - . - , , , . , - - - - , , . , .. - -- ,s . . - - , - - - - . . .
c
- 21 -
t i necessary steps to repair any chipping or damage caused during removal of the blockouts, and a final inspection after the application of sealant coating. The TRT does not
\(/ determine this concern to be safety significant.
The TRT is preparing a summary of its findings on allegation AW-82 to forward to the alleger wha dact-ined :n i ter>4ew.R n 4.8 Additional Concerns and Findings: During the TRT interview with the #' alleger identified in the transcript dated March 5,1985 at Gra bury, Texas, additional allegations regarding the liners were presented. Those allegations are characterized as follows: (1) Floor plate liners are supposed to overlap the angle member at ,L} - W the bottom edge of wall-to-floor joint. (2) Plate-to-plate seal welds are so thin that a man pushed a pin through a weld. i (3) Liner wavfness and floor elevations exceed allowable tolera (4) A particle of concrete trapped in the weld could eventually eat its way through and cause leakage. t es { l
The TRT assessment for safety significance of these concerns are as follows: (a) The overlap weld joint concern is an exact repeat of allegation AW-81. The TRT found these conditions resolved and having no safety significance. (b) The alleger identified the person who" pushed a pin through a - liner seal weld! The TRT located and interviewed this person who safd "Yes, I made a statement like that!" and related the following event. He said that while he and a few other ? were standing in a group having a
" - typical " nonsense" conversation, he pulled a pack of cigarettes from his pocket where he has the habit of carrying pins and said, "Aw hell, I bet I could just walk over there and stick this pin through the weld." He continued to tell the TRT that it would be impossible to push a pin through any of thoseweldsandthatheissurprifedthatthis" nonsense" remark could have been overhead and interpreted that he had actually stuck a pin through one of the liner welds. The TRT finds no safety significance to this allegation.
(c) The TRT reviewed DC/DDA 602 which clarifies the waviness and elevation requirements and these "as-built" conditions of the liners fall within the elevation and waviness requirements i of plus and minus 1/2-inch each side of the mean. The TRT finds no safety significance to this allegation.
(d) The presence of concrete contamination significant to the quality of the weld would cause significant blow holes and splatter to be easily detected by visual examination and certainly by dye penetrant examinat le so minute that it's disintegration or outgasing as a result of ,
\) 6 contact with molten welding material, and Rso incapsolated I 0.cp ypp not to be detectable by the dye penetrant examination, such
*jW. a particle would be no more apt to eventually ea.t through
,/ -
-. ~
the weld than would the contact of massive concrete _ structure to eat through the linersAhe weld is acceptable in accordance with the applicable requirements. The TRT does not consider this concern to have any safety significance. The TRT reviewed ASLB testimony where issues pertaining to the fuel pool liners were discussed from Sept.10 through Sept. 21, 1984. These discussions question the adequacy of inspections and governing procedures, and adherence to the procedures. These testimonial issues and the implementation of requirements in accordance with Appendix B to the 10 CFR 50 are covered in the TRT'; QA/QO SSER.-- O e CM'S* 9 ' ) c \\ e w W , ,- , S., Conclusion and Staff Positions: The TRT review of requirements established the following facts: O 1 .
The CPSES/FSAR does not list the liners for the spent fuel pools, transfer canal, and reactor refueling cavity as a "G" item, and does not show any failure safety analysis. There are no industry codesthatdirectlyspecifie[requirementsandcriterianapplicable to the li_ners. The G&H specification 2323-5S-18 is the source document for requirements and criterion specifically applicable h ',s co@.m th k e Lw to the liners. The TRT has determined that,the.G&H specification 4 & requirements d ,,..::r W e ;S Q B&R procedures. The TRT notes that_ B&R procedure CCP-38 does not make mention of Appendix B to 10 CFR 50, nor does it reference the G&H specification. However, it does identify QC activities and responsibilities for inspections, testing and documentation for control of processes and records . storage, utilizing the existing QA/QC organization and program plans which do comply with the ]adopte requirements of the G&H twh % hhM specification, y4w9 . The TRT detennined the trace of requirements to be in compliance with the source G&H specification and acceptable. The review of all requirements, including pertinent reports and memorandumsregardingseismicclafifications,levelsofsafety relationship, and NRC staff positions, has established the following TRT position (The TRT believes this to be consistent with the NRC staffposition): The liners for the spent fuel pools, transfer canals, and reactor refueling cavities are not required to be seismic category I because damage or loss of the plate would not result in a L-
- o significant loss of water since the concrete cavity structure would withstand the effects of a safe shutdown earthquake without significant damage. The primary purpose of the plate is to provide a smoother and less permfable surface which is easy to decontaminate; and also provide a construction form for the cavity. The liners. do not provide any structural integrity to the concrete structure. Therefore, the concrete structure is the only concern and not the liner plate.
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[hcTR7'[reviewofallegations,relatedconcerns,andissues described in this report, and based on the findings and position established, the TRT determines there to be no safety significance to the alleged concerns. [- l 6. Actions Required: None.
- 8. Attachments: None.
l .
- 9. Reference Documents:
- 1. G&H Specification No. 2323-SS-18, Revision 3, April 6, 1979
" Stainless Steel Liners," issued for B&R Construction
- 2. G&H drawings:
(1) 2323-S-0831, "F.B. Spent Fuel Pool Liner Details." (2) 2323-S-0832, "F.B. Spent Fuel Pool Liner Details." (3) 2323-S-0833, "F.B. Spent Fuel Pool Liner Details." l (4) 2323-S-0834, "F.B. Spent Fuel Pool Liner Details." i t -
1
- 3. B&R drawing WRB-10559, Sheet 1, " Fuel pool liners Imbeds -
Weld Identification No's."
- 4. B&R Procedures:
(1) QI-QAP-11.1-4, December 26,1979, " Welding Inspection of Stainless Steel Liners" (deleted in error on January 15, 1982 and reissued with no changes on Janaury 26,1982). l (2) CCP-38, Revision 4, dated January 5,1984, " Stainless Steel Liner Erection." .
- 5. DC/DDA 2946, Revision 1, November 13, 1978. ,
- 6. Comanche Peak Steam Electric Station / Final Safety Analysis Report (CPSES/FSAR), Section 17.2, " Quality Assurance Requirements, and Section 3.2, " Design of Structures."
- 7. U.S. NRC memorandum, dated January 25, 1979 From: G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE
, To:' D. B. Vassallo, Assistant Director for Light Water Reactors, Division of Project Management IE
Subject:
Classification of Spent Fuel Pool Liner Plates (A!T! F12*.91tl) (AITS F30382H1).
- 8. U.S. NRC memorandum, dated February 6, 1979 From
- G. W. Reinmuth, Assistant Director, Division of Reactor Construction Inspection, IE To: R. T. Carlson, Chief, Reactor Construction and Engineering Support Branch, RI
Subject:
Classification of Spent Fuel Pool Liner Plates (AITS F12193H1) (AITS F30382H1).
- 9. U.S. NRC Regulatory Guide 1.29 Revision 3, September 1978,
" Seismic Design Classification."
- 10. Region IV Report 50-445/79-15; 50-446/79-15.
- 11. Allegation Source:
(1) AM-11 --- 84-006, 3/7/84, A-4 Testimony Pages 51, 52-55. (2) AW-40 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15. (3) AW-42 --- Testimony dated 5/24/82, Page 65A.36.b, IR-79-15. (4) AQW-80 --- A-49, 8/8/84, and A-4, 8/24/84. ' (5) AW-81 --- A-4, 8/24/84. (6) AW-82 --- A-4, 8/24/84.
- 10. This statement prepared by:
______ E. G. Thompson Date TRT Technical Reviewer C. Richards Date TRT Technical Reviewer Reviewed by: L. C. Shao Date Group Leader Approved by: 1 V. Noonan Date Project' Director i l l n
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- e November 21, 1984 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD s
In the Matter of )
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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445-2 and COM PANY, _e t _al. ) 50-446-2 (Comanche Peak Steam Electric ) (Application for Station, Units 1 and 2) ) Operating Licenses) PREFILED TESTIMONY OF C. THOMAS BRANDT REGARDING CASE'S FURTHER " EVIDENCE" OF A QUALITY CONTROL BREAKDOWN IN THE CONSTRUCTION, INSTALLATION AND INS PECTION OF THE STAINLESS STEEL LINER PLATE Ol. Mr. Brandt, have you had an opportunity to review the memo-randum concerning the stainless steel liner plate filed by the Citizens Association for Sound Energy on November 15, 19847 .
. A1. Yes.
Q2. Mr. Brandt, directing your attention to page two of that memorandum, CASE contends that applicants incorrectly assert that the liner plate is not safety-related. Do you see that passage? A2. Yes. It is set out in the first three paragraphs on the page.
- 03. Is that contention correct? -
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, A3. No. CASE's contention shows a lack of understanding of my testimony and the procedures applicable to the fabrication and installation of the stainless steel liner plate. As I i testified before, the fabrication and installation of the stainless steel liner have been designated safety-related activities by the architect engineer. I would like to note my testimony on this point appears at page 45,315 of the transcript of this proceeding. Therefore, CASE'is factu-ally incorrect when it asserts that applicants have testi-fied 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 l 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 requirements such as those imposed by the ASME code, for the fabrication, installation, inspection and testing of j the liner and the welding associated with these activities. The architect-engineer's only concern was that the welds pl*4e % not leak. Accordingly, welding on the liner gLeer is not now, nor has it even been, under the jurisdiction of the ASME Code. Only two matters remotely tie the liner plate to ASME activities, but nefEher of these matters apply ASME fabri-cation and installation requirements to the liner plate. I ]
a . First, the specification for the liner plate requires that welders who work on, and welding procedures used in connec-tion with, the 1iner plate be qualified in accordance with Section IX of the ASME Code. This Section, however, is N 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 unrelated to the applicability of the ASME Code require- , ments to the fabrication and installation of the liner
- plate.
Q4. 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 was deceptive. Do you see these allegations? A4. Yes, I do.
- 05. Is CASE correct?
v AS. No. First, my testimony was that I could find no evidence that the correct traveler form was used before April 18, 1979. My review of the travelers indicates 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 building. All thirteen . hundred travelers at issue in this proceeding are for that cavity. I would like to point out that I made this point on pages 15,921-923, 15,927 of the transcript of this pro- - ceeding. Traveller 988 cited by CASE is not for a weld in this cavity. It is for a weld in the Unit 2 fuel transfer canal, which is located inside the fuel building. This is not only a completely different cavity; it is for a cavity , located in a completely different building. Thus, CASE's allegation is premised on a traveler that was not even 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 l 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. Yes I do.
- 07. Have you reviewed the travilers for these welds? -
A7. Yes. 1
-5
- 08. What were the results of your review?
A8. In each instance, I found that there was either a chit and/or a traveler documenting QC verification of the fit-up and cleanliness of the outside weld. Accordingly, CASE's allegation is factually wrong. Q9. CASE asserts on page three of Exhibit 1, "it is evident that the chits (attached to the 147 travelers] were not - intended to verify step 1, but was [ sic] intended to verify Step 3 and/or 2 only." Is this correct? A9. No. The chits themselves reflect that they document QC -' verification of the fit-up and cleanliness of the outside weld. Q10. CASE also alleges on page 3 that 170 other welds lack QC verification for fit-up and cleanliness of the outside . weld. Did you review the documentation for these welds? A10. 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 inspection of the fit-up and cleanliness of the concrete side of these welds. Thus, with the exception of weld 326, CASE's alle-gation is factually wrong. 012. Have you determined why there was no documentation verify-ing the cleanliness and fit-up of the outside weld for traveler 326? A12. Yes, I have.
v 013. Why das documentation of the OC verification for this weld not found during your review? A13. The weld has not been made. It is a weld between an angle and the top plate of the cavity, which as of November 20, 1984, had not yet been fit-up. Q14. CASE next states on page four of Exhibit 1 that five welds lacked OC verificat. ion of fit-up and cleanliness for the outside welds prior to welding which allegedly renders their conditions indeterminate, contrary to procedure and 10 C.F.R. Part 50, Appendix B, Criteria V. Do you agree with this characterization? A14. I cannot agree with CASE's position. I do agree with CASE's contention that, because of the dates of the signa-tures, the chits attached to these travelers do not . definitely establish that the five cleanliness and fit-up inspections were performed prior the time the backing strip was tack-welded to the plates. This is a violation of site procedures, and I have directed that an NCR be written to address this deficiency. While I agree that there is a paper problem with these five travelers, I cannot agree that the deficiency is tech-nically significant. The fit-up of the plates associated with the travelers identified by CASE was reverified and documented and the cleanliness of the inside joint was verified and documented prior to making the inside welds. Under these circumstances, the verification of the fit-up and cleanliness of the plates prior to tack-welding the
- ~
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. _7_
backing strip to the plates is not a technical concern. The only purpose of verifying the cleanliness of the plates prior to tack-welding the backing strip to the plates was to assure that the backing strip could be securely tacked N on and would not become dislodged inside the leak chase channel. The sole purpose for the inspection is to ensure that the backing strip remains in place until the time of the inside fit-up. The reason for verifying fit-up prior to tack-welding the backing strip to the plates was to prevent difficult rework which would be required after the attachment of the leak chase channel if the original fit-up between the plates was out of tolerance. .In any event, if the backing strip had dislodged or if the fit-up have been improper those deficiencies would have been noted when the , cleanliness and fit-up inspections were performed for the inside welds. 015. On pagd five of Exhibit 1, CASE identifies a number of welds which were done using welding procedure 88023 and claims that the correct procedure for those welds was weld-ing procedure 88025. Do you agree with this assertion? A15. No. The welds CASE identified are embed to plate welds. All welds made on the liner plates between embeds and plates are groove welds in which the deposited weld metal thickness (joint thickness) is .1875" (the thickness of the plate). The proper procedure for making this weld in 1978 was W PS 88023, which was qualified for thickness ranges t
.0625" through .750". Prior to October 15, 1979, W PS 88025
-g-was qualified for welds with thicknesses of 0.75" through 3.5". On October 15, 1979, WPS 88025 was revised and the thickness range was expanded from 0.75" through 3.5" 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 N 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.
016. On page six of Exhibit 1, CASE identified 243 travelers which CASE claims lack OC verification for Step 5, fit-up and cleanliness of the inside welds. Have you reviewed the traveler packages for these welds? , A16. Yes. 017., What was the result of your review 7 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 five-line travelers, for example weld 6, the fifth line is for the final V.T. inspection, not for a fit-up and clean-liness inspection. thu s, CASE's allegations for the five-line travelers does not make any sense. In any event, i
+
_9 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 fall into several categories. First, many of the travelers are for welds N that are welded on one side only (welds 875, 896, 901, 908,
. 9 0.9, 910, 912, 682, 713, 714, 779, 783, 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-tions to be performed on the second side of the liner.
Second, CASE is correct with respect to a small group of e'ight-line travelers (welds 12, 51, 59, 65,66, 72, 73, 90, 93, 107, 147, 203, 709, 851, and 907), and I have directed , that an NCR be written identifying the welds for which the inside fit-up and cleanliness inspections have not been documented. Finally, my e:: amination of all of the remain-ing eight-line travelers on CASE's list reveals that CASE is 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 allegation 7 A17. Yes. 018. What conclusions have you drawn as a result of that review 7
A18. This is another example of CASE's lack of understanding of the fabrication and inspection process. CASE is correct in noting that a final visual inspection has not been perform-ed for these welds, but the final visual inspection has not been performed because the welding / inspection process has ' not been completed. My review of the travelers indicates that no holdpoints have been bypassed and no violation - exists for any~of these welds. Q19. Mr. 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 procedure or a 1 j deficiency. There is simply"no requirement specifying that, a copy of the applicable WFML is to be kept in each traveler. I might also add, there is no requirement for filler metal traceability on any of these welds. i
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Q20. On pages 9-15 of Exhibit 1, CASE alleges that WFMLs are referenced on travelers indicating that new welding was done, but there is no OC verification or involvement when the welding is done. Assuming this to be true, what significance does this allegation have? A20. Although I have not reviewed all the travelers listed by CASE on pages 9-15, I have reviewed enough to lead me to believe that this is another instance where CASE does not understand the requirements and/or the fabrication sequence. In all travelers I reviewed, no inspection. hold-
-n.
points have been bypassed. If CASE is attempting to infer that OC must perform some type of " verification" each day 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 attentien 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. None. Once again, as I discussed above, this is apparently, another instance where CASE is attempting to assert that verification of welding must be performed on each day that welding occurs. of the travelers.f. hat I' reviewed in
~
connection with this allegation,' all welds were still in-proce'ss, 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 significan'ce. This information is jygt required by specification, and serves no quality function.
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(e ast, ac,b proceJW) U/21 fo 35AM-TE W h The millwrights are pr,ocedurally required to enter this information but they simply have not done so as of this date. l l
022. Mr. Brandt, CASE identifies 5 NCRs on page 21 of Exhibit I which describe welds for dhich vacuum box testing was improperly noted as not applicable. Is there significance to this observation? A22. No. It was an error made by the inspector, but was proper- ' ly reported and dispositioned on an NCR. Q23. On page 22, CASE lists fifty-seven (57) welds which it alleges are deficient because final V.T. has been performed without vacuum box and/or liquid penetrant examination being performed. Have you reviewed this allegation? A23. Yes, I have. 024. What was the result of your review? A24. CASE apparently misunderstands the inspection testing sequence. The final V.T. precedes the vacuum box testing . and the liquid pehetrant examination. As these welds are clearly still in process, no holdpoints have been bypassed and no violation exist's. 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 is the significance, if any, of this observation? i A25. I am not quite sure 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. and/or V.B. test. If this is CASE's all&gation, it is without
~-
merit because t,here is no requirement that the same inspec-tor 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 which 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 you reviewed this allegation? A26. Yes, I have. 027. What did your review indicate? A27. The welds listed fall into several different categories. For a number of welds which CASE asserts that " 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," CASE is incorrect as the travelers clearly indicate that the weld is still in process. Welds 5, 7, and 8 are I examples of this category. As the welds are incomplete, no i l violation exists. For a small group of welds, (weld numbers 1240, 1242, 1245, 1248, 1182, 1209, and 1210), CASE is correct and I have directed that an NCR be written identi-fying the condition as nonconforming. For all other welds listed on page 23, CASE is incorrect because the referenced tests are not required; therefore, no violation exists.
028. CASE alleges on page twenty-four of Exhibit 1 that "[m]any NCR's were written for welds that James Cole had N/A'd the vacuum box test on. The vacuum box 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. Yes, I have. 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. Brandt, CASE alleges on the bottom of page twenty-four of Exhibit 1, that "PT test has been performed on these welds but vacuum box has not". Have you had an opportunity to review this allegation and the related travelers. A30. Yes I have. 031. What vere 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. For four (4) of these welds (welds 1230, 1232, 1235, and 1238), CASE is correct
and I have directed that an :CR be prepared describing.this condition. 'For all other welds listed here, CASE is incorrect; the step has properly been marked not' applicable as these welds do not require vacuum box testing. 032. Mr. Brandt, directing your attention to page twenty-five of N Exhibit 1, in particular to CASE's discussion of NCR M ' 01847 dated 7/7/83. CASE states that "The NCR was written in 1983 and a hold tag applied. It has not been disposi-
'tioned yet, and there is no copy of this NCR in traveler 151. There is no RPS in package for weld 154. 154 was signed of f by Don Vogt, S.M. McCoy, for steps 2, 3, and 4. ,
Jim Cole inspected 151 on 4/20/80 and 153 on 4/24/80." What is the significance, if any, of these allegations? A32. First,. CASE is incorrect in stating that " ...it has not . been dispositioned yet." In fact, CASE describes the disposition of this NCR on pa'ge 25 of Exhibit 1. Second, original NCRs are not 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, specification, or procedure. Third, CASE's observation that no RPS is in package 154 is correct, but it is without significance.for two reasons: first, the repair is not yet complete, and second, the repair, when completed, will be of weld 151, not weld 154, and accordingly a copy of the RPS will be in
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package 151, not 154. Fourth, with respect to CASE's i observation that " Jim Cole inspected weld 151.on 4/20/80, [actually 4/2/803 and 153 on 4/24/80," CASE is apparehtly i
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. speculating on Mr. Cole's ability as an inspector. There is no indication that weld 153 was improperly inspected. The NCR clearly states that the backing bar had been ground through. No evidence exists which indicates that the back-ing bar was not intact when Mr. Cole performed his inspec- s tion on 4/24/80, and, as CASE notes, the incident (grinding through the backing bar) was properly reported as nonform-ing. In the ot'her incident described, i.e., the failure of the backing 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 improperly inspected 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', 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-cient condition becomes clearer after looking at the draw-ing. Weld 151 is a vertical weld which. attaches 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 attaches. Welds 151, 155, 157, and 159 all form the vertical weld which attachos a gate guide to plates A35, 835, H35 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, and 159) was continuous for the length of the weld. The fact
that the backing strip for weld 154 lacked 3/8" from running the full length of the weld was properly reported on an NCR, and is attributable to inspector error. . 033. On page 26 of Exhibit 1, CASE refers to a numbering discrepancy which was reported on NCR M-83-00907. What s significance, if any, is there for this allegation? A33. This allegation is correct, however without significance. In this case the construction group which issued the travelers, assigned separate weld numbers for the welds attaching the backing strip and leak chase to the gate guide. Although clearly indicated on the traveler, the , millwrights were not timely in assignment of these weld numbers to the marked-up drawing which they were proca-durally required to maintain. This condition was properly , identified by OC on an NCR and the situation was corrected. In no way was this an inspection deficiency. 034. 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 regarding these NCRs? l A34. Quite frankly, I am unable to find that CASE alleges 1 anything with regard to these two NCRs. Both identified problems, and both were properly dispositioned in accord-ance with site procedures. CASE's note regarding the absence of a copy of the NCR in all of the packages is not t a violation of any requirement. As I stated earlier, the original NCR is filed in a location separate from the
10-traveler package. All packages do contain the corrected PT i report and reference NCR M-84-00948. Other than the defi- i l ciency which was reported on these two NCRs, I am not aware of any deficiency in the way they were processed or dispo-sitioned, s e I 1 a e e e
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?P.O %g'h I ?.T 1 'cuesticas and -len Mr. Kathins will ccrrect it if it turns .
2 out to be wrong. 3 MR. ROISMAN: Mr. Brandt seems to be still 4 looking and rather than have us all sit and 1:>sk, he'can 5 do hat at a break and I'll just move en to something else 6 and he can do that later. 7 MR. WATKINS: I . cant to make sure he has enough 8 time to review. t t 9 JUDGE SLOCH: How much time do you need to '. 10 review that7 , THE WITNESS: I don't know. The table is 50-something 11-12 pages long. - 13 MR. ROISMAN: He indicated ea'rlier, I think in 14 answer to a question about the appropriate table of the FS.3..., 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 testi=cny, that it 18 w as "non-ASME. " . . 19 .- JUDGE 3 LOCH: Non-ASME. MR. ROISMAN: I believe it was non-safety. I. 20 . 21 don't know what his current testimony is but - THE WITNESS: What I intended was non-ASME. My
. 22 23 prefiled testimony clearly states that it is _
- 24. safety-related, and it is considered safety-related by the 25 designer.
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7 4 dssessmentof afety Significance: The TRT review for the evaluation
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of the above' allegations included a study of the applicable
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specifi,9bns, drawings, procedures, 'documeItahon, rp gu s, NRC Region IV iitvestigation reports (irs) and NRC memos. he R'T also performed visual inspections of the fuel pool liners. The visual inspection was general for the overall liner instalaltion and a more expertise examination of approximately 20% of the welding in the spent fuel pool, reactor fuel pool, and fuel transfer canal. The areas of weld inspection covered the floor plate liners, those portions of the wall liners which were easily accessible from the floor, and areas adjacent to the sparger spray system which runs horizontally, about half way up two walls of the fuel pools. The , liner installations are complete and the details of the leak chase
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[O(( description of 4he-liner p= L L ..j _The followingg p;sa s : g details /,The wall liner plates are joined by full penetrations butt l 8 2 welding using a backing strip. A C3x4.1 S.S channel is welded over p the back side of every seam to provide a leak chase, where any leakage f through a liner seam weld will be collected. The completed sections l
.p of wall liners become the form for the pouring of concrete wall w
4,,gstructureofthefuelpools. The concrete floor is poured prior to k floor liner installation. The leak chase grooves in the floor are 4 kf molded during the pouring of concrete using "blockouts". Also 3/8" x
% 2" bar strips are imbedded to be flush with the surface of th'e
%' concrete floor. These imbeds form the lattice work to which the Ji m a 0 L
Th . F01A-85-59 i/z/
',* '.* p ,f'2- (s a--&- d) t floor liner plates are fillet wrlded. Both the wall liner plates and floor imbeds are anchored in the concrete using nelsnn studs. The design features of the fuel pool liners iiclude a system of drains where each drain connects to a sectional group of leak chase channels or grooves to provide an early detection system for leakage from a given number of seam welds. It also provides a means to recycle the captured leakage. f gaf f [e)Gibb& Hill (G&H) specification 2323-SS-18,Rev.3"stainlesssteel N liners," and B&R's Quality Assurance Instruction QI-QAP-11.4, Rev. O,
" welding inspection of stainless steel liners," cover the requirements f for the fuel pool liners. Material is specified as ASTM grades of 3A type 304L. Liner sheetskr//'t--seal welded by inert gas-shielded (gas tungsten-arc) welding. Welding procedure qualifications and welders performances are required to be qualified in accordance with ASME B&PV Code, Section IX. The required inspections are visual, liquid dye i penetrant, and radiographed where specified by drawing. It also -
7 requires the entire length of all seal welds to be vacuum box leak : tested. [nkydf f ela[ als a)[r,1fa[ Surfaces of
; welds are required to be smooth and free o[ irregularities and may be i
ground to obtain this smooth finish. A weld reinforcement of 3/32" ' h l maximum and a weld undercut of 1/32" below minimum wall tolerance is
, pennitted.fhe G&H drawings2323-5-0831 through 0834 show the liner 1
is fabricated predominantly from 3/16" and 1/4" sheet and assembled using fillet and full penetration groove welds. f
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7 4 Assessment of safety significance: The IRT review for the evaluation of the above allegations included a study of the applicable )
, specifikIons, drawings, procedures, documentation, reggiator NRC Region IV investigation reports (irs) and NRC 'The JRTalsoperformedvisualinspectionsofthefuelpoolliners. The visual inspection was general for the overall liner instalaltion and a more expertise examination of approximately 20% of the welding in the spent fuel pool, reactor fuel pool, and fuel transfer canal. The areas of weld inspection covered the floor plate liners, those portions of the wall liners which were easily accessible from the floor, and areas adjacent to the sparger spray system which runs horizontally, about. half way up two walls of the fuel pools. The .
. - ~
liner installations are complete and the details of the leak chase
'$ g channel network, and floor inbeds are not accessible for visual n
$( e sem WT$en j The following description of -the- liner--.. . . ) '
}yg , C details[,i n.Thesewallsliner
- plates are joined by full penetrations butt i
j d,weldingusingabackingstrip. A C3x4.1 S.S channel is welded over Ily; ,p the back side of every seam to provide a leak chase, where any leakage i v. L
- 6 through a liner seam weld will be collected. The completed sections ql A of wall liners become the form for the pouring of concrete wall
, 4a structure of the fuel pools. The concrete floor is poured prior to a
)
t
\
f k floor liner installation. The leak chase grooves in the floor are
.g ( molded during the pouring of concrete using "blockouts". Also 3/8" x M d 2" bar strips are imbedded to be flush with the surface of the
%*$ concrete floor. These imbeds form the lattice work to which the v
Cm ies d h L p
[ , p,,7 " ( r u -h- 9 floor liner plates are fillet wrlded. Both the wall 11nt r plates and floor imbeds are anchored in the concrete using nelson studs. The design features of the fuel pool liners include a system of drains where each drain connects to a sectional group of leak chase channels or grooves to provide an early detection system for leakage from a given number of seam welds. It also provides a means to recycle the captured leakage.
=
1 qJ/r# \[e)Gibb& Hill (G8H) specification 2323-55-18, Rev. 3 " stainless steel Ie ; liners," and B&R's Quality Assurance Instruction QI-QAP-11.4, Rev. O,
" welding. inspection of stainless steel liners." cover the requirements l
I for the fuel pool.. liners. Material is specified as ASTM grades of I SA f type 304L. Liner sheetshst/Lseal welded by inert gas-shielded (gas
, tungsten-arc) welding. Welding procedure qualifications and welders performances are required to be qualified in accordance with ASME B&PV Code, Section IX. The required inspections are visual, liquid dye penetrant, and radiographed where specified by drawing. It also requires the entire length of all seal welds to be vacuum box leak tested. [n/Iystem,.w'as/alsoIater leak tIste Surfaces of welds are required to be smooth and free of irregularities and may be ground to obtain this smooth finish. A weld reinforcement of 3/32" maximum and a weld undercut of 1/32" below minimum wall tolerance is
~ permitted, he G&H drawings 2323-5-0831 through 0834 show the liner
- is fabricated predominantly from 3/16" and 1/4" sheet and assembled l using fillet and full penetration groove welds.
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m. e- e e G F O l .-. . ...
, o Category 43 Comanche Peak Open Issue Action Plan Task: Welding - Poor welding conditions for spent fuel pool liners.
Ref. No.: AM-ll, M-40, M-42, AqW-80, M-81, M-83 Characterization: It is alleged that: AM-11: Incorrect fitup and poor welding technique resulted in thin welds joining stainless steel liner plates for fuel pools in fuel building and reactor building for Unit 1. AW-40: One seam is largely rust and concrete. AW-42: Poor welding conditions for field installations of the stainless steel , liners in the spent fuel pools of the fuel handling facility. A0W-80: Liner plate weld seams do not match drawing locations on - floor around Unit 1 reactor vessel. AW-81: The stainless steel floor plate liners in the spent fuel pool l and transfer canal are supposed to overlap the angle at the bottom edge of wall to floor. There were areas of no overlap and weld was builtup to meet. - l l AW-82: A single block, related to the leak chase channels under the, floor liner of the fuel pools or transfer canal, is defective and could affect leak detection. l FID f f am M h-TUutdD-bd L /23
Initial Assessment of Significance: Allegations having similar concerns
~
and relating to the fuel pool liners, were dispositioned in IR 50-445/
~
79-15 and 50-446/.79-15. The allegations in this category are general and lack specificity. However, the nature of these issues, as such, warrant investigation. Source: Mechanical & Piping Category No. 43; see allegation list. Approach to Resolution:
- 1. Review source transcript 84-006 interviews and testimony, A-4 and A-49 testimony, and testimonies dated 5/24/82.
- 2. Review IR 79-15.
- 3. Review applicable codes, specifications, drawings, documentation, -
and any other source of infonnation beneficial to determine the requirements (i.e., CPSES/FSAR, memorandums, etc.).
- 4. Visually inspect liner installation for any variance or deviation from the requirements for placement, fitup, and welding (final configpration).
- 5. Evaluate the findings in accordance with the requirements and identify any violations. .
- 6. Evaluate allegation for generic / safety implications.
i Related Open Issues:
- 1. Using system codes from the tracking system open item list and identify any open items.
- 2. Review activities necessary to close or partially close related items.
- 3. While performing physical inspections, examine surrounding system, components , and structures for any apparent defect or indicator of faulty workmanship.
- 4. Complete portion of IE Module on welding if it relates to effort made on allegation.
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- Y f A.38.b. HRC Inspection Report 79-15 reported an investigation Mnterrelated allegations conceinEg the a series of welding of the stainless steel liner system in the fuel The allega- ,-
handling facility spent fuel storage pools. tions, simply stated, indicated tha ' welding condition _ p, a,t- QC We very poophat welders were unqualified at welding procedures were
~
inspections wer.e inadequate; 't Yt one weEseDaTTaYge[
~
le _.g y-ff not followed; A The investigation indicated that the l st and concrete. AW,yy allegations concerning poor welding conditions were sub-
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stantially true and that some of the welds might well be - The allegation about unquali- ( of relative low strength. l q fied welders was found not to be the case in a tec , sense, since each welder had passed the necessary tests. l It was apparent that the alleger meant that the welders : The matter of QC.e were not competent in his opinion. ' y inspec-ions and welding out of procedure could g (L). ne I substantiated nor refuted since it was just one person's " In any case, the matter . l word with no other confirmation.. - was considered to be unimportant since the welds in . question were seal welds rather than strength welds \ and not of any safety significance. . A.38.c.% NRC Investigation Report 79-22 related to allegations by a former Comanche Peak employee which . appeared in a news article of the University of Texas at F01A-85-59 ' ud
t,
- 66 -
Arlington " Shorthorn," dated July 18, 1979. Ther alleger ' stated that he was' told that improper welds were made on ' the primary coolant system and that he was told that a 6" ' check valve weld deficiency had been repaired without correct procedural instructions. Subsequent interviews with the alleger and on-site investigations by NRG 4nspec-p- b tors e'stablished that the allegations either had no merit Awp/ or could not be substantiated. .. A.38.d. g NRC Inspection Report 80-02 discussed an ' investigation of allegations that had appeared in a local newspape The allegations were reported to have been by - three Authorized Nuclear Inspectors who had left the site due .to dissatisfaction with B&R's " lax QC procedures" and were further reported to have records and photographs to support contentions that poor welds in the reactor coolant piping existed. Interviews with the allegers revealed no
. specific facts that could be further investigated. The allegers stated to the investigators that their concerns , ,
did not appear to have any safety consequences. A.38.e.gNRC Inspection Report 80-22 discussed an - investigation of allegations to the effect that B'&R QA management was not"unsuring that corrective actions were taken for documented nonconformances; that nonconfonnance reports were disapproved and subsequently destroyed; and
*. i.
'ITEOI DCP5 - AW-43, 60, 65, 73, AQW-77 ,
Draft 9 - 1/29/85 SSER
- 1. Allegation Group: Mechanical and Piping Category No. 45, Miscellaneous Welding Deficiencies
- 2. Allegation Numbers:
/ / /
AW-60, AW-84, AW-43, AW-65 and AQW-77 v M,Yg wQ tvd de AS k - Lu ,.W 'd s d
- 3. Characterization: Itisallege@l)thatfr: er- + #d W g = Ms on f V the steam generator top head insulation supports [(AW-60); (2) thata ~ ~'g 1,4
. . ..d m.:., 4 excessive grinding of weld surfaces has taken place (AW-84); (3) that 8" 1 -
an unqualified pipefitter fit and welded socket joints in one of the boron systems (AW-43); (4) that circumferential butt welds were made sx %M in the fuel transfer ~ tubes of Units 1 and 2 and that these welds had incomplete penetrat$(AW-65); (5) that anti-vibrational straps attached as supports to the auxiliary building 790-foot elevation heat exchanger tubing exhibited unacceptable burn through of the welds (AQW-77); and, (6) that the weld-numbering sequence on the weld data cards revealed duplicate weld numbers for the top and bottom strap supports (AQW-77).
- 4. Assessment of Safety Significance:
To assess the safety significance of these allegations the NRC Technical Review Team (TRT) reviewed codes, specifications, quality control (QC) inspection reports, and other pertinent documents F01A-85-59, y l __. - . -- .. ._ -
2-applicable to each of the several allegations to determine requirements. The resolution of each allegation is addressed separately in the remainder of this report, y.h*- To assess the safety significance of allegation AW-60, the TRT reviewed testimony of the alleger and of Brown & Root (B&R) personnel and reviewed vendor drawings and nonconformance report M-82-01178, which was initiated by QC, -
"'A %
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9 g-e # The TRT reviewed the vendor drawings fo rror Insulation to determine if_ full peneiration weld joints were called for, as alleged.- The TRT found that the drawings called for f.illet joints and partial Y, N penetration joints, but no full penetration joints. WW*W y* .y
~ 'yV p"
h, A review of NCR M-82-01178 revealed that the following rejectable > DM defects, per the requirements of American Welding Society (AWS) D1.1, 0,s
" Structural Welding Code," were found on the welds of the insulation
- y. " supports:
j 7
,q igt. p d' l
fhy
- arc strikes
< *' .b' g't.
undercut 5,#
- overlap
- weld spatter 1ack of fusion
yQf' f W -d ' b pcE SM # S wJ i W $ %q_95 u ,, e
~ 'These defects were reworked per the instructions from the repair
. , , , j The NCR was closed process sheet (RPS) issued by welding engineering.
on August 26, 1982. The TRT is preparing a sumary of its findings on allegation AW-60 to forward to the alleger, who declined an interview.
/W-Si TheTRTrevieweddWS01.1andtheAmericanSocietyofMechanical Engineers (ASME) Boiler and Pressure Vessel Code (B&PV), Sections
.._. 1 III and VIII agcah{ egg 1legogy"q -g-found no requirements M
[ The TRT that prohibit or encourage grinding of the weld surface.
. \
' noted that grinding of the surface of the weld may be used to remove
.>i ,
- irregularities that interfere with liquid penetrant, radiograph and
.9 ,, -
'~ .
ultrasonic inspectiorI; to remove notches which could act as stress l
risers; to remove ' overlap and blend undercut; and to enhance the surface for the application of protective coatings. l %' ' . - ' V.-M yu
'fhY .M Y iOr
/ /,.,.}< Attempts to contact the alleger to review with him the TRT's findings v j~ on allegation AW-84 have been unsuccessful.
k~*ehy P ' A 3- *! .- - y Since allegation AW-43 did not refer to a specific system, the TRT ' selected several documentation packagehe boron recycle system The TRT reviewed weld data cards and inspection rep.7rts, but found no ggs f.r evidence of any rejectable fitups or welds. 6& *- N'c3&$.. 3 The alleger of allegation AW-43 is unknown.
-4 l In assessing allegation AW-65, the TRT visually examined both the internal surface of the fuel transfer tube between the Unit 1 Reactor Building and the Fuel Building and theG. externalN b bsurface M c AtCI'80 of the
*N fuelu)W transfer tube behind welds 3a and 3c. 'I As identified in design change M. 1 "F +
authorization (DCA) 6560, Revision 3, weld 3a is the penetration
,$.c, A M sleeve-to-expansion joint weld; weld 3c is the fuel transfer {*f be dre=W.
sleeve-to- expansion joint weld. The TRT found no circumferential butt welds in the fuel transfer tube. Note 7 of This was in accordance with Westinghouse drawing 1209E53. this drawing states that "the tube shall be fabricated in one length without circumferential splice welds." jThe uel ansfer ube sT ngit inally elde . , f. ma[fom la e, b ke pres formed and I The a leger may have been.NierifnTup,ld 3arlihh was originally F
..h ,
~
s, . designed as a circumferential butt weld, but wat modified to use a
. -- ., -6(. ?
washer type ring to accommodate k-diametral mismatch between theyeu sc '_A
*,~ penetration sleeve and the expansion joint mating parts., DCA 6560, g,
,)-.
revision 2,pages3and5showsthemodifiedjointdesignsforUnits_1{
./
and 23 /T'hese joints, however, would not affect the fuel transfer tube gq.,g . ,m..A ) /
,3
, [,. ,
fIinthemanneralleged. . c,c. $ h D M N, :.:j 5 ,, v E.% ~ .v t I :. . g.ua cu m 3 dog W ,,' g b y The TRT noted that the(pansion joint assembly
- - - - - - . _ - t m,._
tontainsh0.024-inch e, e thick butt lao welds joining p e end members to the beflows. The
#w
./'* cross-sectional area of these joints is significantly less than the 3 .
approximately 1/2-inch thick welds that join the expansion joint g'$1- assembly to either the penetration sleeve or the fuel transfer tube.
$ During a visual examination, the TRT observed that the expansion joint
e J
/ assemblies at the containment building end of both fuel transfer tubes One assembly had a flapper sander and a ifi~k
,i contained debris and dirt.
[ " throw-away" paint brush lying on the bellows convolutions Dirt was and a
\ .
second flapper sander lying on the near bellows end fitting. 1 , The other assembly had a rag and [ ,, , piled up against the weld 3a spacer.
' a piece of pipe about 1-inch long lying in the near bellows end fitting. There was also some dirt against the weld 3a spacer.
The TRT is preparing a summary of its findings on allegation AW-65 to forward to the alleger, who declined an interview.
.b. Y~
The TRT reviewed allegation AQW-77 and the August 8 and 23, 1984'
'ss Ww3 t to identify the heat exchanger
/
e.,ft,ranscrip9,ofthealleger.inanattemp N in question. The TRT inspected the inanediate location specified by the alleger and found that four heat exchangers were located just outside the auxiliary building in Rooms 68 and 69 on the 790-foot elevation of the Unit 1 Safeguards Building. The TRT identified these ' heat exchangers as residual heat removal (RHR) heat exchangers (HX) TBX-RHAHRS-1 and TBX-RHAHRS-2 and containment spray (CT) heat Thg TRT reviewed the exchangers HX CP1-CTAHCS-1 and CP1-CTAHCS-2.W i t M manufacturer's drawings (Joseph Oat Corporation) and found that the ,
, r RHR HXs were purchased by Westinghouse Corporation (g phs % and ,the b a JL^QCJ.g anti-vibration straps were a vendor-supplied ite . gg gg f
The TRT interviewed Westinghouse personnel and learned that the strap supports for the tubing were added by the manufacturer to correct an unacceptabptubingvibrationconditiondetectedatsomeother
" The TRT searched the nonconfonnance report (NCR) records loc L
v
- e. __ ._ _ _ _ _
g ih*> d.d h d.tcWi~ is a . .A ~/-. fe ms, . .
. . _ . . - . - - 6 .- ! '
/* I -
fo'rthetwoRHRHXsandfoundnoNCRsfissuedtomodifyoradd i
;,J. , .,, anti-vibration straps. Based upon these facts, the TRT eliminated the
- .g. r.
e RHR HXs from consideration for the allegation.
.c A further search of the NCR records yielded NCR numbers M-5102S and i
M-51035 for the CT HXs, both issued on the same day and both containing nonconfoming conditions very similar to those described by the alleger. The TRT detemined that NCR M-51035 was reported by the alleger; however, part 2 of the NCR indicates a condition different l - WW A ~ fromthe[llegationspecNiedon~page52'of'the' August 8,~1784] ) interview. The NCR specified that only nine welds were made, but the The welddatacard(WDC)indicatesthattenweldswererequired. ! . allegation stipulated that there were duplicate weld numbers on the ? that top and bottom strap supports. The TRT could fitidt
' duplicate weld nuinbers!were used or that more than one set of strap t
l Both Texas Utilities Electric Company (TUEC) supports were required. and cognizant personnel drom Joseph Oat Corporation were contacted, and confirmed that only one set of strap supports, located at the top bend of the tube bundle for each HX, was required by the modification. 1
% > . do*L M d g o Since the NCR was initiated by the alleger when he inspected N the
/
. welding, the second part of the allegation which was alleged during \, -
/ On the August 8 and 23, 1984, interviews appeared to be an error.
i September 20, 1984, the TRT contacted the alleger, who confimed that i the nonconfoming conditions listed on the NCR were correct. Furtp'er N l .
~
examination of t[e NCR package revealed that DCA 16462 was written to r -. - - - - - - The TRT discussed the explaic.the discrepancy in the weld numbers. DCA with B&R QA and Welding Engineering and found that the disposition was satisfactory. The TRT reviewed the traveler package for each NCR and found the following discrepancies. For NCR M-51035: (1) the traveler was stamped with
- ne statement " Work requires TUGC0 operations to process an ASME Code NIS-2 Form," and no form was completed; (2) CP-CPM-6.9G required that the Authorized Nuclear Inspector (ANI) initial the WDC to indicate whether a hold point was required, and there was no evidence of the ANI's initials on the WDC; and (3) QI-QAP-11-1-26 required B&R QC to complete a visual examination, and no evidence of such an examinatign was found. The same discrepancies as identified in (1) and (2) also were identified in NCR M-51025. The TRT found evidence of a completed l visual inspection checklist for this NCR.
The TRT interviewed two B&R QA employees to detemine whether the CT Both QA employees said that HX modification required an ANI review. the statement requiring an NIS-2 fann to be completed was a mistake and that the fonn was not required since the welding was not to the Both of these employees also recalled discussing pressure boundary. this problem with TUEC' Operation and Maintenance (0&M) engineering at the time of the modification. They indicatgd that to the best of their recollection 0&M agreed with their position, but they could not L
4 i t explain why the paperwork had not been changed, nor could they The TRT interviewed the document that the discussion had taken place.7 O&M engineer who, at the time of the modifica' tion, was the TUEC QA He confirmed that the inspector indicated on the NCR disposition. NIS-2 fom should not have been required (as stamped on the traveler), but he could not provide any documentation of conversations with B&R QA to this effect. During the TRT interview, both B&R QA employees indicated that the visual inspection checklist should have been completed and that the original of the fom should be in the fabrication package in the QA l vault. A review of these records did not produce the missing checklist. Further discussions with B&R QA revealed that the < manufacturer's representative from Joseph Oat Corp. had inspected the l This weld burn-through and had accepted it for the intended service. was confimed in a Telex (February 2,1983), which was the basis for f The TRT contacted the the dispositioning of part (1) of the NCR. He confirmed ' Joseph Oat Corp. representative identified in the Telex. that he had personally inspected both of the CT HXs for the burn-l After checking his through condition on the anti-vibrati.on straps. notes and files on these items, the manufacturer's inspector indicated l that his' inspection had revealed no damage to the HX tubing and that l The the welding on thel straps was adequate for the intended service. f ' TRT then talked to the QC inspector who had signed off the "QC
1 i Verification" block on both of the NCRs. He indicated that he had completed the visual examination checklist on NCR M-51025, which he co-authored; however, he could not remember completing a similar
/
checklist for the NCR initiated by the alleger (MCR M-51035). The
/
inspector also indicated that the individual who signed the "QC Verification" block.on the NCR was only ensuring that the proper paperwork was completed, and that. he could have interpreted the manufacturer's representative inspection as meeting the requirements for NCR M-5103S. The TRT then interviewed Welding Engineering and Civil / Mechanical , Engineering personnel to determine whether an ANI inspection was j required on the CT HX tubing modification. All individuals contacted stated that since no welding had been done to the pressure boundary, no ANI inspection was required. Welding Engineering referred to procedure CP-QAP-2.4 which governed the repair or alteration of ASME N-stamped components. This procedure currently'is voided, but was in effect during the modification in January / February 1983. Paragraph 6.4.1 of this procedure required the "0wner to assure that the repair procedure is acceptable to the Owner's ANI, and for review by the ANI for assignment of hold points." The TRT spoke with the ANI assigned at the time of the modifications. The ANI indicated that he was present during the modifications but did not personally inspect the burnthroughweldcondigiononthestraps. The ANI also stated that no L -.- - ______ -
~. .
welding was performed on the pressure boundary, but he could not; state that the burn-through condition on the strap had damaged the thin-wall tubing. Accceding to the ANI, , O&M, and Civil / Structural Engineering, the type of modifications made did not require a rehydrotest of the unit. The TRT interviewed the alleger regarding allegation AQW-77 on November 14,1984. The TRT told the alleger that his concern had been substantiated and that the Applicdnt would have to respond to the violation. The alleger was satisfied with the results of the review. e
- 5. Conclusion and Staff positions: The TRT review of vendor drawings showed that the welds in question (AW-60) were meant to be fillet or However, there partial penetration welds, not full penetration welds.
were other defects present that were rejectable per requirements of These defects were repaired by B&R on NCR M-82-01178. AWS D.1.1. Accordingly, this allegation has neither safety significance nor generic implications. -ilC *
+
The TRT concludes that the allegation,ef excessive gpoding of weld
/
surfaces (AW-84)(is, substantiated./J - biHr has no technical merit. The
~ . . . . . . .
various codes, standards, and specifications that are in force at Comanche Peak Steam Electric Station neither prohibit nor require Accordingly, the allegation has neither grinding of the weld surface. safety significance nor generic implications. \ The TRT could not substantiate the allegation related to weld data i *
~
. i 1
cards (AW-43). The weld data cards and drawings reviewed were in order and the weld data cards had been signed off by quality control as being acceptable. The TRT concludes that this allegation has neither safety significance nor generic implications. In visual examination of the Unit I fuel transfer tube, the TRT found no circumferential welds as alleged (AW-65). The tube was fabricated as required by Westinghouse drawing 1209E53, Note 7. The allegation was, therefore, not substantiated. It is the TRT's opinion that the alleger may actually have been referring to one or more of the
'E 'kd bd. t welds between the penetration sleeves and the several h u ev4:.\wsa wk%4 e xact
- ale.e-oA U- YfH expansion joint assemblies., The two such welds examined, while not %%Q full penetration welds, were otherwise visually sound and of a cross-sectional area which would cause any failure to be in the In either case, bellows or in a bellows-to-bellows end fitting weld.
the TRT concludes.that this allegation has neither safety significance nor generic implications. The TRT was able to detennine that a visualdnspection j was performed on the welding modification of one CT HX,/but not on the second CT HX, The which was the one initially of concern to the a11eger (AQW-77). QC inspector who completed the visual examination checklist on one of the HXs could not explain why there was no completed checklist on the other HX. Concerning the lack of ANI review on both of the HX
,/ . ,
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modifications, the TRT obtained conflicting explanations from all individuals interviewed when compared to procedure CP-QAP-2.4, which requires ANI involvement and which Weiding Engineering said was in effect at the time. a' The TRT concludes that the allegation that the CT HX which was initially written on an NCR by the alleger had not been properly The WDC indicates inspected by B&R QC personnel is substantiated. that the first nine welds were satisfactorily inspected by the alleger; the remaining nine welds were initially accepted by the Further documentation, alleger who subsecuently removed his signature. on the WDC reveals that 88R QC accepted these welds based on the This manufacturer's inspection and with no further 88R inspections. finding indicates a violation of procedures for failure to visually examine the identified welds by B&R QC as indicated by Operation No. 4 on the WDC. However, the TRT concludes that this allegation has no safetysignificance,sincetheweldswereinspectedandapprovedby f l themanufacturer'srepresentative(nordoesithavegeneric s implications. f
- 6. Actions Required: None z.,-
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- 8. Attachments:
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- 9. Reference Documents:
AW-60
- 1. NRC M-82-01178.
- 2. Drawing Mirror Insulation 590159-232C. .
V
- 3. A D1.1 Code.
AW-84
- 1. NRC reports 50-445/82-11 and 50-446/82-10.
- 2. AWS D1.1 Code.
- 3. ASME Section III and VIII.
~
AW-43
- 1. Weld data cards 09666, 09682, 18942 and 33679.
- 2. B&R Drawings BRP-BR-X-AB-052, 025 and 036.
AW-65
- 1. Westinghouse Drawing 1209E53, " Fuel Transfer Element."
- 2. Westinghouse Drawing 1209E54, " Fuel Transfer Tube Assembly."
- 3. DCA 6560. Revision 3.
- 4. B&R Data Package, ME 80-2008-4000.
- 5. Westinghouse Manual. DCC-CP-0001-069.
- 6. WPS 11010.
v
\ .
- 7. WPS 11032. .
- 8. WPS 88025.
- 9. WPS 88032.
- 10. Pathway Bellows, Inc., Drawing D-3-4570, Revision E.
- 11. Pathway Bellows, Inc., Drawing D-4-4570, Revision 4.
- 12. Pathway Bellows, Inc., Drawing D-5-4570, Revision E.
- 13. B&R Data Package, ME 81-2116.
- 14. G&H Specification 2323-MS-100," Piping Erection Specification."
A0W-77
- 1. Interviews with the alleger on August 8, August 23, and November 14, 1984.
- 2. Telephone conversation with the alleger on September 20, 1984.
- 3. Results of eddy current tests on the CT HXs, dated November 4, 1982.
- 4. Daily inspection records on the ANI for January 20-22, 1983.
- 5. ANI interface instructions No. MEI-028.
, 6. NCRs M-5102S and M-51035, dated January 23, 1983.
- 7. Traveler packages ME83-1010-4800 and ME83-1012-4800.
- 8. B&R procedures CP-QAP-2.4, CP-CPM-6.96, QI-QAP-11.1-26, and .
CP-QAP-18.6.
- 9. Joseph Oat drawings No. 5776, C-7420, and 5773.
- 10. Telephone conversation with Joseph Oat manufacturer's .
l representative on September 20, 1984. i l
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- 16 -
- 10. This statement prepared by:
D. Hansen. Date TRT Technical Reviewer Reviewed by: L. Shao, Date Group Leader Approved by: ' V. Noonan, Date Project Director 4 e 1 4 v- w --
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