ML20198L522
| ML20198L522 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/10/1984 |
| From: | Baker W, Bielfeldt L, Wright B BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.) |
| To: | |
| Shared Package | |
| ML20197J316 | List:
|
| References | |
| FOIA-85-59 CP-CPM-6.9G, NUDOCS 8606040303 | |
| Download: ML20198L522 (87) | |
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BROWN & ROOT, INC.
PROCEDURE EFFECTlyE CPSES NUMBER REVISION DATE PAGE JOB 35-1195 CP-CPM-6.9G 6
7/10)f4 1 of 20 3
TITLE:
ORIGINATOR:
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OATE REVIEWEDBY:[M 7
I CP-CPM 6.9 B&R QUALITY ASSURANCE DATE AT FOR ASME WELDING.
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7_A pd FABRICATION, M GC0 QUAL 3 W AS NCE DATE AND INSTALLATION REVIEWED BY:
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4-M8M ACTIVITIES SR. PROJECT WELDI ENGINEER DATE APPROVED BY:
M-N es7 CONMRUCTION PROJECT' MANAGER DATE 0.1
_TABE OF CONTEMES e
1.0 IFTRODUCTION GINEERINGll 3
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2.2 RESPONSIBILITY 2.3 DOCUMENTATION LOCS 2.4 DOCUMENTATION STORAGE 2.5 VERIFICATION OF INSPECTIONS 2.6 ANI REVIEW 2.6.1 Inspection Plan 2.7 ROUTING OF DOCUMENTATION 2.8 DOCUMENTATION MODIFICATION REQUIREMEVIS 2.8.1 Piping Subassemblies And Component Supports 2.8.2 Field Welds (Piping) 3.0 DOCUMENTATION PREPARATION AND PROCESS FLOW 3.L WELD DATA CARDS AND MULTIPM WELD DATA CARDS 3.2 WDC AND MWDC CRIGINATION 3.2.1 Pre-established Repair Sequence 3.3 REPAIR PROCESS SHEET 3.3.1 Required Approvals 3.3.2 Repair Process Sheet Init ia t io n 3.3.3 Weld Metal Repairs 3.3.4 Maior Base Metal Repairs 3.4 MANUFACIURING RECORD SHEET 3.5 COMPONENI MODIFICATION CARD 3.5.1 Doc ume nta t io n 3.6 DOCUMENTATION ACTIVITIES DURING FABRICATION / INSTALLATION 3.7 NONDESTRUCTIVE EXAMINATION DOCUMENTATION REQUIREMENTS
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l EFFECTIVE INSTRUCTION DATE PAGE BROWN & 100I, INC.
REVISICN CPSES MER JOB 35-1195 CP-CPM 6.9G 6
7/10/84 2 of 20 o.11 LIST OF TABUS_
"ASME INSPECTION REQUIREMENTS NATRIX" (4 sheets)
" REQUIRED EXAMINATION, QC HOLD POINTS AND APPROVALS REQUIR 6.9 G-1 6.9 G-2 FOR REPAIRS" (2 sheets)
"INSPECIION REQUIREMENIS FOR COMPONElff SUPPORTS" (3 6.9 G-3 o.111 FIGURES WELD DATA CARD (Front Only) 6.9 G-1 MULTIFIZ WELD DATA CARD (Front and Back) 6.9 G-2 POST-WELD HEAT TREATMENT CHECKLIST 6.9 G-3 6.9 G-4 REPAIR PROCESS SHEET MANUFACTURING RECORD SHEET 6.9 G-5 WELD DATA PROCESS SHEET /INSPECIION PLAN FORM 6.9 G-6 6.9 G-7 MATERIAL IDENTIFICATION LOG s
o. iv SUPP MMENTS_
OVERVIEW W WELDING DOCUMENTATION REQUIREMENTS INITIA 6.9 G-I e)
PRIOR TO JULY 20, 1979.
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1.0 INTRODUCTION
This appendix to Procedure CPM 6.9 provides the doctanentation fabrica tion, requirements of ASME Section III for welding, and installation activities.
2.0 REQUIREMENTS 2.1 APPROVAL AUIHORITY The requirements for origination, review, and approval of this appendix shall be in accordance with procedure CPM 6.1.
In addition, this appendix and its' DCN's shall be approved by the Project Welding Engineer.
2.2 RESPONSIBILITIES Doctanentation of Unit 1 governed by this appendix shall be originated and primarily controlled by the Project Welding Doctanentation of Unit 2 governed Engineer during field use.
by this appendix shall be or.iginated and prinarily controlled by the PFG per CP-CPM 7.1.
The B&R Site QA Manager is e
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v EFFECTI7E INSTRUCTION BROWN & 100r, INC.
REVISICN DATE PAGE 3
..CPSES NUMBER I
Q JOB 35-1195 -
CP-CPM 6.9G 6
7/10/84 3 of 20 The responsible for ASME Code certification, as required.
Permanent Plant Records Vault Supervisor and IRV Coordinator l
have responsibility for.docuentation storage and retrieval.
2.3 DOCUMENTATION LOGS Responsible groups shall keep a status of such documentation suf ficient to permit traceability and retrieval. I4gs shall be used to list the applicable drawing numbers, weld utanber(s),
ites designations, and current status or locations of the doctamentation. Unit 2 tracking and status will be done per CP-CPM 7.1.
2.4 DOCUMENTATION STORAGE When doctmentation is stored in an unattended location, such a
storage area shall be locked or otherwise secured.
2.5 VERIFICATION OF INSPECTIONS T
Inspections shall be evidenced by signature, initials, or ink stamp that identifies the individual making the inspec-t ion. All doctmentation entries shall be made with a black, indelible, ink pen (not felt tip pens).
2.6 ANI REVIEW Upon completion of documentation or any doctanent change, the applicable doctmentation shall be presented to the ANI for review as noted below.
If the doctamentation is acceptable, the ANI indicates 'his concurrence by initiality and dating l
the applicable welding documentation.
Initial Review Required:
All weldios doctanentation, e.g.
I WDC, MWDC, RPS, Hanger Packages, Travelers, MRS's NUrE 1:
The following documentation changes require ANI re-review :
Deletions of items designated as ANI holdpoints a.
(unless a weld 1,s voided).
b.
Deletion of insphetion verifications that provide
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objective evidente of ASME Code compliance (e.g.
fit-up, preheat, PWHT, NDE, material verification, etc.).
BROWN & 100r, INC.
PROCEDURE EFFECTIVE CPSES NUMBER REVISIN DATE PA2 q~--
JOB 35-1195 CP-CPM 6.9G 6
7/10/84 4 of 20 c.
Additions of operational steps in sequences previously reviewed. This is to include addition of material to an MRS.
2.6.1 Inspection Plan 2.6.1.1 Wald Data Process Sheet / Inspection Plan ANI review of docuentation may be accomplished with a " Weld Data Process Sheet / Inspection Plan Form" (Figure 6.9G-6) in lieu of the weld doctseentation. The forn is initiated and controlled by Welding Engineering and completed by the drawing nasaber, code class, individual weld identification and QC holdpoints. A line entry may also be completed for a MRS or travelers.
6 Hold or inspection points are established on this form by indicating them in the applicable spa.:e(s).
Hold / inspection points not shown, such as travelers or MRS operations, are
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noted in the " comments" coltaan.
Upon completion of each review / inspection denoted above the WE, QC, or the ANI representative shall sign and date in the appropriate space at the bottom of the fo rm.
The holdpoints as defined on the form shall be transcribed
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to the appropriate MRS, WDC, or traveler by Welding Engineer-ing and in the " Reviewed by: ANI" block shall be written "ANI/IP" to indicate that a completed Weld Data Process Sheet / Inspection Plan is. on file to doctament the ANI review.
A copy of the complete WPS/IPF form shall be. retained by the ANI and the original transmittal to the Site QA Manager when all WDC's listed on the inspection plan have been I
prepared.
I NOTE:
(This note applies to the above paragraph only)
Any ANI holdpoint that is not transferred to the weld doctanentation from this form constitutes a nonconformance if the ANI holdpoint is bypassed and shall be doctamented in accordance with CP-QAP-16.1 W
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EFFECTIVE INSTRUCTION BROWN & ROOT, INC.
REVISIQf DATE PAGE (A]
NUMBER CPSES
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JOB 35-1195 CP-CPM 6.9G 6
7/10/84 5 of 20 Normally, weld documentation will be made out for a complete ISO.
RPS's will be presented to the ANI for review.
ROUTING OF DOCUMENTATION (ASME) 2.7 Upon completion of the ANI review, MRS(s), Banger Packages, From this WDC(s), RPS(s) shall be returned to the PWE.
point on, the doctamentation listed above shall be controlled by the Package Flow Group and maintained as described in Section 2.3 hereof.
At the completion of each shift, or the end of the related work, all doctamentation shall be returned to the FWTC l
substation or the PFG for Unit 2.
Upon completion of all work presented by such documentation, the affected doctanentation If completed, it shall be shall be reviewed for completion.
transmitted to the B&R QA Doctanent Review Group or to the PFG j
for Unit 2 per CP-CPM 7.1.
. DOCUMENTATION MODIFICATION REQUIREMENTS 2.8 Piping Subassemblies (Revisions To MRS and Related WDCs) 2.8.1 and Component Support s When documentation revision is necessary be fore or during forwarded to:
fabrication, the af fected doctamentation shall be Piping Docueentation - revised by Welding Engineering i and common, and the PFG for Unit 2 in accordance a.
for Unit with Appendix 6.9G and CP-CPM 7.1.
Component Support Doctamentation - Revised by the Hanger b.
Package Distribution Station in accordance with Appendix 6.9G, and P.rocedure CPM-9.10.
This process shall include surveillance, review, and modifications by the ANI as defined in Section 2.6.
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EFFECTIVE PROQDURE BROWN & 100f, INC.
REVISIN DATE PAGE NUMBER CPSES
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JOB 35-1195' CP-CPM 6.9C 6
7/10/84 6 of 20 2.8.2 Field Welds (Piping) f Revisions to WDCs shall be made and reviewed (Section 2.8.1 above) with the exception that doctamentation of the changes /
revisions shall be made by WE and the changes shall be i
I initiated and dated near the change.
Changes that substantially revise the designated NOTE:
work may require that the affected weld doctamenta -
j tion be voided and new doctamentation issued.
l DOCUMENTATIN PREPARATION AND PROCESS FLOW 3.0 WELD DATA CARDS AND MULTIPLE WELD DATA CARDS 3.1 Documentation initiated and dated by the Welding 8
NOTE:
Engineering department before July 2,1979, may be j
used as prescribed in Supplement 6.9G-I.
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i Weld Data Cards (WDC, Figure 6.9G-1) or Multiple Weid Data 1
Cards (MWDC, Figure 6.90-2) shall be prepared for all welds e
. hich must meet the requirements of ASME Section III, WDCs and MWDCs shall wDivision i except as provided herein.
meet additional requirements given below, MWDCs for ASME welds are limited to socket welds and l.
component support welds on the same drawing or No more than ona pipirs subassembly, subassembly.
j support, or isometric or hanger drawing (for component field welds) shall be doctamented on a single MWDC.
t Spaces requiring entries on WDCs.and MWDCs that are not 2.
applicable shall be marked N/A by the WDCC.
A maxistas of four (4) welding procedures may be assigned t
2 3.
WPSs may be changed by the WT in the to a given WDC.
The WI shall enter the change on the WDC prior field.
l to the start of the operation involving the change.
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BROWN & E00r, INC.
PROCEDURE EFFECIIVE CPSES NUMBER REVISICE DATE PAGE JOB 35-1195 CP-CPM 6.9G 6
7/10/84 7 of 20 4.
Corrections to an entry on a WDC, MWDC, or other documentation shall be accomplished by drawirs a line through the incorrect entry, and initialing and dating the new entry.
5.
Class 2 and 3 Component Support Welds do not require unique identification (weld utsabering) except for the following: Attachment welds to pressure retaining
-j members; hangers or welds utilizing multiple processes or filler materials; full penetration welds excluding flare beveling on structural tubing; and welds requiring NDE (weld ntabers for welds requiring NDE may be added upon completion of work).
Class I component support welds require unique veld numbers for all welds. Heat number traceability is required for all Class I and impact tested materials and shall be recorded on an MIL.
3.2 WDC AND MWDC ORIGINATION The following entries are required for all WDCs and MWDCs for the work to be accomplished:
1.
All identification information, as applicable.
2.
WPS ntabers: The correct WPS revision utsabers and any applicable ICNs shall be entered by the WI just before the release of the card to Construction. When a welding procedure for the automatic CIAW process is used, as a minista, an appropriate GTAW procedure for manual tacking shall be listed in addition to and above the automatic GTAW procedure. A maxista of four WPSs may be provided.
3.
Enter the " Weld Filler Metal Required."
NUIE 1:
Unless specified otherwise by the PWE, if a WDC references ER308, than ER308L is accept-able; if ER316, then ER316L is acceptable.
Westinghouse applications will require approval of the W representative.
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o EFFECTIVE PROCEDURE NUMBER REVISIGt DATE PAGE BROWN & ROOI, INC.
CPSES Jos 35-1195 CP-CPM 6.9G 6
7/10/84 8 of 20 Enter the " piece" ntmber (PCf) and "P" neber on the WDC.
4.
The NWDC piece number is noted in the MRS section on the back or on an attached MRS. For component supports this The "P" may be accomplished' on a Bill of Materials.
number (s) for the material should be antered adjacent to the applicable connectics weld numbers.on the top of the NWDC (front).
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In addition, verify that the L?S is acceptable fbr the wall thickness, material type, etc. (wall thicknesses may be fbund by consulting ANSI Standards B16.9, B16.11, 336.10, and B 36.19).
Verify that the WPS was qualified to ASME Sections III 5.
and IX and approved by G4H.
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NOIE 2:
An applicable WPS is shown on Table 6.9G-1 by If Piping Specification Category and Code Class.
the one shown is used, this verification is unnecessary.
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.6.
Check if PWHT is required by the WPS.
If no PWHT is If PWHT required, enter N/A in all applicable spaces.
is required, attach a PWEI checklist as snown on Figure 6.9-3 and complete all identification information.
Enter Heat Treatment Procedure on the WDC.
Add sequential operations to be followed during fabrica-7.
tion or' installation including inspection requirements.
For NF Supports, hold points shall be entered in accordance with the requirements delineated in Table i
6.9C-3 and, as applicable, fort the hanger to be fabricated / installed from the following:
Support Ntaber Ident.
Sire, Configuration, Tolerance /Dwg.
Material Correct Dwg.
I Fasteners Correct & Complete I
Tocation and Elevation /Dwg.
Spring Can Stops Installed Spherical Bearings All Welds /Dwg. & WPS (V.T.)
P.T./M.T.
srrr.
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EFFECTIVE PROCEDURE BROWN & RO M, INC.
NUMBER REVISICN DATE PAGE CPSES JOB 35-1195 CP-CPM 6.9G 6
7/10/84 9 of 20
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Make entries as noted on the Entry of QC holdpoints.
ASME Inspection Requirement Matrix" (Table 6.9G-L), as 8.
noted by ASME Section III Code Class and Piping Category or the component Support Inspection Matrix (Table 6.9G-3).
to the Enter weld numbers as applicable adjacent applicable sequence on the MWDC.
For dissimilar metal shop welds, PT is required on Buttwelds NOIE 3_:
both the root and final weld surfaces.
shall be 100% RT'd.
For branch connections, any additional NDE shall NME 4_:
be as required by Note 4, Table 6.9G-1.
Use one. space for each type of NDE required.
NUEE 5_:
Boldpoints are denoted with a check "
NOIE 6:
"Wr" inspection Inspection points with an "X".
points shall be as required by the PWE and indicated with an "X".
CON. (Construction) holdpoints shall be as defined by the PS.
J Required holdpoint and inspection point operations NorE 7:
shall be performed by the group defined on the WDC to right (i.e.,
or RPS in the order shown from left if an operational sequence requires WT and QC holdpoints, the WT inspection shall occur before QC inspection).
Delta ferrite checks shall be performed as required NOIE 8:
by Appendix 6.9D.
Line, drawing no., weld no.(s), and fabrication NOTE 9_:
code and class entries shall be made on WDCs and MWDCs, as applicable.
Upon acceptable completion of the WDC(s), the NOIE 10:
individual reviewing the above entries shall denote
" Review" immediately below the last operational sequence and sign and date in the "WE" column.
For B0P WDC's a line may be skipped.
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EFFECTIVE INSTRUCTION BROWN & R0ct, INC.
REVISICH DATE PAGE CPSES NUMBER s
,, I Jos 35-1195 CP-CPM 6.9G 6
7/10/84 10 o f 20 Pre-established Repair Sequence (Optional - In Process)_
3.2.1 A pre-established repair sequence may be added at the direction of the P.WE below final NDE.
Signoffs for Normally the--
review shall be made below such sequence.
pre-established sequence will contain the following operations:
Excavate de fect.
a.
b.
Perform Info PT.
Evaluate excavation and attach a sketch to the WDC c.
and return to Welding Engineering or the PFG for Unit 2.
a In the event that this pre-established repair sequence 2.
is not used, all steps may be marked N/A by the PWE in the " Inspection Results" column.
The WDC shall reflect the revision and ICN's which are current l
3.2.2 at the time welding is started. Revision changes which
. occur after veldits has started, but prior to completion of the item, will be documented on the WFML.
3.3 REP AIR PROCESS. SHEET Welds requiring rewelding which were rejected after final inspection, all " major" repairs, and all base metal repairs requiring welding shall be documented on the RPS, Figure 6.9G-4 (or continuation sheet). The RPS is normally reproduced on the back of the WDC.
Specific requirements by classification of repairs are given in Appendix 6.9D, Before defining each repair operation sequence, Section 3.
the repair type shall be defined (i.e. Base Metal Repair, In-Process Repair, Cosmetic Repair, Major Weld Repair).
The applicable repair operations shall be established and approved be fore proceeding with the repair work.
For socket, component supports, and pipe butt welds NarE l_:
using the MWDCs and WDCs, the first repair sequence may be defined for each weld before initial issuance
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Should the repair not be required, the of the card.
appropriate signoff areas' are marked N/A by the cognizant QC Inspector or WT and initialed and dated.
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I EFFECTIVE PROCEDURE BROWN & ROOT, INC.
REVISIGE DATE PAGE NUMBER CPSES JOB 35-1195 CP-CPM 6.fG 6
7/10/84 11 of 20 The repair work and the inspection holdpoints on NorE 2:
the RPS aust be totally completed (signed) by the When the repair is complete and the QC Inspector.
RFS is signed,' work may continue to the next sequential step on the front of the WDC or MWDC.
The rejectable operation identified on the front of the 1.
WDC is marked "U" for unsatisfactory and signed and dated by the QC Inspector before continuing to the RPS operational repair sequence.
Each major welded repair (excludits in-process welds)This 2.
shall be numbered consecutively as R-1, R-2, etc.
shall be stated next to the repair type before the first operational step. Operation designations shall be " operation number" of the rejectable operation on the In-process front of the WDC suffixed by an A, B, C, etc.
welds will be sequentially number IF-1, IP-2, etc.-
Should an operatio'nal step result in a rejectable
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condition that cannot be considered an in-process repair, 3.
then one shall be added to the repair number and this shall be affixed prior to the next operational sequence, i.e.:
R-1 Major Wald Repair 7A Crind defect 78 PT excavation 7C Fill per WPS 88023 l
7D Crind for NDE inter-pretation' 7E Peeforn final. RT."U" 7F Remove Purge Dam N/A l
R-2 Major Wald Repair 7A Crind de fect 78 PT excavation 7C Fill per WPS 88023 In a given operational sequence, steps that are not to 4.
be used may be marked "N/A" in the Inspection Results section by the PWE.
i Upon completion of g given operational sequence, work 5.
succeedirg step on the front shall proceed to the next of the WDC 1.e., Step 7D is the last operational step which includes signoff for required final NDE.
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t EFFECTIVE PROCEDURE BROWN & R00r, INC.
NUMBER REVISION DATE PAGE CPSES JOB 35-1193 CP-CPM 6.9G 6
7/10/84 12 o f 20 On the Weld Data Card, Step 8 is the next step after signoff of the required NDE, as required by the last step on the RPS.
3.3.1 Required Approvals _
Base metal repair - ANI, WE, G&H Major veld repair - ANI, WE In-process repairs - WE Cosmetic Repairs - ANI, WE Approval signatures and dates shall be affixed in the appropriate coltsan of the RPS directly below the lastOn MWDC's, seq operation step defined. welds may be defined before affixing of approv at the end of the last operation defined.
The' PWE shall maintain a list of his designees authorized to approved documentation. A copy of this list is to be provided to the Site QA Manager, A repair cycle shall be defined as operations on a
a weld after a rejectable code-required final NDE N(7FE:
that results in either an acceptable or rejectable additional code-required final NDE.
I The repair nunber on applicable RPS's shall be advanced only under these circumstances unless determined otherwise by the PWE.
3.3.2 Repair Process Sheet Initiation The Repair Process Sheet shall be completed and verified as follows for repairs to ASME items:
The WDC Serial No. (where applicable), drawing no., and For 1.
weld no, shall be entered at the top right corner.
support applications, both the component componentdrawits number and the applicable piping For base support isometric drawing number shall be provided.
metal defects, the spool number shall be entered.
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u EFFECTIVE PROCEDURE NUMBER REVISION DATE PAGE BROWN & ROOT, INC.
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Jos 35-1195' CP-CPM 6.9G 6
7/10/84 13 of 20 3.3.3 Weld Metal Repairs Required approvals, inspections and holdpoints shall 1.
be established as delineated in Table 6.9G-2, required examination, QC holdpoints, and approvals required for repairs to ASME Section III, Subsection NB, NC, ND.
For Subsection NF, see Table 6.9G-3, Note 6, page 4 of 4.
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The Repair Process Sheet shall describe the defects, 2.
including sketches or attachments (i.e., overlays) in order to adequately locate the defect (s) at a later date.
For weld repairs, if the original weld points were 3.
i completed, verify that in addition to the weld repa r requirements of the original weld QC hold points are If a delta ferrite check as required by Table 6.9Gl.
is required, verify that " Delta Ferrite Check" has been entered.
The repair cycle (the ntsnbar of repairs to this weld) 4.
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shall be noted. Requirements for more than two repairs are given in Table 6.9G-2.
If all items on the RPS have been acceptably completed, 5.
the originator shall denote " Final Acceptance" on the line immediately below the last entry and sign date in The applicable documentation the appropriate column.
shall then be transferred to QA for QA review /ANI review /
approval, as required.
3.3.4 Major Base Metal Repairs for Verify that the required approvals have been made 1.
For base metal repairs by referring' to Table 6.9G2.
supports, the applicable CSTP or HP number compo nent shall be entered.
the WPS to be used is acceptable for Enter / verify that 2.
the material and the type of weld to be made, and that the " Weld Filler Material Required" where shown is as specified on the WPS.
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EFFECIIVE PROCEDURE NUMBER REVISICN DATE PACE BROWN & ROOr, INC.
CPSES JOB 35-1195 CP-CPM 6.9G 6
7/10/84 14 o f 20 is subsequently required, If post-weld heat treatment 3.
enter / verify that the time and temperature requirements have been entered and that a "PWHT Checklist" (Figure 6.9G-3) is attached.
Establish the required QC holpoints and approvals 4.
required on the RPS operation sequence, and the NDE requirements of Table 6.9G-2.
Establish the " Repair Cycle No.." the nsaber of the 5.
repair to be made is entered.
Verify that the sketch or overlay attachment is adequate 6.
to find the repaired defect at a later date.
Establish that spaces for delta ferrite readings have 8
7.
been established where applicable _ for S/S materials.
(See also Appendix 6.9D, Section 3.18.)
If all items above have been acceptably completied, the originator shall sign and date the " Weld Engr." approval 8.
v' column.
Review and modify an applicable MRS, HP, and CSTP for 9.
required items such as described in Section 2.8 of this Appendix and concurrently with the RPS operational Review and approval of the RPS operational sequence.
sequence shall be as required by Section 2.6 and 2.7 o f this Appendix..
Base metal repairs that are not associated with a weld, or I
weld metal repairs that are necessary after the original doctmentation is complete and/or unavailable, shall be The WDC shall be defined on an RPS on the back of a WDC.
completed as to all applicable items and the " production QC should utilize release" section marked N/A or crossed out.The RPS shall be the pre-printed spaces M&TE, NDEP, etc.
completed on the back definirig the repair sequence and requirements.
Base metal repairs associated with a weld having a WDC (such as weld end prep repairs) may be completed as part of the repair '.*
sequence on the RPS for that weld.
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EFFECTIVE PROCEDURE NUMBER REVISIN DATE PAGE BROWN & E00r, INC.
CPSIS JOB 35-1195 CP-CPM 6.9G 6
7/10/84 15 of 20 TE MANUFACTURING RECORD SEET 3.4 A MRS (Figure 6.9G-5) is shop traveler for ASME Section III piping subassemblies and fior modifications to Code-certified (The MRS is not required for component piping fabrications.
A MRS shall be initiated for all supports or field welds.)
fabricated and is routed with the pipirs subassemblies to be I
WDC's for any welds to be made as part of the documentation The boundaries of a subassembly shall be field package. welds, flanges, or threaded connections, unless otherwise noted.
For socket welds documented on the MWDC, the MRS on the back of the card (as shown in Figure 6.9G-2) may be used or a separate MRS may be attached. (For component supports, the s
MRS may be used as a Bill of Materials.)
Subassemblies composed of screwed fittings also require an MRS.
s The MRS shall be completed as follows:
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Enter all applicable identification information (drawing
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revision, line, composite, subassemblies, or component support, numbers).
I Complete the Bill of Materials on the MRS or the back i
l 2.
of the MWDC from the construction drawirg for item, quantity, size, schedule / rating, material specification, Other items are completed in the and type or grade.
field.
For a MRS where a Code-certified item is to be modified, 3.
the Bill of Materials shall be completed as above for the items to be added or deleted.
Every attempt should be made to install pipe exactly on 4.
However, when this cannot be accomplished, location.
Code-certified items may be shortened in the field to fitup and installation provided the following permit conditions are satisfied:
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EFFECTIVE PROCEDURE BROWN & ROOr, INC.
REVISIN DATE PAGE NUMBER CPSES JOB 35 1195 CP-CPM 6.9G 6
7/10/84 16 o f 20 No shop welds are altered or cut; a.
dimensions are maintained The final working point b.
22 inches 'for Unit 1, 2 and Common building, of the dimensions specified on the drawing (reference by CPM-6.9E, paragraph 3.12.1);
final dimension after shortening will be c.
The verified on a modification MRS.
Modifi-A GC is not required to perform such modifications.
cations in excess of tolerances and/or those cutting shop The welds, shall require GC's and modification MRS's.
cutting of field welds will also require a GC.
Modifications to Code-certified items resulting NorE 1:
from design changes or a change in weld numbers such require a drawing revision, or GC to permit modifications.
When final dimensional inspection for piping NUIE 2:
20, 1979, subassemblies was completed after July b}
cleaning and packaging was not a required QC The QC holdpoint and need not be inspected.
. Inspector shall note such hold points N/A and initial and date.
Any marking falling within the allowed modification area shall be transferred prior to the nodification.
NOTE 3:
The MRS is routed with associated weld data cards for surveillance / review as delineated in Section 2.6 and 2.7 above.
THE COMPONENT MODIFICATION CARD 3.5 The mC's shall'be issued and controlled in accordance with Upon receipt, the GC shall be applicable TUSI procedures.
reviewed and appropriate action taken as follows.
(
for ASME Class I applications, mC's to add Except or delete materials or welds, within the original NUTE:
for welding problems, misfabrication or de sig n, l
misaligranent, may be issued by Welding Engineering.
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--- - - - - ~ -
- EFFECTIVE INSTRUCTION BROWN & 100t, INC.
REVISICN DATE PAGE CPSES MER
,]
JOB 35-1195 CP-CPM 6.9G 6
7/10/84 17 of 20 3.5.1 Docmentatio n 3.5.1.1 Wald Data Cards Where a shop weld on a certified piping subassembly is -
1.
1ssue a modification MRS with a step added to be cut,-
to c6nfira joint removal. The associated WDC's may be issued concurrently.
If the subassembly has not been l
certified, the existing MRS may be revised and reapproved as described in Section 2.6 above. Revisions to Ranger j.
Packages shall be in accordance with procedure CFM 9.10 and with W3C's added or deleted as described in this section.
2.
The cognizant welding technician will verify any When an MRS is not required weld removals on the MRS.
8 required, as in the case of field welds, this verifica-tion shall be made by the welding technician signing or initiating the applicable hold point on the WDC.
The PWE may stamp " VOID" on original WDC's in lieu NarE:
of QCR when the docuentation is available.
s l
Upon issuance of associated WDC's, the C(C neber shall 3.
be entered on the card.
4.
If all welds on the cards are " VOID" and not presently in the Records Vault, they shall be transmitted to QA or to the PFG if Unit 2, in accordance with CP-CPM 7.1.
If all w' elds on cards are not affected the card 5.
may be used for further production use.
EXCEPTION 1:
WDC's for BOP applications shall be controlled and processed as noted above with the exception that they are forwarded to the BOP Inspection Croup for the docuentation file.
EXCEPTION 2:
CMC's af fecting BOP welds listed on weld data sheets shall be filed with the approriate drawing and all appropriate corrections made on the associated
~~
Weld Data Sheets prior to turnover.
177 m
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EFFECTIVE PROCEDURE NUMBER REVISION DATE PAGE BROWN & ROOr, INC.
CPSES Jos 35-1195 CP-CPM 6.9G 6
7/10/84 18 o f 20 3.5.1.2 Verification Concurrent with the above activity, the following verifica-tions and/or actions shall be taken/make by Welding Engineering:
the QiC is completed for line number, Verify that 1.
drawing neber, and weld numbers and that all instructions and sketches are clear.
the necessary approvals have been made 2.
Verify that using a OfC.
REQUIRED:
Site Engineering is located adjacent Where Westinghouse supplied equipment 3.
to the weld to be removed, approval by an authorized W representative is also necessary (the " Owner's Agent").
DOCUMENIATION ACTIVITIES DURING FABRICATION / INSTALLATION 3.6 The craftsman makirg the weld fit-up shall enter the 1.
heat neber of the base materials to be joined on the
~
When subassemblies are to be joined, applicable WDC.
traceability shall be verified through the use of the subassembly are welded together and an MRS is used,
(
traceability shall be through entries on the MRS is used, traceability shall be through entries on the MRS.
In such instances, the heat number block on the WDC may is to When a valve or other equipment be marked "N/A".
be joined, the serial number of the item may be entered in place of the heat number.
supports, verification of materials shall.
For component be made on the MWDC, MRS or MIL (Figure 6.9G-7).
NOTE 1_:
An Inspector verifies that the materials used and the heat numbers entered are correct at the time of first inspectio n.
For ASME Fabrication activities, these verifications l
shall be made by the QCI; for BOP, the CIT.
When pipirg subassemblies or other code-stamped NorE 2:
items are joined, the subassembly serial no. shall l
l be recorded in lieu o f the heat number.
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EF IVE INSTRUCTION BROWN & 100f, INC.
CPSES NUMBER s
JOB 35-1195 i
CP-CPM 6.9G 6
7/10/84 19 of 20 i
For Class 2 and 3 component supports and Class 1 standard items, the heat number block on the MWDC NOTE 3:
MRS or Bill of Materials may be marked "N/A".
Entries shall be made in the WFML during the welding 2.
process as defined in Appendix 6.98.
When welding austenitic stainless steel, the weld interpass temperature shall be checked by the craftsman 3.
after each pass has been completed around the entire pipe joint.
When M&TE is used to perform inspections, the QC Inspector shall enter the M&TE number and calibration 4.
due date in the space provided on the WDC or MWDC, and s
initial and date the entry.
Certain austenitic stainless steel welds shall be The 5.
required to be measured for delta ferrite content. measu record the four readings in the space immediately to the right of the NDE procedure / revision designations on the
)
If the readings are within the specified require-ments, he shall sign and date the applicable operation WDC.
(see Appendix 6.9D, Section 3.18).
Upon completion of all work required by the documenta-tion, the MRSs and WDCs, and associated docmentation shall be routed to the WE or the PFG if Unit 2 per CP-CPM the FWTC shall review as noted, weld 7.1.
Upon receipt, If acceptable, " Final docmentation for completion.
Acceptance" shall be written on the front after the last operation step defined and the WE column shall be signed and dated and ASME docuentation transmitted to the PFG for review, approval, and certification, and the IRV for I documentation vill be sent to QA Review storage. Unit For BOP WDCs, the MDS shall forward and then the PPRV.
l the completed cards to the BOP Inspection Group for approva.
supports, upon completion of the hanger, For component shall return the Hanger Package to Welding the Craft
- After final review, the Engineering for final review.
for final Hanger Package will be returned to the crafttransmittal by QC of
~
inspection by QC and subsequent the accepted Hanger Package to the Permanent Plant Unit 2 docmentation will be processed Records Vault.
t per CP-CPM 7.1.
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M.
v EFFECTIVE BROWN & ROOT, INC, REVISION DATE PAGE INSTRUCTION 3
CPSES NUMBER e
JOB 35-1195 CP-CPM 6.9G 6
7/10/84 20 of 20 NONDESTRUCTIVE EXAMINATION DOCUMENTATION REQUIREMENTS I
3.7 f
forms shall be completed for NDE performed on NDE Report Non-ASME safety-related items, " Info" NDE, RT and UT 1.
examinations, and unsatisfactory VT, PT and MT inspections For in accordance with the NDE Procedures Manual.
sati'sfactory PT, MT and digital thickness UT, a NDE report is required.
For welds that use WDCs or MWDCs, the following informa-2.
tion shall be recorded.
The NDE procedure and revision to which the a.
examination was performed.
The inspection results (i.e., "S" Satisfactory, b.
"D" "Unsatis factory).
The inspector shall verify that the fabrication for the c.
code / acceptance standard was correct 3,
examination performed.
l..
The signature or initials and date of the inspector d.
conducting the examination.
The inspector's level of certification.
e.
NDE required by hold points must be certified by a NOTE:.
level II on the applicable report or WDC, Upon completion of all holdpoints for welds which do n to the FWTC or to the PFG if Unit 2 per CP-CPM 7.1.
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...._._._..M_........__..___._-_
EFFECTIVE PROCEDURE BROWN & ROOT, INC.
REVISION DATE PAGE NUMBER CPSES f
JOB 35-1195 w
.)
6 7/10/84 1 of 4 CP-CPM 6.9G TABLE 6'.9G-1 ASME INSPECTION REQUIREMENTS MATRIX
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REVISION DATE PAGE NUMBER CPSES JOB 35-1195 s
CP-CPM 6.9G 6
7/10/84 l 2 of 4 TABLE 6.9G-1 ASME INSPECTION REQUIREMENTS MATRIX e
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REVISION DATE PAGE NUMBER CPSES JOB 35-1195 7/10/84 3 of 4 6
o ov 6 or TABLE 6.9G-1 ASME INSPECTION REQUIREMENTS MATRIX v
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REVISION DATE PAGE NUMBER CPSES JOB 35-1195 a
6 7/10/84 4 of 4 -
,4 CP-CPM 6.9G TABLE 6.9G-1 ASME INSPECTION REQUIREMENTS MATRIX SID.:
For dfsstattar metal shop welds the rest am final weld surfaces shall be liquid penetrant esamined and 1005 RT ts regefred for 1.
butt welds.
Final MT PT or RT rewired for buttwalds greater than 4* (N05212).
2.
For P-1 materials. Pf may be substituted for NT (P3-438.1.10.2 (a).
3.
For socket welds. PT will normally be perfomed.
Full penetreties butt and corner welded bronch and piping connectfens..
4.
shall reentre final W as follower Class one weldsents greater then 4* require RT and NT or PT.
Class one weldsents eeuel to or less than 4' require MT or PT.
4.
Class two weldsents greater than a* Poesire RT.
b.
Class tw ogsal to or less then 4* reputre MT or PT.
c.
I 4.
NT or PT is reeutred enternally, and when accessible.
Mr internally. (NS 1242. 5243. NC 5242).
mest rewired for P 1 meterials as receired by ASME Section !!!.
5.
If PWMT is restrod. use WP511012 (MS-100 4.33.6),
g Rewired for wort falling within the scope of MS-100 only, and in 6.
d accordance with other notes (MS-100 2.1.2).
The delta ferrite check shall be accomplished by a welding tech-ntcian and surveillance over such operettons shall be performed 7.
as follows by the establistment of a QC hold point for delta fer-Class 2 & 3 weldsents Class 1 weldments 10C1 QC hold point.
rite:
los randon QC hold potat.
Selection of insoection (WT) and Oc held points and their discosttien shall be in accoreance with MS-100. Paragraph 4.34.6.
For melds which have teen exemoted from testing by the provisions of CP CDI 6.90 paragraph 3.18.4. QC hold pefnts may De marked *N/A* by the Project We14tng Engineer.
All Code Class 1 & 2 weld end preoeration surfacus 2* or more in thickness shell be maantned my the magnetic norticle or liquid 8.
penetrant method (N05130. NC3120).
l i
Purge can Removal reeutred for field welds amore purging fs reoufred g.
by the apolicable WPS.
- 10. For class I welds def fned in ASME Section !!!. h4380. (Specially Cesigned Welded feels) serform MT or PT on the final =eldsent sur-face (N3 one. (NOTE: CRIM Welding)
VT and QC Pold potats es* te on a surveilf ance or other systen r
other than the Es at tne option of the PWE or $1te QA Manager.
'OTE:
- 11. The final pass of all pressure boundary welds and f fetshed nachined surfaces of all hardfaced areas stuli te PT esamined (MS-425),
f j
- 12. In addition to randatory hold oo'nts. Welding Engineering may add addf.
tional I Nold points enere desses necessary.
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1 BROWN & ROOT, INC.
PROCEDURE EFFECTIVE CPSES NUMBER REVISION DATE PAGE i
JOB 35-1195 g
v, CP-CPM 6.9G 6
7/10/84 1 of 2 TABLE 6.9G-2 Required Examination, QC Hold Points and Approvals Required for Repairs Repairs Y
Repair Completed Required u
l Cavity Repair Approvals E
g u
o fd VT PT HI RT VT UT PHE PUE ANI C&H }
gg g
g e
g Defects y
y a
m (1) Re-pairs' 9
not re-0 5
1 2
1 X
X X
X X,
K 7
quiring welding (2) Less 4
1 10 10-9 e
than 10%
z
.eg X
X
~X X
X X
X X
7
/
or 3/8" 5
1 4
1 10 10 9
below m
min. wall y x
x x
x x
x x
x x
x 7
(3) 4 1
10 10 9
Creater g
than 10%
X X
X X
X X
X X
X 7
or 3/8" 5
1 4
1 10 10 9
below m
Min. wall W X
X X
X X
X X
X
.X X
X 7
Weld Repairs (1) Mi-1 2
nor re-X' X
pairs X
X X
X not re-quiring velding 8
8 (2) Ma-3 4
4 4
6 6
jor.re-m pairs X
X X
X 3
X X
X X
X Code Stamped 9
Parts Appur-X X
_X X
3 tenances
.n-
o EFFECTIVE PROCEDURE BROWN & ROOT, INC.
REVISION DATE PAGE NUMBER CPSES JOB 35.1195 6
7/10/84 2 of 2 CP-CPM 6.9G TABLE 6.9G-2 Required Examination, QC Hold Points and Approvals Required for Repairs REPAIR CHART NOTES:
MT may be substituted for PT where applicable.
1.
When it is not possible or practical to examine a possible minimum wall violation through UT measurement, Mechanical measurement of 2.
wall thickness may be substituted.
For code stamped or certified items, the repair or modification of items which fall within the scope of Brown & Root certificate of 3.
For items authorization a manufacturer's approval is not required.
which f all outside such scope, repair shall be with the approval to s
the specifications of, or by the manufacturer, The examination of repairs shall be repeated as required for the original iten except that repair'of defects originally detected by 4.
MT or PT methods when the repair cavities do not excee
()
If the repair cavity exceeds the above, RT is -
an NT or PT method.
required.
All other component Pr is required for Class I components only.
5.
classes shall receive a VT of the cavity.
Required for more than 2 repairs to stainless steel welds.
6.
Repair situatlons which fall outside the scope of this matrix shall be analyzed as per job specification and code requirements 7.
and dispositioned accordingly.
Owner Engineer approval is required to repair excavations over 3"
~
in length with the open bute welding technique to welds where a 8.
consumable insert was used to complete the root.
W approval is required on items furnished by W,.
9.
Base Metal repairs requiring Owner Engineer aproval: Arc st 10.
l A.
l Base Metal repairs exceeding 25% of the pipe diameter in length minimum wall.
B.
Weld End prep repairs exceeding 3/8" in depth.For pressure tested piping C.D.. Minimum Wall violations to piping.
l be where the violation exceeds 10% or 3/8" the approval shal obtained on an NCR.
k m
EFFECTIVE PROCEDURE BROWN & ROOT, INC.
REVISION DATE PAGE NUMBER CPSES JOB 35-1195 CP-CPM 6.9G 6
7/10/84 1 of 4 3
TABLE 6.9G-3 INSPECTION REQUIREMENTS FOR COMPONENT SUPPORTS CU ANLINESS PREHE AT VT PT/MT RT
(,T PWT_
ftT-t?
CLA35 TTPE Futt Penetration tutt (7)
X X
X X (3 )
X (2)
(4 )
t VF52tl (7)
X X
X X '))
X (2 e
(* )
Plate 4 smell Fult Penetration X
X (3)
X (2)
(3)
Welced Jo X
X (3)
X 82 )
(5)
_Douole Fillet FutL PtLLet Welded Tee
^~-
(7)
X X
X X (3Y X (TF - - 4)_
~
t W 52t2 Full Penetrat ton X
X X (1)
X (2) 4)
X X (3)
X (2)
(5)_
Futt Penetration Tee & Ca r.or ( 7 ) X Linear Tne (5)
FutL Fillet Walds X
X
( 7)
AL L Ot ne r 'ie t ds t W52k1 Fult Penetettion Sutt (7)
X X
X X
(4 L (5)
X X
X Compo nent Wetos v/ Throat Ois t" (5)
S t a nda r d Fillet X
4L; Gt5er Welds (7)
Support J
(4)
II XFS221 (7)
X X
X X
(* ) _
Place & Shell Futt Penetration Butt X
X X
X
- 4. 5 )
Fult Pe:etration Oroeie(7)
X
( 5 )__
7Juble Fillet Welced "e7 X
'5)
'elded Tee Jotet X
Ful'. 8ttlet Memeeru ?'
'5s Ot ner as iJs. tn Pe t=arv X
e7' Att Other Wette 4)
T II 6 MC NF5222 Futt Penetration Sutt (7)
X X
(76 X
'3)
F u t t Pe re c r a t io n Tee We '.d s III 4FSD2 (3)
AlL F ttiet Welds X
'7)
Alt Cther Welds
(*'
X
!! i MC NF5221 Full Penetration Sutt (7)
X (5)_
X Class ;;I
- 5?
V75233 Fillet '~ elds
(
47' AL'.
Ot her We L ds (45 Futt ?toetration Sutt Velds X
X III XF5231 Plate i Shett Sceediv ' ti2" in T5tekeess (7? X X
Ali a ner We tas ' ')
3e fer to Page 1 (NGTES) for thcee numbers that are in parenthests.
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m EFFECTIVE PROCEDURE BROWN & ROOT, INC.
REVISION DATE PAGE NUMBER CFSES JOB 35-1195 7/10/84 3 of 4 6
- n CP-CPM 6.9c TABLE 6.9G-3 NOTES Purge is not required if wall thickness of pr'1tssure piping exceeds Where purge is required, a hold point for purge dam removal 1.
thickness.
is also required.
Modification data cards for attachment welds to piping systems which ha been pressure tested shall be noted as to the maximum size weld that can 2.
be made in accordance with the following criteria:
~~the welds shall be restricted to fillet welds not exc
~~
~
exceeding 1/2 inch thickness; the welds shall not exceed a total length of 24 inches for fillet welds or 12 inches for full penetration welds.
~
Partial penetration welds shall be subject to the same size requireme sv' as fillet welds.
In those cases where the design change document specifies a weld s excess of that described above, or when the added welds will require Welding Engineering shall indicate "rehydro required" on the K1DC an present the card to Quality Engineering for review and signature.
When the results of radiography are not meaningful, ultrasonic examin In addition, the adjacent base material for at least 3.
1/2 inch on each side of the joint shall be examined by either ffT or P shall be performed.
When neither of the above requirements can be shall be examined by either MT or PT.
Full penetration welds in P1 material over 1-1/2" requires Post Weld 4.
Heat Treatment.
Fillet and partial penetration welds in P1 material over 1-1/2" with a throat thickness or groove dimension over 3/4" require Post Weld Heat 5.
Treatment.
(Continued)
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EFFECTIVE PROCEDURE BROWN & R00I, INC.
REVISION DATE PAGE NUMBER CPSES JOB 35-1195 6
7/10/84 4 of 4 CP-CPM 6.9G TABLE 6.9G-3 NOTES _(Cont'd)
.~.
Inspection Requirements for Repairs to Component Supports 6.
Repairs that require welding will be reinspected with the The cavity does A.
original NDE method that detected the defect.
not require inspection.
Elimination of surface defects by grinding, that do not require weldirg, will be examined by MT or PT after blending.
B.
Bese metal repairs will be examined in accordance with the Base metal C.
material specification for the material af fected.
repairs made by welding shall be built-up a minimum of 1/16" above the surface and shall be ground flush with the surface This note is to be added to all Base Metal after welding.
Repair Process Sheets, For full penetration welds where the SMAW process is used to deposit f
the root and is subsequently background or chipped to sound metal be ore 7.
m depositing weld metal on the second side, the cavity shall be checked
/
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REVISION DATE PAGE NUMBER CPSES I
JOB 35-1195 6
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REVISION DATE PAGE NUMBER CPSES JOB 35-1195 6
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REVISION DATE PAGE NUMBER CPSES JOB 35-1195 CP-CPM 6.9G 6
7/10/84 2 of 2 FIGURE 6.9G-2 MULTIPLE WELD DATA CARD (BACK)
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PROCEDURE NUMBER REVISION DATE PAGE J
CPSES JOB 35-1195 s
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7/10/84 1 of 1 FIGURE 6.9G-3 POST-WELD HEAT TREAIMENT CHECKLIST post wl.s w.at Tuanat ortnist Drawine i_
veld #
M ht,yl L f
- 1. Jef at Preparation _ pre-rien visual emastaatten empleted (if acceptable.
a.
sign WDC held point)I patet, dirt. grease. et1. and other
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C1enaltness (4:
4.
forefgs matter re eved fra heated arose)
Adessate f acelattes (required type thersel tasulattaa mia. of fear pipe diameters or 24 lar.has. whichever c.
is less. to each side of weld Jefat)
Protecties agafat internal draf ts (open ended pipe d.
capred,etc.) Thermocouple placement (placment as per prececuro)
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Temperetsro ricoretag tretrumentatten_ !ast. f Callbretten Date las t.i Calibretten Cate Yelve preparatten (valve la proper posittoa Gled 3
if necessary)
'**]*'
Date QC/!aspector 5tgnature
- 2. Meattae and Coettae Rates. Molefne Time and Temeerstvee (Verify acceptasoity oy esamining the FWNT Ghart) a.
Heating Rate
- b.
Cooling Rate
_F Temperature variation (between theruccouples not exceedtag 100*F) c.
4.
Malding time hours sinutes M
Melding temperature (dandeasrequiredly7tcable Weld Date Card) 4.
Mas the Ptsti chart been signed and dated by tae f.
operator and the Field Weld Techafcf ant Is the PWHT chart traceable to the applicable g.
Weld Data Card by drawing and meld numbers?
QC/ Inspector 5tgaature
- Oste
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Final visual esaminatten b.
Is the PWMT chart attached to the applicable weld c.
Osta CardT MT or PT of removal area for Class 1 and 2 components 4.
_ Oate OC/taspector Signature _.
All resalts will be answeed $4C (/). Umsat (I) not applicable (N/A)
Unsat answrs will require a close out la E:
unless otherwise noted.
the 'Cauments' sectica.
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7/10/%
I of I FIGURE 6.9G-4 i
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CP-CPM 6.9G 6
7/10/84 1 of 1
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FIGURE 6.9G-5 MANUFACrJRING RECORD SHEET (TYPICAL)
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CP-CPM 6.9G 6
7/10/84 1 of 1 FIGURE 6.9G-7 MATERIAL IDENTIFICATION LOG
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PROCEDURE EFFECTIVE CPSES NUMBER REVISION DATE PAGE
.,1 JOB 35-1195 CP-CPM 6.9G 6
7/10/84 1 of 5 SUPPLEMENT 6.951 OVERVIEW OF WELDING DOCUMENTATION REQUIREMENTS INITIATED PRIOR TO JULY 20, 1979
4.0 INTRODUCTION
This supplement defines requirements for weld documentation issued before the release of ICN 10 to CPCPM 6.9, Revision 0.
It shall be used in conjunction with Appendix 6.9G of this document. Obvious requirements for documentation completion have been omitted.
2.0 GENERAL
~~
2.1 A88REVIATIONS
~~~
~ ~ ~ ~ ~ ~ '
1.
CSWDC Component Support Weld Data Card 2.
RDF Resolution 'of Defect Form 3.
WDC(SW) Weld Data Card for Socket Welds
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4.
WDRC Weld Data Repair Card r ~~
2.2 TERMS /0EFINITIONS 1.
Component Support Weld Data Card A form used to document l
welds made on "NF" component supports.
i 2.
Resolution of Defect Form A form used to docuntent welded repairs made to base metal.
3.
Weld Data Card (Socket Weld) A form used to document socket or permanent attactinent welds.
4.
Weld Data Repair Card This document is the same as the Weld Data Card except the card shall delineate only those appli-cable requirements associated with the repair of a specific weld joint already controlled by a WDC.
3.0 DOCUMENTATION 3.1 DOCUMENTATION FOR ASME WELDING, FABRICATION / INSTALLATION ACTIVITIES 1.
A WDC (SW) for ASME welds are limited to socket welds and in-tegral attactment welds on. the same drawing, subassembly, and WPS, with a maximum of three welds per card. No more than one piping subassembly or isometric drawing (for field welds) shall be,representedperWDC(SW).
/
2.
The CSWDCs shall be issued for welding component supports and combined into the CSTP
-- 3 -- --
BROWN & ROOT, INC.
PROCEDURE EFFECTIVE CPSES NUMBER REVISION DATE PAGE JOB 35-1195 CP-CPM 6.9G 6
7/10/84 2 of 5 SUPPLEMENT 6.9G-1 3.
Routing of Documentation (ASME)
The WDC(s), RDF(s), and CSWDCs in CSTPs shall be controlled by the FWTC substations. A logging system shall be maintained indicating the status and the responsible group for all documentation. The CSTP(s) is logged and transmitted to the FWTC by WCC.
~
~~'
- 4..Upon completion of all work required by the documentatiott,_
the MtS(s), WDC(s), CSTP(s), and associated documentation shall be routed back to the WE. Upon receipt the FWTC shall review all weld documentation for completion If acceptable ~
~
~
the " Final Acceptance (WE)" block shall be signed and dated,
and ASME documentation transmitted to QC for review, approval
~
certification, and storage.
3.2 00CUMENTATION OF BOP WELDING, FABRI. CATION & INSTALL 5 TION ACTIVITIES 1.
The WDC (BOP) may be used to' document welding activities.
2.
The RDF may document repairs to weld joints or base metal requiring repair by welding for BOP piping and structu'ral items.
3.3 FIGURES 1.
Component Support Weld Data Card I
2.
Weld Data Card (Socket Welds) 3.
Weld Data Card c
l 4.
Weld Data Repair Card 5.
Resolution of Defects l
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PROCEDURE EFFECTIVE CPSES NUMBER REVISION DATE PAGE JOB 35-1195 CP-CPM 6.9G 6
7/10/84 3 of 5 SUPPLEMENT 6.9G-1 COMPONENT SUPPORT WELD DATA CARD
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7/10/84 4 of 5 SUPPLEMENT 6.9G-1 WELD DATA CARD
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PROCEDURE EFFECTIVE CPSES NUMBER REVISION DATE PAGE
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JOB 35-1195
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he acknowledged that he typed In our interview with the letter to Mr. Feehan, but he told us that he had not written the second sentence of letter Item 4, but had typed it-from a fold handwritten letter prepared by us he had no knowledge of C.P. welding being performed by uncertified people to " speed up" the job or for any other reason.
Both and isclaim responsibility for as no knowledge of sentence 2 of letter Item 4.
Therefore, based welding by uncertified en loyees, as noted herin.
we find no on o'ur interviews with basis for the concerns expressed in letter Item 4.
I have reviewed with Mr. Dodd the B&R management response to letter Item #4, I no longer have a concern about this item as contained in this memorandum.
based-on my review.
/
/(date)
Ritnessed 5.
Item 5 - Steam Generators "The main support steel on installation of a.
The letter states:
lagging on the steam generators was received on the jobsite with improper welding.
I reported this t my supervisor, and to Greg Brown, a mechanical engineer.
I was told that the problem had been solved by writing a letter to Westinghouse telling them to strive for better craftsmanship among their subcontractors.
The bad welds are still.in existance and have not been repaired.
We could by repaired them oursegs, as a backcharge to Westing-accepted the faulty supports, house, but thereby making Brown ag! ApctAesEs' le59 m-L /d7
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ew old us he identified a problem with welds on Westinghouse main support steel used for the installation of
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insulation lagging.
He said he uncovered the problem "in the sandblast yard during blasting."
said he was 1 coking at Westinghouse vendor material in the yard (prior to plant install-ation), and that welds on the material in question had pinholes and j
old us this was contrary to the no penetration.
w requirements of "the print" (drawing) for the vendor material, which he said called for full penetration welds, old us that he brought his concern td ttention, and that.
old him that the problem had bee
" sol v ed. "
ftated that he is still con-t.
cerned because he h'as seen no rework performed on the welds.
c.
Investication Results We asked and B&R equipnent engineer super-concern.
visor, whether they were familiar wit Even though it was not responsibility to install t
or inspect the welds in question, he did notice a potential problem old us that when he was and reported this to.-
infonned of' oncern J ent to the 1aydown yard to look at the welds.I greed that with engi ing should review the welds.
Within a day, took Ig'to the yard so that%ould perform an engineering
~~
Yeview.
who told us that he inspected the welds being We talked to-s aid the welds were furnished not questioned by by Westinghouse, but by Mirror Insulation Co.b said the welds
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18 were not safety-reTated and that therefore, QC inspections had
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not been required. Although@ greed that the welds were not of " top quality", his engineering judgment was that the welds would This perform their intended function and could be used as is.
explains why no rework has oeen performed on the welds.
Although disposition was not required to be docu-l mented, we asked him to prepare a memo confirmin thy engineering l
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review that was performed. Attachment 6 is a memo to and dated August 10, 1982, on this subject. The memo
- is gned b and by for The memo states that "aTthough Mechanical Engineering Supervisor.
the welds are not ' pretty' they are acceptable for this non-Q service." The memo also reflects that "the vendor has been cautioned regarding werkmanshid in the future."
Based on our investigation of letter Item 5, we are sat.isfied that original concern over the referenced welds was properly investigated and dispositioned by B&R site management and engineering personnel. We find no evidence that any safety procedures were violated, or that there is any basis for the concern expressed in letter Item 5.
As with all the other items addressed in this letter, management will carefully explain its finding to I
m I have reviewed with Mr. Dodd the B&R management response to letter item #5, as contained in this memorandum.
I no longer have a concern about this item, based on my review.,
W ~/5 8,2 cate)
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o AW a3, 60, 65, 73, AQW-77 DCP5 11/15/84 Oraft 7 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 3.
Characterization:
It is alleged (1) that there are defective welds on thestear,generatortopie,adi,ns,ula,Qonsupports;(2)thatexcessive grinding of weld surfaces has taken placer (3) that an unqualified 8
pipefitter fit and welded socket joints in one of the boron systems; (4) that circumferential butt welds were made in the fuel transfer
~
~~
tubes of Units 1 and 2 and that these welds had incomplet g 74 penetration; (5) that ant.1-vibrational straps attTchtti as supports to the auxiliary building 790-foot elevation heat exchanger tutfing-exhibited una'cceptable burn through of the welds; and, (6) that the
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' weld-dumbering. sequence on the weld data cards revealed dupl'icate wei4
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' numbers for the top and bottom strap. supports.
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4.
Assessment of Safety Significance-implied safety significance of 2
ese allegations is that various tyres of welding. deficiencies could l
cause piping failures untler l'eading nd the.interne1.s.cf-Wa heat exchanger could be_ damaged causing loss of operabitity of the l
w
,(,j
,{. : ~ [.
,c3 j t exchangers.
To assess the safety significance of these allegations the NRC f
Technical Review Team (TRT) reviewed codes, specifications, QC inspection reports, and other pertinent documents applicable to L
N 2-each of the several allegations to determine requirements.I The rest lution of each allegation is addressed. separately in the remainder.
~
s of this report.
To a'ssess the safety significance of allegation AW-60", the TRT testimony of the aileger and of Brown & Root (B&R) reviewed which was personnel and reviewed' vendor drawings and NRC M-82-001178, s
~
initiated by quality control,(QC).
The Tiff reviewed the vendor draMIgs for Mirror Insulation to determineiffullgenetrationweldjointswerecalledfor,asalleged.
The,TRT found that the drawings cal. led for fillet joints and partial
.4 n.
n penetration joints, but no full penetrgion jointsI.
~~
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s,
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k review of NCR M-82-01178 revealed that the following rejectable defects, per the requirements of American Welding Society (AWS) D1.T,
" Structural Wel, ding Code," were found on the welds of the insulation M
supports:
M are strikes o
undercut overlap i
weld spatter lack of fusion 9
~.'
These defects were reworked per the instructions from the repair 3
The NCR was closed process sheet (RPS) issued by. welding engineering.
')
on August 26, 1982.
The TRT reviewed the codes (AWS D1.1, ASPE III and VIII). applicable to allegation AW-84, and found nu requircrents that prohibit or encourage grinding of the weld surface. The TRT noted that grinding of the surface of the weld may be used to remove irregularities that 8
interfere with liquid penetrant, radiograph and ultrasonic inspection; to remove notches which could act as stress' risers; to remove. overlap e
and blend, undercut; and to enhance the surface for the application of
.. protect _ive coatings.
Since allegation AW 8 did not refer to a specific system", the TRT
~
selected several documentation packages from the boron recycl.e. system.
[
The TRT reviewed weld data cards and inspection reports, but found no evidencI of any rejectablg fitups o Elackof dentification of piping systems precludes meaningful evaluation of
~
this alle11ation.hp.the TRT.
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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 the external surface of the fuel
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transfertubebehindweldsjaand3c.
As identified in design change authoriaetion (DCA) 6560, Revision 3, weld 3a ghe penetration sleeve-to-expansion ' joint weld; weld 3c is the fuel transfer sleeve-to-expansion joint weld.
m The TRT found no circurferential butt welds in the fuel transfer tube.
This was in accordance with Westinghouse drawing 1209E53.
Note 7 of
~
this drawing states that "the tube ~shall be fabricated in one length..
~
without circumferential splice welds." The fuel transfer tube was
~
~
made 'from pl1te, brake press formed and longitudinally welded.
ge The alleger may have been referring to weld 3a, which was origjsally designedasacircumfere(ti,albuttweld,butwasmodifiedtousea
~
wager type ring to' accommodate diametral mismatch.between the
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penetr~ation sleeve and the expansion joint mating parts.
DCA 6560,
~
revision 2, pages 3 and 5 shows the modified joint designs for Units 1
~
l and 2.
These joints, however, would not affect the fuel transfer tube in the manner alleged.
.Tiw TRT noted that the expansion joint assembly contalis'.O.024-inch
- < e.-Aw thick byti
- lapweldsjoigingtheendmemberstothebel-
- V 4he cross-sectional area of these joints is sigr.ificantly less than the i
I approximately 1/2-inch thick welds that join the expansion joint i
assembly to either the penetration sleeve or the fuel transfer tube.
During a visual examination, the TRT observed that the expansion joint
5 e
s assemblies a't the containment building end of both fuel transfer tubes t
contained ddris and dirt. One assembly had :. (. ;,per sander and a
~
" throw-away" paint brush lying on the bellows convolutions and a second flapper sander lying on the near bellows end fitting.
Dirt was a
piled.up against the weld 3a spacer.
The other assembly had a rag and a piece,of pipe about 2-injh;1cng lying in the near bellows end
. fitting.
There was also some dirt against the weld 3a spacer.,
The TRT reviewed allegation AQW-77 an'd the August 8 and 23, 1984, transcript of the alleger in an atterpt to identify the heat ex, changer in question.
The TRT inspected the immediate loca. tion speci.fied by'
.a the alleger and found th,at.fo, $ at exchangers were located just outsidethe5u ary bubding in Rooms 68 and 69 on the 790-foot e
elevation of the Unit 1 Safeguards Building.
The TRT identifice tb g,,,
heat exchangers residual heat removal (RHR) heat exchangers (fiX) TBX-RHAHRS-1 and TBX-RHAHRS-2 and the containment spray (CT) HX (CP1-CTAHCS-1 and CP1-CTAHCS-2). The TRT reviewed the manufacturer's
~
~
drawings (Joseph Oat orporation) and found that the RHR HX p re' T _.
purchased by Westi[ghouse Corporation and the anti,-vibration ;tYaps
~
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.h were a ven' dor-supplied item.
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The TRT interviewed Westinghouse personnel and learned that the strap supports for the tubing were added by the manufacturer to correct an unacceptab3etubingvibrationconditiondetectedatsomeother location.
The TRT searched the nonconformance report (NCR) records
~
. for the two RHR HXs and found no NCRs issued to modify or add anti-vibration straps. Based upon these facts, the TRT eliminated the RHR HXs from consideration for the allegation.
A further search of the NCR records yielded NCR numbers M-5102S and N-51035 for the CT HXs, both issued on the same day and both containing conconforming conditions very similar to those described by,
~
the alleger. The TRT determined that NCR S-51035 was reported by the' s
alleger; however, part 2 of.the NCR indicates a condition different from the allegation specified on page 52 of the August 8,1984, interview. The NCR specified that only idne welds were made, but the
~
WDC indicates that ten welds were required.
The allegation stipulated that there were duplicate weld numbers on the top and botton strap supports. The TRT could find no evidgnce that duplicate. weld numbers
....a.
. a....
were used or that more than one set of strap supports were required.
Both Texas Utilities Electric Company (TVEC) and cognizant personnel from Joseph Oat Corporation were contacted, and confirme,d.that only_
one set of strap supports, located at t,he top',b d,of the tube bundle for each HX, was required by the modification.
~
Since.t,he NCR was initiated by the alleger when he inspefted the welding,thesecondpartoft*eallegation)whichwasallegedduring the August 8 and 23, 1984 interviews 7accearedta be an error.
On September 20, 1984, the TRT contacted the alleger, who confirmed that the nonconforming corditions listed on the NCf( were correct.
Further
a eem
. examination of the NCR package revealed that DCA 16462 was written to The TRT discussed the explain the discrepancy in the weld numbers.
~
i ii
.DCA with B&R QA and. Welding Engineering and found that-the d spos t on was satisfactory.
The TRT reviewed the traveler package for each NCR and found the following discrepancies.
For NCR M-51035:
(1) the traveler was starrped with the statement " Work requires TUGC0 operations to process an ASME Code
=
i NIS-2 Form," and no fonn was completed; (2) CP-CPM-6.9G requited that the' Authorized Nuclear Inspector (ANI) initial the Weld Data Card (WDC) to indicate whether a hold point was required, and there was no
~
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evidence of the ANI's initials on the WDC; and,(130'I-QAi-11 26 required B&R QC to complete a visual examination, and no evidence of
~
,~=a.s g such an examination was found.
Thesamediscrepgiesaside'itified
~
The TRT found f
in (1) and (2) also were iden,tified in NCR M-S-1025.
~
~
i evidence of a completed visual inspection checklist for 7his NCR.
~
~
The TRT interviewed two B&R QA employees to determine whether the CT s
l H)Lyodification required an ANI review. Both QA employees said that
~
~
the statement requiring an NIS-2 form to W completed was a mista'k'e l
.a. -.
1 and that the form was not required since t1ie weld'iTg was not to the,
. e,
~.
Both of these empl'oyees also recalled dH" cussing pressure boundary.
this problem with TUEC Operation and Maintc-ance (0&M) engineering at the time of the modification.
They indicated ht ogthe best of their recollection O&M agreed with their positioh, but they could not
. explain why the paperwork had not been changed, nor could they document that the discussion had taken place The TRT interviewed the O&M,engi~eer who, at the time of the modification, wg tie' TUEC $A
~
~~
inspector indicated on the NCR disposition. He confirmed that the NIS-2 form should not have been requi, red (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 fonn should be in the fabrication package in the QA vault. A review of these records did not produce the missing checklist.
FurtherdiscussionswithB&R0jrevealed,thatthe, manufacturer's r.epresentative from Jeseph Dit'L E lad inspecti!d the
~
weld bbrn-through and had lccepted it for the intended service. This was confirmed in a Telex (February 2,1983), which was the basis for the dispositioning of part (1) of the NCR. The TRT contacted the
~
Joseph Oat Corp. representative identified in the Telex. He confirmed thathehadpersonallyinspectedbothoftheCTHXsforthepurn-p through condition on the anti-vibration straps.
After'hhecking his notes and files on these items, the manufacturer's inspector indicated that.Ms i'nspection had revealid'no damage to th.e HX tugi;r[g and that the welding on the straps was adequate for the intended service. The TRT then talked to the QC inspector who had signed off the "QC
9-Verification" block on both of the NCRs. He indicated that he had completed the visual examination checHist on NCR M-52025, which he,
co-authored; however, he could.not remember corpleting a similar The 7
checklist for the NCR initiated by the alleger (NCR M-52035).
~
inspector also indicated that the individual who signed the "QC Verification" block nr the NCR was only ensuring that the proper paperwork was completed, and that he could have interpreted the a
manufacturer's represdhgive inspection as meeting the requirements for NCR M-52035.
~
. The TRT then interviewed Welding Engineering and Civil / Mechanical
= =r" g
Engineering per,sonnel to determine whe,ther an ANI inspection was
~
All individuals _ contacted required on the CT HX tubing modification.
stated that since no welding to the pressure boundary done, no ANI inspection was required. Welding Engineering referred to procedure s
CP-QAP-2.4 which governed the repair or alteration of ASME N-stamped
.?
componenti - This procedure is currenti fis voided,-but was in effect % -
. f.ar durin'gthemodificationinJanuary/ february.19[I., Paragraph 6.4;lof s
cedure thJs procedure required the "($ner to assure hat the repair p 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 burn-The ANI also stated that no through weld condition on the straps.
welding was.perforined on the pressure boundary, but he could not state that the byrn-through condition on the straps had oamaged the thin-wall tubing. According'to the ANI, QA, O&M, and Civil / Structural
~
Engineering, the~ type of modifications made did not require a rehydro b~
of the urrit.
~
- 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 partial penetration welds, not full penetration welds. However, there were other defects present that were rejectable per requirements. of
~
.c h
Priorto) 4-}PQ
, y.,r%.1 AWS D.1.l ted tiiEeTefects were repaired on NCR M -..
.J
?
?.
_1,
A. D'^
, MoIk'engTnskr~iiig~Ta'faccepted, _the, welds "as is.'E Accordingly, this allegation has neither safety significance nor generic implications.
-s _
~ e..:*
j h
The TRT concludes that the allegation of excessive grinding of weld The surfaces (AW-84)~ is substantiated, but has no technical merit.
various codes, standards, and specifications that are in force at Comanche Peak Steam Electric Station neither prohibit nor require l
grinding of the weld surface. Accardingly,,the allegation has neither safety significance nor generic implications.
The TRT could not substantiate the allegation related to weld data cards (AW-43)'. The. weld data cards and drawings reviewed were in
~ ~ -
order and the weld data cards had been signed off by cuality control
(
l l
t
v O
as being acceptable.' The TRT concludes that this allegation has
~
~
neither safety significance nor generic impliqations.
In visual examination of.the Unit I fuel transfer tube, the TRT found no circumferential welds as alleged (AW-65). The tube was fabricat,ed as required by Westinghouse drawing 1209E53, Note 7.
The allegation
~
~~
was, therefore, not substantiated.
It is the TRT's opin-ion that the, s
alleger may actually have meant to refer to one or mo,re of the modified butt welds between the penetration sleeves and the several expansion joint assemblies The two such welds examine,d, whil not
~ full penetration welds, were otherwise visually sound and of a cross-sectional area which would cause any weld failure to be in a
~
~
. ira bellows-to-bellows end fitting weld.
In either case, th f
concludes that this allegation has neith,er g fety significance no'r
~
generic implica'tions.
- The TRT was able to determine that a Q,sual inspection was performed
~
~~
s on the we ng modification of ch. FX. but e e' ve :-tccre CT HX, which was the one initially'of concern to the al, leger'.(AQW-fd. The
~~
..e QC inspector who completed the visual examinatier cFecklist on one of the HXs could not explain why there was no co19sTeted checklist on the other HX.
Concernirg the lack of ANI review on both of the HX
e s
modifications, the TRT obtained conflicting explanations from all individuals interviewed when compared to pr'ocedure CP-QAP-2,4, which requires ANI involvenent and which Welding Engineering said was in effect at the time.
~
~
s
=
The TRT concludes'that the allegation that the CT HX which was
. initially written-on an NCR by the alleger had not been properly inspected by B&R QC personnel is subs,tantiated. The WDC indicates-that the first nine welds were satisfactorily inspected by the allegeryhe rematning nine welds were initially acgepjed by the Firtherslocumentation
~
a],1eger who subsequently r_emoved his signature.
~
on the WDC reveals that B&R QC accepted these wM ds-based on the
.-s-This manu.fa.cturer's inspection and with no further 86R 'ipspectipns.
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 safety significance,.since the welds were inspec,ted and approved by the ma6ufacturer's representati.ve, nor does it have generit-
~
implications.
6.
Actions Required:
AW-60 None.
AW-84 None.
AW-43 None.
t m
?
. i I
~
i
~
TUEC shall address the lack of cleanliness of the f
AW-65,
m 6
expansion joint assemblies observed by the TRT.
~
1
. TUEC shall (1) determine whetiier'the ANI review was t
AQW-77 required for this modification and state which procedures are the basis for this response; (2) correct the travelers which indicate that the form was required if ths' Mk '
NIS-2 form was not required for the mod 4f4+ation; and, (3) '
s/
_, provide justification for permitting a manufacturer's 1-
'((
inspection to be substi4uted for a required B&R QC -
g.
inspection.
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8.
Attachments:
None.
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3 DCP5 AW-43, 60, 65, 73, AQW-77
/
Draft 9 - 1/29/85 d
SSER 1.
Allegation Group: Mechanical and Piping Category No. 45, Miscellaneous Welding Def.iciencies N
D d w f, r
2.
Allegation Numbers:
AW-60, AW-84, AW-43, AW-65 and AQW-77 q
u)64 bog e. d 4e A@ Q w, s+
'ds &
3.
Characterization:
It is allegeQ1) that ?re mW#etivy.:dds on i V' the steam generator top head insulation supports [(AW-60); (2) thatu., :.
1 j,y 8
.1 1
.s..
excessive grinding of weld surfaces has taken place (AW-84); (3) that
'"f -
an unqualified pipefitter fit and welded socket joints in one of the boron systems (AW-43); (4) that circumferential butt welds were made in the fuel transfe 'tNs#of Un s 1 and 2 and that these welds had incomplete penetrat 5 (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 l
Technical Review Team (TRT) reviewed codes, specifications, quality control (QC) inspection reports, and other pertinent documents F01A-85-59 L./ 8
Ce 1 applicable to each of the several allegations to determine The resolution of each allegation is addressed requirements.
separately in the remainder of this report, gN-To assess the safety s'ignificance of allegation AW-60, the TRT testimony of the alleger and of Brown & Root (B&R) 1 reviewed (NCR) personnel and reviewed vendor drawings and nonconformance gW which was initiated by QC.
' 'fi, L _ s % n *'\\
Y*-
M-82-01178, y
y-s.- 3p t <T'p'l^%.f.3" s.N -
% gt The TRT reviewed the vendor drawings for$Trror Insulation to o
~
A determineif_fullpen'eirationweldjointswerecalledfor,asalleged.'
The TRT found that the drawings called for fillet joints and part N
penetration joints, but no full penetration joints.
\\' g
-j
' (s revealed that the following rejectable e;;7 7,i.. A review of NCR M-82-01178.
Ppg. N defects, per the requirements of American Welding Society (AW g$'
" Structural Welding Code," were found on the welds of the insu
.o g.
supports:
y"-
d. y, 4.
x y _, -
arc strikes
<1 y
undercut 3
Q.-
overlap weld spatter 1ack of fusion
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& pcA&g.95 0W(
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,. ?[hese defects were reworked per the instructions from the repair The NCR was closed racess sheet (RPS) issued by welding engineering.
7[.
on August 26, 1982.
The TRT is preparing a summary of its findings on allegation AW-60 to forward to the alleger, who declined an interview.
--g
/4'i~t e*.
ThaTRL..k.;;fhWSD1.1andtheAmericanSocietyofMechanical Engineers (ASME) Boiler and Pressure Vessel Code (B&PV), Sections II
,....._ no requirements [ )',
2go-o,gilgogff"{
' and VIII a ca 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
\\
'}. '"
irregularities that interfere with liquid penetrant, radiograph and
- " F ultrasonic inspectioM, to remove notches which could act as stress risers; to remove overlap and blend undercut; and to enhance the surface for the application of protective coatings.
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- t. f g Attempts to contact the alleger to review with him the TRT's findings Q.,
- g g
on allegation AW-84 have been unsuccessful.
Ay'e tl.__.
s l(\\y/,,\\s Since allegation AW-43 did not refer to a specific system, the TRT j/
./fselected several documentation packagedrom the boron recycle system g, u de
/ f S
u.'
e,, s z p w p<>
l 6# 4 esse <f no
,7Q t
f
... tot aviewed. weld data cards and inspection repor s, Lg Q l
evidence of any rejectable fitups or welds, " 'i /4 "C
)
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Tlf,TheallegerofallegationAW-43isunknown.
,Y
~
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2 M/5 a
h 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 the external surface of the fuel Wbn M W D f % W W W ^ d"O transfer tube behind welds 3a and 3c. As identified in design change v A N A
s...% h n g authorization (DCA) 6560, Revision 3, weld 3a is the penetration A 3,. M..,I sleeve-to-expansion joint weld; weld 3c is the fuel transfer
{,'
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sleeve-to-expansion joint weld.
h ' ' ' r OA The TRT found no circumferential butt welds in the fuel transfer tube.
This was in accordance with Westinghouse drawing 1209E53. Note 7 of this drawing states that "the tube shall be fabricated in one length e withoutcircumferentialsplicewelds.]The/uel
[ansfer ube sT f
madff, rom lafe,br[kepres formed /and engitu inally, elde.
S. ' (( -
Thealleg'erbyhavebeen.referFitytay,1d3ar1ihNwasoriginally y
~
designed as a circumferential butt weld, but was modified to use a
-5
?
washer type ring to acconinodate diametral inism(atch between the
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,1
- t., a. x..,
]_,.
penetration sleeve and the expansion joint mating parts., DCA 6560, y[.,
revision 2, pages 3 and 5 shows the modified joint designs for Units 1CQ w
and 2..JThese joints, hcwever, would not affect the fuel transfer tube j
/
E lIinthemanneralleged.
d., Ts b C h., e e -
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a.. %. % ~~. v w. cc. A ? h D'n 1
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TheTRTnotedthattheganionjointassem6TyNontains0.024-inchs c_1,eg) t
.,..e t a :%
h e,
~
thickbuttlapweldsjo_iningtheendmemberstothebeflows._
The-
/" cross-sectional area of these joints is significantly less than the bi 4
approximately 1/2-inch thick welds that join the expansion joint SS' assembly to either the penetration sleeve or the fuel transfer tube.
During a visual examination, the TRT observed that the expansion joint
.,/ assemblies at the containment building end of both fuel transfer tubes
,i f j contained debris and dirt. One assembly had a flappes sander and a
}
" throw-away" paint brush lying on the bellows convolutions and a
-f, -
\\
l second flapper sander lying on the near bellows end fitting. Dirt was
[,.e piled up aga' inst the weld 3a spacer. The other assembly *had a rag and
- r. -
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.
bb-r The TRT reviewed allegation AQW-77 and the August 8 and 23, 1984, b W.i.
{transcriptsof the al_ leger /in an attempt to identify the heat exchanger in question. The TRT inspected the immediate location.specified by j
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 exchangers HX CP1-CTAHCS-1 and CP1-CTAHCS-2. The TRT reviewed the t Corporation)dd":
A \\ c io *-~
9 W
. Bl_ _t F and found that the manufactureMs drawings Joseph RHR HXs were purchased by Westinghouse Corporation and the g
anti-vibration straps were a vendor-supplied it (g g:5 m%\\ J'^EW -
gggg.
The TRT interviewed Westinghouse personnel and learned that the strap supports for the tubing were added by the manufacturer to correct an
/
unacceptabptubingvibrationconditiondetectedatsomeother locatiok'The TRT searched the nonconfonnance report (NCR) records kia yw.
g jh6..a:4L N d.r cW,k i s
,, AL w~k w/m fo c4.
6-
~ _.--
.,J.
'for the te RHR HXs and found no NCRs,' issued to modify or add h
. as -
- Tr.\\ ~ ~'
anti-vibration straps. Based upon these facts, the TRT eliminated the
,, kc. =
RHR HXs from consideration for the allegation.
m,, e i
.I A further search of the NCR records yielded NCR numbers M-5102S and M-51035 for the CT HXs, both issued on the same day and both containing nonconforming conditions very similar to those described by the alleger. The TRT determined that NCR M-51035 was reported by the o
alleger; however, part 2 of the NCR indicates a condition different WW A
\\o from the aillegation specNied dn~page ~52 ~of the~Auifust 8 T984]
~
q e
/
interview. The NCR specified that only nine welds were made, but the t,*
n,,' '
weld data card (WDC) indicates that ten welds were required. The allegation stipulated that there were duplicate weld numbers on the
?
top and bottom strap supports. TheTRTcouldfin(
that duplicate weld nuinbers jwere used or that more than one set of strap i
supports were required. Both Texas Utilities Electric Company (TUEC) and cognizant personnelIrom Joseph Oat Corporation were contacted, I
and confirmed that only one set of strap supports, located at the t'op bend of the tube bundle for each HX, was required by the modification.
'\\O AacL N Ny SincejeNCRwasinitiatedbytheallegerwhenheinspectedthe N
welding, the second part of.the allegation which was alleged during
\\
/
the August 8 and 23, 1984, interviews appeared to be an error.
Oh September 20,1984, the TRT contacted the alleger, who confirmed that the nonconfonning conditions listed on the NCR were correct.
Furt,ber
\\
examination of t4h NCR package revealed that DCA 16462 was written to f
.g._ _ _ _ _ _ _ _ _ _. _.
, e The TRT discussed the explaio.t_he discrepancy in the weld numb' rs.
DCA with B&R QA and Welding Engineering and found that the disposition l
was satisfactory.
The TRT reviewed the traveler package for each NCR and found the following i
discrepancies.
For NCR M-5103S:
(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 examination The same discrepancies as identified in (1) and (2) also was found.
were identified in NCR M-51025. The TRT found evidence of a completed visual inspection checklist for this NCR.
The TRT interviewed two B&R QA employees to determine whether the CT HX modification required an ANI review. Both QA employees said that the statement requiring an NIS[2 form to be completed was a mistake and that the form 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 indicated that to the best of their recollection O&M agreed with their position, but they could not
~
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 form 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.
s 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 form should be in the fabrication package in the QA 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 This weld burn-through and had accepted it for the intended service.
was confirmed in a Telex (February 2, 1983), which was the basis for the dispositioning of part (1) of the NCR. The TRT contacted the I
He confirmed Joseph Oat Corp. representative identified in the Telex.
that he had personally inspected both of the CT HXs for the burn-After checking his through condition on the anti-vibration straps.
notes and files on these items, the manufacturer's inspector indicated that his inspection had revealed no damage to the HX tubing and that The the welding on.the straps was adequate for the intended service.
TRT then talked to the QC inspector who had signed off the "QC l
l
I 1
9-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 (NCR 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-51035.
The TRT then interviewed Welding Engineering and Civil / Mechanical Engineering personnel to determine whether an ANI inspection was All individuals contacted required on the CT HX tubing modification.
stated that since no welding had been done to the pressure boundary, no ANI inspec' tion was required. Welding Engineering referred to procedure CP-QAP-2.4 which governed the repair or alteration of ASME 6
This procedure currently is voided, but was in N-stamped components.
effect during the modification in January / February 1983.
Paragraph 6.4.1 of this procedure required the " Owner 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 The ANI also stated that no burnthrough weld condition on the straps.
i
. 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. According 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 partial penetration welds, not full penetration welds. However, there wer'e other defects present that were rejectable per requirements of AWS D.1.1.
These defects'were repaired by B&R on NCR M-82-01178.
Accordingly, this allegation has neither safety significance nor generic implications.
- i.' L
-Q, ihN
/
The TRT concludes that the allegation excessivegr)nd'ingofweld
.w The surfaces (AW-84)(is, substantiated pet has no technical merit.
various codes, standards, and specifications that are in force at Comanche Peak Steam Electric Station neither prohibit nor require grinding of the weld surface. Accordingly, the allegation has neither safety significance nor generic implications.
The TRT could not substantiate the allegation related to weld data a
. 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
'kd'bdtweldsbetweenthepenetrationsleevesandtheseveral
-,f M --
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% a o m*..: % u m A s v w d
- ~4 % cce W
expansion joint assemblies.^ The two such welds examined, while not
%sk g full penetration welds, were otherwise visually sound and of a.
cross-sectional area which would cause any failure to be in the bellows or in a bellows-to-bellows end fitting weld.
In either case, the TRT concludes that this allegation has neither safety significance nor generic implications.
/
The TRT was able to determine that a visual,/ inspection was performed l
on the welding modification of one CT HX,/but not on the second CT HX, i
l which was the one initially of concern to the alleger (AQW-77). The 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 l
I I
i
, /
modifications, the TRT obtained conflicting e,xplanations from all individuals interviewed when compared to procedure CP-QAP-2.4, which requires ANI involvement and which Welding Engineering said was in effect at the time.
The TRT concludes that the allegation that the CT HX which was initially written on an NCR by the alleger had no't been properly inspected by B&R QC personnel is substantiated _. The WDC indicates that the first nine welds were satisfactorily' inspected by the alleger; the remaining nine welds were initially accepted by the alleger who subsequently removed his signature.
Further documentation, on the WDC reveals that B&R QC accepted these welds based on the manufacturer's inspection and with no further B&R inspections. This 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 j
saf'ety significance, since the wel,ds were inspected and approved by the manufacturer's representative', nor does it have generic s
implications.
6.
Actions Required:
None 7.x
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Attachments:
None.
l 1
4
. 9.
Reference Documents:
AW-60
- A 1.
NRC M-82-01178.
2.
Drawing Mirror Insulation 590159-232C.
3.
AW 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.
3 15 -
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."
AQW-77 e
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.
DailyinspectionrecordsonthekNIforJanuary 20-22, 1983.
4.
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 HE83-1012-4800.
f 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 representative on September 20, 1984.
l
. 10. This statement prepared by:
D. Hansen, Date TRT Technical Reviewer Reviewed by:
L. Shao, Date Group Leader Approved by:
s V. Noonan.
Date Project Director l
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AQW-77 1.
Reviewed with minor comment noted below.
2.
Acronyms should be explained.
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SSEP Add to Mechanical and Piping Category tio. 45 -
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Allegation Group:
Miscellaneous Welding Deficiencies 2.
Allegation number:
A0W-77 It is alleged that (1) anti-vibrational straps attached 3.
Characterization:
as supports to the auxiliary building 790 elevation heat exchanger tubing exhibited unacceptable burn through of the welds; and (2) the weld numbering sequence on the weld data cards revealed duplicate weld numbers An NCR was written by the alleger, for the top and bottom strap supports.
This allegation implies safety significance.
but was never dispositioned.
The NRC Technical Review Team (TRT; 4.
Assessment of safety significance:
transcript of tne reviewed the allegation and the August 8 and 23, 1984 The TRT inspected alleger in an attempt to identify the heat exchanger.
the immediate ' location specified by the alleger and found four heat exchangers located just outside the auxiliary building in Roces 68 and 69 These heat exchar.gers on elevation'790 of the Unit 1 Safeguards Building.
were identified as Residual Heat Renoval (RHR) Heat Exchangers (HX) TEX-RHAHRS-1 and T8X-RHAHRS-2, and Containment Spray (CT) HX CP1-CTAHCS-1 ar.c The TRT reviewed the manufacturer's drawings, Joseph Oat CT1-CTAHCS-2.
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Corpcration, and f ourd that the RilR bX's were purchased by Westi'rgm.t. -
Corporation ar.d the anti-vibration straps were a vendor supplied iter The TRT interviewed Westinghouse personnel and was toic tha-the RHP.HX.
to the best c# their recollection, the strap sbpports for the tubing w(<e acded by the manufacturer to correct an unacceptable tubing vibration condition detected at 'some other location.
The TRT searched the NC~
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records for the two RHR HX's a'nd found no NCR's issued to modify or aad Baseduponthesefacts,theTR.Teliminate9the the anti-vibration straps.
o RHR HX's from consideration for the allegation.
A further search of the NCR records yielded NCR numbers M-51CES and M-5103S for the CT HX's, both issued on the same, day and containing nonconforming conditions very similar to those described by the alleger.
NCR M-5103S was r,eported by the alleger, however, part (2) of the NCR indicates a condition different from the allegation specified on page 52 i
of the August 8, 1984 interview. The NCR specified that only nine welds i
The were made while the WDC indicates that 10 welds were requirec.
allegation stipulated that there were duplicate welo numbers on the top The TRT could find no evidence that duplicate and bottom strap supports.
weld numbers were used or that more than.one set of strap supports were l
Both TUEC and Joseph Oat cognizant personnel were contacted anc required.
confirmed that only one set of strap supports located at the top bend cf Since the the tube bundle for each HX was required by the modification.
of the i
NCR was initiated by the alleger at the time of his inspectice i
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wr loing..th'e TP.T $clieved that the. second ~part of tre allegati;'
-m the August 8 and 23, 1984 interviews was in errnr.
The TRT cor. tac *.a' "t
oileger 'on September 20, 1984 and he confirmed that the nonctnforrice conditions listec on'the NCR were correct.
F'urther examination c the *:
packagerevealedthatDCA'1646fhadbeenwrittentoexplainthe discrepancy in the weld numbers. The TRT discussed the DCA with ELFCA and Welding Engineering and 'f'ound,the disposition to be 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 the statement " Work requires TUGC0 operations to process an ASME Code I,;5-2 Form," and no form was completed; (2),CP-CPM-6.9G required that the
/Mf WA be Authorized Nuclear Inspector (ANI) ;st;t;pc the Weld Data C'ard (WDC) to indicate whether a hold point is required.
No evidence was found of the 1-ANI's initials 4on the WDC; (3) no evidence could be found that Sr; -
detre (B&R} Q.C. completed a visual examinaticn as requireo by 01-QAP-11.1-26.
For NCR M-51025 the same discrepanices as icentified in of (1) and (2) above existed.
Evidence was found <we a completed visual e
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inspection checklist.
1 The TRT intervi'ewed two individuals from B&R QA to determine whether the ssia CT HX modification required ANI review.
Both QA personnel 54++ed that the s
SD+rfm/wf~-st;. 9-- recu1r1ng the NIS-2 form to be completed was a m1 stake anc the form ii Both was not reqeired since the welding was not to the pressure boundary.
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t_;.n 77t9 f t B&R QA personnel interviewed recalled discussing this pretler,witt Operation and Maintenance (0&M) engineering at the time of the modification. They indicated to the best of their recollection that 0&"
agreed with their position, but could not explain why the paperwork bac not been changed or could they document by means of a letter or neero tna:
the discussion had taken place. The TRT interviewed the O&M engineer who, atthetimeofthemodification,wastheTUGC0QA'inspectorasindicated on the NCR disposition. He confirmed that the NIS-2 form should not have been required as stamped on the traveler, but he also could not provide e
any documented conversations with B&R QA to this effect.
Both B&R QA personnel also indicated that the visual inspection checklist should have been completed and that the original of the form should be in the fabrication package in the QA 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 in'spected the weld burn through and had accepted them for the intended This was confirmed in a Telex dated February 2, 1983 which was service.
The TRT the basis for the dispositioning of'part (1) of the NCR.
contacted the manufacturer's representative at Joseph Oat Corp. iaentified in the Telex and he confirmed that he had personally inspected both of the The CT HX's for the burn through condition on~the anti-vibration strggs.
. manufacturer's inspector indicated to the TRT that after checking his notes and files on these items that his inspection had revealed no camage
-b-to the HX tubing and that the welding on the straps was adequate 'ne in.
intended service.
The TRT then talked to the QC i.nspector who hao sigt r off the "Q.C. Verification" block on both of the NCR's.
He indicated t*r*
on NCR M-52025, which he co-authored, he had completed the visual examination checklist, however, he could not remember completing a sini:ci checklist for NCR M-52035 initiated by the alleger. He indicated that *.re individual who signed t'he "QC Verif'ication" block on the NCR was only assuring that the proper paperwork was completed.
He said that he could a
have interpreted the manufacturer's representative inspection as meeting t%-slo 3 S.
the requirements for NCR "C 2055.
The TRT, at this point, interviewed Welding Engineering and, Civil-Mechanical Engineering to determine whether an ANI inspection was required on the CT HX tubing modification.
All individuals contacted reiterated that, since no welding had been done to the pressure bounday, no ANI participation was required.
Welding Engineering made reference to CP-QAP-2.4 which governed the repair or alteration of ASME N-stamped components which currently is a voided procedure, but which was in effec't during the modification in Jan./Fe6. 1983.
Paragraph 6.4.1 of this procedure required the "... Owner to assure that the repair procedure is acceptable to the Owner's ANI, and for review by the ANI for assignment of The TRT conversed with the ANI assigned at the time of the hold points."
mediciations. He indicated that he was present during the modifications but he did not personally inspect the burn through weld condition on the straps.
He also said that no welding was performed on the pressure
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bcondary, but he could not assure that the burn through conditicr u to-straps had damaged the thin-wall tubing.
According to the At::, OA, OU' anc Civil-Structural Engineering, a rehydro of the unit was cr'. reccirec by the type of modifications made.
5.
Conclusion and staff po'sitions: The TRT was able to determine that a visual inspection was perhormed en the welding modification of one of the HX's but not on the second CT HX, which was the one initially of concern W.sv4 8-to the alleger.
The QC inspector who completed the u;;;Pexaminatior yo comstrfs carmisr checklist on one of the HX's could not explain why there was et c^e or g
the other HX.
Concerning the lack of ANI review on both of the HX modifications, the TRT obtained conflicting explanations from all individuals interviewed when compared to CP-QAP-2.4 which requires Af,I involvement and which procedure Welding Engineering said was in effect at the time.
The TRT concludes that the allegation that the CT HX initially written on an NCR by the alleger had not been properly inspected by B&P Q.C. is substantiated.
The WDC indicates that the first nine welds were satisfactorily inspected by the alleger and the remaining nine welds were initially accepted by the alleger but he subsequently removed his signature.
Further documentation on the WDC reveals that B&R C.C.
accepted these welds based on the manufacturer's inspection and no further B&R inspections.
This allegation indicates a violation of precedures fcr failure to visually examine the identified welds by B&R Q.C. as incicated l
H by operator No. 4 on the WDC.
There is no safety significance, since tne
welct were inspected and approved by the rariufacturer's represcrtative.
The vic:lation pertains to 10 CFR 50 App. B., Article XVII - Quality Assurance and CPSES FSAR Article 17.
Since there is confusior, concerning the AP I involven:ent in this situation, the TRT requires furthe r action.
This allegation has no gereric implications.
6.
Actions Recuired:
The Tid requires the applicant to'(1) determine whether the Af;I review was required for this modification and state which a
procedures are the basis for this response; (2) if the f;IS-2 form was not required for the modification, correct the travelers which indicate that the form was required; and (3) provide justification which allows a manufacturer's inspection to'be substituted for a required B&R Q.C.
inspection.
8.
Attachments:
fione 9.
Reference docuinents:
(1)
Interviews with the alleger on August 8 and August 23,19S4
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(2)
Telephone conversation with the alleger on September 20, 1964 (3)
Results of eddy current tests on the CT HX's dated ficvember 4,
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(4)
Daily inspection records on the At;I for January 20-22, 1983.
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(5) Ahl interface instructions No. MEI-028 (6) NCR's M-51025 and M-51035 dated January 23, 1983.
(7) Travelcr packages ME83-1010-4800 and MEB3-1012-4800.
(2) B&R procedures CP-QAP-2.4, CP-CPM-6.96, 01-0AP-11.1-26, CP-QAP '.F.6.
(9) Joseph Oat drawings No. 5776, C-7420, 5773.
(10) Telephone conversation with Joseph Oat manufacturer's representative on September 20,1084.
s 10.
This statement prepared by:
Name Date Reviewed by:
Group Leader Date Approved by:
Project Director Date O
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.i APPENDIX B U.S. NUCLEAR REGULATORY COPfiISSION REGION IV Report:
50-445/82-11 & 50-446/82-10 Dockets:
50-445 & 50-446 Category: A2 Licensee:
Texas Utilities Generating Company 2001 Bryan Tower
, Dallas, Texas 75201 Faciiity Name: Comanche Peak, Units 1 and 2 Inspection At: Comanche Peak Steam Electric Station, Glen Rose, Texas Inspection Conducted:
April through September 1982 M
/2-3*fL-i Inspector:
R. G. Taylor, Senior Resident Inspector -
Da e 8
Construction (SRIC)
M
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Approved:
T. F. Westerman, Chief, Reactor Project Section A Date Insoection Sumary Insoection Conducted Durine the Period Acril throuch Sectember 1982 (NRC Reoort 50-445/82-11)
Areas Inspected:
Routine and special inspection, announced, by the Senior Inspector (Construction) including facility tours, as-built pipe and support program, investigation of allegations, and participation in ~ASLB hearing.
The inspection involved 94 inspect:,r-hours onsite and 510 hours0.0059 days <br />0.142 hours <br />8.43254e-4 weeks <br />1.94055e-4 months <br /> on ASLB by one NRC inspector.
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l Results:
Within the areas inspected, two violations were identified:
(1) failure to inspect installation of seismic shims in polar crane brackets, and (2) failure to properly train and indoctrinate QC personnel.
Inspection Conducted buring the Period A'pril through September 1982 (NRC Report 50 446/82-10)
Areas Inspected: Routine, announced insoection by the Senior Resident i
Inspector (Construction) consisting of plant tours. The inspection involved 35 inspector-hours by one NRC ingpe,ctor.
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Results : Within the areas inspected, no violations or deviations were identified.
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14 "I have recei ted 175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br /> of Page 4848, lines-12 through 17:This item was discussed with Mr. Taylo 1.
This is a training inspector at Comanche Peak, in our meeting.
documentation falsification. No such training time has been That is, who was the Level II acknowledged, nor can it be proven.
who observed or signed for me?"
Finding i This allegation is the same as allegation e. in paragraph 6, with the findings also being the same.
1
' A component modification card jbPage4849, lines 13through23:was authorization granted by we from traveler blueprint. A CMC was in or would be generated by welding engineering or hanger engineering in a high percentage l
of the packages inspected by me. Now, this CMC--that is the first This is a time I have come across this particular type document.
deviation which can be granted by welding engineering or hanger engineering department, if I, as the inspector, came across a dimension or something which was different from the original
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blueprint."
s Finding - This allegation regarding the use of CMC seems to
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reflect the opinion of the alleger, perhaps based on his past The CMC must be considered as a field design change experience.
and, therefore, within the purview of Criterion III of Appendix B which requires only that such changes shall be subject to the same controls and reviews as the original design.
The CMC may be issued after the change has occurred to document the as-built condition. The allegation is considered substantiated, but having no regulatory or technical merit.
page 4850, lines 1 through 10:
()[~Page4849, lines 24and25;" Excessive grinding of welds by craft pers inspection. Why is this being done out there? Very few weld-What ments which I inspected were in the as-welded condition.
I mean in the as-welded condition, you see the weldment, the ripples in the weld surface itself, left there by the electrode during the welding process and there at Comanche Peak, I would estimate that seventy-five percent of the weldments which I looked at were all ground down like a machined surface. Also, why does the craft grind the toe of the weldment 360 degrees in some cases, causing an undercut condition or a near under-cut condition?"
i' Finding - The grinding of weld surfaces is neither prohibited nor encoursged by the applicable codes and standards, but is sometines necessary,1f one of the forms of nondesrtictive examination is required.
Relative to the grinding of the e
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15 toe'of welds, it is probably being done to remove questionable undercut and is an acceptable way of doing so within the ASME code except when the material is reduced to less than allowable thickness.
Based on the SRIC's experience at Comanche Peak, the ' craft have ground a substantial majority of the welds to make them easier to inspect and easier to apply protective coatings to.
l Again, this allegation is considered substantiated but without regulatory or technical merit.
- 1. fsPage 4850, lines 14 through 25; page 4851, lines 1 and 2:
"During inspection of hangers in Auxiliary Feedwater Room 2 I was on a scaffold with a craft worker inspecting a reworked hanger.
I had the required safety gear and was tied off to existing structure but craft was not tied off, primarily because he was missing a lanyard on his safety belt. When we climbed off the scaffold, I was asked why I did not use the ladder. The craftsman was visited by the safety man and-was~ given no citation.
February,1982. Wayne Mansfield, inspector, was observed not tied off, in which case was given a safety violation citation from safety and this is in violation of OSHA regulations, which I understand are in effect out there."
1 Finding - This allegation regarding the use of personal safety equipment is not within the purview of NRC regulations.
( nED Page 4851, lines 11 to 18:
" Material verification.
In the material verification group, I have probably come across fifteen to twenty hangers which lacked completely any material d,
dP" traceability. They had no heat numbers of any kind.
I'd turn g 33 them in to the material verification group and told them I r
wouldn't sign them off, usually gave them to Danny Leigh.
I don't know what happened to them. As far as I know, they we :
never corrected."
Finding - Regarding the lack of material traceability of hangers, the SRIC interviewed the one named person within the allegation.
This person stated that he had never received any such reports from the alleger at any time. The purpose of the group the person interviewed supervised, and in which the alleger worked for a period of time, was to inspect and research, as necessary, where the documentation on a particular hanger was not completely clear prior to final code certification of the hanger. The i
proper course for the alleger to have followed when the inspection 4
I criteria was not satisfied was to prepare a nonconformance report l
(NCR) which he apparently did not do.
This allegation can neither be substantiated nor refuted due to its vagueness.
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