ML20199A543
| ML20199A543 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak, 05000000 |
| Issue date: | 06/10/1985 |
| From: | Collins W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML17192A346 | List:
|
| References | |
| FOIA-85-313, FOIA-85-59, FOIA-86-A-20 NUDOCS 8606120466 | |
| Download: ML20199A543 (48) | |
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' " ' " g UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tti!SSION bd K M5 ' N g
. BEFORE THE ATOMIC SAFETY AND LICENSING BOARD \. %
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In the Matter of '
) : 6'Io 3 !
) l TEXAS UTILITIES ELECTRIC Docket Nos. 50-445 COMPANY, el g. 50-446
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(Comanche Peak Steam Electric Station, Units 1 and.2) i NRC STAFF TESTIMONY ON WE FABRICATE M CONCERNS
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1 I. INTRODUCTION i Q. Mr. Collins, please state your name and position with the NRC.
A. My name is William J. Collins. I am employed by the United States Nuclear Regulatory Comission ("NRC") as a metallurgical engineer l
in the Engineering and Generic Comunications Branch,' Division of Emergency Preparedness and Engineering Response.
Q. Have you prepared a statement of professional qualifications?
A. Yes, a statement of my professional qualifications is attached to my testimony.
Q. What is the nature of the work you perform for the NRC?
A. I am a technical advisor in the. area of metallurgy and metallurgical problems relating to construction, testing and operation of nuclear power plants. I also assist the national and regional IE staff in field inspections when requested.
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1 Q. Mr. Gilbert, please state your name and position with the NRC.
A. My name is Leslie D. Gilbert. I am employed by the NRC as a Reactor (
Inspector-Mechanical in the Division of Reactor Safety and Projects, RegidnIV.
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o Q. Have you prepared a statement of professional qualifications? I f
Yes, a statement of my professional qualifications is attached to my A.
testimony. ;
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- . ,E Q. What is the nature of the work you perform for the NRC7 A. I am responsible for inspecting nuclear power plants located in l 9
Region IV in the areas of welding and nondestructive examination
("NDE"), primarily for piping systems and containment liners. I l have also performed welding and NDE inspections of other systems and ;
components, as directed by my supervisors. ;
l Q. What have been your responsibilities with regard to the Comanche Peak Steam Electric StaHnn, Units 1 and 2 ("CPSES")?
A. I have conducted periodic welding and NDE inspections of the piping system, and containment liner at CPSES during the past 6 years. ;
Q. Mr. Smith, please state your name and position with the NRC.
A. My name is David E. Smith. I am a material engineer. assigned to the i l
i Materials Engineering Branch, Division of Engineering. ;
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. Q. Have you prepared a statement of your professional qualifications?
A. Yes, a statement of my professional qualifications is attached to l n
this testimony.
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Q. What is the nature of the work you perfom for the NRC? ;!
h A. I am responsible for the review of materials and fabrication proces- lj I
ses used in the construction of nuclear power plants. I also evaluate j l
material and weldment failures in nuclear power plants. i b
l Q. Mr. Taylor, please state your name and position with the NRC.
A. My name is Robert G. Taylor. I am employed by the NRC as a Reactor Inspector in the Division of Reactor Safety and Projects, Region IV. l
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f Q. Have you prepared a statement of professional qualifications? ,
i A. Yes, a statement of my professional qualifications was previously I admitted into the record.
I Q. What is the nature of tha work you perform for the NRC? ,
A. I am responsible for conducting construction inspections of nuclear power plants located in Region IV. !
t-Q. What have been your responsibilities with regard to CPSES?
A. My responsibilities at CPSES are already a matter of record in this proceeding. .
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Q. Messrs. Gilbert and T.aylor,'have you read the September 1982 written
, testimony of CASE Exhibit 667) and the September 1982
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written. testimony o CASE Exhibit 666); the February
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1984 written testimony of( (CASE Ezhibit 919),
those portions of-the transcript in this proceeding where Morally testified concerning their concerns about plug welds, weave welds, downhill welds, and weld. rod control; the Appli-cants' expert witness Mr. Brandt's testimony (Applicants' Exhibit 141) and affidavit (July 15, 1983, attached to " Applicants' Sunnary of the Record Regarding Weave and Downhill Welding" (July 15,1983))
and those portions of Atomic Safety Licensing Board's (" Board's")
Proposed Initial Decision (July 29, 1983) (" Proposed Decision"),
MemorandumandOrder(September 23,1983)(" September 23,1983 Order"),
and Memorandum and Order (October 25, 1983,0rder") relating to the welding concerns of [
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A. (GilbertandTaylor) Yes, we have read and reviewed those materials. The Bo'ard indicated in its three orders that it had some unresolved questions on plug welds, weave welds, downhill welds and weld rod control. Our testimony addresses the Board's questions on these welding concerns.
II. WEAVE WELDS A. TRANSVCRSE OSCILLATION Q. liessrs. Collins and Smith, what are. weave welds?
A. (Collins and Smith)Section IX, Article QW-492 of the 1974 ASME Boiler and Pressure Vessel Code (".ASME Code") states that weave
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4 welding is a weld with."significant transverse. oscillation."
Appendix I of the 1975 AWS D1.1-75 Code ("AWS Code") also definesi a
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weave bead as "a type of weld bead made with transverse oscillation."
1 Weave' welding may be distinguished from stringer bead welding.
Appendix 1. of the AWS Coda defines a stringer bead as, "A type of ) .
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weld bead made itithout appreciable transverse oscillation."
t Q.
Do either the 1974 ASME Code or 1975 AWS Code prohibit weave welds? !
. A.
(CollinsandSmith) No. !
Neither the 1974 ASME Code nor the 1975 AWS Code specifically prohibit the use of weave welds.
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Table QW-253, 1
Section IX of the ASME Code, specifically identifies variable i
QW-410.1, which is a " change from the stringer bead technique to the .
i weave bead technique, or vice versa" as a "non-essential variable" !
j except when impact properties (notch toughness) is required by the designer's specifi, cations. Non-essential variables are defined in :
Article QW-251.3 as:
... those in which a change, as described in the specific variables, may be made in the WPS (Weldin ;
Procedure Specifications) without requalification.g j i
The 1974 ASME Code therefore permits a change from stringer bead i
welding to weave bead welding without a new qualification of the previously qualified weld proc'edure.
Q.
Messrs. Gilbert and Taylor, what Brown and Root welding procedures were qualified to? .
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I IC A. (Gilbert and Taylor) Applicants have indicated that were qualified to 11065 (training procedure),11032 (ASME) .
l and10046(non-ASME).
I Q. -. Messrs. Gilbert and Taylor, what are the transverse oscillation requirements in Welding Procedures 11032 and 10046?
A. (Gilbert and Taylor) Procedure 11032 (Applicants' Exhibits 186, ; ,
189,190) generally permits transverse oscillation up to four times
- the core diameter of the weld rod being utilized. Weld Procedure -
1 10046 (Applicants' Exhibits 187,188) does not have any limitation on transverse oscillation. However, Section 3.15 of Brown and Root ,
Construction Procedure CPM-6.9D recommends a maximum bead width of ;
- i four weld rod diameters. Both Weld Procedures 11032 and 10046 comply with the 1974 ASME and 1975 AWS Codes, respectively.
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Q. Mr. Taylor, what type of steels and welding electrodes are typically
- utilized in the fabrication of pipe supports and cable trays at I
A. (Taylor) The principal steels used in the fabrication of pipe and cable tray supports at CPSES are A-36 and A-500 steels, which are .
I low / mild carbon steels. Welding of these supports is done in accor-dance with Weld Procedures 11032 and 10046, both of which specify the use of E-7018 weld rods. :
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s Q. Messrs. Collins and Smith, is the Brown and Root limitation on ,
transverse oscillation necessary to prevent structural deterioration
,, of the steel?
i A. (Collins and Smith) The Brown and Root limitations on transverse oscillation are a standard industry practice, and are not essential requirements for welding of low / mild carbon steels (i.e., steels .
with carbon content up to and including .3 percent) unless the 1 de.iigner specifies the use of steel with specified energy absorption
- characteristics under load bearing conditions. (To evaluate the . j i
energy absorption characteristic under a given set of welding para-i meters, a testing method known as Charpy impact testing or " notch i testing", is required for materials with specified impact properties.) l
! Low / mild carbon steels are considered to be highly weldable steels.
i Accordingly, transverse oscillation limitations imposed on the fabri-l I
cation of these supports are not necessary from a metallurgical standpoint, unless specified impact characteristics are selected by the designer. However, the transverse oscillation limitations are desirable from a workmanship and weld soundness standpoint, to reduce
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j the likelihood of porosity and slag inclusions. j I
f Transverse oscillation does lead to high heat inputs during the i 1
welding of all steel types. This heat input can change the metal-lurgical properties of the weldment, which can reduce the impact l t $
l properties of these materials under load bearing conditions. j e
Therefore, if the designer selects steel with specified impact j
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properties, heat input during welding is controlled by Mer_ alia, contro111ng' transverse oscill'ation.
- Q. Please coment on representation (CASE Exhibit 919, p.8) that base metal surrounding a weld turning blue four to five inches from the weld is an indication of excessive heat input.
A. (Collins and Smith) The blue color is a result of oxidation of r the surface of the steel, and indicates that the temperature reached l by the steel was approximately 600 degrees F. at the blue-colored j zone. It is' not likely that the base metal would turn blue four to five inches from the weld solely from the heat of welding when using small-diameter (up to 5/32 inch diameter) E-7018 electrodes. Moreover, }
as indicated above, heat input is not an important consideration for ,
t welding of low / mild carbon steels.
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Q. Do you ag'ree wit ' testimony that the start and stop points of a weave weld are weak? !
A. (Collins and Smith) No. The stop and start points of either a l stringer or weave weld do not affect the metallurgical properties of I
the weld or base materials. Porosity and/or cratering may occur at the stop or start points of both stringer and weave. welds. Such surface indications would be required to be removed prior to begin-
, ning the subsequent weld bead, regard 1'ess of whether the weld was a -
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B. SPEED OF WEAVE WELDING Q. Messrs. Collins and Smith, tated that weave welding is f' aster.than stringer beading P. lease comment on s.
A. (Collins and Smith) We find that statement is not entirely correct, and can be misleading. If all welding parameters are held constant.(e.g., weld rod type and diameter, voltage, amperage, base metal type), then the rate that a weld rod is used up
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(consumed). and the total amount of weld metal deposited per unit time remains constant, regardless of the oscillation width or the linear speed of the electrode. Thus, there is normally no advantage in time between weave welding, versus stringer beading.
The only time advantage to utilizing a weave bead, as opposed to a stringer bead, is where the welder has to physically reposition himself to make the complete weld. An example of this is where the welder must fabricate a relatively long (2 feet or more) weld, or where the weld continues around the back side of a large tubular section. In these cases, running a stringer bead would be more time consuming, since the welder would 'have to lay down a full pass over the entire length of the weld, before making subsequent passes. The only way to make the pass over the entire length of the weld would be for the welder to reposition himself, which would cause some time ;
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delay. Each time he laid down a subsequent stringer bead, he would have to repeat his repositioning movement until the weld was built up to the specified thickness. If the welder instead chose to weave c ,_ . . .. . . .. . . . . . . . .. .. ,.... .
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I weld, the welder could deposit a larger weld pass that would result ;
in fewer passes to complete the weld. The welder would move fewer times to complete the same weld. The savings in movement translates )
e- 6 to a savings in time necessary to complete the weld. i i
C. REPAIRS OF WEAVE WELDS Q. Messrs. Collins and Smith, Applicants have stated (Tr. 4598-99, 4650-51) that transverse oscillation during welding which exceeds the four weld rod width limitation may be repaired by grinding ,
down the weld to conform to that limitation. Is this an acceptable repair procedure?
A. (CollinsandSmith) This is an acceptable repair procedure for ,
low / mild carbon steels. In fact, there is no technical reason - Y i why the welds could not be left as-is as long as the weldment meets ;
i the applicable visual inspection requirements. In any case, it is I acceptable to grind the weld until it is within the four weld rod width limitation. At that point, if the remaining weld metal was I
smaller than the specified weld, the weld may be built up until the weld was the specified size. If the weld, when ground down, met
! or exceeded the specified weld size, then no further work is neces-i sary.
j Q. Messrs. Gilbert and Taylor, are weave weld repairs inspected by QC inspectors at CPSES?
, A. (GilbertandTaylor) The majority of support welds at CPSES only I
require a QC inspection of a finished weld. The repair of a weave ;
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weld by the welder, if done prior to the first QC inspection, would f f
be considered an in-process repair and need not be separately g
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i ' weave weld, the subsequent repair would have to be reinspected by ,
i QC. i
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D. INSPECTIONS . !
Q. Mr. Taylor, has the Staff conducted any inspections at CPSES to {
, determine whether transverse oscillation in violation of the Brown ,
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- and Root limitation occurred at CPSES?
! A. , (Taylor) Yes.' NRC Inspection Report 81-12/81-12 reports Region IV's ,
- inspection regarding allegations made in 1981 concerning improper !
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weave welding at CPSES. This Inspection Report has already been
- admitted as Staff Exhibit 178.
Q. Are you familiar wit representation that i
to weave weld in excess of the maximum bead width limitation? l A. (Gilbert and Taylor) Yes. -However, as unable to iden-tify specific locations or hangers on which this occurred. _ j We also are aware that indicated that Mr. Coleman instruc-ted to weave weld to correct gaps due to fit-up. (CASE I Exhibit 666,p.9.)
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Q. Hew. did you investigate this concern?
l A. (Gilbert and Taylor) Both Mr. Coleman and Mr. Peppers stated that tiieyneverdirected or any other welder, to weld in excess of the applicable bead width limitations. is no longer employed at the CPSES site, and we are in the. process of trying to contact him.
Q. What is your understanding of representation that k was directed to weave weld in a fabrication shop by nd A. (Gilbert and Taylor) M testified thath, who was a in a fabrication shop, directe to weave weld in excess of the maximum bead width limitation. However, did not identify any specific hangers that fabricated incorrectly at the fabrication
( shop.
I Q. How did you investigate this concern?
f A. (Gilbert and Taylor) We asked whetherheinstructedh M to weave weld in violation of the maximum bead width limita-tion. He denied ever doing so. He also stated that he never saw l
l weave welding in excess of the bead width limit.
l is no longer is employed at the CPSES site, and we are
) in the process of trying to contact him. .
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E. HANGERS CT-1-017-005-Y35R/CT-1-017-004-Y35R/CT-1-017-006-Y35R (
l Q. Messrs. Gilbert and Taylor, are you familiar with testi- l many (CASE Exhibit 666, pp. 11-12; concerning a support which he welded on to repair an improper
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weave weld performed by A. (GilbertandTaylor) Yes. We understand.that originally '
pointed out hanger CT-1-017-005-Y35R as the relevant support, but that he subsequently decided that an ad,jacent support, CT-1-017-004-
. Y35R was the support that he repaired ,
It is also our understanding that, _
claims that the actual support for CT-1-017-005-Y35R support which he welded on was removed after he had repaired the support.
- i We also inspected hanger CT-1-017-006-Y35R.
Q. Do any of.these three supports utilize steels which require impact testing, or employ attachments to pipe which require impact testing? ,
A. (Taylor)No. The design packages for these hangers do not specify .
l the use of impact-tested steel, nor do they use integral attachments.
The design packages would have specified the use of impact-tested , l steel, if the designer had selected the use of such steel. The design packages would also show integral attachments if they were specified' by the designer.
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Q. Is there any evidence that there are improper weave welds on any j
of these three supports?
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f I C-I A. (Taylor) I have inspected these three supports, and the welds on th,em. The supports have been painted with a phenolic-based paint.
, . The welds appear to not have been ground down, and the longitudinal ridges and valleys of the welds are indicative of properly-made stringer beads well within the 4 rod diameter limitation.
Q. Is there any evidence that support CT-1-017-005-Y35R was removed subsequent to the July-August 1980 time period that claims to have welded on this support? .
A. (Taylor) I reviewed the construction package for this support. The Weld Metal Filler Logs ("WMFLs") for this support show that welding was done on this support in June 1979, January 1981, and October 1983. Ididnotseeanyevidenceintheconstructionpackage(which includes the original design for the support, and all subsequent CMCs for the support) that this support was modified substantially, or that' the support was repl' aced with a new support during the " life" of the support. Further,. when I viewed this support I saw no physi-cal indication that this support had been removed and replaced.
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Q. Are you familiar with opinion that hanger -
CT-1-017-005-Y35R possesses rejectable base metal defects, consistingof" gouges"inabaseplatefTr. 11, 192-93 A. (GilbertandTaylor) Yes. We understand that the gouges were in a vertical surface of a horizontally-positioned base plate which was welded to a horizontal tube steel member.
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- Q. Have you had an opportunity to inspect this support and the " gouges" in the base plate?
A. (Gilbert and Taylor) Yes. The base plate described earlier does I
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l not show any " gouges." However, we did identify depressions on the j milled-surface of a wall-mounted 3/4 inch thick base p. late for this
! support. The depressions measured approximately .032 inches deep.
We also closely examined the two supports upstream and downstream of I this support. We identified several depressions on the cut surface of the li inch thick base plates for these supports (CT-1-017-004/006-f ,
Y35R). The depressions measured approximately 1/16 inch deep.
Q. What are the Applicants' criteria for acceptance and rejection of 2
base metal defects?
A. (Gilbert and Taylor) QC Procedure QI-QP-16.0-5 does not have any criteria for surface irregularities which are not on the original milled surface (i.e., the through-thickness face) of the base material. For 3/4 inch thick material, the maximum defect pemitted on the original milled surface is .053 inch.
Q. Are these depressions re.4ctable base metal defects?
A. (Taylor) No. The depressions in the li inch baseplates for supports CT-1-107-004/006-Y35R are not rejectable defects, since they are not i
! in the original rilled surface of the plates. The depressions in the 3/4 inch bawplate for CT-1-107-005-Y35R are not rejectable defects, since they are less than the .053 inch criteris specified l in QI-QP-16.0-5.
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l F. HANGER TWX-034-714-A35K
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Q. Messrs. Gilbert and Taylor, are you familiar with ---
, representation that viewed a hanger
- (TWX-034-714-A35R)which was weave welding on?
A' . (Gilbert and Taylor) Yes. indicated in k testimony that that told ,
o tell to " cut down" l this hanger. (We note that hanger TWX-034-714-A35R is l located in the Auxiliary Building, and is a Class 5 hanger). This hanger was approved by _C inspection report ,
.for this hanger does not indicate any problem with weave welding.
I Applicants' Exhibit 193; '
r Q. Does the documentation package (Applicants' Exhibit 193) confirm representations regarding the involvement of A. (GilbertandTaylor) No. Thedocumentsdonotconfirmk ,
representation that inspected support TWX-034-714-A35R, or instructed to'have this support
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removed. -
Q. Has the Staff conducted an inspection of this support to detennine whether or not there are improper weave welds on the support?
A. (GilbertandTaylor) ho. tated that the weave weld was subsequently repaired by grinding and re-welding, '
Accordingly, there would no longer be any indication on the support's welds whether improper weave welding had occurred.
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.-.- - - - m Q. Did you interview on this subject?
A. (Giibert and Taylor) Yes. _Wespokewith( who was at that time a QC superintendent for ASME pipe supports during the time i period that this support was approved. We first queried whether he had ever ordered the craft to cut down hangers (supports) or other structures. He stated he had never done so, since it is not within his authority. ,
. We then inquired as to whether he could remember inspecting a Class ,
5 hanger in the Auxiliary Building, or ordering that such a hanger be removed. He responded by stating that he did not remember l
inspecting a Class 5 hanger, or giving an order to cut down hangers. We also asked if he had any authority to inspect Class 5 hangers, to which he answered no.
Q. Did you speak with([
A. (Gilbert and Taylor) . Yes. htatedthatheremembers
}asking him to cut-down this support, and that Mr.
Willis indicated that he had no authority or responsibility for f
this support.- indicated that he inspected a weld which was weaved, but that the bead width was approximately 3/8 inch, and therefore within the Brown and Root bead width limitation, since
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the weld rod used was 1/8 inch rod. ((Taylor) I later looked at the WMFL for this hanger. It indicates that a 3/32 weld rod was used). According to _he also had his supervisor and a welding technician view the weld, and they concurred with his judge-9
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, . . 1 ment that the weld was acceptable. Finally, said that to avoid further confrontation with , he directed that the weld be ground down and covered with a cover pass.
G. HANGER BR-X-181-707-A45R Q. Messrs. Gilbert and. Taylor, are you familiar with claim (CASE Exhibit 667, that hanger BR-X-181-707-A45R was improperly fabricated using weave welds?
A. (Gilbert.andTaylor~) Yes. NCR M-82-00584 (CkSE Exhibit 667Q) shows .
. that a weld' was fabricated using oscillation in excess of the maximum bead width limitation of 4 weld, rod diameters-in this case, I inch. :
Q. What was the disposition of this NCR7 A. (GilbertandTaylor) The final disposition of this NCR was done by weld engineering, which accepted the weld as-is on the basis that there was no concern regarding the structural adequacy of the weld, since the hanger does not utilize material requiring Charpy impact testing. Accordingly, the disposition by weld engineering was technically justified.
III. DOWNHILL WELOS ,
Q. Messrs. Collins and Smith, what is downhill welding?
A. (CollinsandSmith) Downhill welding is a technique where the welder runs his bead from a higher to lower elevation. Neither the 1974 s
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9 6 ASME Code nor the 1975 AWS Code have a specific definition for a downhill weld.
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Q. What, if any, are the 1974 ASME Code and 1975 AWS Code requirements or limitations on downhill welding?
A. (Collins and Smith) Table QW-253.2 of the 1974 ASME Code specifies that a change in progression is a non-essential variable for the welding procedure if notch toughness is not a design requirement.
. If notch toughness is a design requirement, Table QW-253.2 specifies ,
that a progression change is an essential variable for the welding procedure. For welder performance qualification, the change in progression is an essential variable and the welder must be quali-fied for the direction of the progression used.
Section 4.10.7 of the 1975 AWS Code requires that prequalified weld procedures specify that:
The progression for all passes in vertical position welding sn.ill be upward, except that undercut may be repaired vertically downwards when preheat is in accordance with Table 4.2, but not lower than 70*F (21'C). However, when tubular products are welded, the progression of vertical welding may be upwards or downwards but only in the direction or directions for
, which the welder is nualified.
! If prequalified weld procedures are not used, the Section 5.5.2.1(10) AWS Code requires that in vertical welding, a change in the progression specified for any pass from upward to downward or vice versa shall require establishing a new weld procedure by qualification.
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i With regard to qualification of a welder, Section 5.16.1.7 states f
that:
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When the plate is in the vertical position, or the pipe !"
or tubing is in the SG or 6G position, a change in the direction of welding shall require requalification. ,
Thus, the AWS Code, like the ASME Code, does not prohibit downhill
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welding, but requires qualification of the welder for the direction i of the progression used. ,
Q. Messrs. Gilbert and Taylor, do the Brown and Root weld procedures .
set forth any limitations on downhill welding?
A. (GilbertandTaylor) Brown and Root Weld Procedures 11032 ard 10046 have not been qualified for, and do not specify, downhill welding.
However, Chicago Bridge and Iron ("CB&I") weld procedures do permit downhill welding only for root and cover passes.
Q. Messrs. Collins and Smith, is there a technical basis for the 1974 ASME requirements regarding the utilization of downhill welding?
A. (CollinsandSmith) Yes. Welders using downhill welding tend to i"
increase their rate of travel as compared to uphill welding, resulting in a lower heat input. Lower heat input results in a greater possibility for slag inclusion, and poor weld penetration.
It is possible to keep the heat input during downhill welding the same as during uphill welding. However, this would result in a ,
larger, and more difficult to control molten puddle. For these reasons, the 1974 ASME Code requires each welder to be individually qualified to perfonn downhill welds.
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Q. Is there any evidence showing that downhill welds are any less [
t adequate from a structural standpoint, as compared with uphill !
I e welds? j A. (Collins and Smith) If the downhill welds were made by qualified welders, and the welds do not possess rejectable visual indications [
(i.e., porosity, cracks, cratering),thentheweldsareasacceptable as uphill welds.
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Q. Is there any way of detecting downhill welding?
- A. (Collins and Smith) Properly-made downhill welding on the cover pass t
can only be detected by noting the direction of ripples in the weld !
l bead. These ripples, which are sometimes hard to discern, point away from the direction of the weld progression. In downhill welding, the ripples would point uphill. However, if the component l, being welded is repositioned after welding, the ripple direction is ;
i not useful as an indication of downhill welding, since one cannot i determine the original orientation of the component at the time of welding. Moreover, if the weld beads were surface ground, then the ;
ripples would be destroyed.
Properly-made downhill welding of a root pass which is covered by an j uphill cover pass cannot be detected unless the reverse side of the root pass can be examined. If the orientation of the component was subsequently changed, or if the reverse surface of the root pass ,
were ground, there is no way of determining whether or not the root pass was a downhill weld. If the root pass was downhill welded on 4
_ w -- - - x _ - ....._ .- .
- J
)
/
(._
s tube steel members, the reverse side of the weld normally cannot be ;
inspected, since the inner surface (interior) of the tube steel :
~
smmber is essentially inaccessible. Downhill welds on intermediate <
s .- . ;
passes cannot be detected. In sum, it would not be practical to determine whether or not a weld was actually fabricated in the ,
downhill direction.
f Q. Messrs. Gilbert and Taylor suggested,that limited access
, situations may make it easier for a welder to make downhill, as ,
opposed to uphill, welds. ,
. Do you agree with his statement? ' .
. f.
A. (GilbertandTaylor) Since the rod position, and the welders' hand l
and ann position are generally within the same range for either the downhill or uphill direction, we have difficulty conceptualizing l such a situation.
Q. Mr. Taylor, claimed that he did'a downhill weld on a pipe ,
support in an area with limited access, and that he subsequently i ground off the surface of the weld (CASE Exhibit 666 p.29MK '
CASE Exh'ibit 919 p.15; Have you viewed this pipe support?' I I
A. (Taylor) Yes. This support is painted with a thick coat of epoxy ,
ir paint and is in a relatively congested and inaccessible location. ,
j lt is impossible to discern which, if any, weld was done in a down- .
l hill progression, without physically cutting out the support and removing the paint so that the weld metal can be examined. The ,
l i
p y. .... .4 .
...... ..... ........y... . . . . . . . . . , . . . . . . . . ,
r i
Staff will require the Applicants to evaluate whether the hanger ,
in its current condition is satisfactory for service.
- s. . .
' l IV. PLUG WELDING '
Q. Messrs. Collins and Smith, what are " plug welds", as described by l A. (CollinsandSmith) appear to be concerned about a weld which was performed to fill-in holes which were mistakenly j
6
. drilled in the wrong location on steel members. Although the . i refer to this weld as a " plug weld".'in fact the weld that '
th.ey are describing is not a plug weld as defined in either the 1974 ASME Code or 1975 AWS Code.
i Q. What are plug. welds, as defined by the 1974 ASME Code and 1975 AWS I Code?
i' A. (Collins and Smith) . The 1974 ASME Code.Section IX. Article QW-492 '
and the 1975 AWS Code. Appendix 1. h' ave identical definitions for' plug welds:
! Plug weld. A circular weld made through a hole in one member of a lap or T-joint joining that member to the other. The walls of the hole may or may not be a j
parallelandtheholemay(bepartiallyorcompletely filled with weld metal. A fillet welded hole or a ;
spot weld should not be construed as conforming to
^
thisdefinition.)
As the ASME Code and the AWS Code make clear, a plug weld is a weld which is utilized to join two separate pieces of material together.
On the other hand, the " plug welds" which .
describe apparently were utilized to fill misdrilled holes in a
single piece of material. - Such misdrilled holes may be considered to be material defects. Thus, the " plug welds" described by the Stiners can be considered to be " repair welds."
, Q. Does either the 1974 ASME Code.or the 1975 AWS Code prohibit the use ofthe"pl,ugwelds"describedb[ for the repair of material defects such as misdrilled holes?
A. (Collins and Smith) The 1975.ASME Code does not specifically address
. . whether or not "pjug welds" may be utilized to repair material ,
defects. However, Article NF-4131 of the 1974'ASME Code states that defects in materials discovered during fabrication or installation may be repaired by welding. Moreover Article NF-2510 of,the 1974 ASME Code allows repair of unacceptable defects as permitted by the material specifications. The material specifications for A-36 and A-500 steel, as set forth in Section 11. Part A of the ASME Code, permit repair of these materials by welding.
Q. Messrs. Gilbert and Taylor Applicants' witness Mr. Brandt stated (Applicants' Exhibit 141,p.36)that"plugwelds"werepermittedat CPSES to iepair misdrilled holes so long as a final visual inspection of sucn welds is performed by a QC inspector. Are there site proce-dures at CPSES with regard to the utilization of " plug welds" by welders?
i A. (GilbertandTaylor) The Brown and, Root procedures for ASME Code structurefabricationsrequire(andhavealwaysrequired)weldersto
- g. . . . . .
. q. . . .
. s obtain advance authorization of welding engineering to repair mis-drilled holes by obtaining a repair process sheet ("RPS"). I f,
e l[
The Brown and' Root site procedures for non-ASME Code structure fabrications (eA, cable tray supports) do not currently require l welders to obtain advance authorization of welding engineering to repair misdrilled' holes by " plug welds." Prior to January of 1983, Procedure WES-29 did require welders to contact welding engineering to repair misdrilled holes in non-ASME Code structure fabrications. -
j i
and for a RPS to be generated for those repairs. The Brown and Root procedures for repair of misdrilled holes comply with the applicable requirements of the 1974 ASME and 1975 AWS Codes. .
Q. Are there site procedures at CPSES requiring the inspection of such repair welds?
A. (GilbertandTaylor) Yes, the RPS requires a visual inspection of the completed repair weld by a QC inspector.
Q. Messrs. Collins and Smith, are " plug welds" an acceptable technique for the repair of misdrilled holes?
A. (CollinsandSmith) If the " plug weld" repair is correctly made by j a welder, there is little concern for the structural adequacy of the a
repaired material. A welder welding A-36 or A-500 steels need only weld in accordance with qualified welding procedures in order to produce a structurally sound weld.
t f
- 1 As Mr. Taylor has testified, the Brown and Root nielding Procedures 11032 and 10046 specify the use of E-7018 weld rod.. The E-7018 rod
,, is a low-hydrogen rod which produces a weld with a ter.sile strength of approximately 70K psi, or about 10K psi better thar. the tensile strength of the base material. If the " plug weld" was made well enough not to be readily discernable after surface grinding, the weld and the surrounding base material are at least as strong as the original base material before it was drilled.
Q. Messrs. Gilbert and Taylor, is it possible to make " plug welds" on a la inch diameter hole in a 2 inch thick plate in two minutes, using two weld rods?
I A. (GilbertandTaylor) No. Approximately twenty-five 1/8 inch weld ;
rods would be necessary to repair this hole. Assuming that the slag was not removed, the number of rods necessary may be reduced to 20.
It would require approximately 20 minutes to use 20 welds rods.
disregardingallotherfactors(suchascleaningtheweldsurface) which would increase the time necessary to complete the weld.
Q. Has the Staff conducted any inspections to determine whether welders -
i were " plug welding" in accordance with the Brown and Root welding procedures?
A. (GilbertandTaylor) Yes, the Staff performed an inspection at CPSES
- to determine if " plug welds" were being utilized by welders in accordance with Brown and Root welding procedures. NRC Inspection Report 81-12/81-12 (April 16,1982) (Staff Exhibit 178). The Staff l . - - - ..
, p4 . . .. . ... . . . .. . - , , .
- e. "- .-v.-
l QC '
, interviewed five welders. Three of these welders indicated that they had repaired misdrilled holes. The two remaining welders indi-
~
L cated they did not " plug weld," ~and stated that it was not authorized .,
i e- y at CPSES. Staff Exhibit 178, p. 6.
~t 4
l Q. represented that he and welded misdrilled holes in the north cable spreading room without the proper weld h engineering approval, and without QC inspection of the welds (CASE :
. Exhibit 667, p.22; 'also stated that improperly welded misdrilled holes in h the south yard tunnel Has the Staff physically inspected these welds? -
j i .
A. (GilbertandTaylor) No. We have not conducted a physical inspec- j tion of welds in these areas to identify whether there are " plug !
I f welds." Although, " plug welds" with uncorrected surface indications f would be visible. (as well as _
stated (CASE
, Exhibit 919, pp. 22-23) that the repair welds were ground'down and I
painted. Therefore, there would be no visual indication of the l l
location of such unauthorized welds. 1 i
. . 1 Q. At the February 1984 hearing sessior$ stated that direc.ted%to"plugweld" on fabrication holes located in the turbine building. Please i
coment b statement. ,
A. (GilbertandTaylor) We interviewed App 1,1 cants' witness William E.
Baker, Brown and Root Senior Project Welding Engineer at CPSES.
- e. +e . * *. . . . -
- n. . _ . - _ _ - - - . ,.,- _ ,-. nn_, - - --
e
- 28 - ~7 c Mr. Baker stated that id do some welding at fabrication tables located in the turbine building. Mr. Baker also stated that f admitted that he had illegally directed e
to"plugweld"inviolationofapplicableproceduresontwosmall j bore pipe hangers. According to Mr. Baker, )toldhim f 0
that these " plug welds" were discovered by a QC inspector named [
and that these two hangers were imediately scrapped asa.resultoff inspection of tha hangers. Mr. Baker b also a,dded that hangers fabricated by th.is fabrication shop'were , ,
l removed as part of an unrelated decision to scrap small-bore pipe !
f hangers utilizing angle irons as the attachment to the wall, ceiling -
[
t or floor. This decision was made by the pipe support designers. *
~
M'r. Baker also stated that voluntarily demoted himself fromasupervisorypositionaweekafter( discovered l
\
the improper welds. -
l l
Weinterviewedh ,
on March 5, who confimed that he had ,
s identified non-conforming welding on one hanger which was done by based upon a "tip-off" that "something funny" was occurring in the fabrication shop. However, he recalled that the problem which he identif.ied was not " plug welding," but was the i ,
, welding of a short piece of angle iron to an existing angle iron section, in order to extend the dimension of the angle iron. We l asked whether he had written an NCR on this matiter, to which he responded that he had not. since the hanger was scrapped l imediately. .We were therefore unable to' document exactly what kind i
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- 29 - C, of irproper weld was fabricated by so confirmed that demoted himself from a supervisory
~
position to a craftsperson one week after the improper welds were
- s. .
discovered.
-(Taylor), is no longer employed at the CPSES site, and we are currently in the process of attempting to contact him. On Tuesday, March 13, 1984 at the CPSES I'interviewedk site. stated that he was a foreman in the small-bore ,
pipe support fabrication. area during the time period when ,
was. assigned to the fabrication shop located in the turbine building'.
(This shop was responsible for all the material cutting, hole drilling,
" ~
and welding of small-bore pipe supports.
It consisted'of six to eight fabrication tables, each table with a' fitter and a welder.
The shop was given the dimensions of the support to be fabricated by the installer crews,' who were responsible for field measuring the necessary dimen'sions.) According to he recalled a situation where he had two suppo'rts that could not be installed :
becaus~e they would not fit into place. He instructed the fitter to modify the supports to make them fit, but did not give any specific directions how to modify the supports. I then held a joint interview with the QC inspector who identified l
~the improper welds, stated that he recalled only one
- support which had the problem with improper welds; ,
added that an additional support was under the table. The interview participate in.the interview.
~
continued by having
, . . 30 - j who was the individual who " tipped-off"( m i
s,tated that he observed welding at the fabrication shop which he j
. I
- e. believed was improper, but did not receive an answer satftsfactory to ;
i '
him from then stated that he reported j i
his concerns to :
(GilbertandTaylor) In suso, we confirmed to some extent f I
( M representation tha't lhad directed h j
~ '
to " plug weld" in violation of Brown and Root procedures, since we believe that 'did direct to perform ,
a weld in violation of applicable procedures. We were not able
~
to Sonfirm that the improper weld was a " plug weld." According to the two hangers which '
~
, welded on were scrapped. Therefore, there is no remaining l
~
t safety concern with these hangers. l t
. I Has the Staff conducted any inspections to detennine if QC inspec-Q.
tors are, in fact, inspecting " plug welds " in accordance with established procedures and criteria?
A. (Gilbert and Taylor)' Yes. As part of Inspection Report 81-12/81-12 l
(St.aff Exhibit 178), Region IV inspectors interviewed three QC f
I inspectors at CPSES regarding " plug welding"'of misdrilled holes.
These QC inspectors all stated that " plug welding" repairs of ;
i misdrilled holes must be inspected by a QC inspector to determine if ;
the weld was done properly, and does not violate.Hilti bolt spacing
-requirements. Staff Exhibit 178, p. 6.
5 e
l .,'
, 3 i -
l V. WELD ROD CONTROL Q. Mr. Taylor, what weld rods are being utilized for the fabrication of f
, ,. support structures at CPSE57 f A. (Taylor) As I stated earlier the E-7018 weld rod is typically used f
.- in the fabrication of support structures which the expressed j concerns about. i Q. Messrs. Collins and Smith, what are the. characteristics of this weld rod type?
l A. (Co11' ins.and Smith). This weld rod is a low-hydrogen rod which was. j originally developed to minimize the potential for underbead :
. l cracking. Underbead cracking usually occurs with high strength !
6 alloy steeis, and is not a significant concern for the A-36 and -
A-500 low / mild carbon steels.
Q. What are the 1974 ASME Code and 1975 AWS Code requirements for the control of this weld rod? i P
A. (Collins.and Smith) Article NF-4411.Section III of the 1974 ASME :
v Code, entitled, " Identification, Storage, and Handling of Welding !
, Materials " states:
s
~
Each Manufacturer or Installer is respons~ible for control of the welding electrodes and other materials ,
which are used in the fabrication and installation of i
, components supports (NF-4120). Suitable identification.
storage, and handling of electrodes, flux, and other; 1
welding materials shall be maintained. Precautions shall be taken to minimize absorption of moisture by! -
electrodes and flux. l i
1
. I l
- 1 i '
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m
. N<, 1
. No specific requirements are set forth in the 1974 ASME Code for the control of E-7018 weld rods.
. 1
/-
Section 4.9.2 of the.1975 AWS Code states:
All electrodes having low hydrogen coverings confoming to AWS A5.1 shall be purchased in hermetically-sealed
' containers or shall be dried for at least two hours between 450*F (230*C) and 500*F (260*C) before they are '
used. : Electrodes having low hydrogen coverings confoming to AWS AS.5 shall be purchased in hermetically-sealed containers or shall be dried at 1 least one hour at temperatures between 700*F (370*C) and
. 800*F (430*C) before being used. Electrodes shall be . ,
dried prior to use if the hermetically-sealed container '
shows evidence of damage. Imediately after the opening of the hermetically-sealed container or removal of the electrodes from drying ovens, electrodes shall be stored i in ovens held at a temperature of at least 250*F l (120*C). E70XX electrodas that are not used within four i hours EBOXX within two hours. E90XX within one hour, E100XX and E110XX within one-half hour after the opening of the hermetically-sealed container or removal of the electrodes from a drying or storage oven shall be redried before use. Electrodes that have been wet shall not be used.
Q. Is there a technical justification for the 1974 ASME and 1975 AWS requirements for the control and use of weld rods, and in particular, 1
A. (Collins and Smith) Yes. Weld rod controls are required to ensure that the proper type of weld rod is being used for the weld job, in accordance with the qualified welding procedures.
l The detailed requirements of the AWS Code for low-hydrogen rods are ;
intended to assure that the rods do not absorb excessive amounts of water. As discussed earlier, low-hydrogen rods are used to prevent .
l
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. underbead cracking in high strength alloy steels. Water absorbed into the coating of'the E-7018 weld rod will be broken down during l welding into hydrogen and oxygen. This hydrogen can become incorporated into the metal, thereby increasing the possibility of !
underbead cracking. In addition, in both low and high alloy steels, j water absorbed into the weld rod coating will also be turned into vapor, which can cause porosity and embrittlement. The 7th Edition of the AWS Welding Handbook sununarizes the concern with water
. adsorption by weld rods as follows: ,
Water vapor can be harmful, particularly as a source of hydrogen which can cause porosity and embrittlement. l Porosity can be controlled by excluding the gas, or by :
insuring that the molten metal has sufficient fluidity l to allow the gas to escape. A far more serious effect I of hydrogen is the formation of cracks in high carbon j and alloy steel welded joints . . . . Water vapor can i also be hannful in welds because it produces a loss in arc stability. ,
Thus, the AWS requirements are designed to minimize the adsorption j of water.
i Although the 1974 ASME Code does not set forth weld rod control I requirements to the level of detail of the 1975 AWS Code, the 1974 j ASME Code does state that " appropriate" handling and storage of weld rods must occur. Thus, the 1974 ASME Code also requires that !
measures be taken to minimize adsorption of water by low-hydrogen weld rods.
Q. Messrs. Gilbert and Taylor, what are the. Brown and Root requirements l on control of E-7018 weld rods 7 -
- w
.. ~.. ,, .. ,
. . . . . . . , . - .~ ,.
. , , t 34 - '
A. (Gilbert and Taylor) Brown and Root procedures require the use of portable weld ovens by welders to hold weld rods while in the field.
- s. Welders receive their weld rods from centralized issue stations equipped with fixed drying ovens, and an inventory of portable ovens ,
to be used.by welders. The welder takes his portable oven to his work area and then generally takes what he can use in a short time such as an hour and place them in a pouch or can at his actual work location where he can have ready access. A Weld Metal Filler. Log
. ("WMFL") is used by the centralized rod issue stations to record .
l, the number and type of weld rod issued, the identity of the welder receiving the rods, and the weld procedure that the welder will be i using. At the end of the welder's shift, he or she is required to i
turn in all unused rods, as well as used weld rod stubs to the -
control issue stations. The Brown and Root weld rod control pro-cedures comply with the applicable 1974 ASME and 1975 AWS Code ,
requirements.
4 Q. Are there QA/QC inspection procedures for periodic checking of ,
I welders to determine whether or not they are conforming with the ;
t Applicants' weld rod control requirements, and whether or not the ,
weld rod issue stations are comploying with weld rod control '
procedures?
A. (Taylor) Brown and Root Project Welding Engineering is required by the ASME-approved Brown and Root QA' manual to maintain periodic surveillance of the rod issue stations, and welders to whom rods have been issued. Brown and Root Construction Procedure CPM-6.98 -
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. . 35 - )O 1
- and Welding Engineering Instruction ("WEI") provide . instructions for.
s th,ese activities, respectively. These procedures require surveil-
- e. lance of the rod issue stations every 14 days, and of the welder at ;
least once every 10 working days. A sample of the records of these :
. i
. surveillances have been reviewed by me. I found that the. records j
' were complete, that the required surveillances were done. No pattern !
l l .of discrepancies f 6r potential problems with either weld rod control l I
- or welder activities were identified. In addition, the Brown and i Root Corporate QA Corporate Office conducts periodic audits of the .
welder and weld rod issue station surveillances. I reviewed one of these audit reports, and it did not dis'close any significant problems. !
I am in the proc.ess of. reviewing additional audit reports. ,
=
[
i Q. Messrs. Collins and Smith, assuming that weld rods had been exposed
~
to ambient air at CPSES for 2-3 days, what would be the worst-case ,
effect on the quality of a weld on A-500 or A-36 steel which was fabricated utilizing such weld rods? ;
A. (CollinsandSmith) Porosity in the weld (which is due to arc instability and off-gassing of water vapor) would be the' principal indication, which should be detected during the normal visual inspection by the. welder and QC. Underbead cracking would be very unlikely to occur in this' situation.
Q. ! Messrs. Gilbert and Taylor, states that there was a .
practice at CPSES for welders to check out more weld rods than needed and not return all unused weld rods. asserted that this t
..* ,.u.....~...--.. . .
e .
practice which could
- result in welders using rods in an unauthorized manner. Malso stated that found weld rods which were aban-
~
doned but not accounted for. Are the Applicants' administrative e-controls effective in preventing these practices?
A. (Gilbert and l'aylor) The Applicants' weld rod control program, which includes a daily weld rod count for each welder, is a reasonably
' effective method to assure that: the correct weld rod is used by welders at CPSES. The program, by itself, does not provide complete
~
, protection against field exchanges of weld rods, if the used stubs were returned by the borrowers to the welder who had originally checked out the rods. The integrity of the individual welders is the primary means of assuring that this improper practice does not l occur. Additional assurance is provided by the periodic inspections '
! and QA audits of weld controls in the field as well as of the rod distribution stations.
.(Taylor) Over the period of construction at CPSES, NRC inspectors have routinely examined the Applicants' welding activities, including weld rod control. With respect to weld rod control, the emphasis was on whether the documented weld rod was being used in a given I weld under observation, and whether the weld rod was appropriate and properly traceable. There havei b een no identified findings indicating problems in these areas. What frequently may appear to be an "aban-donment," in reality, is that the welder has temporarily left his l imediate work station for personal or other needs. As part of my.
routine inspections, I have: observed apparently unattended weld rods l
- v. - -- -- . .
I i
, . . 4 in cans, buckets, or pouches. I have at times remained near these
" unattended" rods, and have found that welders did return to the dork station in c matter of minutes, s-1 4
4 l
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ATTACHMENT 1 t
PROFESSIONAL QUALIFICATIONS OF :
~
DAVID E. SMITH :
i s
March 80 Materials Enginesr to Materials Engineering Branch I Date Division of Engineering [
r Knowledgeable and experienced in welding, fabrication and inspection l of materials and other related engineering aspects of nuclear reactors. !
Serves as a qualified materials engineer in the Materials Engineering i Branch, Division of E'ngineering. Responsible for reviews, analyses, and !
evaluation of safety issues related to structural and mechanical components of reactor facilities licensed for power operation. Participates as a technical reviewer in evaluating applications for construction permits and operating licenses for power and non power reactors and operational . ,
and design modifications of DOE and D00-owned operating facilities exempt j from the licensing process. Chairman of American Welding Society B4 l Committee, " Mechanical Testing of Welded Joints".
l Specific assignments include review of operating license applications for compliance with Standard Review Plans for which the Materials Application ,
Section is responsible. #
0 l EDUCATION: Bachelor of Metallurgical Engineering, Rensselaer Polytechnic Institute, 1959
~
EXPERIENCE: (Prior to joining NRC) [
May 1967 to Materials Engineer, Naval Sea System Command, Code 05E2, ;
March 80 Washington, D.C.
Responsible for materials specifications, Hull material development programs, consultant on welding, fabrication and inspection of metal structures, material selection, corrosion, machinery materials problems.
The hull material development programs involved basic alloy research, ,
the making and processing of all structural metal forms (castings, forgings, l plate, extrusions, weld wire, rolled product), their fabrication (welding, [
cutting, machining, forming, painting), structural tolerances, and evalua- '
tion of structural performance, strength, toughness, corrosion, fatigue, compatibility with other materials, etc. I would interface with material manufacturers, suppliers, shipyards, and designers, and the type desks
! responsible for providing ships to the fleet.
. April 66 to Student. Acquired commercial and instrument ratings for May 67 single engine land airplanes. s Dec 64 to Manufacturing Engineer for Ling Tenco Vought. Centerline, 1 o
April 66 MI. Developed welding procedures for the LNACE missile l
i tankage assembly.
1 1
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r,,
.A '8 L
, I WILLIAM J. COLLINS Organifation: Office of Inspection anc' Enforcement, U.S. Nuclear
,, Regulatory Comission
Title:
Sen'ior Metallurgical Engineer
' Birth Date: '
Education: B.S., Metallurgical Engineering, University of Missour.i at Rolla - 1959 Experience:
1958- . Metallurgical Engineer / Technical Programs Present Technical Advisor in area of Metallurgy and
. Metallurgical problems relating to' construction. .
testing and operation of nuclear power plants.
Assist Headquarters and Regional IE staff in field inspections as required. Participated as a member on development comittees of National Standards.
NRC Regulatory Guides and NRC-RSR Nondestructive Testing and Corrosion Overview Comittees.
'(NRC/AEC) 1966-1968 Metallurgical Engineer / Supervisor - Quality Assur-ance and Reliability Division - Norfolk Naval Ship-yard - Responsible for training, examination and qualification of personnel in area of nondestructive testing. Developed standards and procedures for NDE, materials inspection and evaluation, Quality Assurance Program plans. Technical consultant to other naval repair facilities in areas of quality assurance, materials en metallurgical problems.gineering, Supervised metallurgy staff of and 8-136.
1959-1966 Comercial and Naval Ship Construction (Nuclear) -
Various titles and responsibilities in Materials Engineering Laboratory. Welding Engineers and Quality Assurance Staff Engineers at Newport News Shipbuilding & Drydock Company. (NNS&DD Co.).
1955-1959 Comercial Foundry - Supervisor with various responsi-bilities in non-ferrous and ferrous casting processes in Foundry Production during college tenure. Super-vised staff varied from 6-55 personner.
1951-1955 U.S. Navy Tenure - Qualified Patternmaker and i
l Foundryman in Class "A" Training School - Assigned Petty Officer in Charge of Pattern & Foundry Shops aboard Naval Repair Ship (USS AJAX 'AR-6). '
Supervised 6-24 personnel.
l
. .I
. C < ,w PROFESSIONAL QUALIFI 3TIONS j t
0F j
~
LESLIE D. GILBERT l Mr. Gilbert is a Reactor Inspector, Engineering Section, Nuclear Regulatory Commission, Arlington, Texas. Mr. Gilbert has held this position in Region IV l since July 1977 and in the course of his responsibilities has performed ;
inspections and investigations of nuclear facilities under Region IV jurisdic- ,
tion. ;
Mr. Gilbert received a' Bachelor of Science degree in Metallurgical Engineering j from California Polytechnic State College in 1963. He is a registered (
Professional Engineer in Quality Engineering in the State of California. e
- l Prior Work History -
1977 - Present Reactor Inspector - Serves as a member of the technical :
staff of Region IV with responsibility for inspection of l assigned power reactors during construction. ,
l*
1968 - 1977 Supervisory Weldina Engineer - Supervised the welding engineering staff with responsibility for providing technical direction for fabrication and repair of nuclear submarines at Mare Island Naval Shipyard.
1963 - 1968 Welding Engineer - Served as a welding engineer for the Welding Engineering Division of the Quality Assurance Office at Mare Island Naval Shipyard. Developed welding i
procedures and resolved welding problems associated with the fabrication and repair of nuclear submarines.
i D
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