ML20199H022
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UNITED STATES 8
f,,a NUCLEAR REGULATORY COMMISSION h
WA$HINGTON. D. C. 20555
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MAR i 3 1985 Docket No.:
50-445/446 MEMORANDUM FOR:
Vincent S. Noonan, Director Comanche Peak Project FROM:
Chet Poslusny, Program Coordinator l
Comanche Peak Technical Review Team
SUBJECT:
FEEDBACK REPORT TO ALLEGER A-46 On November 1, 1984, Alleger A-46 was interviewed by telephone by D. Jeng, R.C. Tang, R. Bangart, and D. Hunnicut.
D. Jeng, acting in behalf of the TRT Reviewer, Mr. R. Philleo, explained the TRT's investigative results.
The alleger is concerned with cracks in the concrete pad below the reactor vessel (AC-44). The TRT reviewed nonconformance report C-650 and evaluated the conclusion drawn by a G&H engineer concerning the cracks in the concrete pad. An NCR Region IV engineer also evaluated this issue and arrived at the same conclusion as the G&H engineer did.
The TRT arrived at the following conclusions:
(1) the pad is heavily reinforced with well distributed rebars to resist main loads (e.g., earthquake and accident pressure loads) so initial cracks like the ones observed would not affect the load carrying capacity of the pad, (2) the crack was unavoidable because of the massive nature of the pad which was poured in one placement without providing for construction joints, (3) the cracks found were optional design using a two-pour scheme, (4)y conceived by the designer in his similar to the construction joints originall rigid forms used in the annular space of the pad prevented normal shrinkage of the concrete, contributing to the formation of cracks, (5) the cracks were repaired using epoxy to prevent rebar corrosion due to ingress of water through the cracks, and (6) the crack formed at mid span of a 20-foot beam would not affect its load carrying capacity.
The TRT investigation determined that reinforced concrete structures are nonnally designed to have well controlled cracks in order to carry their design loads.
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The alleger indicated his concern relating to cracks in concrete pads have been fully resolved. He comended the TRT for thoroughly evaluating his Concern.
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Chet Poslusny Program Coordinator Comanche Peak Technical Review Team cc:
D. Eisenhut B. Hayes J. Youngblood D. Jeng
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M December 18, 1984 ASLB FINDS STINERS TO BE WITHOUT CREDIBILITY The Atomic Safety and Licensing. Board has concluded that Henry and Darlene Stiner, former Comanche Peak workers who made numerous allegations concerning welding practices, are not credible wi.tnesses.
"The record demonstrates that Mr. and Mrs. Stiner are individuals who possess memories that produce different versions of the same facts when questioned at different times and possess selective recall of facts and details favorable to their claims, accompanied by a failure of memory as to other facts regarding those claims," the board concluded in a memorandum issued late i
Monday.
In contrast to the Stiners';'the board said it " finds no inconsistencies from (the company's) witnesses which would call into question their credibility."
The ASLB ruled that with two ' exceptions, the allegations raised by the Stiners are without merit. The board said it still had questions regarding two. welding practices, but said "there is reasonable. assurance that these allegations are not reflective of any condition that could adversely impact the safe operation of the plant."
l The board said part of its conclusion that the Stiners had no credibility stemmed "from our realization that both of the Stiners misunderstood the technical foundation for the weave welding procedure which was.the crux of a substantial portion of their complaint about the plant."
Furthermore, the board said it found that Henry Stiner was fired because of a long-standing absenteeism problem at work, not, as he claimed, because he reported a problem to a QC inspector.
The board noted a number of inconsistencies and contra-dictions in Henry Stiner's testimony last September in hearings in Fort Worth and pointed out Stiner's " willingness to provide adverse testimony to (the company) without sensitivity to whether
'l the matter is beyond his expertise."
Darlene Stiner "apparently relied heavily on what her husband told her" and " responds to questions by significantly overstating the facts," the board said.
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LBP-84-54 UNITED STATES OF AMEP.ICA l
NUCLEAR REGULATORY CCMMISSION Before Administrative Judges:
Peter B. Bloch, Chairman Dr. Kenneth A. McCollom Dr. Walter H.. Jordan la the Matte
- of Docket Nos. Er.-445-OL
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50 146-01
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TEXAS UTILITIES ELECTRIC CCMPANY, et al.)
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(Comanche Peak Steam Electric Station.
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Units 1 and 2)
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b MEMORANDUM (Concerning Welding Issues) e i:
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December 18, 1984 I
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-i-TABLE OF CONTENTS Page l
I.
BACKGPOUND 2
II.
FINDINGS OF FACT - CONTESTED ISSUES 3
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A.
Witnesses and Testimony 3
1.
CASE 3
2.
Applicants.
5 3.
NPC Staff 7
B.-
Credibility 8
1.
Henry Stiner.
10 2.
Darlene Stiner 15 C.
Contested Issues 19 1.
Weave Welding 70 a.
Allegations of Weave. Welding do not Reflect a Breakdown in the OA/nC 21 Program b.
Safety Implications of Allegations of Excessive Weave Welding 31 35 2.
Downhill Welding a.
CASE's Allegations Regarding Downhill Welding do not Substantiate a
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Breakdown in the OA Program 36
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b.
Safety Implications of Downhill Welding 42 1
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Weld Rod Control a.
Allegations of Weld Rod Centrol Violations Do Not Substantiate a Breakdown in the OA/0C Program 46 b.
Safety Implications of Weld Red Control violations 57
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59 4.
Welding of Misdrillec Holes 71 5.
Preheat Requirements.
72 a.
Preheat b.
Safety Implications of Violation of Preheat Requirements 75 III. OTHFP PATTERS CONSIDERED 77 77 IV.
CONCLUSION 78 Y.
ORDER G
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PEP 0pANDUM (Concerning Welding Issues)
In this Memorandum, we decide issues raised by Darlene and Henry Stiner! Mr. Stiner was a welder at Comanche Peak. Mrs. Stiner, his wife, was both a welder and quality control inspector at the plant.
Because these witnesses have direct knowledge of the plant, we have taken their testimony with great seriousness, involving many hours of hearing time.
In deliberating on what we have heard, we have reluc'.antly come to the conclusier that neither of the Stirecs is a credible witness.
Our conclusion about the Stiners' credibility is more fully explained in the body of our opinion. Part of the basis for our conclusion came from our realization tnat both of the Stiners misunderstood the technical foundation for the weave welding prncedure which was the crux of a substantial portion of their complaint about the plant.
Furthermore, we find that Henry Stiner had a long-standing absentee problem at wo-k and that he was discharged from *be plant because of his absenteeism, not because he gave informatien to a OC inspector about a gouge in a pipe preceding the three day absence that l
precipitated his termination. As a result of reaching this conclusion about the Stiners' credibility, we have found it appenpriate to use Applicants' proposed partial initial decision as the framework within which to write our decision.
l Despite tn'e Stiners' general lack of credibility, they have l
l raised questions about some welding practices that are of concern to us and that the Cannission's Staff continues to investigate. To the extent that these concerns are corroborated by others, issues raised l
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by the Sliners may later be found to be meritorious. For the time, howevec,"these issues are the Staff's concern. We expect a Staff report following which we will make a determination concerning whether these should be issues in this case.
1.
BACKGROUND Thi-f: the t" ed cecisicn concerning 111egetions regarding welding at the Comanche Peak Steam Electric Station ("CPSES"), Units I and ?, raised by two witnesses of intervenor Citizens Associations for Safe Energy (" CASE"), Darlene and Henry Stiner. The first, LBP-83-43 Proposed Initial Decision, 18 NRC 122 (1983) (pp. 26-41), resolved all but four issues related to their allegations, viz., weave welding, downhill welding, weld rod control and welding of misdrilled holes.1 The second decision, LBP-83-60, Memorandum and Order (Emergency Planning, Specific Quality Assurance Tssues and Board Issues),18 NRC 672 (1983), discussed weave welding, repair of plug welds, downhill weiding and weld rod control.
In response to objections to the July 29,19P3 Proposed Initial Decision filed on August 27, 1983, by Texas Utilities Electric 1
This first decision was based on testimony presented at hearings held on September 13, 1982, e.g., Testimony of Henry Stiner (CASE Exhibit 666) and Darlene Stiner (Case Exhibit 667) i received into evidence at Tr. 4202 and 4174, respectively; Rebuttal Testimony of C. Thomas Brandt, ~et al.
(Appifcants' Exhibit 141), received into evidence at Tr. T65T; and NPC Staff Exhibits 13 (at 98-99) and 178, both received into evidence at i
Tr. 2336.
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Company', *g al. (" Applicants"), by Memorandum and Order of September 29, 19Q3 at p. 24, the Board closed the issue of weave welding raised by the Stiners in favor of Applicants. Subsequently, in a February 10, 1984 Licensing Board Order, the Board reopened the weave welding issue.
To resolve these remainino open issues, hearings were held on Feb-uar, ?3, Mar:h 10-23, aro April 24, 1984 Du rf r.a. ther* hesefngs, t9eScardexpEdedtheissuestobeaddressedtoincludeallegt-ions made by Mr. Stiner regarding. preheat of weld joints (CASE Exhibit 919 at 9; Tr. 10799, 10807, 10825).
In sum, the welding issues raised by the Stiners which are the subject of this Partial Initial Decision relate to weave welding, downhill welding, weld rod control, welding of misdrilled holes and preheat.
II.
FINDINGS OF FACT - CONTESTED ISSUES A.
Witnesses and Testimon.y 1.
CASE Mr. and Mrs. Stiner each testified on welding issues addressed in the July 29, 1983 Partial Initial Decision, i.e., CASE Exhibits 666 and 667, respectively.
In addition, they jointly sponsored testimony introduced at the second round of hearings on this issue (CASE Exhibit 919, received fato evidence at Tr. 9979). However, major sections "of this testimony were stricken, including Attachment B of their testimony referencing a welding handbook ( m e.g., Tr. 9937, 9960, 10262,10287,10325,10494,11069).
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TheStiners were offered as expert witnesses with regard to welding activities at Comanche Peak. Mr. Stiner was first hired on December 5,1979, and shortly thereafter was trained as a welder. He was qualified a's a structural welder on February 11, 1980. Curing his first period of employment at Comanche Peak, he worked 41 weeks during
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which he was absent a total of six weeks and worked 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> or less dring an additi:nal eight weeks. Hr. Stiner's last day of work (for his first tem bf employment) was November 26, IF. However, he was rehired and was again qualified as a structural welder on ilune 22, 1981. He welded for approximately three weeks before he was again 6
teminated, following a three day absence from work.
Mrs. Stiner was in a qualified welding position (though not welding the entire time) from February ?7,1979 to August 3,1980.
(Applicants Exhibit 177 at 5.) During the summer of 1980 Mrs.- Stiner began work as a welding OC inspector. Tr. 4130.
The Stiners stated that they were." certified to weld to both ASME and AWS 01.1" (CASE Exhibit 919 at 1-2). More specifically, they were qualified to two production welding procedures (Procedure,s 11037 and 10046), one relating to a portion of the ASME Code and one to a portion of the AWS D1.1 Code. These procedures qualified them to weld "with the shielded metal are process only on low carbon steel material such as pipe supports, and not on pressure piping joints, stainless steels or with other processes such as gas tungsten arc.
(Tr.
9981-82.) Mr. and Mrs. Stiner's testimony was found to be qualified as expert welders within the limited areas of their qualifications.
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In additien, based on Mrs. Stiner's experience in quality centrol inspection of welding at CP3ES (CASE Exhibit 667 at 7-14), she was accepted as an expert witness concerning cuality control.
Neither Mr. nor Mrs. Stiner was offered as an expert in metallurgy or any phase of engineering (Tr. 10755,10774,11047),and the Board gives no weight to their testimony with regard to issues relating to those discipiir.es (Tr. 10283,10776).
i 2.
Applicants Applicants presented 10 witnesses (as described below) to respond to the allegations of Mr. and Mrs. Stiner. These witnesses jointly sponsored testimony during the second round of hearings on these allegations.
(App 14 cants Exhibit 177, received into evidence at Tr.
9976.)
Messrs. S. Fernandez, I. Pickett, and A.M. Braumu11er are three welders still employed at CPSES who were on Mr. Stiner's crews. Each welder has at least four years of welding experience at CPSES, and Mr.
Braumuller has a total of 28 years experience as a welder.
(Applicants Exhibit 177 at 3-4.)
i Messrs. F.E. Coleman and C.R. Brown are two welding foreman 1ssigned to Mr. Stiner's crews during his employment at CPSES. The welding foremar),was a non-supervisory technician who would constantly monitor and assist the work of the five to 15 welders on his crew.
Mr. Coleman also worked as a welder in the same areas as Mrs. Stiner, and Mr. Brown welded in the same areas as Mr. Stiner during Stiner's first term of employment. Messrs. Coleman and Brown heve each been y,q ~ -
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employed' at CPSES for over four years in welding-related positiens.
Both ap currently DC Level II inspectors.
(Applicants Exhibit 177 at 2.)
l Messrs. J. Green and E. Hallford were the foreman and general foreman, respective'y, over Mr. Stiner's crew during Stiner's secend term of employment. Both have been employed at CPSES for apprnrimately
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'ive years.
(Applicants Exhibit 177 st 3.)
Fr. C.T. Brandt is the QA Staff Engineer at CPSES. He was formerly Mechanical / Civil CA/0C Supervisor responsible for all non-ASME Mechanical and Civil Ouality Control Activities and had j
overall responsibility for training, staffing and personnel development o' Civil and Mechanical inspectors and QA personnel, including Mrs. Stiner. He has been employed at CPSES in OA/0C related 4
j work for f aur years. Mr. Brandt is also a member of the American 4
I Welding Society.
(ApplicantsExhibitlalatAttachmentA.)
Mr. W. Baker, Senior Project Weldi.ng Engineer at CPSES for six years, has over 28 years of diversified experience in the welding industry. His experience encompasses 15 years of pressure vessel and 1
power plant construction. He is a member of the American Welding Society and currently a Senior Project Welding Engineer at Brown &
Root.
(Applicants Exhibit 177 at Attachment A.)
Mr. M. Mugente has 25 years experience associated with the design, engineering, fabrication, material selection, and examination and erection of engineered equipment and systems, including pressure vessels, pumps and piping. Mr. Muscente is a member of the American Welding Society, The American Society of Mechanical Engineers and is a
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registekd~ Professional Engineer in Quelity Engineering in California.
He is currently the Manager of Materials Engineering at Brown & Root.
(Applicants Exhibit 177 at Attachment B.)
Applicants' witnesses Brown, Braumuller, Fernanc'ez, Pickett, Coleman, Brandt and Baker are recognized by the Board as expert welding witnesses. Applicants' witnesses Baker and Muscente are recogr.ized 6 the Board as expert witr. esses ir. the area af metalluroy.
Applicants' witnesses P.ra.ndt, Celenan and Brcwn are recognized by the Board as experts in quality control.
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NRC Staff I
The NPC Staff presented the testimony of Messrs. W. Collins, L.
Gilbert, D. Smith and R. Taylor. These witnesses jointly spnnsored testimony provided during this second Yound of hearings on welding allegations.
(NRC Staff Testimony on Welding Fabrication Concerns Raised by Mr. and Mrs. Stiner ("NRC Staff Testimony") and Addendum to Page 77 of NRC Staff Testimony on Welding Fabrication Concerns Raised by Mr. and Mrs. Stiner ("Sta*f Addendum"), both received into evidence at Tr. 12146.)
Mr. Collins is a Senior Metallurgical Engineer with the Office of inspection and Enforcement, U.S. Nuclear Regulatory Comission. He has approximateJy 25 years experiarce in metallurgy,16 of which have been as a technical adviser in the area of metallurgy and i
metallurgical problems relating to construction, testing and operation of nuclear power plants.
(NRCStaffTestimonyat1andAttachment1.)
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Mr. hi1bert is expert in welding and ron destructive examination and is.a Reactor Inspector responsible for inspecting nuclear power plants located in Region IV. He has 14 years experience in welding and seven years experience as a Reactor Inspector. Mr. Gilbert is a registered Professiene.1 Engineer in Quality Engineering in the State of California.
(NRC Staff Testimeny at 2 and Attachment 1.)
Mr. Sr,4th is a materials enoineer respo.niole tnr the -eview of mater als and fa::rication processes used dn the construction of d
nuclear power plants, as well.as the evaluation of material and weldment failure in nuclear power plants. He has 17 years experience as a materials engineer, including four years with the Materials Engineering Branch of the NRC.
(NRC Staff Testimony at 2-3 and.)
Mr. Taylor is employed by the NRC as a Reactor Inspector in the Division of Reactor Se#ety and Projects, Region IV.
In this position, he coordinates all sa#ety-related inspection efforts relative to the NRC Region and the site. He was assigned to Comanche Peak as' Senior NRC Resident inspector for Construction. Mr. Taylor is a registered Professional Engineer in the State of California.
Prior to this, from 1976 to 1978, Mr. Taylor was the construction project reactor
" inspector at the South Texas Project.
(Staf# Exhibit 9.)
B.
Credibility.
Prior to the hearings, the Board determined that there wert direct conflicts in the testimony of witnesses for CASE and the j
Stin2r Welding Issuss:
9 Applicant's regarding important factual allegations. Accordingly, in an attempt to elicit accurate factual infonnation with regard to compliance with welding precedures and the quality assurance program involving welding, the Board directed ifmited sequestration of all witnesses who would provide testimony on craft activities at CPSES recarding these issues, The purpose of this sequestration was to pmhibit :woca.ication between the witnesses co that they wou'd net
<r.sw da*. one abether had said at the time each testified.
(Tr.
9916-17.)
Due to the extensive direct conflicts of factual evidence, the 1
credibility of each witness.was weighed carefully in evaluating the evidence in the record.
Applicants' witnesses provided credible and consistent testimony on direct and in response to the cross-examinatinn questions of all parties.
In addition, in response to cross-examination questions Applicants' witnesses stated that they.were instructed to tell the absolute truth when testifying and that if their testimony reflected problems with the plant, it would not adversely impact their employment at the plant (Tr. 11518-9, 11652, 11703, and 11744-5).
In short, the Board finds no inconsistencies from Applicants' witnesses, I
which would call into question their credibility. The Board makes a similar finding.with respect to the Staff's witnesses.
However, the Board finds that Mr. and Mrs. Stiner's allegations must be considered in light of inconsistencies in their testimony and demonstrated lack of credibility.
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Henry Stiner Henry Stiner has been convicted of three felonies: Theft (State of Texas) in 19P0 (Applicants Exhibit 183 previously received into evidence in this proceeding at Tr.10,579); Robbery with a fireann (State of Oklahorna) in 1979 (4pplicants Exhibit 18?, previously received into evidence at Tr.10,579); and Possessing Mari,fuana with the Mte-t to Deliver (Sta'e of Arkansas) in 1876 Upclicants Exhibit' 121, previs sly reo: Sed into evidence at Tr.10,579). The Boerd finds that this is relevant evidence.
See Rule 609 of the Federal Rules of Evidence, and the accompanying notes thereto.
Mr. Stiner's testimony also indicate: that he has had a tendency to elaborate on testimony adverse to Applicants as the proceeding crogresses'.
For example, in earlier testimony filed in this proceeding, Mr. 4tiner stated that he per#ormed welds on misdrilled holes several times (CASE Exhibit 666 at 18).
In subsequent testimony Mr. Stiner changed from several repair wel.ds on misdrilled holes to at least 20 or 30 such welds (CASE Exhibit 919 at 22) and during redirect examination Mr. Stiner testified that he perfonned hundreds of " plug i
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welds" tnroughout the plant (Tr. 10672). Mr. Stiner subsecuently testified that he had perfonned 20 or 30 plug welds in a single day,
{Tr. 10699-70).
Mr. Stiner, sometimes gave conflicting testimony. For example,'
during previous hearings, Mr. Stiner testified that he never left his weldrodsoutofthecan(Tr. 4301-02). When asked this question again during the March 1984 hearings he directly contradicted his previous testimony by stating that he did leave weld rods out of the i
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Stin:r Welding Issu:s 11 can as muc6 as any other welder did (Tr.10856).
In attempting to explain the obvious inconsistency in his testimony, the following discussion occurred:
BY MR. REYNOLDS:
0.
Do you have an explanation ffor the inconsistency]?
A.
Yes I do.
I believe at the time the line of questbning nr.d '.he manner that it was being --
tne 'ine of, I call it interrogation, wen being handled, I thin *r. maybe I jus + mist.rderstocd what you were trying to get to and in what reference you were trying to actually set me up or whatever.
And that's probably the reasons for the inconsis-tencies in the testimony there and now.
JUDGE BLOCH: Mr. Stiner, your job is never to figure out what the lawyer is trying to get to.
If he asked you "do you put things into a rod can," you just answer what the truth is. You have no i
business trying to figure out what he's trying to get to.
I don't understand that explanation.
Did you or did you not put these things into the
-- leave your rods out of the rod can?
THE WITNESS:
I did leave them out.-
JUDGE 8 LOCH: Why do you think you said you didn't in the last testimony?
THE WITNESS:
Like I say, I was in such a fog when I was up here testifying the first time, that I'm liable to have actually said anything. That's w6y I try to go back and find all these inconsistencies. But I'm sure that 1 did skio.
over some of them that I didn't catch, like that one instance.
I would have clarified it if I saw it when I read through the transcript.
It's not that I intentionally lied.
It's.iust a case where at the time of the quest.ioning it was not in my mind to grasp.
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The Board' Chairmen noted at the time "that this seriously aHects his credibility" (Tr.10861).
As arother example of an inconsistency, Stiner stated in his pre-filed testimony that his work always looked good to QC and they almost always ended up " buying it ou" '(CASE Exhibit 666 at 34; Tr.
1067a). However, during Pr. Stiner's cross-examination he stated that mery of his welds were rajected (~r. I'.005).
As ancther example, Mr. Stiner initia11y testified th*t workers violated weld rod control procedures regarding retention of rods because "they are under so much pressure to get the work done and get j
the hangers up that they try to do anything they can do to speed up work" (CASE Exhibit 919 at 19). However, in response to an inquiry that appeared to bring into question the logic of such a position, Mr.
f Stiner reversed himself and testified that he did not hold out rods because he was under time pressure.(Tr. 11126-8).
i As another example, Mr. Stirer testified that under the direction of Cliff Brown and Jimy Green, he perfomed a downhill weld on a 7
particular hanger in a limited access area (Tr.10622).
Significantly, when Mr. Stiner was confrnnted with conflicting testimony regarding whether Mr. Brown could direct him to perform a.
feeld, he testified that M'r. Erown did not direct him to make this downhill weldt.rather Mr. Brown made the weld himself (Tr. 10967-75, especially 10967 (which references Tr.10622) and 10975).
As another example, Mr. Stiner testified that while he was
" illegally" repair welding misdrilled holes that Messrs. Brown, Coleman and Green stood watch for OC (Tr. 10685-6). Later however, he
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e testified'under cross-examination that only Fred Coleman had stood watch for him while he was repairing misdrilled holes (Tr.11C31).
Mr. Stiner testified that Mr. Brown never stood watch for him for OC f
inspectors in any respect (Tr.11031). Mr. Stiner after being i
infomed by Applicants' counsel of an inconsistercy with previabs I
testimony then stated that Mr. Brown did stand watch for him once (Tr.
l 1:G32).
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Mr. Stiner'a'te testified that it would take him apprer'mately two minutes to perfom a repair weld en a 11/4 inch hole in a twn inch thick plate, excluding blending of the weld and base metal l
I surface (Tr. 10698). Further, Mr. Stiner stated that it would only take two weld rods to perform such a repair (Tr.11158). Staff's witnesses testified that based on simple volumetric calculations it was not possible to do what Mr. Stiner stated. They testified that i
disregarding all other factors, such as cleaning the weld surface, i
caanging weld rods, or turning the member, it would take no less than 20 minutes and 20 to 25 weld rods to complete the weld on the misdrilled hole cited by Mr. Stiner.
(StaffTestimonyat76;Tr.
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12250-51.) Based on independent testing Applicants verified the Staff'stestimony(Tr. 11767-68).
Mr. Stiner testified that it was faster to weave weld than to perfom a strir!ger (line) weld, and accordingly, supervisors directed welders to weave weld to accelerate production (Tr. 10863,10896).
However, in response to cross-examination of earlier testimony, Mr.
Stiner stated first that it took approximataly the same length of time to perform a stringer and weave weld; next, that the strinner weld M.Psee,
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took longet; and finally, that the weave weld took much longer (Tr.
4361-6)).
In explaining how he knew that he was allegedly performing an l
illegal " plug weld" on ASME hangers, Mr. Stiner changed his position in mid-sentence as illustrated by the following discussion:
JUDGE BLOCH:
Do you ever know of having done one fillegal
" plug weld") that was an ASM support?
THE Wi,'.E05: Yes, sie.
JUDGE BLOCH: How do you know it was an ASME support?
THE WITNESS: Because it was a Class 3.
JUDGE BLOCH: How did you know it was Class 37 THE WITNESS: The package numbers will indicate on the end of the package number, A35R or A33R, an A32R.
JUDGE BLOCH:
They brought this material to you, which was an illegal weld, together with the package that legally went with it, just to show you that it was an ASME weld?
THE WITNESS: No 90t to show me that the package -I mean most of the time you know when you're working in a particular area, according to what class of hanger you're working on.
(Tr.10,673-741 Mr. Stiner's testimony concerning the relationship of "are blow" to downhill welding is illustrative of bias, consisting of his willingness to provide adverse testimony to Applicants without sensitivity to.whether the matter is beyond his expertise. Mr. Stiner testified that downhill welding is useful to compensate for the "are blow" caused by the magnetization of the welded metal. Tr. 4246-47 CASE Ex. 666 at 45. Metal, according to Mr. Stiner, becomes
" magnetized" when cut with a welding torch. Tr. 4?46. This T pTt8**
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15 assertio'n','however, indicates total lack of metallurgical expertise.
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" Arc bl.ow" is the phenrxnenon resulting in the deflection of the arc due to a defomation in the magnetic field. Applicants' Ex. 177 at 15 (Baker,Muscente). This deformation in the magnetic field is caused not by " cutting with a welding torch," but by welding close to ground or into obstructed areas such as corners. & Small amounts of are nlow arc beneficiC M the talder becatise i' helps Mm forin the bead sha:e, centrol helter slag, ar.d acnieve proper pe.netration. Jd,.
Arc blow is a potential problem only when using amperage rates in excess of 250 amps, for rate more than double that specified (90-120 amps) for welders at CPSES. jd.
2.
Darlene Stiner With regard to her testimony, Mrs. Stiner apparently relied heavily on what her husband told her. For example, Mrs. Stiner relied on Attachment B to her testimony in responding to several questions l
l concerning why she believed and testified that weave welding caused l
excessive heat input that would result in damage to the paren+ metal l
l (e.g.,Tr.
10305-10). However, in subsequent cross-examination she revealed that she had not even read Attachment'8, but rather her I
husband had discussed it with her and she agreed with his views on the l
subject.
She 4.tated that the Attachment related to her husband's testimony, not her testimony (Tr. 1054245).
Mrs. Stiner responds to questions by signi*icantly overstating the facts.
For example, she testified that her supervisor told her 1
that she "would be fired" if she didn't accept a certain henger (Tr.
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Stin:r Welding Issu:s:
16 t
10276). ' However, in responding to another question, she related the substance of the conversation, which did not include a threat to fire her (Tr. 10276-77). The Board cautioned Mrs. Stiner to not overstate the facts (Tr.10277). As another example she stated that a QC inspector had the authority to order that a hanger be cut down.
However, based on other questions she admitted that she didn't know if an inspectSc had that authority (Tr.10P78-7C). As arother exampie, i
she testified that her supervisor had not given certain weld reds that she had found; subsequently, to Tom Brandt she admitted that she did not know (Tr. 10474-75). As another example, Mrs. Stiner testified that "she is sure" that Mr. Brown does not monitor his welders and watch them make their welds so that he would know if they were weave welding contrary to procedures (Tr. 102001. However, on ernss-examination she testified that Mr. Brown was never her foreman, she did not know he was a. foreman and she was simply speculating-(Tr.
10291).
Mrs. Stiner testified that welders did not generally have and could not easily obtain pencil grinders (Tr. 10235-86). Other welders and foremen (Messrs. Pickett, Braumuller, Fernandez, Coleman, Brown and even Mr. Stiner) testified that they had pencil grinders and, when asked, they testified that penc11 grinders were readily accessible in the areas in which they were working (Tr. 10614, 11469, 11547, 11621-22,11643,11666). On this direct conf 1fet of testimony, we find that Mrs. Stiner lacks credibility.
In her testimony, Mrs. Stiner made one specific allegation regarding excessive weave welding by one of Applicants' witnesses, Mr.
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Braur:uller." However, this testimony was inconsistent and lacking in credibility. Significantly, when testifying Mrs. Stiner had notes allegedly made at around the same time as the events in question. (The noteswerenotadmittedintoevidence.) The Board notes below only a few of the inconsistencies in this testimony:
e Mrs. Stiner testified that on March 24, 1981, while inspecting a companion hanger, she first noticed Mr.
5 sumu11er makine excassive wetva welds en hangv R X-0397-14A25R iTr. 10161, 10183-85).
She testified that, she inspected the hanger fo-a final inspection on March 26 and again saw Mr. Braumuller weave welding on the hanger (Tr. 10156,10164). However, in earlier testimony she had stated that her initial inspection was on March ?6 and the final inspection occurred later (CASE Exhibit 667 at 25; Tr.10185). Mrs. Stiner provided a long explanation attempting to reconcile the difference (Tr. 10185-89). At bottom, however, her earlier testimony was, at best, incomplete. Mrs.
Stiner testified that after her inspection on March 26 she returned on March 27 and wrote an NCR on the hanger (Tr. 10173). Again, conflicting earlier testimony was presented that the NCR was not written until several days after the " initial" inspection of March 26. CASE Exhibit 667 at 25. This time Mrs. Stiner just admitted that the earlier testimony was wrong (Tr.10196). Te sununarire, at the conclusion of the hearing on February 23, 1984, Mrs. Stiner's story was that she had seen Braumuller weave weldi6g on the hanger on March P4 and l
26, 1981, and had written an NCR on March 27.
(Tr.
10196.) When the hearing reconvened over three weeks later, Mrs. Stiner, responding to a Board question precipitated by an inconsistency, testified that she had not seen Mr. Braumuller welding on the hanger on March 24; indeed, the first tire she noted weave welding on the hanger was nn March 26, 1981 (Tr.
10454-56).
e
. Prs. Stiner testified on many occasions that she had' never approved the hanger due to her concern over the alleged weave welding (Tr. 10273). Yet, Applicants l
presented an Inspection Report dated April 8,1981 that was signed by her (Tr. 10266) indicating that the
~
hanger was satisfactory (Tr. 10763-64). Mrs. Stiner testified that while she doesn't remember signing it.
she may have (Tr. 10273). She testified that she must
, have signed it under threat of being fired (Tr.10765, b
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I Stiner Welding Issu:s:
18 i
)
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10261). Later however, she admitted that there was no direct threat of firing (Tr. 10276-77).
Mrs. Stiner testified that the NCR she had written had
)
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been voided and Applicants had no record of it. The Board reminded Mrs. Stir.er that even voided NCRs are j
given numbers. Mrs. Stiner did not know and could not find the number even though she kept a log of her significant work activities and stated that she had 4
i written it down.
(Tr. 10144-45.) On the Inspection j
Report for this hanger, that we conclude was signed by i
Mrs. Stiner on April 8, however, she had written "not l
applicable" unde
- the sect.4on for listing cutst?nding NC.Rr.
(Tr. 10767. ) She reconciied the testimony by stating that the NCW had been voided and she had no num er to put in the box. However, she earlier testified that she had not known what had happened to the NCR.
(Tr. 10267.) Mrs. Stiner could not provide a satisfactory explanation as to why she wrote "not applicable" in this section of the inspection Report if she had reported an NCR which, to the best of her knowledge, had not been dispositioned (Tr. 10267-68).
e Mrs. Stiner's notes purported to be contemporary l
records of events taking place at the plant. However, key entries about the disputed hanger were in blue pen.
4 These were the only entries in blue pen. Mrs. Stiner was unable to explain this aberration in a convincing way. We conclude that these blue-penned entries were not conteworaneous 5t wa, m:de et a later adate tn support Mrs. Stiner's testimony.
(Tr. 10,172-74, see also10,520.)
s On this record, Mr. Stiner is shown tn be a convicted felon; further, the record demonstrates thet Mr. and Mrs. Stiner are individuals who possess memories that produce different versions of 1
the same facts when questioned at different times and possess f
selective recal,,1 of facts and details favorable to their claims.
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accompalii'ed by a failure of memory as to other facts regarding those 2
claims s C.
Contested Issues The welding issues raised by CASE and addressed in this Partial Initial Decisien relate to weave welding, dowchill welding, weld rod cent-el, weld re air of misdrilled holes and prehetting cf welds.
In addressing each'of these issues in the centext of the quality assurance contention raised by the intervenor, the Board examined and weighed the testimony presented to detennine if it reflected systematic or significant violations of the QA/DC program indicative of a breakdown in the program.
In addition, in that resolution of many of the issues involved balancing conflicting testimony raising credibility issues, the Board attempted to address the probable impact on plant safety assuming the allegations were well founded.
)
1.
Weave Welding l
Weave welding as defined by Section IX of the ASME Code is a weld with significant transverse oscillation (NRC Staff Testimony at 4; Applicants Exhibit 177 at 7). The AWS DI.1-1075 Code also defines a, weave weld as a type of weld bead made with transverse osef11ation, l
f
)
~
2 additional inconsistencies are contained in their While many(See e.g., Tr. 10744-58, 11153), the Board will not testimony take the time to detail them.
However, some additional inconsistencies in their testimony are noted below in discussions of specific allegations, t
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Stiner Welding issu:s 20 L
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Weave welding may be distinguished from a stringer bead, which is defined as a type of weld made without appreciable transverse oscillation.
(NpC Staff Testimony at 5; Tr.17153.) Neither the ASME Code nor the AWS Code prohibits weave welding (Applicants Exhibit 177 at 7; NRC Staff Testimony at 5; Tr. 11222). Fur *,her, weave welding is i
1 l
nnt in itself contrary to applicable welding procedures used at Ceunche. Peak ur 1ess tn'e f f..s1 weave width is in ex:ess e# 'c"r '. ins the dianster of the weld roo being used.
For example, if the welding material specified to be used is 1/8 inch diameter ef ectrode, it would be acceptable to use an oscillating weld technique up to 1/2 inch wth (four times the diameter of the weld rod).
(Applicants Exhibit 177 at 7.M.)
CASE's concerns regarding weave welding were based on Mr. and 3
Mrs. Stiner's allegations that although excessive weave welding was 3
The record reflects that Mr.
and Mrs.
Stiner's initial allegations were based on a belief that all weave welding, oc matter how slight, was unauthorized (Applicants Exhibit 177 at 7-9; Tr.
- 9991, 10589-90).
Henry Stiner subsequently acknnwledged that weave welding was not 4ptmissible at Comanche.. Peak if the bead width did not exceed four core diameters.
See Tr,10,590 (H. Stiner); CASE Ex. 919 at 6 (H.
Stiner).
He~TIien stated that his concern had always been for (Footnote Centinued)
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77 s
contrary tg procedures at CPSES, it was conson practice and foremen even di,rected welders to use improper weave welds (Tr. 4147-48, 4210-11, 11098-11103; CASE Exhibit 919 at 9-10). Mr. and Mrs. Stiner were concerned that weave widths in violation of procedures could result in excessive heat input into the weld joint (CASE Exhibit 918 at 5; Tr. 10305, 10591, 10785). #
As discussed wre fully below, the record reflects that the allegations raised by Mr. ar.d Mrs. Stiner regarding weave welding are not reflective of systematic or significant violations of the QA/0C program.
In this regard, no specific instances where violations were alleged to have occurred were substantiated. Fur +.homore, the record reflects that even if Mr. and Mrs. Stiner had violated procedures by welding in excess of weave width procedural requirements as they alleged, excessive heat input in the welds they made would not have had a significant adverse impact on plant safety.
a)
Allegations of Weave Welding do not Reflect a Breakdown in the OA/0C Program Henry and Darlene Stiner testified that excessive weave weiding in violation of procedures was a widespread problem at CPSES (CASE
} Footnote Continued)
- excessive, weave welding (Tr.10.590 (H. Stiner)).
However,'we find that the earlier testimony is lacking in credibility, thereby seriously questioning the basis for CASE's allegations regarding weave welding.
During the hearing, the Board detemined thet the issue of weave welding included the impact of heat input during weeve welding (Tr.9947).
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Stiner Welding Issues:
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t Exhibit 9k9 at 6, 9,14).
Mc. and Mrs. Stiner testified that under the dimetion of their supervisors they had welded and had observed others welding with weave widths in excess of procedural requirements. While they stated that such violations routinely occurred, they were only able to identify a few specific hangers where they believed unauthorized weave welding ecturred. Thetwos;e-ifi incidentsidertific[invc1 veda.
Braumu11er, one of Appficants' witnesses who had previously testified that he had never perfomed weave welding.in violation of procedures.
(Applicants Exhibit 177 at 9; Tr. 11675.)
(The two specific incidents identified are addressed below.)
In response to these allegations of widespread weave welding in violation of procedural requirements (i.e., who,re the weave width was over four times the diameter of the weld rod used), Messrs.
- Fernandez I Pickett and Ersumuller (welders still remaining at CPSES 5
Mr. Stiner alsn alleged that Fred Coleman directed him to beat the flux off a rod, insert it into a weld gap and weave weld over it (CASE Exhibit 919 at 9).
However, he was not able to identify a specific harger or weld which could be investigated.
In any event Mr. Coleman presented contradictory testimony (Tr.
11538).
Further, other welders who were under Mr. Coleman on the same crew as Mr. Stiner, stated that Mr. Coteman had not given them similar instructions and they had never heard of this beingdoneatCPSES(Applicants'fxhibit177at9).
6 Mr. Stiner testified that Mr. Fernandez was not on his crew and had never welded in the same area as Mr. Stiner (Tr.10589).
Subsecuently, when asked if Mr. Fernandez ever perfomed an 111egal weld, Mr. Stiner stated that Fernandez hadt Stiner knew 10675-76),
in any because he was welding in the same area ((Tr.
event, Pessrs.
Fernandez and Brown Mr.
Stiner's welding (FootnoteContinued)
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I-Stin2r Weiding Issu:s:
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who were 'oh Mr. Stiner5 crews) testified that they had never welded or seeg another person weld using a weaving pattern in excess of the l
l bead width specified in welding procedures. Further, they testified that they had never heard a foreman or supervisor direct a welder to perfom such illegal welds.
(Applicants' Exhibit 177 at 9.) All welders (including the Stiners) apparently knew that intentional i
i violetior, r.f procedures cculd result in temination (Tr. 11779). 7 i
i i
i In addition, Messrs. Brown, Coleman, Green and Ha11 ford 1
(supervisors on crews over Mr. Stiner and/or welders in areas where i
Mrs. Stiner welded) stated that they had never heard any supervisor direct a welder to perfom illegal weave welding (Applicants Exhibit l
j 177 at 9-11). Significantly, Messrs. Brown and Coleman (welding i
foremen on H. Stiner's crews) testified that they monitored each j
j welder on their crews (including Mr. Stiner) several times a day (Tr.
i l
11464,11534,11541) and if any welders were using excessive weave i
l welding as a practice (as alleged by Mr. and Mrs. Stiner), they would have known about it (Applicants Exhibit 177 at 10; Tr.11587).
f i
4 (FootnoteContinued)
I
'j foremen) testified that Mr. Fernandez was on the same crew under i
Mr. Brown (Tr. 11857; 11673).
7 Mr. and Mrs. Stiner alleged that welders routinely violated procedres under the direction of their foreman even though they j
knew that they could be terufneted if they were caught (Tr.
l 10794,10287-88,10312-14). Mr. Stiner stated that the guidance l
he was given by his foreman was not tn get caught (fr.106A0, l
10897).
In addition, they stated that foremen and other welders j
kept a look out for QC to worn welders if CC was coming (Tr.
l 11030-37,11103). This is in direct conflict with testimony of J
welders presented as witnesses by Applicants who, when asked by (Footnote Continued) i i
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Mr. 5a'ker testified that he was unaware of any instances of excessi,ve weave welding which had not been identified and appropriately dispositioned, and that if a welder was using excessive weave welding as a practice, Mr. Baker would have found out about it.
Mr. Baker based his testimony on his personal observaticns of and discussions with welders coupled with the monitoring programs.he ad linis ared in welding construction, e.g., welding techr.fcfans who all reported to him and the welder inspection program. Mr. Baker testified that welding technicians (assigned to each area of the plant where welding was taking place) continuously monitor the welders they are assigned. Mr. Beker stated that if any weider used excessive weave welding as a practice, it would have been detected by these technicians and reported to him.
(Applicants Exhibit 177 at 12-13.)
Further, Mr. Baker testified that welding engineering (apart frcm 0A/0C) also conducted unannounced inspections of each active welder approximately every 14 days.
(For example, Mr. Baker testified that during the short time Mr. Stiner was actively welding, he was inspected 15 times, and Mrs. Stiner was inspected at least 28 times during the period she welded.) During the inspection, numerous areas are checked, including the filler material, the acce'ptahi11ty of the, welding, progression of travel (uphill or downhili), bead width, and l
weld rod contro). Mr. Baker testified that to his knowledge, ncne of (Footnote Continued)
)
the Board, stated that, in essence, it did not make sense to intentionally violate procedures if you knew you could loose your job (Applicants' Exhibit 177 at 11; Tr.11729).
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the inspe'c'tions identified any concerns regarding excessive weave welding.
Further, Mr. Brandt testified that he was unaware of any instances of excessive weave welding which were not identified and dispositioned appropriately, and if a welder did excessive weave welding as a practice (as alleged by Darlene and Henry Stiner), OC would have f scd out abot.t it ar.d taken apprepriate actiers. Mr.
i Brandt's testimony was based on his observations of welders in the plant, and his discussions with numerous OC inspectors (who are monitoring the welders) regarding this issue.
(Applicants. Exhibit 177 at 12-13.)
The NRC Staff investigated the allegations made by Mr. and Mrs.
Stiner regarding weave welding (NRC Staff Exhibit 178 at 11-13).
Based on the investigation, the Staff concluded that there was no evidence to support Mr. and Mrs. Stiner's allegations (NRC Staff Testimony at 11-12).
While testimony reflected that all welders were trained on the appropriate weave width that could be used (see e.g., Applicants Exhibit 177 at 9, 13; Tr. 9991, 11797), Mr. Stiner testified that he was never told that weave welding in any fashion (even less than four times the diameter of the weld mater'ial) was authorized (Tr. M11 and 10590). However, Mr. Stiner contradicted himself by stating that o'ne of his training instructors (Kenneth Golden) told him that weave welding was acceptable and even at times preferable (CASE Exhibit 666 at9).
In addition, in March 1980 Mr. Stiner attended a training class on CPP-6.9 (CASE Exhibit 666 et 8) which requires a maximum bead
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Stiner Welding Issues:
26 t
width of*feur times the weld rod diameter (NRC Staff Testimony at 6).
In short, despite the contradictory testimony of Mr. Stiner, the Board finds that welders were properly trained on acceptable bead width.0 Mr. Stiner's Specific Allegation. On cross-examination, Mr.
Stiner could recal-1 only one instance where he had witnessed excessive weave welding. Tr. 10,592. According to Mr. Stiner, he nnticed that the hanger on which a welder named "rmend Braur.'?ler was we' ding had turned blue appreximately 4-5" from the weld joint. CASE Ex. 919 at 8.
In Mr. Stiner's view, the blue discoloration was due to overheating of the base metal caused by excessive weave welding. Tr.
I 10,592.
The steel used at CPSES to construct hangers, A36 steel, has a carbon content of less than 0.3 percent and is considered "7ow-carbon" steel. Staff Testimony at 6-8 (Taylor, Gilbert). I.ow carbon steel, which changes color during oxidation, fjd,. at 8; Tr.10,070 (Baker)
" turns blue on the surface at 600 *F.".. Tr. 10,020 (Baker). This surface discoloration is not an indication of embrittlement, or a loss of ductility or tensile strength. Tr.10,020-24 (Baker, Puscente).
Thus, the fact that Mr. Stiner may have observed a blue discoloration on the hanger at issue does not mean that the bead width of the weld made by Mr. Braumuller exceeded four core diameters.
Applicants testified that the bead width weld specified as acceptable in some welding procedures may have been confusing
~
(Tr. 9991).
Accordingly, these procedures are being changed to remove confusion (Tr. 9992).
However, it appears that the (Footnote Continued)
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Stiner V23 ding issues:
27
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i It is noteworthy that Mr. Braumuller, a welder with 2P years experience (Applicants' Ex.177 at 4), denied that Mr. Stiner ever i
assisted him on a welding job and had no recollection of the incident
~
described by Mr. Stiner. Tr. 11,694-95. Mr. Coleman, who was Mr.
Stiner's foreman at the time, stated that Mr. Stiner was a welder "like all the rest", Tr.11,539, and denied that Mr. Stiner was assigned the task of walking around correcting other welders' work.
Jd. Clifford 6Fown, who was a member of Mr. Stiner's welding crew, also controverted Mr. Stiner's statement that he and Mr. Stirer were roving repairmen, responsible for getting " bad welds" bought off by OC. Comoare Tr.11,467 (Brown) with Tr.10,606; Tr.10,622-E3 (H.
Stiner).
Indeed, Mr. Stiner admitted on cross-examination that Mr.
Coleman's and Mr. Brown's testimony on this point is correct. Tr.
10,974-75.
Mr. Stiner visited Comanche Peak with the Board chairman to indicate the hanger that contained the improper weave weld made by Armand Braumuller. Tr. 11.118. Mr. Stiner identified hanger CT-1-017-005-Y35R as the offending hanger. Tr. 11,023.
The weld package for hanger CT-1-017-005-Y35R, however, indicates that neither Mr. Stiner nor Mr. Braumuller ever welded on hanger CT-017-00F-Y35R.,
Tr. 11.023.
(Footnote Continued) confusion, if any, was cet widespread.
Further, any confusion would have resulted in telders conservatively using less of a s
l weave pattern than they could have used.
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Stiner Welding Issues:
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The' Staff inspected hanger CT-1-017-005-Y35P. and the two adjacent Staff hangers to determine whether any had excessive weave welds.
Testimory at 13 (Taylor). The welds did not appear to have been ground down and thus the longitudinal ridges and valleys of welds Id.; Tr. 12,224 (Taylor). The ridges and valleys d
could be observed.
of these welds were " indicative of properly-made stringer beads well within the four red diameter limitation." Staff Testimony at IA '
i (Taylor).
The Staff also reviewed the construction package for hanger CT-1-017-005 Y35p. to determine whether it had been removed or replaced subsequent to the July-August 1980 time period that Mr. Stiner claims he and Mr. Braumuller welded on it. The construction package indicates that welding took place only in June 1979 January 1981, and October 1983, and nothing in the construction package or in the Staff's inspection of the hanger indicates that it has ever been Jd.
d remued or repiaced.
One of the adjacent hangers did have the weld symbols of both Mr.
Braumuller and Mr. Stiner, suggesting the possibility tha,t this was the hanger Mr. Stiner had described. However, the documentation for this additional hanger showed that Mr. Braumuller and Mr. Stiner had.
welded on that particular support several months apart. (Tr. 11074, CASE Exhibit 966, received into evidence at Tr. 11180.) So the documentation contradicts Mr. Stiner's testimony.
Fur +her, since the l
hangers pointed out by Mr. Stiner did not require Charpy impact testing (NRC Staff Testimony at 13), the existence of excessive weave
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Stiner Welding Issues:
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welding on these supports would merely have indicated an isolated violation of a procedure without an adverse safety consequence.
See Staff Testimony at 5, 7 (Collins, Smith); Tr. 9998 (Muscente).
We conclude that Mr. Stiner did not establish the existence of eyen one illegal weave weld. However, this incident does cast doubt on Mr. Stiner's credibility. When he was forced into pinpointing the location of a mysterious problem he stated positively that he knew existed, he faiied to do so.
Mrs. Stiner's Specific A11ecation. Mrs. Stiner testified that she saw Mr. Braumuller and Mr. Stiner weave welding on. an Auxiliary Building hanger, TWX-034-714-A35R (elevation 790) on March 24, 1981 and March 26, 1981 (Tr. 10161, Tr. 4149; Case Exhibit 667 at 24).
This issue is discussed in Section II.B., above, as it relates to the credibility of Mrs. Stiner. While this discussion casts substantial doubt on her credibility as a witness as well as the accuracy of this specific allegation, documentation reflects that, in any event, Mr.
Braumuller used a total of two rods on the hanger on March 24 and five rods on the hanger on March 25, 1981 (Tr. 11790-91). (We find, based on the documentation, that Mr. Stiner did not weld or. the hanger on March 26, 1981 as allega' (Tr.11791).)
Significantly, Mrs. Stiner.
I During cNss-examination, CASE questioned Mr. Baker as to the adequacy of weld filler material documentation for this and other Class 5 hangers. Specifically, CASE was concerned that because weld filler material log sheets were not numbered for Class 5 hangers (as they are for Cla'ts 1, 2 and 3 hangers),
there would be no way of telling if any sheets were missing (Tr.
(Footnote Continued)
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Stinar Welding Issues:
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testified that 17 to 18 weld mds would not have completed even one weld on tne hanger (Tr. 10149). Accordingly, if Mr. Braumuller had weave welded on the hanger as Mrs. Stiner had alleged, he could not have weave welded for very long.
In any event, the welds on the hanger did not require Charpy impact testing and would, therefore, have been constructed safely even if there had been weave welding.
We conclude that whether or not Mr. 'Braumuller may have weave-welded on 'this particular hanger, there is at most proof of one isolated instance of a violation of procedures. The violation, if it eccurred would not have safety consequences. Consequently, Mrs.
Stiner's testimony does not establish any serious shortcomings in welding practices with respect to weave welding.
Based on the evidence, the Board finds that CASE's allegations regarding weave welding do not reflect significant violations of procedural requirements, and thus, do not reflect even a minimum breakcown in the QA/QC program at CPSES. There also is no reason for concern about safety consequences of the alleged practices.
(Footnote Continued) 11942-43).
Mr. Baker testified that this hanger package was taken from official company records and he had no reason to believe that it (as well as any).other Class 5 hanger package) was not complete (Tr. 11978-79 Further, he testified that there are no Code requirements regarding retention of such documentation for Class 5 hangers (Tr. 11983).
Further, Mr.
Baker stated that after the filler material is used, the weld filler material log sheets for Class 5 hangers serve no safety function (Tr.
11981-83).
CASE presented no conflicting testirsny.
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In*mhking these findings, the Board notes that the testimony regarding this issue is in direct conflict. Or. the one hand Applicants' witnesses testified that they were not aware of any unreported weave welding in violation of procedures. These witnesses included welders who worked in the same areas as Mr. and Mrs. Stiner and who would have experienced the same working conditions that they did.
Indeed, each of these welders has been at CPSES larger than either Mr. or Mrs. Stiner.
In addition, Applicants' witnesses included two of Mr. Stiner's welding foremen and two of his other supervisors, all of whom would have monitored him and others on his Finally, Applicants' witnesses included Messrs. Baker and crew.
Brandt who testified as to direct and substantial oversight of welding by the welding engineering department and QC personnel. Significant-ly, while each of Applicants' witnesses was sequestered and thus did not hear the testimony of the others before testifying, there were no inconsistencies of any moment in any of Applicants' witnesses' testimony.
b)
Safety Implications of Allegations of Excessive Weave Welding In the course of the foregoing discussion, we reached certain
' coni:1usions about the safety significance of Mr. and Mrs. Stiner's
~
allegations, had we found them to have been true.
In this portion of our opinion we discuss that conclusion in greater depth.
Mr. and Mrs. Stiner stated that their primary concern regarding weave welding was that it would result in excessive heat input into es e om-ee
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the par!nt metal resulting in damage (CASE Exhibit 919 at 5; Tr.
1 10784).
With regard to CASE's concern, Messrs. Muscente and Baker testified that the type o' steel Mr. and Mrs. Stiner were qualified to weld on was low carbon steel with a carbon content below 0.3 percent l
(Tr. 9997-98). Applicants testified that the vast ma,iority of all carbon steel used at CPSES is low carbon steel. Further, Applicants testified that this material is extremely ductile, not susceptible to cracking or entrittlement, and not susceptible to reduction in strength from excessive heat input.
(Tr. 9998-99.)10 Applicants testified that heat input during welding on these materials. is only a factor when welding on materials that require Charpy impact testing (Tr. 10017). Applicants testified that excessive heat on such materials may alter the fine grain structure (Tr.10012). The NpC Staff testimony was consistent with Applicants in this regard (NRC Staff testimony at 7; Tr. 12'56, 12178-82).
Applicants testified that the main steam and feedwater systems were the only two systems installed by Brown & Rcot in which there were any portions that required Charpy impact testing, (Tr. 9996, 10100). Mr. and Mrs. Stiner's qualifications would have restricted.
10 Applican[s testified that these characteristics were present in low carbon
- steels, including A-36.
- Further, Applicants testified that due to the fabrication process for SA-500 tube steel (also a low carbon, unalloyed steel), excessive heat input may cause some change in the mechanical properties and perhaps tensile strength.
However, these characteristics would be essentially the same.
(Tr. 11976-27.)
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them to* welding structural attachment welds on these systems (Tr.
9996). To detennine whether Mr. or Nrs. Stiner welded on these systems, Applicants conducted a computer search of the welding documentation of the sections of the main steam and feedwater systems requiring Charpy impact considerations.(Tr. 9996,10013). 'To verify that this documentation contained all pertinent attachments to the systems, Applicants also conducted a cross-check of all the drawings for the main steam and feedwater systems and identified all of the hangers attached to portions of those systems that required Charpy impact testing (Tr. 11765). From th;se reviews, Appifcants determined that neither Mr. nor Mrs. Stiner welded on materials requiring Charpy impact testing (Tr. 9996,10012). Another computer check by Applicants of all systems welded on by Mr. and Mrs. Stiner supported this conclusion (Tr. 9996). While Mr. Stiner stated that he was sure that he welded on systems requiring impact testing, he could not Par.eTaer tr.e hanger numbers or exact locations (CASE Exr.ibit 919 at 7-8).
On the basis of this record the Board finds that neither Mr.
nor Mrs. Stiner welded on material requiring Charpy impact testing.
To illustrate worst case heat input conditions, Mr. Stiner testified that he observed hangers on which the weld was in excess of
.our times the diameter of the weld rod and the parent metal was f
heated so hot that four or five inches out frem the weld it was " blue tempered" (CASE Exhibit 919 at 8). Applicants testified that this coloration was a surface condition which occurred at 600'F (Tr.
10020). Applicants attempted to simulate this condition using the,
material Mr. Stiner alleged to have seen, six inch by eight inch tube e
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steel, P/4. inch thick (Tr.10021).
(In that this material was tube steel, it was SA-500 low caroon steel (Tr.11977).) Applicants welded on this material continuously for 37 minutes using excessive vaave beads. During the test, there were interpass temperatures of over 650*F, which exceeds the 500*F specified by the procedure. The result was a blue ring on the surface 13/4 inches from the top of the weid.
(Tr. 20022.) Applicants testified that the excessive heat would not have had an impa"ct on the characteristics of the base material (Tr.
10021-25). Judge Bloch summarized Applicants' testimony in this regard as follows "...first, it is impossible to get that wide a blueness and second, if it did, it wouldn't matter anyway" (Tr.
10,025, citing Applicants Exhibit 178,179). NRC Staff testimony I
supported Applicants' position in this regard (NRC Staff Testimony at 8).
I I
Applicants also performed a test on low carbon SA-36 material where interpass temperatures of 750*F (250*F in excest of tre maximum j
i interpass -temperature) were achieved (Tr.10015). ' Specimens were cut from the test plate and tested. These tests confirmed the I
acceptability of the material's important properties (Applicants Exhibits 178, 179; Tr. 10018)..
From the testimony, the Board finds that even if Mr. and Mrs.
Stiner had made.some weave welds in violation of procedures, as alleged, that it would not have had an adverse impact on safe
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operation of the plant.
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2.
Downhill Welding Downhill welding is an industry term with its expected common meaning.
It refers,to vertical welds made by progressing from the top of the weld toward the bottom of the weld.
Downhill welds are accepted for many applications, Neither the ASME nor AWS Codes exclude any particular direction of progression.
Rather, both Codes would allow the contractor to specify direction of travel. 'wr.ile the Cetes do ot exc)Lde upnill or downhill welding, the Codes do state that regardless of wnich direction of progression is selected the welder must be qualified to weld in that direction.
Brown & Root welding proc::dures do not authorize downhill welding. However, welding procedures of other contractors on site do authorize downhill welding.
(Applicants Exhibit 177 at 15-16.)
CASE's concerns regarding downhill welding were based on Mr.
Stiner's allegations that (1) "once metal has been welded on and cut on with a torch, it builds up a magnetic field which causes are blow" i
and to correct are blow" lots of times, people will run a downhill weld instead of doing it correctly, because then you're going in the direction of the magnetic field" (Tr. 4246-47) and (2) because of limited access conditions welders were at times directed to make downhill welds instead of uphill welds (CASE Exhibit 191 at 15). Mr.
Stiner contended that such downhill welds were contrary to procedures and could potentially result in trapped slag and lack of fusion (Tr.
4247).
As discussed more fully below, the record reveals that the allegations raised by CASE regarding downhill welding have not been mm me...e.
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substanti'ated.
In any event, even if isolated instances of downhill welding occurred, as alleged, the likelihood that it would have an adverse impact on plant safety is remote.
a)
CASE's Allegations Regarding Downhill Welding do not Substantiate a Breakdown in the QA Program Mr. Stiner alleges that downhill welds were routinely made to 1I c:rrect for are blow anc, as directed by suoervisars, in limited access conditions (CASE Exhibit 919 at 15). While Mr. Stiner stated that unauthorized downhill welding was comon practice at CPSES, he was only able to identify two specific instances where he alleged I
downhill welding occurred (Tr. 10607,10622).12 With regard to are blow, Applicants testified that contrary to Mr. Stiner's assertions, welding on metal or cutting it with a torch 1
l I
will not result in a magnetic field on the base material.
In any event, are blow is not caused by the base material being magnetized.
F f
Applicants testified that are blow is a phenomenon sometimes
[
11 encountered in D.C. are welding where the arc is deflected due l
to the deformation of the magnetic field which is present in 1
some fann in all are welding (Applicants Exhibit 177 at 15).
~
U In addition to the two specific instances. *tr. Stiner states generally. that t8essrs. Coleman, Brown and Green (and othe-
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unnamed foremen) directed him to perform, or themselves made, i
downhill welds in limited access conditions (CASE Exhibit 919 at 5; Tr. 10607-20, 10622, 10624-26, 11189).
Messrs. Coleman, Brown and Green denied these allegations.
(Tr.
11488, 11716;
.l Applicants Exhibit 177 at 19.)
Mr. Brown, however, testified
,i that in restricted positions he had made welds that Mr. Stiner could not make, but such welds were not downhill (Tr. 11488).
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Applicanfs testified that if proper grounding is present are blow is.a prcblem only at elevated amperage rates, usually above ?50 amps.
(Applicants Exhibit 177 at 14-15.) Applicants further stated that because of the method of grounding used at CPSES, and the small diameter electrodes and low amperage ranges used in the field for vertical welding (90-120 amps), are blow for vertical welding is not a 4
ovoblenatCPSES(Jd.;Tr. 10085-86). However, Applicarts testified tnat due tc a separate grounding system in the we'dir.g training facility, at one time are blow was a problem in the training facility, but not in the plant (Tr. 100P5-88). Mr. Stiner did rot take issue with this testimony.
With regard to Mr. Stiner's allegations that downhill welding was routinely perfomed in limited access situations under the direction of a supervisor, Messrs. Fernandez, Pickett and Braumuller (weiders remaining at CPSES from Mr. Stiner's crews) testified that they had not welded or seen others weld downhill in violation of procedures.
Further, they testified that welders knew downhill welding was unauthorized and there was no incentive to do it; if caught it could mean the loss of the welder's certification or perhaps termination.
(Applicants Exhibit 177 at 18.) In this regard, Applicants testified i
that the welders at CPSES are trained that downhill welding is not authorized. In. addition, the weld technique sheets used by all welders specify an upward progression.
(Tr. 10130.)
Messrs. Brown and Coleman (welding foremen on Mr. Stiner's crews) testified that they had never welded or seen others weld downhill in violation of procedures. They testified that due to their close
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monitorins,of welders on their crews (including Mr. Stiner), if a welder welded downhill as a practice, they would have known about it.
(Applicants Exhibit 177 at 19.)
Mr. Baker testified that based on his personal observations in combination with numerous interviews with welders, welding technicians 1
(including the results of the periodic unannounced welder inspections), fitters, welding foremen, and construction supervision, f
he. H unaware of any infor:nt.fisn which would indiccte thac unauthorized downhill welding on safety-related or Class 5 supports occurred at CPSES. Based on his personal observations of welders and I
his review of pertinent records as well as discussions with numerous welders, foremen, fitters and OC inspectors, Mr. Brandt also testified that he was unaware of information that would indicate that such unauthorized downhill welding occurred at CPSES.
(H.at16-18.)
Significantly, Applicants testified that there was no situation where~it was easier to do a downhill weld than an uphill weld (Tr.
11488-89,11854-57). NRC Staff testimony of Pessrs. Gilbert and Taylor supports Applicants' testimony (NRC Staff Testimony at 22).
The Board now turns to the two specific incidents of alleged downhill welding raised by Mr. Stiner. The first involved another welder, Mr. Roy Combs, who allegedly welded stainless steel lugs to a pipe using a doynhill weld (CASE Exhibit 919 at 15). Applicants I
testified that they perfonned a computer search of all stainless steel welds made by Mr. Combs (who is no longer working at CPSES) and performed a record seerch to assure that in all instances where he welded stainless steel lugs to a pipe, proper QC inspections had been e-
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i conducted.. In addition, all welds that had not been ground down for nondestructive examination were again v'sually inspected to assure thattherewerenoindicationsofdownhillwelds.
(Tr. 10036.) Based on this sample, which is the best available under the circumstances, we conclude that this alleged incident provides no support for Mr.
Stiner's allegations.
In the second incident, Mr. Stiner testified that under the direction of Cliff Brown and Jimy Green, N performe: a dow'ihill weld on a particular hanger in a limited access area (Tr. 10613,10622).13 However, when Mr. Stiner was confronted with conflicting testimony regarding whether Mr. Brown could direct him to perfonn a weld, he reversed himself and testified ; hat Mr. Prown did not direct him to make this downhill weld, but rather Mr. Brown made the weld himself (Tr. 10967-M ). An example of Mr. Stiner's inconsistency in this regard:
BY MR. REYNOLDS:
Q.
Mr. Stiner, on page 10,622 you state that you were instructed to downhill weld by Jimmy Green and Cliff Brown?
A.
What paragraph?
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This is lines 10 through 13.
Id The Board notes that while Mr. Stiner relates this incident in vivid detail in his oral testimony (Tr.10612), in his earlier testimony (CASE Exhibit 666) Mr. Stiner did not mention this downhill wel'd.
Since Mr. Stiner's earlier testimony discussed this hanger in detail (although not this downhill weld), the Board questions why Mr. Stiner failed to relate this incident earlier (CASE Exhibit 666 at 35-36).
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That's correct.
O.
Yet, you say on lines 19' and 20 that you didn't even know Brown was a foreman?
Is that correct?
A.
I think when I said " instructed" I should have said "they told me to."
That'd probably have been the--
JUDGE BLOCH: As I understand the testimony, am I correct, Mr. Brown had a kind of a responsibility to ge+ things fixed up so they could be bought-off.
Ts that correct?
That's your testimony?
t THE WITNESS:
Tha-is correct.
JUDGE BLOCH: And that you sometimes had thet responsibility, too?
THE WITNESS: Yes, sir.
4 JUDGE BLOCH:
Now, whrn you had that responsibility, you sometimes told other welders how to help you do that?
THE WITNESS:
Yes, sir.
THE WITNESS: No, I never had the authorizetion to actually instruct a welder to go to another support and do something.
JUDGE BLOCH: Okey.
Did Mr. Brown ever have that authorization, to your knowledge?
THE WITNESS: Not at the time I worked there.
JUDGE BLCCH:
So whet was he doing telling you what to do?
THE NTNESS:
Like I say, the reason why he came down there was because I couldn't crawl into the area; I couldn't crawl into the space due to the--my chest cavity being too big; s.d he was much thinner than I am; and they went to get him to come down there and do it.
a 2
And he tell me, he said, "Well you can do it, just run a downhill path."
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.. And I said, "Well, I can't even get to it."
So, you know, he went out and did it.
j That's what I mean by he " instructed" me is when he told me, "Well, you can do it, you know"--
i (Tr. 10967, 10975.)
In any event, Messrs. Brown and Green testi#1ed that they did not instruct Mr. Stiner to perform a downhill weld nor had they ever heard i
any foreman direct any welder to per#orm a dcwnhill weld in violation c procevu es (Tr. 10C27, 11715-15,1I752).
n addi'.icn, pursuant to plant precedures, all such welds ware required,ta receive a OC inspection.
Furthermore, the NRC Staff inspected the hanger in question and testified that without cutting the hanger down and removing the paint it would be impossible to determine if a downh'11 weld was made. However, the Staff has testified that it will reouire the.4pplicants to evaluate the hanger and provide assurance that it is satisfactory for service. (NRC Staff Testimony at 22-23.)
In short, due to the inconsistencies in Mr. Stiner's testimony this incident provides no support for CASE's position. The Board finds that the Staff action noted above.is acceptable to provide reasonable assurance that even if this isolated incident did occur, there will be no compromise of public health and safety.
Based on the record, the Board finds that CASE's allegations j
"regarding downhill welding are not substantiated.
In addition, the Board finds ef fher that the specific incidents of downhill weldin'g J
alleged by Mr. Stiner did not occur or, in any event, that there is i'
reasonable assurance that isolated violations that may have occurred would have no adverse impact on safe plant operation.
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In. making these findings, the Board is cognizant of the direct conflicts in testimony between Applicants witnesses and Mr. Stiner.
Based on the substantial inconsistencies in Mr. Stiner's testimony regarding this and other issues, as well as other factors set forth in Section II.S.., above, the Board finds Applicants witnesses to be more credible.
b)
Safety Implications of Downhili Welding t
Mr. Stiner testified that his concern regarding downhill welding was that slag may be trapped and there may be a lack of fusion in the weld (Tr. 4247).
While Applicants testified that the likelihood of downhill welding in violation of procedures is extremely remote, they further testified that even if it occurred the probability that it would have an adverse impact on the plant is virtually zero. Applicants testified that if a welder experienced in downhill welding made the weld, it would in all likel,ihood be acceptable from a structural standpoint. (As previously noted, downhill welding itself is not contrary to any welding code.) However, if a welder was inexperienced Applicants testified that his mistakes would in all likelihood result in obvious unacceptable visual in'dications which 1
would be detected by either the welding technician /'oreman (before OC inspection) or by the OC inspector during his inspection.
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(Applicahts Exhibit 177 at 18-20.) The NRC Staff supported this conclusion (ftRC Staff Testimony at 20-21).I4 Mr. Stiner attempted to refute this testimony by raising one l
instance where downhill welding may have adversely impacted the structural integrity of a weld, i.e., the weld which he alleged first that he performed and later that Mr. Brown performed, as discussed above. While Mr. Stiner's tesWony on this wcld is of questionable reliacility in the first instance, in any ever.t. as previously noted, the Staff will satisfy itself that there is reasonable assurance that the hanger is acceptable.
Accordingly, from the record the Board finds that even if there were some downhill welds as alleged by Mr. Stiner, there is reasonable assurance that they would not adversely impact plant safety.
3.
Weld Rod Control CASE's concerns regarding weld rod. control are based on allegations by Mr. and Mrs. Stiner. Mrs. Stiner alleged three specific instances of alleged weld red control violations:
l I4 In cross examination of Applicants and Staff witnesses, CAS'E attempted to show that downhill welds could be made faster than uphill welds, and because of such speed there was a greater chance far lack of fusion and slag entrapment
(
Mr. _e.g,, Tr.
11841-6).
- However, the Board notes that Stiner's allegations regarding downhill welding only related to instances where uphill welding could not be perfonned due to limited access or because of are blow.
In these instances, there would not be any accelerated welding speeds on downhill welds.
Accordingly, such cross-examination is irrelevant to the issues before the Board.
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(1) she wrote an NCR on a welder who she alleced had used two.
weld rods that had been checked out and not returned the day before (Tr. 4166);
(2) she alleged that on one weld 75 rods were reported to have been used when it should have only taken three to four rods (Tr. 4164); and (3) she fcund two bundles of rods laying in the plant which she alleges were turned over to a OC supervisor who did not investigate the incident but simply threw the rod:: in the trath (Tr. 4164).
in adcition, Mr.' Stiner raised one specific instance cf alleged inappropriate weld rod control, i.e., that he welded hangers with rods that were checked out to others in the crew (Tr. 4220-21). From these specific instances and other general observations, Mr. and Mrs. Stiner alleged that weld rod control violations were connon practice at CPSES.15 At the start of each shift, the foreman signs and issues to each i
welder one or more weld filler material log ("WFML") sheets (s).
(Prior to 1979, the fom used was called a filler material reouisition fom; it contained essentially the same information as the WFML.)
Each WFPL specifies, among other things, (1) the specific item or joint to be welded on, (2) the weld rod material type and quantity requested to perform the work, (3) the welding procedure to be used.,
and. (4) the identification symbol of the welder doing the work. The 15 The issue of unplugged weld rod containers was also raised.
However, in the July 29, 1983 Partial Initial Decision at p. 36 the Board ruled that this issue would have "no effect on the safe operation of the plant."
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welder thee takes the WFML to the appropriate issue station to draw the weld rod mat.erial for each specific work item. The distribution station attendant enters on the WFML the amount of material issued and the heat number of the material. The attendant also checks the welder's symbol against the welder qual.ification matrix to assure that the welder is qualified for the welding procedure listed and verifies that the material requested is the correct type for use with the procedt re.
In a separate accountability log, ti:e station attendant lists the welder's symbol and the container numbers that have been issued.
After obtaining the filler material, the welder goes to a work station to weld.
It should be noted that before a welder uses a weld rod, he checks it to assure that it is not damaged. Damaged and used rod stubs are retained by the welder.
l At the conclusion of each shift, each welder is required to return to the issue station to turn in any unused or damaged filler material and to turn in all remaining rod stubs.
The amount of unused and undamaged filler material is entered on the WFPL. Unused rods, rod stubs and damaged electrodes are counted and where this count does not equal the number of rods issued, this information is entered on a welder's log which is periodically tracked by the distribution station attendant and reviewed by welding engine' ring to assure that there is e
i no trend of excessive red stubs unaccounted for.
Tf a welder does not turn in his filler material at the end of the shift, this can be a basis for firing the welder.
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In.short, regardless of what area the welder is welding in, at the beginning and end of each shift each welder must go te the issue I
station to disposition the material he is using.
In this way, filler material used is accounted for at the beginning and end of each shift.
If a welder fails to turn in his filler material at the end of his shift, an investigation is conducted to determine where it is.
it should be noted that this weld red control procram exceeds all ASME or AWS Code requi enents for control programs.
5 Finally, the Welding Engineering Department inspects the rod
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distribution stations for compliance wit.h these procedures every two weeks.
As discussed more fully below, the record reveals that CASE's allegations regarding weld rod control violations are not reflective of a systematic or significant breakdown in the OA/0C program.
In this regard, specific instances where violations were alleged to occur 4
wers either unsubstantiated or were previously detected by CC and corrected.
In any event, the record reflects that even if violations
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had occurred as alleged, the likelihood of an adverse impact on safe plant operation is remote, i
a)
Allegations of Weld Rod Control Violations Do
[
Not Substantiate.a Breakdown in the QA/0C Program Applicants presented testimony describing the weld rod control
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program which the Board adopts in these findings of fact, as follows (Applicants Exhibit 177 at 21-23):
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Stinst Walding Issuts:
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The Brown & Root weld rod control program at CPSES is governed by a construction procedure. The program is based on a daily system of accountability where each welder is accountable for all weld material he uses on each shift.
In response to Mr. and Mrs. Stiner's allegations that violations of the weld rod control program at CPSES are widespread, Applicants presented Messrs. Fernandez, Pickett and Braumuller (welders on Mr.
Stiner's crews who also worked in areas inspected by Mrs. Stiner), who had.1ct ther:szlv-s violated or seen ot.wrs dolste test' fled 15st{.c/
the wcld red can'tml procedures at CPSES. Further, they testified that welders who intentionally violated these procedures would be fired; thus, there was an incentive' to adhere to these procedures (Applicants Exhibit 177 at 31-33; Tr. 11534).
Mr. Brown (a QC inspector who was also welding forman over one of Mr. Stiner's crews) presented similar testimony. Mr. Coleman (a CC inspector and a welding foreman over one of Mr. Stiner's crews and who also welded in the same areas as Mrs. Stiner) stated that except for one incident, he also had never observed violations of the weld rod control program.
(Mr. Coleman's exception related to an instance where he had unintentionally failed to turn in a rod container; the rod shack attendant alerted his supervisor and the next morning Coleman was " chewed out" by his foreman.)
(Applicants Exhibit 177 at
'31-33.) Messrs. Brown's-and Coleman's testimony in this regard is significant in'that they closely monitored the work of all welders on their respective crews and.would have been in a position to notice violations if they occurred ( I,d at 10).
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Mestrs. Green and Hal1 ford (foreman and general foreman over one of Mr. Stiner's crews) testified tcat they had not observed any violatiens of the weld red control program, but they were eware of one where QC noted a violation and the welder was fired ininediately.
(This incident is one raised by Mrs. Stiner and discussed below.)
Messrs. Baker and Brandt testified that based on personal chrervations of welders 4n the ;?e".t. as wall as discusCons with numerous weleers', fitters, foremen, QC inspectors, welding forenen and welding technicians, the weld rod control procedures at CPSES are, with very few exceptions, strictly adhered to.
In this regard Applicants testified that in addition to the inherent checks built into the rod control program (eA, the counting of returned rods and red stubs to detennine if any are missing), other mechanisms that provide assurance that violations are detected include the periodic inspections of each active welder every la days (previously addressed), routine monitoring of welders by welding technicians /
foremen and other supervisors, and OC inspections-(during which weld 1
i rod traceability is checked) and surveillance.
(Applicants Exhibit 177 at 33-4.)
I The NRC Staff presented supporting testimony regarding fpplicants' weld rod control program.
Further, the Staff testified that over the period of construction at CPSES, MRC inspectors have routinely examined the Applicants' welding activities, including weld rod control. With respect to weld rod centrol, the inspectors emphasized "whether the documented weld rod was being used in a given weld under observation, and whether the weld rod was appropriate and e
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(NRC Staff Testimony at 36.) The Staff l
testified that there were no identi*ied findings indicating problems in these areas.
In this regard, the Staff noted that what may appear to be a situation where a weld rod has been abandoned, in reality may be where a welder has temporarily left his ininediate work station for l
personal or other needs. As part of the NRC's routine inspections, the ins ects-has ebre-ved tpparently unattended weld rods in cans, j
backets, er pouches and after remaining near these " unattended" i
rods found that welders did return to the work station in a matter of i
minutes. (NRC Staff Testimony at 36-37.)
i The NRC Staff also testified that Brown & Root Project Welding Engineering is required by the ASME-approved Brown & Root QA manual to I
maintain periodic surveillance of the rod issue stations and of l
welders to whom rods have been issued. This reouires surveillance of l
the red issue stations every 14 days, and of the welder at least.once every 10 working days. A sample of the records of these surveillances has been reviewed by the Staff. The Staff found that the records were complete, the required surveillances were done, and no pattern of discrepancies or potential problems with either weld red control or welder activities was identified.
In addition, the Staff testified,
.that the Brown & Root QA Corporate Office conducted periodic audits of the welder and. weld red issue station surveillances. The Staff reviewed one of these audit reports, and it did not disclose any significant problems.
'NRC Staff Testimony at 34-35.)
I Mr. Stiner testified that he received no training or 1
indoctrination regarding weld rod control (Tr.11140). However, he g,.; -
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Stiner W21 ding Issues:
50 t
later contradicted himself by stating that his first foreman, Mr.
Coleman, gave hin indoctrination regarding weld rod control (Tr.
11146).
In addition, Arplicants testified that after successful completion of qualification testing and prior to being released for production welding, each new welder at CPSES (including Mr. Stiner) was given an orientation by welding engineering as to the requirements ef the we'd rod control,nrecedure. Applicants testified that at this orientation the'importance ># filler material control at the facility was explained to the welder and the welder was informed that any j
i willful violation of the procedure would result in imediate firing.
This orientation was documented and the welder signed a form indicating his understanding.
(Applicants Exhibit 177 at 27-28.)
With regard to the threat of termination for weld rod control violations, Mr. Stiner testified as follows (Tr. 10853-4):
BY MR. REYNOLDS:
Q.
What would happen if you were caught doing that [ccmitting weld rod control violations) Mr. Stiner?
A.
Immediate termination.
O.
What is the incentive for doing it?
A.
The incentive for doing it is, as I said before, the convenience to the welder.
O.
You would risk your job to avoid having to walk back to the rod shack for rods?
~
A.
Well. as I have stated before, the cuality control program at Coma,nche Peak is, you know, less than adequate in the fact that they can't catch these types of problems.
So they can literally do.it all over the place and the quality control inspector has no way of knowing that it is being done.
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51
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,, JUDGE BLOCH:
But before, Mr. Stiner, you said that the
~
quality control people would wander around the plant and yru WoJid haV9 to wo"ry about them and Cover for your welds. Why wasn't the same thing true for additional weld materials as it was for your repair welds?
THE WITNESS: That is why I say they always had somebody watching when they do this.
JUDGE BLOCH: But why do you always have to have someone watching when you are doing a repair weld but you don't worry at all about OC finding extra weld rod materials THE WITt.ESS: Well, you do worry about it. Like I said, it is reasor. for temination, you see.
Mr. StIner also testified that workers violated weld rod control procedures regarding retention of rods, even under threat of temination, because "they are under so much pressure to get the work done and get the hangers up that they try to do anything they can do to speed up work" (CASE Exhibit 919 at 19). However, in response to an inquiry that appeared to bring into question the logic of such a position, Mr. Stiner reversed himself and testified that he did not hold out rods because he was under time pressure (Tr. 11126-8). The
~
Board finds Mr. Stiner's testimony on this issue to be inconsistent i
and unreliable.
Mr. and Mrs. Stiner also testified that the accountability process specified in the weld red control program was ineffective.
Specifically, they alleged that rod stubs were not counted or recorded i
I 6
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Stiner Welding Issues:
52 t
by rod stiack attendants (Tr. 10638,10970-83).16 However, Mr. Stiner testified later that early in his employment he was told by his first welding foreman, Mr. Coleman, that he had to " keep account of everything... don't lose none of your stubs... because they may count them on you when you go back and if you don't have any they will write you up, you know." (Tr. 11146).
Aeolictrts testified that rod stubs are counted 90plicants Exhibit 177 at 2'1-23; Tr.11415-20,11422,11592,11670) and introduced an exartple of the checksheets maintained by the rod shacks reflecting shortages resulting from such counts (Applicants Exhibit 185, introduced into evidence at Tr. 11975).
Mr. Baker testified that the red counts are monitored on a daily basis by the rod shack attendant and reports are sent monthly to the piping general superintendent who reviews them for trending purposes (Tr. 11892-93). Mr. Coleman testified that nonnally the attendants in the red shack would take the red stubs and pour them out of the stub can, count them and then throw them into a barrel (Tr.11594).
However, Messrs. Coleman, Pickett and Braumuller testified that at busy times the attendants would take the stub cans and write the welders' symbols on them and place them off to the side; when the rush yas.over they would count the stubs (Tr. 11594-95, 11637 41, 10 Mr. Brandt testified that the pr1ctice of issuing a precise number of weld rods and counting returned stubs was not widely used at other nuclear construction sites.
Other nuclear
-l
.with Code construction projects which are in compliance requirements merely issue rods by weight.
(Tr. 11422.)
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Stiner Welding Issu2s:
53 i
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11684-85}.. Further, Mr. Brown testified that if a welder did not return his unused weld rods and stubs, the weld technicians would conduct an investigation (Tr. 11501-02).
Mr. and Mrs. Stiner raised four specific incidents of weld rod control violations.
In the first incident, Mrs. Stiner testified that she wrote an NCR on a welder who had used two weld rods that had been checked out =rd aa. re'erned the day 'before (Tr. 416f'. Apolicants' witness Baker t'stified that Applicantr' imestigation of Mrs, e
t Stiner's NCR (#M8?-0034) revealed that while the facts were substantially as Mrs. Stiner had stated, she did not discuss the resolution.
In this case, Applicants testified that the welder had completed the weld the day before and intended to alert OC that an inspection was needed the next day. The next morning the welder was assigned another task, drew his weld rods for the other task, and went back to the weld he had worked on the preceding day to get a OC inspection. For some reason he did some more welding on the weld (perhaps he saw something he had missed) using two additional rnds (either from his rods checked out for other tasks that day, or as Mrs.
Stiner alleges, from two rods he kept from the previous day).
In any event, the incident was uncovered in the OC inspection and an NCR was
. written. The resolution of the NCR was that the welder was terminated imediately and. the weld was ground out and replaced.
(Applicants Exhibit 177 at 28-79.) The Board finds that this incident provides no support for CASE's position.
If anything, it reflects that the QA program functioned properly and that violations of the weld rod control procedure at CpSES are taken seriously.
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J' StinIr Welding Issues:
54 In the second incident, Mrs. Stiner alleged that 75 weld rods were used on hanger SI-0135032.535R (Tr. 4164). She alleged that that particular hanger should not have required more than three to four rods (Case Exhibit 919 at 20; Tr. 4165). Applicants testified that the Applicants' investigation revealed that only 50 weld reds (not the approximately 75 that Mrs. Stiner reported) were issued.
Further, the weld rod acceun}.abili y log did not r5flect thal. acj n.h we. lie,ing (i.e., the total number of unused rods, rod stubs and damager' rods turned in wu 50). As to the specifics of the incident, records reflect that at 7:10 a.m. on Ap-il 9,1980, the date in question, the welder checked out 50 rods for the hanger. At 1:48 p.m. that same day he returned the rod can, plus unused and damaged rods and rod stubs.
(Pecords indicate that there were no missing rods.) The welder then checked out additional rods for another job using a separate WFML. At the end of the day he turned in the remaining unused rods, stubs or damaged rods. The welder could not remember the incident. (Applicants Exhibit 177 at 29-30.) The Board finds that this incident dees not raise a safety concern or provide support for Mrs. Stiner's allegations.
In the third incident, Mrs. Stiner testified that she found bundles of unburned rods' wrapped in a rubber band (Case Exhibit 919 at 20). Mrs. Stiner alleged that after she gave the rods to her supervisor, he threw them into the trash (Tr. 4165, 10206-07, 10293-97,10470-74). Mrs. Stiner stated, however, that she did not know if he later removed them from the trash (Tr. 10296). Applicants testified that the two bundles of weld rod material were not 9 g ;,. _-
)
Stinar Welding Issues:
55 t
1 immediately discarded withcut an investigation, as Mrs. Stiner had l
indicated. Rather, the weld red material was given to Mr. Brandt who subsequently turned it over to construction to assure that an investigation was conducted.
(Applicants Exhibit 177 at 30; Tr.
11459-60.) Based on the investigation, Applicants were able to trace the rods to the organization which used them (not Brown & Root) and tratr.ing was conduct.ei to correct the sitation (Tr.11G 35).1 1
The Board finds tnat this incident also reflects that the QA program was effective and appropriate corrective action taken.
t However, there is a gap in the record for the Staff to fill through j
investigation.
If Applicants found bundles of unburned rods left uncontrolled by Grinnell Fire Protection Company, an organization doing construction on site, it is not at all clear that instruction alone would cure the problem with respect to work that had been already done. We trust that the Staff will inquire into whether this 4
nonconforming condition was properly re' solved with respect to prior work of Grinnell Fire Protection Company.
In the final incident, Mr. Stiner testified that his supervisor was under a great deal of pressure to complete a particular assignment which Mr. Stiner described in detail. He stated that to accomplish.
this the welders on the crew used rods checked out to other welders to I7 Mr. Brandt testified that other QC inspectors have at times also discovered loose rods and reported them to their supervisors (Tr. 11426-7) who assured that the incidents were investigated (Tr. 11440).
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Stinar Welding Issues:
56 i
complete work.
(Tr. 4220-21.) Mr. Baker testified that the Applicants f
investigated the allegation and determined that welders from Henry Stiner's first crew remaining at Comanche Peak (Messrs. Picket and i
Braumuller) stated that no such incident occurred. Further, the f
l welding foreman (Mr. Coleman) on Stiner's crew at that time also i
stated that no such incident occurred.
In any event, even if the inciden+ dio ec ur, Applicaim testified that all the wclders o.1 l
Stiner's crew would have been welding on the same material with the l
l same type weld rod. Thus, while such action would have been a l
l violation of procedure, Applicants concluded it would not have had an adverse impact on plant safety.
(Tr. 4220 and 10648-50.) The Board finds that substantial and credible testimony from Applicants' I
witnesses reflect that the incident never occurred.
l From the testimony, the Board' finds that CASE's allegations regarding weld rod control do not reflect systematic or significant i
violations of procedures indicative of"a breakdown in the OA/0C program.
In addition, the Board finds that there is reasonable assurance that the specific incidents of weld rod control violations raised by Mr. and Mrs. Stiner do not raise a significant safety concern.IO I
10 During direct examination of Mrs. Stiner, CASE attempted to raise in connection with weld rod control, the new issue of I'
placement of welders' symbols adjacent to welds (Tr.
10477-10494).
Upon a representation by Applicants counsel that such symbols would not be relied on to support the adequacy of j
the weld rod control program, the Board ruled that such testimony was not admissible (Tr. 10494).
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StinIr Welding Issuss:
57 1
b)
Safety Implications of Weld Rod Control Viciations Mr. and Mrs. Stiner raised as their concerns regarding weld rod control violations, the possibility that weld rods left out may absorb moisture and result in defective welds due to excessive porosity (CASE Exhibit 919 at 18; Tr.10648). Also, they were concerned over the imsact of welders exchanging weld reds (Tr. 10640-41,10650); however, I
in later testimony, Mr. Stiner stated that this wcs not a safety concern (Tr. 11150).
With regard to the first concern, Mr. and Mrs. Stiner testified that when weld rods are kept out and not controlled they can absorb moisture (Case Exhibit 919 at 19, 21; Tr.10283,10648,10858,11124).
They stated that E-7018 type electrodes should not be exposed to an unheated atmosphere for more than four hours (Case Exhibit 919 at 20; Tr. 10646).
The NRC Staff testified that if weld rods had been exposed to ambient air at CPSES for two to three days (such as alleged here) the
" worst-case effect" would be porosity in the weld (which is due to arc instability and off-gassing of water vapor) which should be detected during the nonnal visual inspection by the welder and OC (NRC Staff
\\
1 testimony at 33, 35).
Applicants conducted tests of E-7018 electrodes (the electrodes
~
used by Mr. and Mrs. Stiner) which had been stored for seven mcnths in an open containv in an uncont N 'ed atmosphere.. Using this electrode, test specimens were welded utilizi,ng a full penetration
)
butt weld. Nondestructive and destructive examinations conducted on y.
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Stinar Welding Issuss:
58 1
~
the resulting scecimen showed no rejectable defects; failure of the base material (not the weld material) occurred at a reading in excess I
of 70 ksi, the maximum requirements for any affected steels (most steels have a much lower requirement).
In short, even if weld
)
material was left out for 2-3 days 'fas alleged by Mr. and Mrs.
j Stiner), the Eoard finds that there is little likelihood that tHs could.. ave an adverse impact on the safety of the plan.
(*pplicants i
Exhibit 177 at 27.)
l-With regard to the second concern, Mr. and Mrs. Stiner alleged
{
that welders deliberately saved weld rods to lend to other welders so l
that these welders would not have to get rods issued from the i
distribution stations (Case Exhibit 919 at 19; Tr.10209-10,102?3, 10648-50). However, Mr. Stiner stated that this was not a safety concern (Tr. 11150). Applicants presented testimony that all welding i
I l
on safety-related low carbon and mild steals at CPSES which is of concern here (the welding to which Mr.'and Mrs. Stiner referred in their testimony) uses the same electrode (weld red), E-7018.'Thus, Applicants testified that the possibility of a welder borrowing an f
electrode from another on his crew and getting the wrong electrode for the job was virtually nonexistent. Applicants further testified that, in any event, welders are trained to know that they can only use the specific electrodes designated for that job.
(Applicants Exhibit 177 at 26.) The Board finds that even if some weld rod control violations such as alleged by Mr. and Mrs. Stiner occurred, there is reasonable assurance that they would not have a significant adverse impact on plant safety.
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Stinar Welding Issurs:
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4.
Welding of Misdrilled Holes Mr. and Mrs. Stiner alleged that under the direction of supervisors, welding of misdrilled holes without appropriate welding engineering authorization or proper QC inspection was common practice at CPSES (CASE Exhibit 919 at 22-23).
The numerous inconsistencie-in Mr. and Mrs. Stiner's testimony called 17to qct; tion their credit 4* f ty on all issues (set Section II.B., supra).
On this issue we do not believe that Mr. Stiner's testimony can be relied upon and accordingly, the Board gives it no weight. The one overriding factor regarding the Board's decision involves Mr. Stiner's incredible statement that a 11/4 inch hole in two inch thick material (on which he allegedly welded many times (Tr.
10683-84)) could be easily welded in about two minutes (excluding the blending of the weld with surface material (Tr.1069P.-9)), and it wculd only require two weld rods to complete (Tr.11158).
NRC Staff witnesses stated that it"was impossible for such a hole to be welded in two minutes or with the two weld rods as noted by Mr.
Stiner. The Staff testified that a simple volumetric calculation reflected that it would require 25 weld rods to fill the hole.
(Staff Testimony at 26; Tr. 12250-51.) Further, the Staff testified that it,
'akes approximately one minute to burn one weld red (Tr.12250).
t Accordingly, even assuming that only 20 rods were required to fill the volume of the hole, it would take 20 minutes to simply burn the rods, not including the time required to change rods or turn the specimen over (Tr. 12251-52). Based on independent testing, Applicants w _..
s-Stiner Welding Issu2s:
60 testified that such a hole would require approximately 20 weld rods to complete (Tr. 11768).
Mr. Stiner's sworn testimony on this point is not accurate and reliable. The Board believes that any welder who had ever weld-repaired a misdrilled hole of this large. size or smaller would have been able to at least provide a response thet was in the ballpark.
In 4
that Mr. Stiner wss not able te do se, the Board questions whatter Mr.
Stiner has ever performed a weld repair on a misdrilled hole. This, in combination with other inconsistencies noted in Section II.B.,
above, leads the Board to conclude that on this issue Mr. Stiner's testimony will be given no weight.
In any event, Mr. Stiner's principal concerns are that misdrilled holes were performed without proper authorization or OC inspections, and may contain slag so as to call their structural integrity into question.I9 These concerns are addressed below in conjunction with the Board's discussion of Mrs. Stiner's' allegations.
With regard to allegations concerning widespread repair of misdrilled holes without proper engineering authorization or OC inspection, Messrs. Fernandez, Braumuller and Brown, who each were welders or foremen in the same areas as Mr. and Mrs. Stiner for an extended period of time, testified that they had never welded a 19 it should be noted that individuals that Mr. Stiner implicated q having performed such welds or having directed him to perfonn
^
these welds have denied the allegation, (viz., Messrs. ColemanTr~.1162?),
(Tr. 11540), Brown (Tr.11479), Pickett (Tr.11690) and Braumuller (Tr.11690).
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61 L
~
misdrilled ' hole (Apolicants Exhibit 177 at 38; Tr.11479,11690). Mr.
Coleman testified that he had welded some misdrilled holes on cable tray supports in the cable spreading room, but that these had all been properly inspected (Tr. 11542-53). Mr. Pickett also stated that he had welded a few misdrilled holes on cable tray supports in the cable spreading room which had also been properly inspec+ed by OC (Tr.
1162C;.
Ir#eso,tactn Messrs. Coleman and Piccett te2ti m J that 00 personnel were N. the cable spreadirg ree:r.s wFen the repairs were being made (Tr. 11543,11625).
The testimony of both Messrs. Coleman and Brown that they had not observed any unauthorized welding of misdrilled hofes is significant in that they routinely monitored the work of the welders under them, including Mr. Stiner, and would have been aware of any problem which existed in this regard (Applicants Exhibit 177 at 10; Tr. 11480, 11534). Messrs. Green and Ha11 ford, who have also had welders under their supervision for an extended period of time at CPSES, provided similar testimony (Applicants Exhibit 177 at 41). -
Applicants further testified that there was little motivation to violate procedures by performing unauthorized welding on misdrilled holes, to do this could result in termination (Applicants Exhibit 177 lit 41).
Both Mr. P.ickett and Mr. Coleman stated that they were not sure what design documentation authorized their repair of the misdrilled i
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62
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I holes in cable trey supports (Tr. 11544 A5, 11647).20 Applicants testified that these repairs were made in accordance with a Design Change Authorization ("0CA") issued by the design engineer for the welding of these and other holes on cable tray supports (Tr. 10039).21 Since these repairs were non-ASME repairs, only the DCA was needed, not an RPS (NRC Staff Testimony at 24; Tr.10137). The Staff furtNr tutif =6 th:t on Inspectice Report 81-12 (Staf" Exidbit 178) determined that " plug welds" were being utilized by welders in accordance with Brown & Root welding procedures (NRC Staff Testirony at 26, 30).
With regard to the welding procedure used to make the repairs, Applicants testified that if the welds were authorized by engineering, welding procedures 10046 and 11032 could be used to repair AWS and ASPE welds, respectively (Tr. 11393). As previously noted, a DCA had been authorized to repair misdrilled holes on cable tray supports.
Repair of pipe supports was not authorized by this DCA.
(Tr.20040.)
20 Mr. Coleman stated t'1at he had no papenverk when repairing the holes (Tr. 11545). He stated that his foreman may have had the paperwork (Tr. 11545,11787).
In any event, the Board requested that Applicants provide it a report on this issue (Ti..
11786-87). By letter of April 27, 1984, Applicants provided to the Board and all parties a report which explained why separate authorization at trat time was not v.eeded to weld repair misdrilled holes on cable tray supports in the cable spreading room. The Board is satisfied with the report.
21 DCA 5347 provided direction on which misdrilled holes needed to be repaired and authorized their repair (Tr.11407).
It should be noted that based on this DCA, Mrs. Stiner's testimony that all misdrilled holes needed to be welded (Tr. 10506) is in error.
- r e-
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Stinar Welding Issues:
63 I
i I
i l
In response to cross-examination on this issue, Mr. Pickett verified f
this by testifying that baseplates for pipe supports which had I
misdrilled holes were discarded (Tr. 11632-3),
i t
To determine if the QC inspections were being routinely perforined I
on weld repair of misdrilled holes, Applicants conducted a preliminary search of documentation for cable tray hangers in the cable spreading
)
l l
rooci and repsrted t%t DC inspectier. repo-ts of over 150 msd-illec holes were located (Tr. 10038). Applicants concluded that this reflected that misdrilled holes were being properly inspected by OC (Tr. 10029, 11401-07).
i 1
Mrs. Stiner testified that she weld repaired misdrilled holes under orders many times (Case Exhibit 919 at 23). However, she stated that she could only remember doing them on the " fab tables" in the l
f turbine building (Tr.10555). She stated that while a couple of other l
welders who worked on the fab tables also made such welds (she doesn't l
remember the names), she did not know what other welders in the field f
did (Tr. 10553-4).
She stated that she made such welds under the orders of James Stembridge (her foreman), and though she was less sure, Clay Andrews (another foreman).
(Tr. 10786-88, 10541. ) She stated that.she thought it was improper because she was told to watch
'for QC (Tr.10529). The record reflects that Mr. Andrews was Mrs.
Stiner's first. foreman while she was a welder; Mr. Stembridge replaced Mr. Andrews and was her foreman for a fairly short period of time.
(Tr. 4130 and 11782 )
Applicants investigated Mrs. Stiner's allegation by interviewing Mr. Stembridge (Mr. Andrews no longer works at CPSES) and others
Stiner Welding Issuns:
64
~
associated with the incident (Tr. 11781-86). Mr. Stemb-4dge stated that he had directed Mrs. Stiner to make unauthorized repairs on three hangers that had misdrilled holes in them (Tr.11781). Applicants testified that Mr. Stembridge had been a foreman in the small bore hanger fabrications area for about four months when the incident occurred. App 11cantt testified that one day, seven hangers were sent fror the fab shop to Mr. Stembridge to install, b::t three o: them wre wrong. Applicants testified that Mr. Stembridge stated that as a new foreman he tried to shortcut the system.
(Tr. 11782.) However, another foreman sav the activity and infonned a OC inspector, Mr.
Wilkerson. Mr. Wilkerson stated that he investigated and caught Mrs.
Stiner making unauthorized repairs. (NRC Staff Testimony at 28; Tr.
11782.) The hangers were subsequently scrapped and Mr. Stembridge was demoted to and remains in a non-supervisory position (NRC Staff Testimony at 28-20; Tr. 11735). Staff testimony supported the results
~
of Applicants' investigation (NRC Staff Testimony at 27-30).
Mrs. Stiner stated that her concern with' repairing misdrilled holes is slag entrapment 22 (Case Exhibit 919 at 22).
She further stated that if slag were left in the weld it would be an 22 Mrs. Stiner also stated that repair welds could not be traced because welders did not put their symbols on them (Tr. 10504, 10528-29,10670-71). Applicants' witness Coleman stated that he repaired misdrilled h~ oles in accordance with procedures and that included placing his welding symbol by the welds (Tr.
11545-46).
Applicants' witness Pickett also placed his symbol i
on the " plug welds" he did in the cable spreading room (Tr. 11629). In any event, the allegation does not raise a safety concern.
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9 Stin2r Welding Issu2s:
65
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improper ' weld (Tr.10497). While she attempted to clean out as much slag as possible with a chipping haniner, she testified that there was still some left inside the weld 23 (Tr 10229,10235,10236,10284).
Applicants testified that welding of a misdrilled hole is a relatively simple procedure (Applicants Exhibit 177 at 42; Tr.11623).
Further, Applicants stated that it was very difficult to leave sig-if t:an* sle; -'ncCt: Using low nydr: gen e%ctroce.;. like these used at CDSES, because the normal welding technique provides assurance that slag remains fluid, floats to the top of the weld and is removed (Applicants Exhibit 177 at 36). The Staff testified that if there were large arounts of slag entrapped, when the are was struck much of this slag would become granulated from the force of the are and would float to the top with succeeding passes (Tr. 12240). Applicants testified that it was very difficult to weld over unacceptable slag T..
deposits using nonnal welding techniques (Applicants Exhibit 177 at 36,37). Further, if the weld was not-relatively free of, slag, there would in all likelihood be unacceptable surface indications remaining on the face of the weld., Test techniques corroborated this.
(Applicants Exhibit 177 at 37, 39.)
23 Mrs. Sti er testified that a pencil grinder was needed to clean slag completely out'of a misdrilled hole, but there were none available (Tr. 10285-10286, 10a99).
Other welders and foremen (Pickett, Braumuller, Fernandez, Coleman, Brown and even Mr.
Stiner) testified that they had pencil grinders in the areas in which they worked (Tr. 11468, 11547,11621-22,116a3,11666).
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3 Stin2r Welding Issues:
66
~
~
To de'tennine the possible impact of slag deposits on repairs of misdrilled holes, Applicants conducted a test of the effects of slag inclusions in a misdrilled hole on the strength of the material. Two test specimens of SA36 plate material with a minimum tensile strength j
requirement of 58 KSI were prepared. The specimens were approximately eight inches in length and 3/8 inch thick,2 and, in the area of
< or.:er;., appr.x nattiy 1.5 inches 'n wd.:th. A 3/4 in:h d 4..eter helt.
d (which was to b4 welded) was d'illed in the arte of concern of each specimen. This hole, therefore, comprised 1/2 of the 1
cross-sectional area of the test specimen.
(Applicants testified that in view of gauge tolerance requirements under which a hole cannot be placed nearer than 1-hole diameter to the edge of the material (here being 3/4 inch), this configuration was extremely conservative.)
(Applicants Exhibit 177 at 43 44.
However, it is difficult to generalize about the probable location of welds made in violation of procedures because there was no authorizing weld repeir paper.)
l The hole in one of the specimens was properly, welded and radiographed to assure that it was perfect. Applicants testified that after numerous attempts and using abnormal welding techniques, the hole in the second specimen was welded with significant slag deposits f
1 Temaining.
(As previously noted, it is very difficult to weld over 24 Mr. Stiner stated 'that this test was flawed because the specimens should have been two inches thick (Tr.
10683).
Applicants testified that the thickness was ininatorial in that the relevant parameter of concern (psi) was dependent and coro11ated with the cross-sectional area (Tr. 11905-6).
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.l Stin r Welding Issu;s:
67
~
slag in a hole.) The second specimen was radiographed showing major slag inclusions ttiroughout the weld, including one which was about 1/4 inch at its widest point, 1/2 inch in length and about 1/8 inch thick.
1 Tensile tests were perfonned on each specimen. The first specimen (with the good weld) failed at a tensile strength of 71,639 psi.
Signi#icantly, the failure occurred in the specimen meterial and net tu weid. aterial (i.e., t.he we:d..atoria' was s m.nge.- than tV. '.,ase material ).
The se:end spc:fren (with major sle.g inclusions 1 faileo at a tensile strength of 69,918 psi, still significantly above the 58,000 psi reouired of the material.
(Appiteants Exhibit 177 at 43 44.)
In suu Applicants testified that even when skilled craftsmen I
attempted to weld a worst case weld such that ma,ior slag inclusions f
l were present in the material, the strength of the resultant weld was I
not significantly lower than the strength of the base material, and still well above the required strength. Applicants thus stated that j
even if some degree of slag was present in a weld of a misdrilled I
hole, as alleged by Mrs. Stiner, it would not have had a significant l
adverse impact on the strength of the material.
l Ordinarily, we would not accept any test of a single sample to be dispositive of any safety issue, particularly where the relevant
~variable--the amount cf slag inclusion--is not fully detailed and where it is not,possible to tell whether the test caused stress 1
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concentration within the welded area.
In addition, the only thing j
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Stinir W21 ding Issues:
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i that was tested was a newly made weld, which may or may not be representative of the extent to which inclusions may progressively weaken the weld material over time.
However, the NRC Staff supported Applicants' conclusions and testified that the Brown & Root Welding Procedures 11032 and 10046 i
specified the use of E-7018 weld red, a low-hydrogen rod which piv fucers a weld.with a tersne st vngth of appre:.ierate y 7F p".1, o*
l e
acas 10K psi better than the tensile strength of the base caterial.
If the " plug weld" was made well enough not to be readily discernible after surface grinding, which was the case for both Mr. and Mrs.
Stiner, the Staff testified that the weld and the surroundingL base material would be at least as strong as the original base material I
before it was drilled. (Staff Testimony at 26.) Although the Staff did not testify about the continued strength of the weld, over time, the technical point is fairly obvious and we expect that the Staff considered it.
If the Staff did not, Je would expect it to correct the record on this poirit.
From the foregoing, the Board finds that Mrs. Stiner was directed to perfonn unauthorized weld repairs of misdrilled holes on at least three hangers on the turbine building fab tables.
~
In any event, in view of the testimony of Applicants and Staff, the Board finds, that most, if not all, hangers repeired by Mrs. Stiner on the fab tables were subseouently cut down and replaced.
In addition, based on (1) Applicants testing which suggests that even large amounts of slag in the repair weld would not effect the weld integrity of a newly made weld and (2) Staff testimony that as long as g
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I the surface cf the weld repair of a misdrilled. hole was acceptable (as both Mr. and Mrs. Stiner stated) the weld would provide acceptable f
structural strength, the Board finds that even if some weld repairs of 1
I misdrilled holes were not properly inspected and contained defects as alleged by Mr. and Mrs. Stiner, it is unlikely.to have an adverse 7
impact en the safety of the plant.
Cone.tus ion _About Imorepe jy DNu.eeted Repirs. We 4.= far iess sanguine about Applicants' failure to comply with their procedu*es than we are with the possible safety implications of their having failed to do so. Violations of procedures are important in their own right because they contribute to the workers' understanding of the i
extent to which procedures are to be taken seriously and followed scrupulously. The record in this instance convinces us that there was a practice of indeterminate extent at Comanche Peak with respect to l
welding unauthorized repair welds.
Since Applicants did not make the l
required contemporaneous investigation'of this practice, we find that the practice was of substantial extent and that this violation of procedures was a significant violation of Appendix B to 10 CFR Part 50.
First, we note that until January 1983, welding procedure WES-29
' required that the welding engineering department issue a Repair Process Sheet (FPS) specifying the methods and techniques to be used for any base metal repairs, the qualified welding procedure to be used in making the repair (for Class 4 & 5 hangers the repair procedure is CDM 6.9 (Tr.11,969)(Baker), and the type of nondestructive i
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i examinatio'n to be made o# the repair. The RpS also provided for a final inspection by quality control. Tr. 11,766 (Baker).
Second, we note that when Applicants detected Mrs. Stiner making an improper repair at the direction of her supervisor, they failed to create any deficiency paper and made no conterrporaneous investigation of the extent of this improper practice. Tr. 11,783-84 This was a ciccr viu'n:cn of Apper.3tx B recuir6ments for the perpt identification of deficiencies and for trending of deficiencies that may be significant.
(At that time, Applicants had not done studies of the effects of improper repairs and they cannot take credit for their subsequent studies as an excuse for not trending this earlier deficiency.)
Third, we note that Applicants repeatedly testified that l
individuals are " terminated" when they violate procedures. However, l
Mr. Stembridge was merely reduced in rank. We infer from other testimony and from the failure to investigate the extent of the i
1 l
practice at that time that Mr. Stembridge's directions to his welders about repair welds may not have been an isolated incident.
Fred Coleman, who was a welder at the plant, testified that there were many misdrilled holes repaired in the Unit I cable spread room. Tr. 11542.
Additionally, Mr. Coleman was not even aware that any fom of paper, such as a Repair Process Sheet, was needed for him to repair such a hole. Tr. 11544-45. Nor have Applicants even attempted to explain this testimony of Mr. Coleman.
The welding of misdrilled holes without authorization is further I
I substantiated by a Staff inspection of 56 supports in the north cable 27*.ar*~ ~ ~ - -
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spreading room. Staff found two plug welds in each of three supports, but none of these welds was properly documented. Addendum to Page 27 of Staff Testimony at 1 (Gilbert).
We note that the Staff has requested and is evaluating an explanation of these undocumented repairs from the Applicants. NRC Staff Proposed Findings of Fact on Weld Fabrication at 57. We wil' considu the 3Dgf's er,alysis of the Applicant:' respar.se in this proceed:ng. We are particularly concerned about the extent te which welding procedures and, possibly, QC procedures may have beer ignored.
The possibility of QC procedures being ignored is supported by the testimony of Mr. Fred Coleman, who stated that OC inspectors were present in the cable spreading room during the time he was welding misdrilled holes. Tr. 11542.
We find that there was a significant violation of Appendix B in that there was a practice in which misdrilled holes were not properly documented.
5.
Preheat Requirements Preheat requirements are specified temperatures above which the parent metal surrounding a weld joint must be heated prior to beginning to weld (Tr. 10076).
Brown & Root welding procedures, however, requiry all weld joints to be preheated to at least 70"F (Tr.
118367).
Mr. Stiner alleged that most of the hangers he worked on at Comanche Peak "were not preheated." Case Exhibit 919 at 9.
He later i
l testified that "all" har.gers he worked on were not preheated (Tr.
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.i >. 7 Stin:r Selding Issu s:
72 10824). Subsequently, he testified that he did preheat one hanger and that there were many he did not have to preheat (Tr. 10876-8). Mr.
Stiner testified that he was directed by his supervisor not to preheat in order to speed up production (CASE Exhibit 919 at 9). He testified that failure to preheat was a comon practice at Comanche Peak (Tr.
10800,10826). He further stated that on many occasions he had welded 4
- 4.w: ;re cai: whe tnt t.Mpors'. ore es t.eVr freniac (CNJ. Exh: bit 919 at 9; Tr. 11004-5).
As discussed more fully below, the record reveals that Mr.
Stiner's allegations regarding preheat are not reflective of systematic or significant violations of procedural requirements.
Further, even if isolated events of violation of preheat requirements l
have occurred, the likelihood of an adverse impact on plant safety is remote.
a)
Preheat Mr. Stiner alleged that he welded.on Class 3 hangers that were not preheated on days when the temperature was below 32*F. He stated that he was ordered to do this in order to speed up production. CASE Ex. 919 at 9 (H. Stiner). Although the Board discussed striking this portion of Mr. Stiner's testimony, it decided not to do so atter Applicants withdrew their motion rather than have this natter referred to the Staff.,,Tr. 9947 49.
During Mr. Stiner's first term of employment at Comanche Peak, the environmental temperature dropped below 32*F only on March 3, 1990, when the recorded temperature rose from 28'F at 6 am to a high of 60'F.
(Tr.10,035(Baker). The Board took official notice that
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during Mr. Stiner's second term of employment, from June 1981 to July 1981, the temperature at Ccmanche Peak (in central Texas) did not drop below 3?'F.
Tr. 10,035.
l.
Welding when the temperature is below 32*F is not necessarily a violatien of the applicable procedure. Paragraph 4.J of Section IV of the ASME Code prohibits welding only "where the ambient temperature is oe lc. hhre9eit." Tr. 10031 (Eder).
ahmiert terparnure' does not refer to the atomospheric or environmental temperature, but rrthe.r the temperature in the imediate vicinity of the weld joint. M.
Thus, even if it were 0*F outside, welding operations could continue so long as the area adjacent to the weld joint were maintained at 0*F or hicher. H.
l
" Preheat temperature" is the temperature of the material immediately prior to welding. Tr. 10,026 (Baker). Weld procedure 11037 specifies a minimum preheat temperature of 80'F for material up to li" thick and 200*F for materials of greater thickness. H. Joint I
Affidavit, p. 9 (Gilbert, Taylor).
Procedure 10046 (nen-ASME) specifies a pre-heat temperature of 70*F for steel up to 1}" thick.
For steel froi' It" to 2" thick, preheat is specified as 150*F, and for steel over 2.nches thick, the specified preheat is 225'F. Joint
' Affidavit at 9-10 (Gilbert, Taylor).
l l
During thg. colder months, the temperature in the areas where welding takes place is likely to be somewhat higher than the environmental temperature because welding usually takes place inside heated enclosed structures. Tr. 10.034 (Baker). Moreover, the ambient temperature is even higher than room temperature due to l-L me e---
s Stiner Welding Issu:s:
74 t
supplemental heat sources such as space heaters, and lighting. M. ;
Tr. 11,618 (Pickett).
It is not necessary to preheat material when the room temperature has been greater than the required preheat temperature for a period of time.
When it is necessary to preheat, however, a propane torch is used.
See Tr. 11,537 (Coleman).
Mr. Stiner also testified that the welders at Cemanche Peak, I
hb.alf 4..ch;ced, did nct f,rcht metal before weldhg.
- A.i h. 919 at 11. The weight of the evidence is tc the contrary. Mr. Pickett, for example, testified that Mr. Stiner did preheat. Tr. 11,643 (Pickett). Mr. Pickett was certain of this because he remembered lending his propane torch (" rosebud" or " preheat bottle") to Mr.
Stiner. Jd,.
The other welders who worked on Mr. Stiner's crew or in the same general area as Mr. Stiner each testified that they complied with preheating reouirements.
E.g., Tr.11,665 (Fernandez); Tr.
11,665 (Braumuler); Tr.11,615 (Pickett).
Although Applicants' witnesses testified that welders preheated material prior to welding, this testimony does not address precisely the allegation made by Mr. and Mrs. Stiner: that welders do not check to make certain that the temperature prior to welding is at least 60"F for materials less than 11" in thickness. Applicants' witnesses T.estified only that they used preheating bottles. There is no evidence, however, that suggests that welders utilized any kind of temperature measuring device to verify that the temperature of the metal after being preheated was at least 60*F or 200"F, whichever the case may be.
In fact Mr. Muscente implied that it is sufficient for a welder "to take his torch and play it over this material until be g.
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supplemental heat sources such as space heaters, and lighting. H. ;
Tr. 11,618 (Pickett).
It is not necessary to preheat material when the room temperature has been greater than the required preheat temperature for a period of time.
When it is necessary to preheat, hcwever, a propane torch is used.
See Tr. 11,537 (Coleman).
Mr. Stiner also testified that the welders at Ccmanche Peak, hb.Alf 4..chced, did nct f,raht metal before weldf.9
'A.,i h. 919 at 11. The weight of the evidence i, tc the contrary. Mr. Pickett, for exampic, testified that Mr. Stiner did preheat. Tr. 11,643 (Pickett). Mr. Pickett was certain of this because he remembered lending his propane torch (" rosebud" or " preheat bottle") to Mr.
Stiner. H. The other welders who worked on Mr. Stiner's crew or in the same general area as Mr. Stiner each testified that they complied l
with preheating reouirements.
E.g., Tr. 11,665 (Fernandez); Tr.
11,665 (Braumuler); Tr.11,615 (Pickett).
Although Applicants' witnesses testified that welders preheated material prior to welding, this testimony does not address precisely the allegation made by Mr. and Mrs. Stiner: that welders do not check l
to make certain that the temperature prior to welding is at least 60"F for materials less than 11" in thickness. Applicants' witnesses lestified only that they used preheating bottles. There is no evidence, however, that suggests that welders utilized any kind of l
temperature measuring device to verify that the temperature of the metal after being preheated was at least 60*F or 200"F, whichever the
(
case may be.
In fact, Mr. Muscente implied that it is sufficient for i
a welder "to take his torch and play it over this material until be w
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gets it u'p'to what we refer to as hand warm." Tr.'10,028 (Muscente).
Accordingly, the Staff has required Applicants to assess the signi'icance of pemitting welderssto make subjective deteminations as to whether the preheat requirement of Procedure 11032 is met.
Staff's assessment of Applicants' response will be considered in this proceeding.
i 51 Safety Implications of Violation of Preheat Requirements Mr. Stiner's apparent concern regarding failure to preheat is that porosity (Tr.10709) or "under bead" cracking could occur (Tr.
10802-03).
In this regard, Mr. Stiner relates an incident where he failed to adecuately preheat and the result was a visible crack down the middle of the weld. Mr. Stiner testifies that he ground out the weld and repaired it.
(Tr. 10801-4.)
With regard to Mr. Stiner's concerns, Applicants testified that in view of Applicants' use of low-hydrogen electrodes, failure to preheat would not have had a significant adverse impact on the low carbon steels welded on by Mr. Stiner or resulted in a hydrogen embrittlement related defect in the weld joint itself. However, given extreme conditions, restraint of the weld joint, and thick materials,
~
i failure to preheat may result in shrinkage stresser that could impact
~
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the we1&sent and possibly the heat affected zone of the weld. While the likelihood of a problem even under these conditions is remote, Applicants testified that if such a weld was not adequetely preheated to retard the cooling rate, excessive stresses could develop in the
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7 Stin2r Welding Issues:
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joint res'ulting in a wide-open, centerline crack o# the weld.
(Tr.
11820-38.) This was apparently the type of crack that allegedly l
occurred when Mr. Stiner failed te preheat the one weld joint he i
described in his testimony (Tr. 10802-3). Significantly, this type of failure is clearly visible and would result in detection by the welder
{
(with appropriate action such as that allegedly taken by Mr. Stiner)
- e the. QC intpcter d. airs his 'insi visial inspe'. tion cf the weit.
In either case,'the resulting defect wculd be detected and corrected.
With regard to Mr. St.iner's concerns regarding possible porosity in a weld resulting from lack of preheat, if such a condition should occur Applicants have previously testified that it would also be detected by the welder and corrected or by QC during their final visual inspection (Tr. 11897).
In this regard, Applicants have testified that the AWS and ASME Codes state that some porosity in a 4
weld is acceptable.
For example, for Class 3 welds, such as alleged to have been welded without preheat by-Mr.
Stiner, the ASME Code does not even address porosity as a visual accept / reject criterion, and it i
is rejectable under ASME subsection NF construction only 1f a pore of i
porosity exceeds 1/16 of an inch (Tr.11215).
In addition, pursuant to the AWS Code porosity is rejectable only'to the extent that the sum tf the diameters of the porosity exceeds 3/8 of an inch in any linear f
inch of weld, or 3/4 of an inch in any linear 17 inches of weld.
Nr.
11215). There has been no. testimony that even implies porosity nf this magnitude.
L In sum, the Board findt that even if Mr. Stiner had failed to j
preheat some weld joints as alleged, there is reasonable assurance g
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Stiner Velding Issu;s:
77
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that this would not have resulted in an adverse impact on plant safety The principle impact in this proceeding would be on the Peard's opinion of whether Applicants have conscientiously applied 1
their procedures.
III.
OTHER MATTERS CCNSIDERED We nave a.-l % sed dn thi!, decision each of the rer. air,1nc allegations by Mr. and Mrs. Stiner regarr'ing the welc'ing issues at Comanche Peak which we perceive could have affected'our detemination as the adequacy of the OA program or the sa#e operation of the plant.
To the extent CASE may have raised other questions, we have considered those also, and found they were without merit, were improperly raised or were insignificant and could not affect our determination here.
IV.
CONCLUSION
~
The Board concludes that the allegations raised by Mr. and Mrs.
Stiner and addressed here (i.e., weave welding, welding of misdrilled holes, downhill welding, weld rod control and preheat) are without merit except to the extent that the Board has specifically indicated in this opinion, primarily with respect to implementation of repair,
h1d procedures and the use of temperature measuring instruments to verify preheat We await further Staff filings befnre detemining the extent of the breakdown indicated by these situations. The Board i
further concludes, however, that there is reasonable assurance that these allegations are not reflective of any condition that could adversely impact the safe operation of the plant.
(We expect 9
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Stiner Welding Issu;s:
78 Applicants or Staff to correct the record, however, if they know that slag inclusions may cause a long-tem safety problem because of the effect of the inclusions'on weld integrity over time.)
ORDER For all the foregoing reasons and based on consideration of the entire record is thh mnter, it is thic 15th dc., of Cecember IM4 ORDERED:
1.
Staff analyses of Texas Utilities Electric Company, et al.,
(Applicants) responses concerning preheat and repair welding will be considered in this proceeding.
2.
Applicants appear to have had the practice of verifying preheat by subjective detemination of whether materials were " hand wam."
3.
Applicants had a practice, of indeteminate extent, of making
~
repair welds without proper documentation.
k 4
Applicants demoted a welding supervisor for directing improper l
welding in violation of procedures, but they violated Appendix 8 by: (a) failing to document this personnel problem in deficiency paper and (b) by failing to conduct an adequate contemporaneous investigation of the e'xtent of the practice or the effect of the practice on plant safety.
5.
In all ather respects, the welding allegations discussed in this opinion are found to be without merit.
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FOR THE ATOMIC SAFETY AND LICENSING BOARD D
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.Feter B.7Toch, Chaiman ADMINISTRATIVE JUDGE Y
Pa'ii.er H. Jdre v
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ADMINISTFATIV DGE m
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Kennetn A. McCollem OI ADMINISTRATIVE JUDGE Bethesda, Maryland O
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p 1,0 Y In Reply Refer To:
Dockets:
50-445/84-29 50-446/84-10 Texas Utilities Electric Company ATTN:
M. D. Spence, President, TUGC0 Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Gentlemen:
This refers to the inspection conducted under the Resident Inspection Program
)
by Messrs. J. E. Cummins, H. S. Phillips, and D. M. Hunnicutt of this office and NRC contract personnel during the period July 22, 1984, through August 25, 1984, of activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 of the Comanche Peak facility, Units 1 and 2, and to the discussion of our findings with Mr. J. T. Merritt and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection included plant status, action on previous NRC inspection findings, action on applicant identified design construction deficiencies (10 CFR Part 50.55(e) reports), inspection and enforcement bulletin followup, on-site followup of safety evaluation report open items, inspection cf spent fuel rack installation (Unit 1), applicant management of quality assurance activities, audit of licensee surveillance of contractor quality assurance / quality control activities, observation of work on reactor vessel closure head (Unit 2), interpass temperature control, and plant tours.
Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors. These findings are documented in the enclosed inspection report.
During this inspection, it was found that certain of your activities were in violation of NRC requirements.
Your letter (TXX-4300) of September 17, 1984',
in response to our letter, dated August 28, 1984, adequately addressed this violation and no further response from you concerning this violation is required at this time.
The corrective action delineated in your response and subsequent NRC followup inspection of that corrective action are discussed in paragraph 10 of the enclosed inspection report.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure i
will be placed in the NRC Public Document Rocm unless you notify this office, by telephone, within 10 days of the date of is letter, and s mit written RRI.3 TL/TF ^
0/RIVTF RP82 D/0RSM NRR
/
nholt OHunniNtt RLBangart ORHu_
r R0enis h VNoona JCum y/g/84" p/g/84
/ /84 p A $ /84 Q/g/84 \\q/84 wm
- y. F014-85-59 W
hp W3/
Texas Utilities Electric Company application to withhold information contained therein within 30 days of the date of this letter.
Such application must be consistent with the requirements of2.790(b)(1).
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
.og n.: stance ", -
D. M. HUNNI=
- 0. R. Hunter, Chief Reactor Project Branch 2
Enclosures:
1.
Appendix A - Notice of Violation 2.
Appendix B - NRC Inspection Report 50-445/84-29 50-446/84-10 cc w/ enclosures:
Texas Utilities Electric Company ATTN:
B. R. Clements, Vice President, Nuclear Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Texas Utilities Electric Company ATTN:
J. W. Beck, Manager Licensing Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 bec to DMB (IE01) bec distrib. by RIV:
RPB1 RRI-OPS TX State Dept. Health RPB2 RRI-CONST.
Juanita Ellis EP&RPB R. Bangart Renea Hicks R. D. Martin, RA J. Gagliardo Billie Pirner Garde C. Wisner, PA0
- 0. Hunnicutt R. Denise, DRSP S. Treby, ELD RIV File V. Noonan, NRR MIS System
APPENDIX A NOTICE OF VIOLATION Texas Utilities Electric Company Docket:
50-445/84-29 Comanche Peak Steam Electric Station, Unit 1 Construction Permit:
CPPR-126 Based on the results of an NRC inspection conducted during the period of July 22, 1984, through August 25, 1984, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 49 FR 8583, dated March 8,1984, the following violation was identified:
Failure to Follow Procedural Requirement for Checking Minimum Weld Interpass Temperature l
10 CFR 50, Appendix B, Criterion V requires that, " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Brown and Root Welding Procedure Specification (WPS) 11032 has been established in accordance with Criterion V.
Instructiog3onpage2ofWPS-11032requiresthatinterpasstemperature s
(above 150 F) be checked using temperature indicating crayons or an approved equal.
Contrary to the above, in the applicant's response, dated June 15, 1984, to NRC Region IV's request for additional information, dated April 23, 1984, the applicant stated that some welders had not complied with the requirement to use temperature indicating crayons or an approved equal to verify minimum interpass temperatures.
This is a Severity Level V Violation.
(Supplement II) (445/8429-01)
No further response is reqiyared from you at this time concerning this l
violation.
l l
i Dated:
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APPENDIX B k
U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report:
50-445/84-29 Construction. Permits:
CPPR-126 50-446/84-10 CPPR-127 Oockets:
50-445; 50-446 Category: A2 Licensee:
Texas Utilities Electric Company (TUEC) i Skyway Tower 400 North Olive Street Lock Box 81 Dallas, Texas 75201 Facility Name:
Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 Inspection At: Glen Rose, Texas i
i Inspection Conducted: July 22, 1984, through August 25, 1984 Inspectors:
I A fbJ,/W--
//k/79 pv J. E. Cummins, Senior Resident Reactor Inspector Datei
/
(paragraphs 1, 2, 3, 4, 5, 6, 7, 10, 12, and 13) l l
+
///9/!V H. 5. 7hillips, Seni'or Resident Reactor Inspector Date (paragraphs 1, 8, 9, 12, and 13) t
)
k.
Y
///T/?9 i
D. M. Hunnicutt, Team Leader, Task Force Date' (paragraphs 1, 3, 4, 7, 11, 12, and 13)
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. NRC Contract Personnel:
P. Snyder, Senior Nuclear Engineer, EG&G Idaho, Inc.
B. Cloward, Senior Power Engineer, EG&G Idaho, Inc.
V. Berg, Quality Engineer, EG&G Idaho, Inc.
D. Hill, Operations Specialist, EG&G Idaho, Inc.
R. W. Bonnenberg, Senior Engineer, EG&G Idaho, Inc.
R. R. Harbron, Senior Field Engineer, EG&G Idaho, Inc.
L. H. Jones, Engineering Specialist, EG&G Idaho, Inc.
G. R. Thomas, Quality Engineer, EG&G Idaho, Inc.
B. L. Freed, Management Specialist, EG&G Idaho, Inc.
Approved:
M hj. ::bwfe-
- N 89
- 0. M. Hunnicutt, Team Leader, Task Force Date' Insoection Summary Inspection Conducted July 22, 1984, through August 25, 1984 (Report 50-445/84-29)
Areas Inspected:
Routine, announced inspection of plant status, action on previous NRC inspection findings, action on applicant identified design / construction deficiencies (10 CFR 50.55(e) reports), inspection and enforcement bulletin followup, on-site followup of safety evaluation report open items, inspection of spent fuel rack installation, applicant management of quality assurance activities, audit of applicant surveillance of contractor quality assurance / quality control activities, interpass temperature control, and plant tours.
The inspection involved 636 inspector-hourt onsite and at TUGC0 corporate offices by three NRC inspectors and NRC contract personnel.
Results: Within the ten areas inspected, one violation was identified (failure to follow procedural requirem,ents for checking weld interpass minimum temperature, paragraph 10).
Inspection Summary
)
i Inspection Conducted July 22, 1984, through August 25, 1984 (Report 50-446/84-10)
Areas Insoected:
Routine, announced inspection of plant status, action on previous NRC inspection findings, action on applicant identified design / construction deficiencies (10 CFR Part 50.55(e) reports), inspection and enforcement bulletin followup, on-site followup of safety evaluation report open items, applicant management of quality assurance activities, audit of applicant surveillance of contractor quality assurance / quality control activities, l
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. observation of work in progress on reactor vessel closure head, and plant tours. The. inspection involved 121 inspector-hours onsite and at TUGC0 corporate offices by three NRC inspectors and other NRC contract personnel, e nine areas inspected, no violations or deviations were iden i ed I
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. DETAILS 1.
Persons Contacted
- J. T. Merritt, Assistant Project General Manager, Texas Utilities l
Generating Company (TUGCO)
- L. Fikar, Executive Vice President Engineering, TUGC0
- R. Baker, Staff Engineer, TUGC0
- A. Vega, Site Quality Assurance Manager, TUGC0 "L. Popplewell, Project Engineering Manager, TUGC0
- 0. Chapman, Quality Assurance Manager, TUGC0 J. B. Bodine, Electrical Maintenance Supervisor, TUGC0 D. Rencher, Technical Services Design Review Engineering Supervisor, Black & Veatch R. Moller, Project Manager, Westinghouse i
G. Maedgen, Welding Engineer Brown and Root (B&R)
J. Gilbreth, Civil Engineer,' B&R M. D. Palmer, Shift Test Advisor, TUGC0 S. Bhujang, Structural Job Engineer, Gibbs & Hill G. McGrath, Results Engineering Supervisor, TUGC0 l
J. Keller, Preservice Inspection Engineer, TUGC0 B. Hamilton, Results Engineer, TUGC0
- 0. Davis, Maintenance Engineer, TUGC0 The NRC inspectors also contacted other plant personnel including members of the construction, operations, technical, quality assurance, and administrative staffs.
- Denotes those attending one or more exit interviews.
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2.
Plant Status l
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Unit 1 At the time of the inspection, construction of Unit I was approximately 98% complete with fuel loading scheduled for October 1984.
The applicant continues to complete and turnover systems and areas from construction to operations. The turnover process is accomplished in two phases.
The '
first phase takes place when construction completes a system or area and turns that system or area over to the startup group.
The turnover process
(
is completed for a system or area when operations make final acceptance L
.of the system or area from the startup group.
The table below shows the status as of August 25,1984, of the 422 distinct areas identified by the applicant for turnover from construction to operations:
Total number of areas 422 Number of areas submitted to startup 347 Number of areas accepted by startup 347 Number of areas submitted to operations 248 Number of areas accepted by operations 109
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The table below shows the status as of August 25, 1984, of the 331 distinct subsystems identified by the licensee for turnover from l
construction to operations:
e Total number of subsystems 331 l
Number of subsystems submitted to startup 326 Number of subsystems accepted by startup 326 Number of subsystems submitted to 214 operations
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Number of_ subsystems accepted by 117 j
operations J
Unit 2 At the time of the inspection, construction of Unit 2 was approximately 65 percent complete with fuel loading scheduled for March 1986.
l 3.
Action on Previous NRC Inspection Findings (0 pen) Unresolved Item (445/8214-01):
Alleged Unqualified Corner Field Welds on the Four 4' 6" by 4' 6" Box Structures on the Main. Steam /Feedwater Pipe Whip Restraint - The AWS " Structural Welding Code," 01.1, page 14, 2
figure 2.9.1 depicts a prequalified weld joint identical to that described
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by Mr. Atchison (reference: NRC Inspection Reports 50-445/82-14; l
50-445/82-22) as shown on NPS Industries (NPSI) shop drawings. The NRC inspector reviewed the following to verify that the applicant has completed the corrective actions related to these corner field welds:
Nonconforming Report (NCR) M-82-01589 R.1 Final IR MS-1-0014363 Repair Process Sheet (cracks in weld) for Weld Data Cards, Serial Nos. 40702, 40703, 40704, and 40955 Orawing E-117-0-153 for Weld 23 Orawing E-117-0-157 for Weld 48 Orawing E-117-0-140-1-AW for Weld 23 j
NPSI Drawings E-117 and 118 for Weld 221 Magnetic Partical Testing Reports T-1624, T-1625, T-2782, and T-2783 Nondestructive Examination Procedure QI-QP-11.18-2, Rev. 1
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This item will remain open pending further review during a subsequent inspection.
(Closed) Severity Level V Violation (445/8230-01):
Failure to Follow Procedures - The NRC inspectors reviewed the corrective action taken by the applicant regarding the vendor certified stress calculations.
In an l
attempt to further reduce the error rate of the pipe support design j
calculations, activities related to these calculations were being done at the CPSES site under TUGC0 supervision.
Some of these activities had l
previously been performed at offsite vendor facilities. The NRC inspectors reviewed approximately 160 randomly selected vendor certified stress calculations.
These calculations were checked to determine if the i
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. applicant had adequately corrected the problem with errors in calculations for component and piping sup' ports in safety-related systems.
Nine of these calculations contained minor inaccuracies but in no case were the errors found to be significant.
These minor errors were discussed with the cognizant applicant representative. The NRC. inspector stressed to the applicant representative that the program for checking calculations should be continted and it was stressed that efforts should be made to further reduce the, error rate.
Based on the sample review of the vendor certified stress calculations, the inspector had no further questions regarding this matter.
(0 pen) Unresolved Item (445/8119-02):
No Verification That Component Modification Cards (CMCs) Issued After Quality Control Hanger Acceptance are Included in the Hanger Installation Package and Reinsoected by Quality 1
Control - The applicant revised Procedures CP-CPM-9.10 and CP-QAP-18.2 to incorporate the following:
Detailed distribution instructions to ensure that CMCs issued after hanger acceptance are forwarded for inclusion into the installation package.
Instructions that require the cognizant quality engineer / quality control inspector to review the amended hanger package to assess the need for any rework and/or reinspection and to take appropriate action.
The NRC inspector reviewed these procedures and also verified by training record review that applicable personnel had been trained on the content of the revised procedures.
This item will remain open pending further. review during a subsequent inspection.
(Closed) Unresolved Item (445/8405-02):
Compressibility of Epoxy Grout -
The NRC inspector verified by review of applicant's Procedure CEI-25, Rev.
6, " Epoxy Grouting of Base Plates," that Escoweld 7502 grouting material had been deleted from the procedure.
The NRC inspector also verified by review of NCR M-81-00849, Rev. 1, that the Escoweld 7502 grouting had been removed from the affected hanger base plates.
The inspector has no further questions regarding this matter.
(Closed) Unresolved Item (445/8211-01):
Piping and Support As-Built Verification Program - Applicant's analysis of the support resulted in a modification to the support that provided a 1/4" gap on either side of the pipe such that lateral thermal displacement is not restrained.
The NRC inspector verified applicable portions of the applicant's response by comparing the completed support installation to Design Drawing BRHL-AF-1-SB-003.
No discrepancies were noted.
(Closed) Unresolved Items (445/8218-01; 445/8219-01; and 445/8222-01 related to IE Information Notice No. 82-34):
Welds in Main Control Panels
-An NRC inspector performed an inspection of the hot shutdown panel (CP2-ECPRLV-01) and determined that the weld anomalies on this panel
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. exceeded the maximum permitted for the types and severity of weld defects (examples:
porosity, uneven fillet length, undersize welds, weld splatter adhering to panel and weld areas, and weld wire remnants attached to the structure) found in the installed panels at Comanche Peak, Unit 1.
This panel, CP2-ECPRLV-01, was subsequently qualified by a seismic simulation test using a bi-axial shaker table.
Other panels for Comanche Peak were similarly qualified.
This seismic simulation test met the requirements of Gibbs & Hill, Inc.
Specification 2323-MS-605 (Rev. 1), including the requirements of IEEE-344-1975.
This panel and the other panels successfully survived a series of earthquake simulations without any weld related failures.
Panels and cabinets in question can now be qualified by comparison to physically similar " seismic simulation test qualified" panels and cabinets, since the weld adequacy has been demonstrated.
Criteria for comparison include:
Overall dimensions Anchorage mechanisms Seismic required response spectra Construction details, including mate. rial type and thickness, type of stiffeners,-and weld quality Analysis indicates that the lowest margin of safety of this panel and related panels is above the specified lowest margin of safety.
All margins of safety are based on normal stress applied to analytical model beam elements.
The stresses applied to CP2-ECPRLV-01 panel welds were artificially increased by the flexible mounting configuration, thus providing a greater margin of safety or conservatism.
An SDAR (50.55(e) Report) was originally issued on March 21, 1980, to confirm a verbal report to NRC that control board welded connections had 1
deficiencies that were identified by applicant QA staff inspections during February 1980.
These deficiencies were described as follows:
1.
The specified eight inch spacing of the welds was found to vary from sixteen to eighteen inches on several panels.
2.
Some of the panels had been set on buttered weld surfaces some 1/4 to 5/16 inches above the embed surfaces.
3.
Where the panels were resting on the buttered weld surfaces, the embed to panel welds were undersize and in many cases did not possess sufficient leg or throat dimensions to be considered a fillet weld.
The applicant p.repared as-built drawings of the welds on each panel.
These drawings and a complete weld plot were made on panels CP1-ECPRBC-1 through -11.
The weld plots were analyzed by Reliance Electric to determine the extent j
of rework. Gibbs & Hill made recommendaticns after reviewing the Reliance T
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. Electric recommendations.
Design changes were completed subsequent to the completion of the Gibbs & Hill review.
Work packages on each panel were prepared, showing step by step implementation of the Reliance Electric recommendations.
NRC followup on this reported series of deficiencies on control board welded connections was reported in the following inspection reports:
1.
445/82-18 (Unresolved Item 8218-01) 2.
445/82-19 (Unresolved Item 8219-01) 3.
445/82-22 (Unresolved Item 8222-01) 4.
445/83-02 (Inspection performed at Reliance Electric Company, Stone Mountain, Georgia)
Based on the review of this matter, including the applicant corrective actions, the NRC has no further questions regarding this item at this time and the item is considered closed.
(Closed) Severity Level IV Violation (445/8324-04; 446/8315-04):
Failure to Provide Adequate Control of Ventilation System Fabrication - The applicant issued a potential 10 CFR Part 50.55(e) report (SOAR CP-83-06, dated March 1,1984) and subsequently issued a stop-work order on March 8, 1984 (CPPA-28,428) on all structural welding at CPSES.
Ther.e two documents were the result of identified welding dimensional discrepancies or incorrect member sizes on duct support welding.
The stop-work order was lifted on April 27, 1984.
The inspection was initiated to determine the applicant's corrective actions related to failure to provide adequate control of ventilation system fabrication (reference:
NRC Inspection Report 50-445/83-15; 50-446/83-12, Severity Level IV Violation).
The NRC inspector reviewed the four separate phases of reported activities performed by Corporate Consulting and Development Company, Ltd. (CCL) for the licensee.
These evaluations and recalculations are contained in the following:
TUSI CPSES Ductwork Evaluation of Nonconform.ing Velds, dated July 25, 1983 Phase I, CCL Report A-548-83-01 Phase II, CCL Report A-548-83-02 Phase III, CCL Report A-571-83-01 Phase IV, CCL Report A-578-83 Phase I (CCL Report A-547-83-01) detailed a review of 104' duct supports to obtain a preliminary assessment of nonconforming welds.
These duct supports were selected for detailed weld inspection based on evidence that a
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some welds were not in accordance with installed guidelines.
The CCL engineering review was to evaluate the actual welds in comparison to the specified welds on a case-by-case, joint-by-joint basis. CCL recommended that the evaluation be carried to a greater depth to examine in detail duct supports known to have high weld stresses as the sample of 104 duct supports did not include supports which were heavily stressed.
In Phase II (CCL Report A-548-83-02), CCL identified all duct supports with weld stresses greater than 1/2 safe shutdown earthquake (SSE) allowable weld stress. A total of 240 duct supports were identified.
CCL completed a review of the structural adequacy of 240 duct supports with the highest weld stresses.
These duct supports were selected by reviewing CCL Seismic Qualification Report of Seismic Category I Ductwork and Hangers for CPSES - CCL Report A-424-91-05.
The CCL engineering review evaluated the welds, assuming 1/2 of the specified thickness and 75% of the specified length on a case-by-case, joint-by-joint basis.
This CCL review determined that all welds in the heating, ventilation, and air conditioning (HVAC) duct supports will carry the design loads and meet the specification requirements relative to allowable stresses and exhibit an additional margin of safety.
Even though all duct supports were shown to be adequate, three (R81-PS25, CB-852-1N-4F, and CB-852-2N-4E) of the eight duct supports with the highest identified weld stresses were determined to be qualified by an evaluation using actual weld size and length rather than the assumotion of 1/2 specified thickness and 75 percent of specified length.
There were no duct supports qualified by similarity to these three duct supports.
CCL concluded that the ductwork and supports meet functional design requirements based on Phase I and Phase II evaluations of the weld nonconformances on the CPSES duct supports.
In Phase III (CCL Report A-571-83-01), a statistical sample of 285 duct supports were physically reinspected to establish engineering assumptions used in Phase III engineering analysis (licensee office memorandum, dated March 29, 1983, from L. M. Bielfeldt to R. G. Tolson stated a sample size of 280 duct supports was required to achieve a 95 percent confidence level l
that greater than 95 percent of the duct support welds are adequately sized).
CCL completed a review of the structural adequacy of the 285 duct i
supports.
This study demonstrated that the welds on the HVAC duct i
supports will carry the design loads, meet the specification requirements I
i for allowable stresses, and maintain a load carrying safety margin.
Of the 285 duct supports reviewed, none were found to be overstressed after examination of the actual weld details and loads existing on these welds.
In Phase IV (CCL Report A-578-83) CCL presented an analysis which uses i
data from accessible hangers in conjunction with data from the inaccessible hangers as a basis for evaluation.
Because 57 hangers were inaccessible and detailed inspection could not be perforr.ed, it was necessary for CCL to perform statistical techniques to evaluate the adequacy of these 57 hangers.
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. Statistical methods were employed to determine the probabilities that specific joints on specific hangers would not be overstressed under both operating basis earthquake and SSE scenarios. The probability that at least one joint would not be overstressed was also obtained.
Statistical analysis provided the probability or confidence level (for the belief that the joints were not overstressed) calculations for the 620 joints on the 57 hangers).
Six hundred and sixteen joints have calculated confidence levels of 99.9 percent or greater, while the remaining four joints have confidence levels of at least 98.9 percent.
The four hanger joints with confidence levels less than 99.9 percent are:
CB-830-1N-4Q, CB-830-1N-4Q, CB-830-1N-4F, and CB-830-1N-4R (NOTE:
hanger CB-830-1N-4Q had two joints with confidence levels less than 99.9 percent, thus hanger CB-830-lN-4Q had a calculated confidence level of 98.9 percent that no weld joint on this hanger is overstressed).
CCL reevaluated the fan coil unit supports for CP1-VAAUSE-05 and -06.
Reevaluation indicated that dimensional changes do not affect the seismic adequacy of the supports (see Bahnson Service Company Drawing FCUS-0010, Sheet 1 of 3 sheetsT.
The seismic qualification for the fan coil unit supports is discussed in CCL Report A-456-82-01.
The seismic analysis used floor response spectra curves for safeguards building el. 873'.
These fan coil unit supports are attached to the ceiling (overhead) of the safeguards building el. 802'.
The CCL reevaluation determined that the anchor bolts for the fan coil unit supports are acceptable with a small safety factor.
Beam member stress and the compression member coefficient in the seismic qualification report indicated large safety factors for each of these two areas.
The NRC inspector determined that the CCL evaluations and calculations were made using reasonable assumptions and with acceptance data and that the calculation results were adequate.
The NRC randomly selected 13 duct supports in 4 different systems and inspected 11 duct supports (2 were inaccessible) in detail.
The NRC inspector used FSAR, Section 9.4, the approved design and installation drawings, and all phases of the CCL report to determine the as-built condition.
The NRC inspector evaluated the following attributes during the physical portions of duct support inspections:
Duct Supports Duct Segments Location Size Welding Location Dimensional Requirements Orientation In addition, a previous NRC inspection (reference:
NRC Inspection Report 50-445/84-10, paragraph 6) of the HVAC included inspection by NRC inspectors of 24 duct supports and approximately 120 feet of duct in the CPSES, Unit 1 cable spread room, review of Bahnson procedures pertaining to the fabrication, installation, and inspection of the seismic duct and hangers, and a review of CCL Report A-579-83.
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. l These two NRC independent inspections (50-445/84-10 and this inspection) determined that the scope of the CCL evaluation was adequate to evaluate I
the identified discrepancies in the Bahnson fabricated and installed duct supports.
l (0 pen) Open Item (445/8323-07):
Review of Hanger Package Records -The I
licensee has formed a hanger task force and has instituted a total package concept. This concept is designed to prevent having parts of packages in the field. Three Class V hanger packages were reviewed by the NRC j
inspector for current drawings, inspection reports, and CMCs.
Revision of drawings and CMC incorporation into drawings were verified to be current through the document control center.
The backlog of records at the time of the NRC inspector's review was approximately 1 day.
The following items are being reviewed by NRR and the Atomic Safety and Licensing Board (ASLB) and Region IV will take appropriate followup action as dictated by the conclusions of the reviews:
Open Item (445/8226-05):
Analysis of Pipe Sucoort MS-1-003-009-C72K Unresolved Item (445/8226-06; 446/8214-05):
Excessive Deflections in Supoorts Unresolved Item (445/8226-07):
Stress Analysis of Pipe Support CC-1-107-008E23R f
Open Item (445/8226-04; 446/8414-03):
Stability of Box Frames l
These matters are considered open pending completion of the actions by the ASLB and NRR.
4.
Action on Apolicant Identified Design / Construction Deficiencies (10 CFR Part 50.55(e) Recorts)
The 10 CFR Part 50.55(e) rep' orts identified in the table below were reviewed by the NRC inspectors and closed.
The 10 CFR Part 50.55(e) reports were reviewed for content, compliance with NRC requirements for reporting, appropriate evaluation, and adequacy and implementation of corrective action. The 10 CFR 50.55(e) reports identified in the table below were evaluated by the applicant and determined to be not reportable.
Each report is identified and tracked by the unique, assigned number shown in the left column.
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. 50.55(e)
Applicant Report Letter Number Subject Number CP 77-08 Installation of Pipe Whip TXX-2474 Restraint Anchor Bolts, Nuts and Plates CP 77 Cadweld Test Specimen Rebar TXX-2269 i
Failure CP 77-05 Omission of Baron Recycle TUS-1416 Evaporator Foundation Anchor (Memo)
Bolts CP 83-03 Review of Procurement and TXX-3624 Installation Activities for Non-metallic Insulation on Stainless Steel Lines may not be in Strict Compliance with Regulatory Guide 1.36 (FSAR, Section 1A(B)15&l6)
CP 77-02 Concrete Curing Blanket Fire TXX-2265 (Service Water Intake Structure)
CP 78-06 Cadweld Sleeve Failure TXX-2896 CP 84-01 Lamination in Cable Tray TXX-4154 Support Column CP 78-01 Service Water Pump Supports No licensee letter CP 79-12 Internals for filters for CPP-2669 Atmospheric Cleaning Units (TUSI Memo)
CP 80-01 Service Water Pumps -
No licensee Manufacturer's Defect letter CP 80-06 Reactor Upper Internals TXX-3217 i
Roto-Lock Insert CP 82-04 Pacific Pump Multi-Vane TXX-3634 Diffuser Linear Indications CP 82-14 Reactor Coolant Pressurizer TXX-3592 Surge Line i
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50.55(e)
Applicant
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Report Letter l
Number Subject Number i
CP 84-06 Pipe Support Design Error TXX-4107 f
CP 84-13 Final Safety Analysis TXX-4213 Report and Technical Specification Consistency CP 84-A Vendor Inspector Eye Exams TXX-4204 l
CP 84-8 Vendor Supplied Stock Material TXX-4161 l
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CP 84-15 Indeterminate Fluoride Content TXX-4221 r
of Manville Insulation The 10 CFR Part 50.55(e) reports discussed below were evaluated and determined to be reportable.
Each report is identified and tracked by the unique applicant assigned number shown at the beginning of each discussion.
j CP 77 Fuel Building Crane Girder Desian.
Applicant letter
[
(TXX-2609) dated November 18, 1977, reported to the NRC that this f
deficiency was reportable and delineated corrective actions.
The i
deficiency involved crane girder support design load combinations for the fuel building crane.
The stress analysis for the fuel building I
was repeated, including the seismic response of the lifted load.
Modification of the building structural design was required in the I
fuel building upper walls, roof and roof beams, crane rail supports,
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and crane trolley stops.
These changes were incorporated into the structural drawings.
The problem apparently occurred during the design data transfer between the architect engineer's structural special analysis group and the structural design group.
The design data for other seismic Category I cranes was checked,and found to be correct.
p CP 83 Westinghouse Motor Operated Gate Valve Position Indication.
Applicant's letter (TXX-3633) dated February 25, 1983, l
reported to the NRC that this deficiency was reportable and l
delineated corrective actions.
The deficiency was that certain i
Westinghouse gate valves would indicate " closed" prior to the valve disc fully isolating flow.
This could have resulted in a situation where flow was reduced, if the valve were to bind or stall.s fter reaching the " closed" indication position but prior to the valve disc l
fully isolating flow.
The affected valves in safety-related applications have been modified to correct this condition.
CP 83 Broken Tack Welds In Westinchouse Supplied 480VS Switchaear. Applicant letter (TXX-4078) dated November 16, 1983, reported to the NRC that this deficiency was reportable and delineated corrective action.
Westinghouse Model 05-416 breakers were found to have unacceptable tack welds on the secondary disconnect support bracket.
A 100% inspection of the 05-416 breakers
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- 7 was performed and all support brackets with defective or suspect welds were replaced (36 brackets were replaced).
No violations or deviations were identified.
5.
Inspection and Enforcement Bulletin (IEB) Followup The NRC inspectors reviewed the applicant's file for each of the IEBs discussed below and performed inspections when required to verify that the applicant had conducted an adequate review to determine if the IEB was applicable to the CPSES facility, and to verify that the applicant had taken the required action on applicable IEBs.
IEB Nur.ber Subject 79-02 Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts 82-01, Rev. 1, Alteration of Radiographs of Welds in Supplement 1 Piping Subassemblies 79-07 Seismic Stress Analysis of Safety-Related Piping 78-12, -12A, -128 Atypical Weld Material in Reactor Pressure Vessel Welds 80-08 Examination of Containment Liner Pen'etration Welds 80-03 Loss of Charcoal From Standard Type II, 2-inch Tray Absorber Cells 80-05 Vacuum Condition Resulting in Damage to Chemical Volume Control System Holdup Tanks 83-03 Check Valve Failures in Raw Water Cooling Systems of Diesel Generators 83-07 Apparently Fraudulent Products Sold by Ray Miller, Inc.
a.
IEB 81-03:
Flow Blockage of Cooling Water to Safety System Components by Corcibula SP (Asiatic Clam) and Mytilus SP (Mussel)
In response to IEB 81-03, TUGC0 letters TCP-1216 and TCP-83073 stated that an inspection by an independent consultant of the cooling water sources for CPSES, Squaw Creek reservoir (SCR) and Safe Shutdown j
Impoundment (SSI), had found no clams (Corbicula)
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i present in any of the areas sampled.
Based on this, the licensee committed to semiannually sample likely Corbicula habitat areas in the SCR and the SSI.
The semiannual inspection performed in December 1983 identified live Corbicula in the SCR and the SSI.
When the licensee determined that Corbicula was present in the cooling water sources Procedure ENV-211 for sampling the cooling water sources was cancelled and action was taken by the licensee to deal with the existence of Corbicula in the cooling water sources.
The licensee is presently setting up programs for monitoring the service water system and the fire protection system for Corbicula infestation.
The following specific actions that have been taken and or will be taken were delineated in TUGC0 memorandum l
TIM-840142, dated January 18, 1984.
f f
The Unit 1 component cooling water heat exchangers and a selected number of service water strainers were opened and inspected.
Clams estimated to be one growing season old were found in the strainer baskets.
Strainers and heat exchangers in safety-related systems-and components using service water will be added to the licensee's routine maintenance program to periodically inspect for clam infestation.
, Service water system flow rates will be monitored and trended to detect any blockage of the flow i
paths.
The base line flow rates for this trending will come from preoperational test data i
and the licensee will initiate trending
[
activities upon completion of the preoperational testing of the service water system.
i The fire protection system will be inspected for clan infestation as part of a semiannual flush which is performed in accordance with Procedure OPT-220A, " Fire Suppression Water and Sprinkler System Operability Test."
l The licensee performs chlorination of the service water and fire protection bay in accordance with Procedure 50P-501A, " Station Service Water System," to help control biofouling.
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. The NRC inspectors will continue to monitor the service water and fire pr' otection systems as-part of routine NRC inspections.
b.
IEB 79-02:
Pipe Support Base Plate Designs Using Concrete Expansion Anchor Bolts.
The NRC inspector determined from review of documentation and discussions with cognizant applicant personnel that the requirements of IEB 79-02 through Revision 2 appeared to be met by the licensee.
Design assumptions at CPSES now include the component support
. baseplates, which fall under the provisions of IEB 79-02, are flexible.
Consistent analytical methods are in place at CPSES for baseplate and anchor load analyses.
A testing program was conducted to determine anchor bolt torque valves and to assure the required anchor preloads.
c.
IEB 79-07:
Seismic stress analysis of safety-related piping.
No corrective action was required as the seismic analysis of safety-related piping at CPSES did not utilize the deficient summation methods outlined in this IEB.
d.
IEB 80-03:
Loss of charcoal from Standard Type II, 2-inch tray absorber cells.
A visual inspection of the absorber section was performed on a randomly selected number of ventilation units.
The perforated screens were secured to the frames by spot welds spaced at 2-inch centers.
No defective spot welds were observed and there was no evidence of the screens sagging away from the cell frames. The absorber cells used at CPSES were manufactured by C.V.I. Corporation.
e.
IEB 80-05:
Vacuum condition resulting in damage to Chemical and Volume Control System (CVCS) holdup tanks.
l The applicant reviewed the CPSES design for all low i
pressure process or holdup tanks and concluded that the tanks have adequate measures to protect against vacuum conditions.
The NRC inspector determined from an inspection of the volume control tank, the recycle holdup tank, and the waste holdup tank that the tanks appeared to be adequately protected against vacuum conditions.
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l f.
IEB 83-03:
Check valve failures in raw water cooling systems of t
diesel generators, j
t The valves at CPSES are corrosion resistant stainless steel and will be full stroke tested every three months.
No response to this IEB was required from
(
CPSES (construction permit holder).
g.
IEB 83-07:
Apparent fraudulent products sold by Ray Miller, Inc.
[
A search conducted by the applicant of the CPSES l
procurment files did not identify any materials.
A search of the CPSES procurement files did not identify any fraudulent materials which may have been I
supplied by Ray Miller, Inc.
This search included a j
survey of vendors to CPSES who may have supplied fraudulent Ray Miller, Inc. material.
h.
IEB 78-12:
Atypical weld material in reactor pressure vessel welds.
Combustion Engineering Power Systems, the manufacturer of the applicant's reactor pressure vessels prepared a 1
generic report in response to the requirements of IEB 78-12.
The applicant determined from review and investigation that this report satisfactorily represented data for the reactor pressure vessel welds i
at CPSES.
l i.
IEB 80-08:
Examination of line penetration welds The NRC inspector determined that containment fluid head design piping penetrations were radiographed and no backing bars were used.
This satisfied the requirements of this bulletin.
l j.
IEB 82-01:
Revision 1, Supplement 1:
Alteration of radiographs of welds in piping subassemblits.
(
The applicant performed a complete review of all radiographic film of piping subassemblies, furnished
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by ITT Grinnell.
This review included Class 1, 2, and 3 piping and involved approximately 3,949 welds
'(39,760 radiographs).
No violations or deviations were identified.
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. 6.
On-Site Followup of Safety Evaluation Report (SER) Open Items The NRC inspectors held discussions with cognizant applicant personnel and reviewed related documentation to determine which actions the licensee had taken to fulfill commitments made to each of the SER ftems discussed
- below, a.
SER, Section 2.5.6.5, page 2-37; Supplemental. Safety Evaluation Report (SSER) 1, Section 2.4.3.1, page 2-1; and SSER 1, Section 16, page 16-2
Subject:
Technical Specification for Annual Inspection of Integrity of the Rip-Rap Construction Protection for the Safe Shutdown Impoundment (SSI)
Findings: The applicant had implemented Procedure EDA-304, Rev. O, "SSI Dam Inspection," which describes the required inspections of the integrity of the rip-rap construction on the SSI.
An inspection of this area was made in accordance with EDA-304 on September 20, 1983, and no discrepancies were found.
A visual inspection of the SSI was performed by a consultant on August 25, 1982, and no discrepancies were found.
The licensee was in the process of revising the procedure for accomplishing the SSI annual inspection.
As a result of this revision, Procedure EDA-304 will be superseded by Procedure EGT-758 which was in the applicant's procedure concurrence cycle at the time this NRC inspection report period ended.
b.
SER, Section 2.5.6.7, page 2-39
Subject:
Technical Specification for Surtey and Visual Inspection of SSI to Record Instrument Readings Annually Findings:
The applicant had implemented Procedure EDA-304, Rev. O, "SSI Dam Inspection," which documents annual readings of the surface alignment monuments and the well point piezometers.
Reference data for the SSI surface alignment monuments are based on readings taken on June 23, 1980.
Piezometer measurements for the SSI have been recorded annually since 1979.
The applicant was in the process of revising the procedure for accomplishing the SSI annual inspection.
As a result of this revision, Procedure EDA-304 will be superseded by Procedure EGT-758 which was in the applicant's procedure concurrence
-cycle at the time this NRC inspection report period ended.
SER 1, Section 2.4.8, page 2-2; SER, Section 2.4.8, page 2-23; and c.
SSER, Section 16, page 16-2
Subject:
Program to Monitor Sediment Buildup in the SSI and Technical Specification Procedure for Sediment Removal Findings:
The applicant had implemented Procedure EDA-304, Rev. O, "SSI Dam Inspection," which addresses the annual inspection of the
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4 4 Station Service Water (SSW) intake channel.
Base line data for the actual elevation of the SSW intake channel bottom was collected on March 10,1983, by use of a measured sounding line and weight.
The elevation was measured at locations 50, 75, and 100 feet upstream of the SSW intake structure.
The applicant was in the process of revising the procedure for accomplishing the SSI annual inspection.
As a result of this revision, Procedure EDA-304 will be superseded by Procedure EGT-758 which was in the applicant's procedure concurrence cycle at the time this NRC inspection report period ended.
I d.
SER, Section 3.5.3, page 3-10
Subject:
Final Design of Concrete Missile Barrier on Top of Diesel Fuel Storage Tanks Findings: The NRC inspector verified the adequacy of the concrete missile shield on top of the diesel fuel storage tanks by performing a review of selected portions of the applicant's missile barrier calculations. This review indicated to the NRC inspector that the i
design meets the requirements and intent of FSAR, Section 3.5.
The concrete barrier slab design is for a depth of l' - 9" is identical in thickness to roof Category I safety-related concrete structures designed to provide environmental missile protection.
The NRC inspector reviewed B&R Drawings 2323-S-03061, 2323-S-0307, " Diesel Fuel Oil Storage Cover," as amended by DCA-12316, Rev. 3 which detailed the missile barrier slab layout and cross sections.
e.
SER, Section 6.2.3, page 6-11 1
1
Subject:
18-inch Containment Pressure Relief Valves Qualified for Closure at 50 PSIG; Installation of Seismic Category I Debris Screen i
Findings:
The NRC inspector reviewed Nordan Test Report 2060-R-001 which documented testing of valves of an identical design to the installed 18" containment pressure relief valve.
The testing l
)
involved 12" and 30" valves and required that the valves be opened and closed against 275 psi upstream pressure.
The NRC inspector reviewed the seismic screen structural analysis (Seismic Category I) for the containment pressure relief valve, verified that the debris screen was installed on containment pressure relief valve 1HU5549, and reviewed the environmental qualification certificate data for the valve operator for valve 1HU5549.
4
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No violations or deviations were identified.
7.
Spent Fuel Storage Racks (Unit 1)
The NRC inspector reviewed the installation records for the Unit 1 spent fuel racks.
The records indicated that installation was as required.
New fuel elements are presently stored in these fuel racks.
The NRC inspector i
reviewed the documentation in the following:
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l Traveler ME-83-1055-4000 Traveler ME-82-2239-4000 Reference Drawing (Westinghouse) 6125E32 Traveler ME-82-2204-4000 Traveler ME-83-1078-4000 B&R, Inc. CPSES Material Requisition 165792, dated June 14, 1982 Weld Filler Material Log B-1914 NCR M-80-00085 R.5 Welder Qualifications for Welder Symbol BR4 - dated April 16, 1983 (Westinghouse) Procedure 2463A81, " Installation Procedure for 16-inch Spaced Spent Fuel Storage" DCA-13,296 (Modify Rack to Fit Anchor 8alts) i DCA-13,716 (Accept As-Built Location of Rack as Shown on Stearns-Roger Orawing 8934/4-23, Rev. F Traveler ME-81-2054-4000 The NRC inspector determined that the licensee adequately prepared, i
reviewed, and maintained an acceptable system of quality records.
The NRC inspector determined that these spent fuel racks do not indicate a i
potential generic problem; however, the licensee does plan to replace the existing spent fuel racks with new "high density" spent fuel racks at a later date.
l The NRC inspector determined that the licensee personnel involved with the installation of spent fuel-storage racks were qualified to perform their assigned tasks.
The NRC inspector reviewed applicable sections of the Safety Analysis Report and SER (Sections 1, 3, 9, and 17) and applicable referenced codes and standards.
In addition, Regulatory Guides 1.13, 1.29, 1.38, 1.58, and 1.88 and ANS 57.2 (ANSI N210)'were reviewed.
No violations or deviations were identified.
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8.
Applicant Management of Quality Assurance Activities During this inspection report period, the NRC inspectors initiated but did not complete an inspection of the applicant's management of quality assurance activities.
The inspection is being performed to determine the status and effectiveness of applicant management and implementation of the
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corporate quality assurance program for ongoing activities of design, I
procurement, and construction.
The inspection included a review of both corporate and on-site quality assurance management and programs.
i The findings and details of this inspection will be reported in a subsequent NRC inspection report.
(
9.
Applicant's Surveillance of Contractor Quality Assurance / Quality Control i
Activities 1
During this inspection report period, the NRC inspectors initiated but did j
not complete an inspection of the applicant's surveillance of contractor I
f
. quality assurance / quality control activities. The inspection is being performed to determine whether the applicant's implementation of quality assurance responsibilities relating to surveillance of contractors is consistent with the quality assurance program described in the application for the construction permit.
The findings and details' of this inspection will be reported in a subsequent NRC inspection report.
- 10. Minimum Weldina Interpass Temperature Control In response to a request from the ASLB to look into allegations concerning welding practices at CPSES, NRC inspectors interviewed a number of welderr employed at CPSES. These interviews were conducted during the first
/
2 weeks in March 1984.
The NRC inspectors determined from these j/dtd interviews that there were instances in which welders did not use co ftg temperature indicating crayons to verify interpass temperatures as required oy B&R Welding Procedure Specification WPS-11032.
Subsequently,'$[g the NRC Region IV office, in a letter, dated April 23, 1984, requested that the licensee respond to specific questions concerning welding practices at CPSES.
The licensee, in his response letter, dated June 15, 1984, stated that it had been determined from interviewing welders that some of the welders had not always complied with the requirement to use temperature indicating crayons to verify minimum interpass temperature, but that the welder sometimes used judgement to determine that minimum interpass temperature requirements were met.
The failure to use temperature indicating crayons as required is an apparent violation.
(445/8429-01)
The applicant provided additional information rel'ated to welding practices in his letter TXX-4300, dated September 17, 1984.
This additional information included corrective actions designed to resolve the monitoring of minimum interpass temperatures discussed above.
These corrective actions included the following:
Revisions to applicable welding procedures to clarify the use of positive temperature indication between each weld layer.
Training of welders on these procedure changes.
Welding engineering department and quality control personnel will perform surveillances to insure the interpass temperature control requirements are being met.
The NRC inspector determined from reviewing revisions to selected I
procedures, welder training records, and quality control interpass weld surveillance records that the corrective actions described above had been implemented or were in the process of being implemented.
Portions of the following documents were reviewed by the NRC inspector:
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I CP-CPM 6.90, Rev. 6, Document Change Notice (DCN) 4, " Welding and Related Processes" (in concurrence cycle at time of NRC review) l CP-CPM 6.98, Rev. 2, DCN 1, " Weld Filler Material Control" (in j
concurrence cycle at time of NRC review)
QP-QAP 11.1-26, Rev. 16, "ASME Pipe Fabrication and Installation Inspections" Documentation of welder training on use of thermometers which was completed on September 26, 1984 Quality control surveillance of interpass welds records.
This item is closed.
- 11. Observations of Work in Progress on Reactor Vessel Closure Head, Unit 2 1
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The NRC inspector selected the reactor vessel closure head, Unit 2, as a representative component to observe work performance, partially completed l
work, and completion of a portion of the work.
a.
Receipt Inspection l
l (1)
Initial Receipt The NRC inspector reviewed the material received record for l
100 "Y" inserts.
These "Y" inserts were procured on Purchase Order CP-0001, 460600, dated June 4, 1984.
The "Y" inserts conformed to Westinghouse drawing 271C740, Rev. 3.
The material is identified on Material Report 11907.
(2) Nonconforming Items One head adapter plug, S/N U420A08, was found to have an unacceptable female head plug weld edge to the mating land surface.
The specified tolerance was 5.125" + 0.002".
The actual dimension was 5.12225".
A " hold tag" Iiad been applied.
(3) Documentation The reviewed documentation had been properly prepared and was being maintained as required by receipt inspection instructions.
i 1
b.
Storace, Handling, and Protection 1
P (1) Storage and Protection The control rod drive mechanism housings (CROMH) (latch and rod travel) were protected in wooden crates as required by manufacturer's instructions.
Each CROMH was inspected for 1
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. damage by licensee and Westinghouse personnel when it was removed from the crate.
(2) Cleanliness The CRDMHs, the head adapter plugs, and the closure head housing extensions were maintained in a clean condition.
The housekeeping in the plastic enclosed area was adequate for
)
installation and welding performed.
(3) Surveillance Activities and Documentation The applicant and contractor personnel performed surveillance by requiring review and concurrence by quality assurance personnel, mandatory holdpoints for Authorized Nuclear Inspector (ANI) review and observation, and by contractor engineer observing the installation, NOE, weld repairs, and related activities.
c.
Installation l
(1) Observations of Installation Activities The NRC inspector observed the various installation activites, including installation of five head adapter plugs; nine CRDMHs; seal welding of five components (two head adapter plugs and three CROMHs); repair of two seal welds; cleaning, application of dye penetrate and developer, interpretation of liquid (dye) penetrant test (PT) results; documentation of satisfactory and r
rejectable PT results; weld metal requirements; repair welds by a welder, symbol ARK; and other related installation activities.
4 (2) Personnel and Equipment The applicant and contractor personnel performing the various installation activities were qualified as required.
The welder and NDE personnel had met the recommended requirements for their i
l respective work assignments.
The specialized equipment, automatic welding apparatus, was properly checked out prior to use and was properly positioned prior to start of argon purging and subsequent welding operation.
(3) Drawings and Work Procedures The NRC inspector observed that the appropriate procedures and 4
drawings were available in the immediate work area and that these documents were the latest revision and were legible.
The work results were documented as work progressed.
The workmen referenced the document package during various work activities prior to performing subsequent work-related activities.
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r (4) Hold Points The NRC inspector obserfed thht all work was stopped at a designated hold point requir6d by the ANI. The seal weld was not attempted until the ANI reviewed the work package and authorized the seal weld on head adapter plug 24.
(5) Preparation and Maintenance of Records The NRC inspector reviewed the work package being prepared as the work progressed and observed that the record was maintained.
The entries made in the record were legible, error: were lined out and properly re-entered, and the records were kept in an area free from oil or other materials that could render the entries illegible.
d.
Documents Reviewed The NRC inspector reviewed the following documents related to the observed work activities associated with the installation of CROMHs and head adapter plugs:
CE Orawing E11773-161-002, Rev. 6 Work Sheet - CP 2 Selective Positioning and Welding Plan Westinghouse Drawing 1553 E 84, Sheets 1 and 2, Rev. 2 Weld Procedure Specification 99029, Rev. 3 Traveler ME 84-4548-5500 Traveler ME 84-4611-5500 Traveler ME 84-4586-5500 Traveler ME 84-4588-5500 Traveler ME 84-4589-5500 Traveler ME 84-4587-5500 Traveler ME 84-4585-5500 Traveler ME 84-4661-5500 Repair Process Sheets for Weld Data Cards, Serial Nos. 00360 (Weld FW-18) and 00131 (Weld FW-12)
QI-QAP-10.2-1, " Liquid Penetrant Examination," Rev. 3, dated February 18, 1983 QI-QAP-2.1-1, "NDE Personnel Certification" SAR Chapters 3, 5, 6, 9, and 17 No violations or deviations were identified.
- 12. Plant Tours At various times during the inspection period, the NRC inspector conducted general tours of the reactor buildings, fuel building, safeguards building, electrical and control building, and the turbine building.
During the tours, the NRC inspector observed housekeeping practices, preventive maintenance on installed equipment, ongoing construction work, and discussed various subjects with personnel engaged in work activities.
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. No violations or deviations were identified.
13.
Exit Interviews The NRC inspectors met with members of the TUEC staff (denoted in paragraph 1) at various times during the course of the inspection.
The scope and findings of the inspection were discussed.
The applicant acknowledged the findings.
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UNITED STATES OF AMERICA
' i 6 *r PI'CLEAP REGULATORY C0$?!? ION Before Administrative Judges:
Peter R. B!cch, Chairman Dr. Kenneth A. McCollom Dr. Wa'ter H. Jordan I
In the Matter of I
Docket Nos [0 445-08 i
50 446-OL
)
TEXAS UTIL? TIES ELECTRIC CnMpANY, e+ al.)
-)
ASLRP No.70-420 06 OL (Comanche Peek Steam Electric Station,
)
Units 1 and 2)
)
)
January 16, 1085 MEF PAMDUM (Clarification of Welding Issues Order of December 18,1094) 1.RP-84-55 should be modi #ied, at the suggestion of the Staf# of the Nuclear Pegulatory Commission (Staff) and of Citizens Association for Sound Energy (CASE) so that specific information about uenry Stiner is omitted.
The omission is necessary because this information, which was subject to a confidentiality agreement among the parties (Tr. 10578-79),
was included in Texas Utilities Electric Company g al. (Applicants')
proposed findings, filed Sep+ ember 7, 70PA, without obfection # rom the o+her par +.ies.
Temnera'ure indicating crayons and weld svmbnis ara no+ considered by the Snard
+.o he cending issues.
Similarly, the safety of repair welds due to their location was not raised on our record and is not part of this procaeding unless: (1) there are grounds 'o reonen tha record, or (2) the Staff had knowledge of this problem prior to the time we dacided this issue and ' ailed to infom us that +5ey had substan+ial 3
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Welding Clarification:
2 doubt about the validity of prior Staff testimony.
However, we note the Technical Review Team's ongoing inquiry into this concern and would consider readmitting the issue if it has sufficient safety importance to make it important for the adequacy of the record.
On the subject of undocumented repair welds, the Board agrees with the Staff's suggestion concerning the current state of the record.
There record reveals a Staff finding that repairs were found for which Applicants coulo not produce documentation.
However, in the interest of an adequate record, the resolution of this issue remains before us.
The question of QC Hold Points for Weld Repair is not within the scope of our previous order.
We are awaiting the Staff response before determining whether or not to make the issue a part of this proceeding.
Other issues raised by the parties will be decided subsequently.
ORDER For all the foregoing reasons and based on consideration of the entire record in this matter, it is this 16th day of January 1985 ORDERED:
1.
The first paragraph of page 10 of the 5117 opinion of LBP-84-55 shall be deleted, replacing it with: Informaiicn igarding certain aspects of Mr. Stiner's background were iocei.ta,nto evidence by the Board (Applicants' Exhibits 181, 182, 183, CASE Exhibit 965, Tr. 10578,
- 79) and duly considered. -
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Velding Clarification:
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Or pace 18 of the slip opinion of f.PP-84-55, dele +e the first sentence of the last caragraph on the pace, in Section "A."
- Then, delete "also" ir the followinc sentence.
FOR THE ATOPIC SAFETY AND LICENSING P0ARD
./
Pet.er F. Blocn, Chaiman ADMINISTRATIVF JIIDGE Rethesda, Mary 1and 4
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