ML20199K565
| ML20199K565 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/06/1986 |
| From: | Schapker J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| References | |
| CON-#386-894 OL, NUDOCS 8607090191 | |
| Download: ML20199K565 (233) | |
Text
{{#Wiki_filter:- ORIGINAL ' 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 00 3 BEFORE THE ATOMIC SAFETY & LICENSING BO 4 'l P2 pg 5 ------------------k CF EE c .
$ h$f 6 In the matter of: : Dock t Nos'. 50-456 OL 7 COMMONWEALTH EDISON COMPANY : 50-457 0" 8 [Braidwood Nuclear Power Station, :
9 Units 1 and 2] : 10 - - - - - - - - - - - - - - - - - -x 11 Isham, Lincoln & Beale 12 Three First National Plaza l f*j 13 51st Floor LJ 14 Chicago, Illinois 15 March 6, 1986 16 Deposition of: JEROME F. SCHAPKER 17 called for examination by Counsel for Licensee, Commonwealth 18 Edison, pursuant to notice, taken before Garrett J. Walsh, 19 a Notary Public in and for the Commonwealth of Virginia, when 20 -------------------------------
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21 ANN RILEY & ASSOCIATES, LTD. 22 1625 I Street, N.W. 293-3950 Washington, D.C. l p-1 O l 8607090191 860306 PDR T ADOCK 05000456 PDR
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2 1 were present on behalf of the respective parties: ( 2 3 APPEARANCES: 4 For the Licensee Commonwealth Edison Company: 5 MICHAEL MILLER, ESQ. 6 Isham, Lincoln & Beale 7 Three First National Plaza 8 Chicago, Illinois 60602 9 10 For the Intervenors BPI, et al.: ) 11 ROBERT GUILD, ESQ. 12 109 North
Dearborn,
Suite 1300 13 Chicago, Illinois 60602 [ 14 15 For the NRC Staff: 16 GREGORY ALAN BERRY, ESQ. 17 Office of the Executive Legal Director I 18 Nuclear Regulatory Commission 19 Washington, D.C. 20555 20 21 22 O
3 1 CONTENTS !O2 3 Witness: Examination by: Page: 4 JEROME F. SCHAPKER Mr. Miller 6, 84 5 6 7 *** 8 EXHIBTS Page: 9 Exhibit No. 1: 7 10 Resume of Mr. Schapker consisting 11 of 3 pages. 12 ( 13 Exhibit No. 2: 79 14 Comstock Procedure 4.3.14 bearing 15 a handwritten date of 9/18/80. 16 17 Exhibit No. 3: 95 18 Comstock Procedure 4.3.10, Rev .C 19 dated 12/8/83. 20 21 22 1 O l
4 1 EXHIBITS [ Continued] 2 3 Exhibit No. 4: 96 4 Nonconformance Report 32-75 dated 5 11/13/85. 6 7 Exhibit No. 5 through 7: 104 8 Exhibit 5, CMTR, heat number 9 401S7441; Exhibit 6, CMTR, heat number 10 402S90ll; Exhibit 7, CMTR, lot number 11 3S202061. i _ 12 () 13 Exhibit No. 8:
- 109 14 Comstock Nonconformance Report 15 34-23 bearing handwritten date of 16 5/24/85.
17 18
. 19 20 21 22 i
O l
'Y ! 5 1 EXHIBITS [ Continued]
. I 2 Exhibit No. 9: 114 3 L.K. Comstock NCR 37-10 4 bearing handwritten date of 4/29/85. 5 6 Exhibit No. 10: 122 7 Comstock Procedure 4.7.1 dated 8 4/18/84. 9 10 11 12 lO' 4 14 15 16 17 l 18 19 20 21 22 O
--. . - = ._
6 1 PROCEEDINGS 2 Whereupon, 3 JEROME F. SCHAPKER 4 was called as a witness and, having first been duly sworn, was 5 examined and testified as follows: 6 EXAMINATION 7 BY MR. MILLER: 8 Q Mr. Schapker, my name is Mike Miller. I am one of 9 the attorneys for Commonwealth Edison in this proceeding.
- 10 During the course of the deposition I will be asking you 11 questions. If my questions are unclear, or for any reason you 12 don't understand them, please let me know, and I will rephrase 13 it. If at any time you wish to take a break, again, let me
[ } 14 know -- this isn't an endurance contest -- and we'll do that. 15 A All right.
- 16 MR. MILLER
- Off the record.
17 [ Discussion off the record.] 18 MR. MILLER: Back on the record. 19 BY MR. MILLER: i l 20 Q Mr. Schapker, in conversations with your counsel, 1 21 Mr. Berry, I asked that you bring with you any documents which 22 relate to your investigation into certain allegations made by O
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7 1 a man named Worley Puckett. Do you have any such documents 2 here? 3 A No , I don't. We do have the draft of the inspection 4 report. Other than those documents, that's all I retained. 5 Q You did, however, create documents during the course 6 of your investigation into Mr. Puckett's allegations? 7 A Yes, I did. 8 Q Did you destroy those documents at some point in 9 time? 10 A Yes. I discarded them after the final inspection 11 report was issued. 12 Q Was that in accordance with NRC practice or ( 13 procedures?
}
14 A It's considered normal practice. 15 MR. MILLER: I would like the reporter to mark as 16 Schapker Deposition Exhibit 1 a three-page document which 17 appears to be a resume of Mr. Schapker's experience and is 18 headed with his name, Jerome F. Schapker. 19 [Schapker Deposition Exhibit 20 No. 1 was marked for 21 identification.] 22 O
8 1 BY MR. MILLER: 2 Q Mr. Schapker, I show you a document that has been 3 marked Schapker Deposition Exhibit 1 for identification, and 4 ask you first whether it is an accurate reflection of your 5 employment experience? 6 A Yes, it is. 7 Q The document indicates that you got a bachelor of 8 arts or bachelor of science degree from the University of 9 Evansville. In what year did that occur? 10 A 1978. - 11 Q In what discipline did you receive that degree? 12 A It's a bachelor of liberal studies degree, which ( ) 13 encompasses a liberal studies program. It was completely 14 night courses. 15 Q Is it fair to say, Mr. Schapker, that looking at 16 your resume, beginning in 1967, when you were employed by the 17 Department of Defense as a supervising quality assurance 18 representative, that you have had experience with weld 19 inspections? 20 A Yes. 21 Q Looking at your third page of Exhibit 1, there is an 22 indication that in 1967 you took what I would assume to be a lO
9 1 two-week course in quality assurance given by the Department O D 2 of Defense. Is that correct? 3 A Quality assurance. Yes. 4 Q And that in that same year you took a course in 5 specialized training in nuclear components. Could you 6 describe what training, if any, you received in that course 7 with respect to weld inspections? 4 8 A Well, it was a specialized training course which 9 described the fabrication of nuclear components which included 10 welding, nondestructive examination, destructive testing, any 11 special processes needed to fabricate such components. 12 Q Turning back to the description of your job with the () i l 13 Department of Defense, it indicates that you were a qualified 14 supervisor. When did you attain that designation? 15 A Supervising and quality assurance representative was 16 in 197 '.U Previous to that, I was assistant to the supervisor 17 and quality assurance representative. 18 Q In the description of that job, it says that you 19 were -- in the last sentence -- were "a qualified supervisor 20 -- NDE, RT, UT, MT, PT to Nav -- shit,ss 250-1500-1." 21 A Yes. 22 Q Could you tell me what that designates, sir? O
10 1 A That's "RT" is radiography. Nondestructive 2 examination is NDE, is nondestructive examination. "RT" is 3 radiography. "UT" is ultrasonic examination. "MT" is 4 magnetic particle examination. And "PT" is liquid penetrant 5 examination. 6 Q Does NDE include visual examination of welds, for 7 example? 8 A Yes, it does. 9 Q The Nav ships procedure that's referenced here -- 10 A That is the welding standard for Navy nuclear 11 components. 12 Q Does it have an analogue to either the ASME or the I ( ) 13 AWS welding code? 14 A It is similar in nature. It is a military standard 15 which describes the requirements for welding of Navy nuclear
~
16 components. 17 Q Would it be more similar to the ASME rather than the 18 AWS code? 19 A Yes, it would. 20 Q The designation of qualified supervisor -- well, let 21 me back up. Are you familiar with the ANSI N-4526 22 designations of Level 1, Level 2, and Level 3 inspectors? O ___. , , - - - , - - - - ,v---- - ='
11 1 A Yes.
\_) 2 Q All right. Is a qualified supervisor analogous to a 3 Level 1, Level 2, or Level 3 inspector under the ANSI 4 standard, or to none at all?
5 A It doesn't have a direct correlation, but it would 6 be essentially a Level 3 ASMT. 7 Q What do those letters -- 8 A ASNT TC-1A, which describes the qualifications for 9 NDE, nondestructive examination in the commercial field. It's 10 ASNT TC-1A. 11 Q And when did you attain this designation as a 12 qualified supervisor? 13 A To the best of my recollection, it was I first ( ) 14 qualified as an inspector probably in 1967-68 in a different 15 -- this was an accumulative qualification. First I qualified 16 in liquid penetrant examination, then I qualified in magnetic 17 particle examination, then I qualified in ultrasonics, and " 18 then in radiography; and this was over a period of time of 19 about a year, '67 to '68. 20 As a supervisor, I believe that was in 1969 when I i 21 first attained the qualifications as a supervisor. 22 Q In your capacity as an employee of the Department of O
12 1 Defense from September of 1967 to July of 1974, did you have 2 occasion to perform visual weld inspections as well as these 3 other nondestructive examination techniques? 4 A Yes, I did. 5 Q In performing those examinations, Mr. Schapker, what 6 were the acceptance for the welds or in what sort of a 7 document were they found? 8 A Well, it would be in Nav ships 250-1500. 9 Q Turning to the first page of Schapker Deposition 10 Exhibit 1, in July of 1974, this document indicates, you 11 became a senior engineer at the Nuclear Power Generation Group 12 of Babcock & Wilcox. The description of your duties say that ( ) 13 it included quality assurance duties, audits, inspections, and 14 NDE. What were the nature of your quality assurance duties 15 with B&W? 16 A Well, I audited the nuclear equipment division of 17 Babcock & Wilcox on a regular basis, their p ocedures, in the A o *J 18 area of special processes such as welding NDE. 19 Q All right, sir. And that also includes the audits 20 that are referred to in that same sentence? 21 A Yes. 22 Q All right. What sort of direct inspection i O
13 l 1 responsibility did you have at B&W? 2 A Direct inspection efforts were witnessing of 3 nondestructive examinations to verify that the NDE such as
-4 ultrasonics, liquid penetrant, magnetic particle were 5 performed within the code requirements.
6 In the area of radiography,.I performed film review, 7 reviewed the film, final film, to assure that the welds met 8 the code requirements. And also did witnessing the 9 hydrostatic examinations, testing, destructive testing, weld 10 procedures, welders qualifications, inspections. 11 Q All right. Let me stop you if I might for just a 12 second. I don't mean to cut you off. Did you say that you ( ) 13 witnessed the welder qualifications, or did you actually 14 administer a welder qualification test? 15 A No. I witnessed the welder qualifications. 16 Q And I think you also -- 17 A That was in the quality assurance function, to 18 assure that the welders were performing the correct 19 procedures, correct tests they qualified to in the manner they l 20. were to be performed. 21 Q And then I think -- you said that you witnessed 22 inspections or actually performed the inspections yourself? O
14 1 A Witnessing of inspections in NDE. O-. 2 Q Did you ever witness any visual welding inspections 3 by an inspector? 4 A Yes. 5 Q At this point in time or at any point in time of 6 your employment by Babcock & Wilcox, were you certified to any 7 code or standard as an inspector? 8 A Yes, I was. dWY-I was certified to -GMPE TC-1A Level 2 f J 9 and RT, UT, MT, and PT. 10 Q When did you obtain that certification, sir? 11 A I believe initially in 1974. 12 Q And then were you recertified from time to time i 13 ( ) thereafter? j 14 A Yes. Every three years ASNT TC-1A requires 15 recertification. 16 Q All right. Does the ASN TC standard have the same 17 hierarchy of levels that the ANSI 4526 standard does at Levels 18 1, 2, and 3? 19 A Essentially, yes. It has different applications, 20 but it's essentially the same meaning. 21 Q When you say it has different applications, do you 22 mean in terms of the type of activity -- l 0
- 15 1 A Type of inspections, type of qualifications that the 2 person is deemed capable to do.
3 Q At this point in time, Mr. Schapker, while you were 4 employed by Babcock & Wilcox, were you certified to ANSI N4526 5 in any discipline? 6 A Yes, I was, in dimensional inspections. 7 Q Were you certified as a Level 2 inspector? 8 A Yes. 9 Q And I take it that that was a certification to the 10 Babcock & Wilcox procedure for dimensional inspections, is i 11 that correct? 12 A That's correct. l 13 Q ( Were you certified as a weld inspector, a visual 14 weld inspector? i 15 A Other than the ASNT TC-1A requirements, no. 16 Q Does ASNT TC-1A include visual weld inspection as 17 well as the other nondestructive techniques that you've 18 described? 19 A It does. The -- I was not certified ASNT TC-1A in 20 visual examination with Babcock & Wilcox. I was ASNT TC-1A -- 21 I'm not sure. 22 Q Okay. Did there come a time when you were certified O
16 1 as a visual weld inspector? O (_) 2 A In -- as a -- in the Navy nuclear program I was 3 certified as a visual inspector, yes. 4 Q All right. So that was prior to your employment by 5 Babcock & Wilcox? 6 A Right. 7 Q I am looking at the third page of your Exhibit 1, 4 8 Mr. Schapker, and I see about the middle of the page there is 9 an ASNT certification Level 2. There is RT, UT, MT, PT, and 10 VT. I think you've described everything except what "VT" is. 11 What is that? 12 A That's visual testing.
/~'\ 13 Q I see. Would you describe briefly for us what the NJ 14 difference is between visual examination of a weld that's done 15 pursuant to the SNTC standard and the AWS standard, for 16 example?
! 17 A There is very little difference. They each -- the 18 standard for AWS describes the type of -- the types of welds, 19 the types of abnormalities, the description of the profile 20 undercut and so forth, and describes what is acceptable to the 21 standard. 22 Q Is the SNTC standard comparable? 1 s O
17 1 A It is similar in nature. 2 Q Now, from January 1980 until September of 1981, I 3 see that you were a reactor inspector employed in Region III. 4 And looking again at the third page of your exhibit, I see 5 that there were five courses that you took in the year 1980. 6 Were those required courses as part of your employment as a i 7 reactor inspector by the Nuclear Regulatory Commission? 8 A Yes, they were. 9 Q In the course that you took in welding technology 10 and codes, can you briefly describe what the course content 11 was? 12 A Okay. In 1980? I 13 Q Yes, sir. [ } 14 A Basically, it was on welding metallurgy. 15 Q You'll have to forgive me. As a layperson -- does 16 that mean whether the techniques that would be used in welding ! 17 to ensure a sound weld?
- 18 A Yes. It describes -- welding metallurgy is the i
19 study of the effects of welding on metals. 20 Q Well, I also notice that the title of the course is l 21 " Welding Technology and Codes." Which codes did you review j 22 during that 80-hour course session? i I i 4 w-- _ , - . . . , , , _ .._-sy__ . - _ , , , , _ _ _ - . - _ - , ,.w,.-.-e,.,.y,.- _.-y__.__.m _ _ , -,. y- . . _% -_ -.-,
18 1 A ASME codes and AWS codes. 4 I 2 Q The AWS codes that you reviewed, did that include ] 3 AWS D.1.1?
- , 4 A To the best of my recollection.
5 Q Did it also include AWS D.1.3? 6 A I don't believe so. 7 Q I realize this is quite a while back. But do i 8 you recall the edition of the AWS code D.1.1 that you looked 9 at? 10 A The edition? 11 Q Yes. , i 12 A No, I don't. It probably would have been the 13 ( ) current edition at that time. f 14 Q All right. Were there any specific aspects of the i 15 AWS code that were emphasized in this review that you took in
- 16 1980, this course?
l 17 A No. It was just a general review of all the codes. l. l 18 Q Now, for the period January 1980 to September 1981, 19 it indicates that you were a specialist in nondestructive 20 examination and welding technology. For how many different 21 power plants did you conduct construction inspections that 22 involved nondestructive examination and welding technology? O
19 1 Do you recall? 2 A I'll have to go through them. 3 Q Okay. A 4 Let's see. They would be Perry, Fermi -- 5 Q Well, it would be useful actually if you would 6 identify the plants as you went through them. Sure. i 7 A And the Region III plants would be: Perry; Fermi 8 -- Fermi-2, that,i ; of course, Braidwood; Byron; Marble Hill; C//efey David 8MJC) KI#D M L l 9 4 Zimmer. I think t t about covers the ones in Region III. 10 Q All right. Your resume indicates that you conducted , 11 both inspections and investigations during the period January l 12 1980 to September 1981. I take it that the inspections are i () 13 the routine inspections of power plants under construction 14 that are conducted by the I&E branch of the NRC. Correct? 15 A That's true. ! 16 Q In connection with these inspections, did you review 17 the licensees with respect to both ASME and AWS welding? 18 A Each individual -- 19 Q Well, I may have tried to short-cut the question too i 20 much. 21 A Yes, I did do inspections on AWS and ASME within l 22 this period. O
20 1 Q Okay. And did you do such inspections for each of 2 .the power plants that you identified in the previous answer -- 3 Perry, Fermi-2, Braidwood, Byron, Marble Hill, and Zimmer? 4 A Okay. Do you want it broken down? 5 A If you could. t j 6 A Okay. Perry was ASME, I believe. Braidwood was AWS i l 7 and ASME. Byron, I believe, was ASME. Zimmer was ASME and 8 AWS. Marble Hill was ASME. What did I leave out? i 9 Q You left off Fermi-2. i 10 A Fermi-2 was ASME. That's the best of my 11 recollection. 12 Q Okay. Now, in connection with your review of ( } 13 welding activities at these six power plants from January 1980 i 14 to September 1981, did you have occasion to review the 15 procedures in use by the contractor or constructor at these i 16 various power plants? 17 A Yeah. It's a normal part of the inspection. 18 Q Your Exhibit 1 also indicates that during this 19 period you performed certain investigations. For which power j 20 plants did you perform or conduct investigations during this l 21 time period? 22 A Zimmer and Fermi-2. One other one that I left off: O
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21 , 1- -Davis-Besse. l 2 Q Did you conduct inspections at Davis-Besse? I 3 A Yes. 4 Q All right. And at Davis-Besse --
- 5 A That was ASME.
- 6 Q ASME. Thank you.
7 A I believe. 8 Q All right. Would you describe -- i 9 A Wait -- 10 Q I'm sorry? 7 11 A I'm not sure it was ASME. It could have -- I'd have j 12 to review that report to be sure. 13 Q Would you describe the nature of the investigation .! 14 that you participated in at the Zimmer facility? 15 A My part was welding procedures review for the Wd/8e , 16 qualification review, NDE. 17 Q All right. Approximately -- I'm sorry, did you 18 finish your answer? 1 j 19 A Yes. 20 Q Approximately how much time did you spend on the l 21 Zimmer investigation in this time period? l l 22 A It extended past this time period, but I really I O . i
l 22 1 would have to research our reports to give you a time period A 4 k-) m 2 as to how much time. 3 Q Could you make an estimate as to what percent of 4 your time in this approximately 18-month period? 5 A It began in January of '81 and went through the 6 period 9/81. During that time period, maybe -- it would be a 7 guess -- but it's probably 20 percent of my effort was 8 involved with Zimmer. 9 Q All right. Turning now to the -- well, to finish up 10 for the moment, with respect to Zimmer, was that a review of i 11 the welding procedures and qualification, welder 12 qualifications, with respect to both AWS and ASME welding? () 13 14 A Yes, it was. Q could you describe briefly for us the nature of the 15 Fermi-2 investigation? 16 A It concerned the -- it concerned welding, but I'm 17 not -- I don't remember exactly what the allegation was in 18 that. That was sometime in the latter part of '80 or the l 19 first part of '81, I believe. 20 Q I guess I should have asked this earlier. Was the l , 21 investigation that you conducted at Zimmer done as a result of 22 allegations by an employee or ex-employee of some contractor? u _ _ _ _ _ _ _
l 23 l 1 A It was a result of allegations. ! O2 Q And I take it, from your preceding answer, that at l 3 Fermi-2 your investigation also arose as a result of employee 4 allegations? 5 A That's true. 6 Q can you give us a rough estimate of how much time , 7 you spent on the Fermi-2 investigation? 8 A To the best of my recollection, I'd say about two , 9 weeks. 4 1 10 Q Is it fair to say that the Fermi-2 investigation was i 11 much less extensive than the one that you participated in at 12 Zimmer? 13 A Yes,' it was. ( } I 14 Q Your resume, Exhibit 1, indicates that in September ! 15 1981 you became a senior resident inspector at the Hartsville 4 16 power plant in Tennessee. I take it that at that point in 1 17 time your duties comprised more than simply review of welding 18 and NDE and so on? 1 j 19 A Yes, it did. i 20 Q All right. During this time period when you were at l 21 Hartsville, did you have occasion -- well, was Hartsville at l 22 that point in time under construction? i 1 O .
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24 1 A Yes, it was. (D.
\~) 2 Q During the time you were at Hartsville did you have 3 occasion to review the welding procedures that were in use at 4 that site?
5 A Yes, I did. 6 Q And were those both the AWS and ASME welding 7 procedures? . 8 A Yes, they were. 9 Q In addition to the carry-over of your Zimmer 10 investigation responsibilities following September 1981, did 11 you have any other assignments after you became the senior 12 resident inspector at Hartsville? t ( ) 13 A I aided Region III in the continued inspections, 14 ongoing inspections, at Zimmer, i l 15 Q Anything beyond the Zimmer power plant? ! 16 A At other facilities? 17 Q Yes, sir. 18 A Yes. I did an inspection at the Watts Bar nuclear i 19 power plant. 20 Q And could you describe for us the nature of that 21 inspection? 22 A The nature of that inspection was quality assurance O
25 1 and procurement, nuclear material procurement, training, n 2 design interfaces. J 3 Q Did this involve at all a review of welding
- 4 procedures or welder qualification procedures?
l 5 A No. 6 Q In April of 1983, your resume indicates, you became 7 a senior resident inspector at Marble Hill. And I take it l 8 that you continued at that facility until it was shut down in 9 terms of the construction activity taking place there. 10 Correct? 11 A Yes. , 12 Q once again, I assume that you -- not assume -- it's 13 correct, is it not, that your duties as a senior resident ( ) 14 inspector at Marble Hill comprised more than simply review of 15 welding activities, nondestructive examination, and so on? 16 A Yes, it is. 17 Q All right. Did you have occasion while you were the 18 senior resident inspector to review the welding procedures and i ! 19 welding activities that were taking place at that site? ! 20 A Yes, I did. I ! 21 Q All right. Does that include both AWS and ASME 22 welds? O \
26 1 A Yes. 2 Q For approximately the last eight or nine months 3 you have been reassigned as a reactor inspector to Region 4 III. In that time period, Mr. Schapker, what power plants 5 under construction have you inspected? 6 A I have inspected at Braidwood, Fermi-2, Waterford, Cfr%+* n > 7 @= -h a r;ak,3 LaSalle. I believe that covers it. b 8 Q At each of the power plants that you identified in 9 your prior answer, Mr. Schapker, was your inspection directed 10 mainly at a review of welding and nondestructive examination 11 of welds? ci.s., 12 A In the case of M *arfed andBraidwood.gh l 13 Q I'm sorry, had you finished your answer? j 14 A Yes. c <. s,- $ 15 Q So for '44terf;rd and Braidwood, the scope of your 16 inspections were welding and NDE. Is that correct? 17 A Welding, yes, mainly welding. 18 Q Okay. Can you describe for us generally and briefly I l 19 what the nature of your inspections were at Fermi-2? 20 A At Fermi-2, a review of allegations. 21 Q Did the allegations relate in any way to welding, 22 welding procedures, welder qualifications? O l l
27 1 A No, they did not.
) 2 Q Okay. At Comanche Peak, what was the nature of your 3 inspection?
4 A Quality assurance procedures. 5 Q And at LaSalle, what was the nature of your 6 inspection? 7 A Degradation of piping material. 8 Q In your inspection at Waterford, did you have 9 occasion to review the AWS and ASME welding procedures and 10 welder qualification procedures that were in use at that I 11 site? 12 A At Waterford? i ( ) 13 Q Yes. 14 A Yes. 15 Q Once again, your resume indicates that you conducted 16 both inspections and investigations in this most recent time 17 period. We're here to discuss one of the investigations with 18 respect to Braidwood. Have you participated in any other 19 investigations since June of 1985 on behalf of the NRC? 20 A Yes. 21 Q All right. Would you identify the power plants with 22 respect to which those investigations have taken place? O
28 1 A Fermi-2 9 And Od*" 2 Q All right. And I think you earlier described that 3 the allegations did not involve any welding or nondestructive 4 4 examination issues. 5 A Right. 6 Q Were there any other investigations besides 7 Braidwood and Fermi-27 8 A Since? 9 Q Since June of 1985. 10 A No. 11 Q I would now like to turn to -- I'm sorry? 12 A Did you say except for Braidwood? 13 Q Yes. 4 A Okay. 15 Q I would now like to turn to the Braidwood . 16 investigation. It's correct, is it not, that the only 17 Braidwood investigation that you've been involved in has i l 18 involved certain allegations made by Mr. Worley Puckett and 19 one other individual whose allegations are referred to in 20 Inspection Report 85-09. Is that right? l 21 A That's true. 22 Q Mr. Schapker, who told you that you would be O
29 1 investigating Mr. Puckett's allegations? 2 A My supervisor. 3 -Q Who is that? 4 A At that time it was Bill Forney. 5 Q Did Mr. Forney characterize the allegations to you, 6 or did he simply -- 7 A No, he did not. 8 Q Did he turn over certain documents to you? 9 A Mr. Forney did not, but Mr. Danielson, who is now my 10 present supervisor did. 11 Q Do you recall the nature of the documents that were 12 turned over to you? () 13 A The deposition of the alleger. 14 MR. GUILD: When you refer to a deposition -- 15 MR. MILLER: Yes. 16 BY MR. MILLER: 17 Q When you refer to a deposition, sir, are you talking _, 18 about a transcript, a shorthand transcript, of the allager? 19 A Yes. 20 MR. MILLER: Let the record reflect that Mr. Berry 21 has shown to Mr. Schapker a transcript of an interview 22 conducted of Mr. Puckett at Region III on September 11, 1984. , O
30 1 BY MR. MILLER: (J s_
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2 Q Did you also look at a transcript of a hearing 3 before the United States Department of Labor? 4 A No. 5 Q How soon after -- well, the record is established 6 that Mr. Puckett was terminated at the Braidwood site at the 7 very end of August 1984. How soon after that were you given 8 the assignment by Mr. Forney? 9 A It was the latter part of February of '85 when I 10 received the assignment. 11 Q In addition to the transcript of the interview, did 12 Mr. Danielson give you any other documents? 13 A I believe there is one other document, the Chuck ( ) 14 Wilde memorandum. 15 MR. MILLER: Well, I am going to mark as -- well, go 16 ahead. 17 MR. BERRY: It's what is marked as Document 113, 18 produced by the staff to the applicant and intervenor in its 19 document production. It's a memorandum from Chuck Wilde to 20 Mr. Spesser on October 26, 1984. 21 THE WITNESS: Yes, this is it. . 22 BY MR. MILLER: O
31 1 Q Did you receive the document with the attachments in 2 the form that it is produced to me and Mr. Guild by the 3 attorneys for the NRC staff? 4 A Would you repeat that? '
; 5 Q Sure. When you got the memorandum from Mr. Wilde, l
i 6 did it have certain attachments to it in the form that it now 7 appears and as it was turned over by your counsel to me and ! 8 Mr. Guild? 1 9 MR. GUILD: Do you understand? i 10 THE WITNESS: The -- yes, I understand the
- 11 question. During the course of the inspection I did receive 12 the attachments. I didn't receive it at the beginning of the 13 inspection.
( ) The document that I was referring to that I 14 received at the beginning of the inspection was the one dated 15 September 6, 1984, from Chuck Wilde to Norelius and Spesser, 3 16 identified as Number 104. i 17 MR. MILLER: May I just see that quickly? Thank 18 you. 19 [ Pause.) l . 20 BY MR. MILLER: l 21 Q Once again, when you received this document dated 22 September 6, 1984, did it have attached to it the August 28, i O 4 i
32 1 1984, memorandum from Mr. McGregor to Mr. Wilde? 2 A I don't believe that it did. 3 Q Did you subsequently receive the August 28, 1984, 4 memorandum? 5 A I subsequently saw this memorandum, yes, during the 6 course of the inspection. 7 MR. GUILD: May I examine that a moment? 8 [ Pause.] 9 BY MR. MILLER: 10 Q Would you just describe generally for me if you 11 would how you proceeded once you had received the assignment 12 from Mr. Forney and received these first documents? l ( ) 13 A Mr. Ward -- Kevin Ward -- and Chuck Wilde had 14 prepared for the -- prepared the inspection prior to my 15 receiving it. I received the prepared allegations from 16 Mr. Ward in inspection format form. 17 Q All right. Let me understand what the inspection 18 format for allegations is. 19 A Well, there's a list of the allegations as described 20 in, I think it's Document 104. 21 Q And the date on that document, sir, is? 22 A September 6, 1984, the one that was previously O
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! 33 l
, 1 addressed. 2 Q Was each allegation given a unique tracking number? 3 A Yes. It was identified. as it is currently 4 identified in the inspection raport. But a unique identifying 5 tracking number, no. 6 Q But the allegations were divided into separate items l 7 as they appaar in your Inspection Report 85-097 8 A Right. That's true. ! 9 Q Generally, although not always, there is one l 10 allegation for each letter under numbered paragraph 2 in the 11 body of the report, is that correct? ! 12 A Yes. l 13 MR. MILLER: ( ) I am showing the witness a document 14 that has previously keen marked as Puckett Deposition Exhibit 15 4 for identification. 1 16 BY MR. MILLER: i 17 Q All right. After you received these documents that i
- 18 you have described, did you discuss this matter with Mr. Ward 19 or Mr. Wilde?
[ 4 20 A I discussed it with Mr. Ward. 21 Q All right. For the record, would you tell us who 22 Mr. Ward is and what his area of specialty is, if any? i
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34 l j , 1 A Kevin Ward is an employee of the Nuclear Regulatory 2 Commission in the Division of Reactor Safety, as I am. His 3 duties are essentially the same as mine. His background is 4 welding and nondestructive examination also. 5 Q Can you give us the substance of your conversation 6 with Mr. Ward when you first discussed the allegations with 7 him? ' 8 A Essentially, the discussion of the allegations was , 9 he just turned over the allegations to me. There really l 10 wasn't any substance discussion about the allegations j 11 themselves except that these were the allegations that I was i { 12 to review at Braidwood concerning Mr. Puckett. 13 Q Did you have any discussion with Mr. Wilde at this 14 initial stage of your investigation regarding the allegations? 15 A No, not at the initial stage. l 16' Q Did you have any discussions with Mr. McGregor at 17 this initial stage of your investigation? 18 A No. 19 Q After you received this initial package of 20 materials, how did you then proceed in your investigation? l 21 A I reviewed the allegations themselves and tried to l 22 put them in their perspective to develop a plan to investigate O
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35 1 each item. I then contacted the alleger by telephone to set 2 up a discussion, a meeting with them, to further clarify his 3 issues, concerns. 4 Q Do you recall how soon after you got the assignment I 5 in February that you first called Mr. Puckett? 6 A It was the first part of March 1985. 7 Q Were you then at Region III or -- 8 A No, I was -- at that time I was still assigned to 9 the Marble Hill project as senior resident inspector. 10 Q At that point in time, Mr. Schapker, was 11 construction underway at Marble Hill, or had it been shut 1 12 down?
/\ 13 A It had been shut down.
V 14 Q All right. So in fact, your inspection activities 15 at Marble Hill were necessarily quite limited, is that 16 correct? 17 A Yes, they were. 18 Q I take it you then went to see Mr. Puckett at his 19 home. Is that right? 20 A That's trhe. 21 Q Do you recall the date on which that occurred? 22 A I believe it was March 12, 1985. O
36 1 Q 1985. Prior to the time that you went to see 2 Mr. Puckett, did you collect any other documents or do any 3 other research into the allegations? 4 A I just reviewed the allegations themselves and 5 referenced the AWS code. 6 Q When you say you referenced it, you reviewed it? 7 A Reviewed the AWS code to coincide with his concerns 8 concerning the code violations. 9 Q Approximately how much time did you spend with 10 Mr. Puckett when you visited him? 11 A Approximately three to four hours. 12 Q Could you describe for us what the format of your () 13 14 meeting was? Did you have specific questions, or did you just ask Mr. Puckett to again in his own words describe the 15 allegations? 16 A I had specific questions in regard to the concerns 17 that he expressed. 10 Q Are those specific questions reflected in one way or 19 another in the inspection report that you ultimately published 20 on these allegations? 21 A Yes, I believe they are. 22 Q Prior to this time that you met Mr. Puckett at his O
' 37 1 home in Ohio, had you ever had occasion to meet him before? 2 A Yes. 3 Q When? I 4 A At the Zimmer nuclear power plant. 5 Q The record establishes that Mr. Puckett held a ! 6 variety of positions at the Zimmer power plant up to the time 7 that construction was halted at that plant.
- 8 on how many different occasions had you met I
9 Mr. Puckett at the Zimmer plant? 10 A Maybe a half dozen. j 11 Q Other than the specific questions that you had of l 12 Mr. Puckett, what other discussions took place when you 13 visited him in March of 1985? 14 (Pause.] 15 MR. BERRY: Are you asking what else they talked 16 about? 17 MR. MILLER: Yes, quite apart from any, you know, 18 just introductory materials. 19 THE WITNESS: Not -- nothing that I can recall other 20 than the allegations themselves. 21 BY MR. MILLER: 22 Q Did you ask Mr. Puckett whether he had any other O
~. - -.-_ . _ _ . . . _ . . - - _ _ . - _ . - . . . . _. - --- . . _ . 'l , 38 1 concerns that he hadn't spelled out in the allegations that 2 you were investigating? -
t 3 A Yes. f 4 Q What was his response? 5 A His response was that the allegations that he had 6 expressed were not of major significance, that if they would 7 have let him do the job, he would have corrected all these 8 problems that he had brought up. 9 Q Who did you understand Mr. Puckett to be referring i 10 to when he said "they"? 11 A Comstock, his employer. 12 Q Did Mr. Puckett make this comment about the i () 13 significance of his concerns at the beginning or at the end of 14 your conversation with him, if you recall? !! 15 A At the end. 16 Q Did you respond to Mr. Puckett's characterizations 17 of his own allegations in any way? 18 A No, I don't believe that I did. 19 Q You didn't agree or disagree with him over the 20 significance of the concerns that he expressed? 21 A No. No. 22 Q Did Mr. Puckett discuss with you at all the O
39 1 proceeding that had taken place at the Department of Labor? O
\~/ 2 A No.
3 Q Did Mr. Puckett make any comments other than those 4 that are found in the allegations with respect to Mr. DeWald? 5 A I don't remember him making a comment about 6 Mr. DeWald. 7 Q Do you remember him making a comment about Mr. Seese 8 other than what may be reflected in the allegations? 9 A No. 10 Q Do you remember him making any comments about any 11 Comstock management personnel other than what's reflected in i 12 the allegations? 13 A No. 14 Q At the conclusion of the interview with Mr. Puckett, 15 did you represent to him that you would be in further contact 16 with him or that he would somehow hear from you? 17 A No. 18 Q Did he ask you to keep him apprised of the status of 19 your investigation? 20 A No. 21 Q Is it NRC investigation practice to keep individuals 22 who make allegations apprised from time to time of the O l l _ __ _ _ _ _ _ _ --
40 1 progress of the investigation? 2 A No. 3 Q Have you ever done that in the past? 4 A No. 5 Q Is it NRC practice to apprise an individual making 6 allegations of the conclusions of an NRC investigation of 7 those allegations? 8 MR. BERRY: You mean apprise him prior to the -- 9 MR. MILLER: No. At the time when the investigation 10 is concluded and the inspection report is released. 11 THE WITNESS: Yes. We -- it's policy to send a copy 12 of the inspection report to the alleger. 13 BY MR. MILLER: 14 Q Did you do that on this occasion? 15 A I -- that's not my responsibility. 16 Q All right. Who within Region III has that l l 17 responsibility? 18 A It would be Chuck Wilde or somebody in his office. 19 Q Is Mr. Wilde assigned to OI? 20 A No. 21 Q He is assigned to the Region? 22 A Yes. O i I
41 1 Q Did you notify Mr. Wilde that your inspection report ; 2 was now in final form and that whatever distribution was to be 3 made could be made? 4 A He was -- he would be aware of it. 5 Q Do you know of any reason why Mr. Wilde would not 6 have sent a copy of the inspection report to Mr. Puckett? 7 A No, I do not. 8 Q Did Mr. Puckett ever call you and ask you about the 9 progress of the investigation? 10 A No. 11 Q Other than your meeting with him on March 12, did 12 you have any further contact either orally or in writing with 13 Mr. Puckett since that time? ( ) 14 A No. 15 Q Following your interview with Mr. Puckett in March 16 of 1985, what was the next thing that you did in your 17 investigation of his allegations? 18 A I would like to go back to the previous question. 19 You asked me if there was anything else that we discussed. 20 And there was one time that I recall concerning a telephone 21 call that Mr. Puckett received from an anonymous person which 22 stated that another NRC employee was responsible for his O
l l 42 1 dismissal. 2 Q Is that the first time that you had heard that j 3 assertion made by anyone? l 4 A I believe I had heard it prior to that, but this is 5 the first time I had discussed it with the alleger. 6 Q From whom had you heard about this claim prior to 7 your interview with Mr. Puckett? 8 A That I don't remember. 9 Q Do you know a man named Gwenn, who is an NRC 10 employee? 11 A Yes, I do. 12 Q All right. Between the time that you received this [ } 13 assignment from Mr. Danielson or Mr. Forney and the time that 14 you had your interview with Mr. Puckett, did you have any 15 conversations with Mr. Gwenn concerning Mr. Puckett's 16 allegations or the fact that you were investigating 17 Mr. Puckett's allegations? 18 A Between the time that I received the allegations and 19 the time -- i 20 Q That you saw Mr. Puckett. 21 A -- I saw Mr. Puckett? Yes, I believe I did. 22 Q All right. Can you tell me the substance of that f l 0
l l 43 1 conversation? 2 A I believe it was in respect to the inference that he 3 had had to some responsibility in the dismissal of 4 Mr. Puckett, that to the -- 5 Q Well, let me back-up just a second. 6 A Okay. 7 Q I want to make sure that we're in the right time 8 frame. Mr. Puckett in your interview told you about this 9 anonymous telephone call. I take it that Mr. Gwenn was the 10 NRC employee who had been identified in that telephone call as , 11 being somehow responsible for his termination. Is that 12 correct? 13 A Yes. 14 Q All right. Prior to your interview with 15 Mr. Puckett, you had a conversation with Mr. Gwenn. And at 16 that time, Mr. Schapker, did you have some information 17 regarding this assertion that Mr. Gwenn was somehow 18 responsible for Mr. Puckett being terminated at Braidwood? 19 A I'm not sure of the time frame. l 20 Q Okay. Well, how many conversations on this subject 21 did you have with Mr. Gwenn? 22 A Two. O
44 1 Q All right. Now, I think you've already said you're 2 not certain of the time frame. But could you describe the 3 substance of your conversation with Mr. Gwenn on the first 4 occasion? 5 A The -- I believe on the first occasion it was the 6 information that there was -- I was relaying the information 7 to him that there was a concern in that area. 8 Q Did you see Mr. Gwenn face to face when you had this 9 conversation with him? 10 A No, I believe this was over the phone. 11 Q Where was Mr. Gwenn at this point in time, if you 12 know? 13 t ( ) A He would have been at Clinton. 14 Q All right. That's the Illinois Power -- 15 ' A Yes. 16 Q -- construction site. What was Mr. Gwenn's response 17 when you related this information to him? 18 A He said that he had talked -- or the person he later 19 said that had called him had called him. 20 Q And Mr. Puckett has identified that person as George 21 Orlov. 22 A Yes. O
45 1 Q Is that who the alleger, Mr. Schapker, identified to 2 you? 3 A Yes. 4 Q Mr. Gwenn confirmed that there had been a telephone 5 conversation between Mr. Orlov and himself? 6 A Yes. 7 Q Regarding Mr. Puckett, is that right? 8 A Yes. 9 Q Did Mr. Gwenn tell you in this first conversation 10 what the substance of the conversation that he had had with 11 Mr. Orlov was? 12 A He didn't describe in detail what the subject was. 13' He just -- I believe he mentioned Mr. Orlov questioning ( } ( 14 Mr. Gwenn as to his opinion of Mr. Puckett's qualifications. , 15 Q In this conversation that you had with Mr. Gwenn, t 16 did you identify a time when this conversation between 17 Mr. Gwenn and Mr. Orlov was supposed to have taken place? 18 A No, we didn't. 19 Q Did Mr. Gwenn tell you what he had told Mr. Orlov J 20 about Mr. Puckett's qualifications? 21 A Not in detail, but he inferred that he supplied him 22 with no information in regard to his qualifications, that he
) 1
46 1 referred him to his previous employers. 2 Q All right. I think you said that you had two 3 conversations with Mr. Gwenn on this assertion by Mr. Puckett 4 that Gwenn was somehow responsible for his termination at 5 Braidwood. What was the nature of the second conversation? 6 A The second conversation was when I read the 7 deposition by Mr. Puckett. 8 Q All right. So that was within the last -- 9 A Yes. 10 Q -- three to four weeks or so? 11 A Yes. 12 Q And what was the nature of that conversation? ( ) 13 A I just mentioned that it had been brought out in the 14 deposition by Mr. Puckett that this matter about him being 15 responsible for Mr. Puckett's dismissal. 16 Q And did Mr. Gwenn respond to your observation at 17 all? 18 A Just that he had -- I'm trying to recall. I don't 19 really remember any direct comment, just that it was part -- 20 it wasn't the only part of the conversation. We were talking 21 about some thing completely different, and I just brought it 22 out to him as information that I had read, had read the O
47 1 deposition. I don't believe that he had any comment in regard 2 -- in that regard. I can't recall any. 3 Q Did you say that the other part of your conversation 4 with Mr. Gwenn related to something entirely different? I 5 take it that it had no relationship to Mr. Puckett's 6 allegation? , 7 A Right. Right. 8 Q Was this a telephone conversahion? ' 9 A Yes, it was. It had to do with another inspection I 10 had performed at Clinton. 11 Q All right. Backing up to when you had your ( 12 interview with Mr. Puckett in March of 1985, when he told 13 you about this anonymous telephone call. ( } Besides these 14 conversations with Mr. Gwenn that you now testified to, did 15 you take any other action in response to Mr. Puckett's 16 assertion that this telephone call -- that he had this 17 telephone call? 18 A I discussed it with management. 19 Q Which individual at the NRC did you talk it over 20 with? 21 A That's who I was trying to recall. And I'm trying 22 to remember who that was. I believe I discussed it with Chuck O l
48 1 Wilde, which is not management, but I believe that's who it (D
'sm/ 2 was.
3 Q All right. In your discussion with Mr. Wilde, was 4 there any reference to turning this matter over to the NRC 5 OIA, Office of Inspection and Audit? 6 A There wasn't between Chuck -- there wasn't any 7 discussion about it between Chuck Wilde and I, but I had heard 8 that it was turned over, through the grapevine or so forth, 9 that OI was going to investigate the matter. I don't know if 10 that had been done or not, though. 11 Q And you still don't know that today? 12 A I still don't know, no. ( } 13 Q Did OIA, any representative of OIA, ever contact 14 you? 15 A No. 16 Q Other than this reference by Mr. Puckett in your 17 March 1985 interview to this anonymous telephone call -- and I 18 think you said that he characterized his own concerns as not 19 being very significant -- were there any other comments that ( 20 were made during the interview that did not relate 21 specifically to allegation items? 22 A I asked him at that point when he brought up the --
49 1 when we discussed the thing about the Pat Gwenn issue -- if he 2 wanted me to look into this further. And he said no, he 3 didn't think it was necessary. 4 Q Any other comments or discussions with Mr. Puckett 5 in March of 1985 other than the specific allegation items that 6 are in the inspection report? 7 A No, nothing else. 8 Q I think you said that you spent about three to four 9 hours with Mr. Puckett. Was there anyone else present 10 besides you and Mr. Puckett? 11 A While we were discussing these? 12 Q Yes, sir. 13 A No. ( ) Just Puckett and -- Mr. Puckett and myself. 14 His wife I think brought us some coffee at one point. But 15 there was nobody present other than that during the 16 discussions. 17 Q Was there, in your judgment, any tension between you 18 and Mr. Puckett? Was he relaxed or was he -- 19 A No, it was a very cordial visit. He was relaxed. 20 Q Now, following your interview with Mr. Puckett, what 21 was the next step in your investigation into his allegations? 22 A That was to prepare my inspection plan to do the O
50 1 actua) investigation or inspection of the alleged concerns, 1 O2 and the next step after that would be to go to the site and l 3 perform the inspections. 4 Q Was your inspection plan in writing? 5 A Yes. It was draft inspection plan. 6 Q Did you show it to Mr. Wilde and Mr. Forney and 7 Mr. Danielson? 8 A Mister -- no, I don't believe so. 9 Q Did you show it to any other person at the NRC? 10 A No, other than the -- the inspection format that 11 Mr. Ward had turned over to me, I think that's probably the 12 only thing that anyone else observed as part of my inspection. () 13 14 Q All right. Do you have a copy of the Inspection Report 85-09 with you? 15 MR. BERRY: I'm sorry, I was responsible for that. 16 I have a copy, but it's marked up. 17 MR. MILLER: All right. Well, other than the fact 18 that this has my name on the top right-hand corner, I hand the 19 witness a copy of Inspection Report 85-09, which has 20 previously been marked as Puckett Deposition Exhibit 4. 21 BY MR. MILLER: 22 Q Looking at the cover letter, Mr. Schapker, it O
51 1 indicates that your special safety inspection took place from 2 March 5 through November 5 of 1985. That's approximately an 3 eight-month period. How much time did you spend during that 4 eight-month period on this investigation? 5 A Well, if you look in the inspection summary, it 6 details the number of hours. 7 Q 192? 8 A 192 inspector hours onsite and 30 inspector hours 9 of in-office review. 10 Q So the total would be, if my math is right, 222 11 hours total? 12 A Yes. l 13 Q All right. On how many separate occasions did you ( ) 14 go to the Braidwood site in connection with this 15 investigation? 16 A I'd have to review some documents. I don't have
- 17 them available to tell you accurately. But I would say 18 approximately maybe seven or eight visits.
19 Q Well, Mr. Schapker, in the Details section of Report 20 85-09, page 2, there is a list of the persons contacted. Next t 21 to some of the names are asterisks. 22 A Yes. l O
52 1 Q And the asterisk is shown on the page as " Denotes (')T s_ 2 those attending the final exit interview." Does that indicate I 3 that that was the only occasion on which you talked with the 4 individuals who have an asterisk next to their name? 5 A No. For some that is true but others -- 6 Q All right. Can you identify ?.he ones with whom your 7 only contact was at the exit interview? 8 A Yes. These are the -- the ones vith the asterisks 9 are the only ones that were present at tus exit interview. 10 Q Yes, sir. No, my question was -- perhaps you 11 misunderstood. 12 A Okay. () 13 Q Of the ones that have an asterisk next to their 14 name, can you identify those individuals who you only saw in 15 connection with this investigation at the exit interview? 16 A only saw? Okay. Mr. Wallace, the project manager. 17 Mr. Groth, G. Groth. Mr. Tomashek. Mr. Smith, D. Smith, 18 nuclear licensing. There are some here I'm not too sure of. 19 Mister -- under L.K. Comstock, Mr. Rolan. Under Sargent & 20 Lundy, Mr. Jonss, Mr. Gallagher, Mr. Kostal. 21 Q So, other than the names that you have just 22 identified, you contacted these other individuals in O 4
53 r 1 connection with your investigation of the allegations? 2 A Yes. To the best of my recollection, that's true. 3 Q The last sentence on page 2 of Puckett Deposition 4 Exhibit 4 says, "The inspector also contacted and interviewed 5 other licensee and contractor personnel." As you sit here 6 today, sir, do you recall the names of any individuals with 7 whom you spoke? 8 A Okay. I believe there was a Mr. Minor, a Level 2 9 inspector. 10 Q Is that a Comstock Level 2? 11 A Yes. Comstock Level 2. To refresh my memory -- 12 Q If you've got something that will help -- () 13 A Mr. Wicks, who is also a Level 2 inspector. That's i 14 all I can recall right now, other than these that have already 15 been identified. Of course, the alleger. Yes, the alleger. 16 Q Right. In addition to talking to the individuals l i 17 who are identified in the inspection report -- Mr. Puckett, 18 Mr. Minor, and Mr. Wicks -- did you collect any documents from
- 19 Comstock or any other sources to aid you in your
! 20 investigation? l 21 A Yes, I did. 22 Q All right. Could you describe generally the O i 1
54 1 documents that you got together? U 2 A The welding procedures for Comstock. The weld 3 inspection procedures. The nonconformance reports that were 4 applicable to the concerns. I reviewed many documents that I 5 didn't actually collect. 6 Q All right, sir. Could you just describe some -- 7 A Describe the documents? 8 Q Yes, sir. 9 A Welder qualification records. Welder qualification lo stamp log. Welder inspection records. 11 MR. BERRY: You can refer to your report if you 12 don't remember. 1 13 ( ) THE WITNESS: Weld rod control procedures. In fact, 14 any of the procedures that had to do with welding for Comstock i 15 .were reviewed.
't 16 BY MR. MILLER:
17 Q Had Mr. Puckett supplied you with any documents 18 when you visited him in Ohio? 19 A No. l 20 Q All right. At some point in time, were certain 21 documents that Mr. Puckett had turned over to other members of l 22 the NRC staff made available to you? O 1
55 1 A Yes.
, 2 Q Do you recall the nature of those documents?
3 -A There were -- if I can review that exhibit? 4 Q Well, I'd like to show you what has previously been 5 marked as Puckett Deposition Exhibit 2 for identification. 6 It's a handwritten list. Mr. Puckett has testified that this 7 is his handwriting, and it purports to be a review of welder 8 qualification records. ! 9 A Yes. 10 Q Any other documents turned over to you by 11 Mr. Puckett? 12 A No. l i ( 13 Q When you interviewed him in Ohio, did you ask him if 14 he had any documents that he thought might be useful to your 15 investigation? 16 A I asked him for any additional -- any information he 17 could supply me that could aid me in my investigation and 18 inspection. 19 Q Okay. And he offered nothing at that point in time? 20 A No. 21 Q Did he indicate that he had turned over materials 22 earlier to other members of the NRC staff? O
56 1 A I don't know if he did or not at that time. He did 2 -- he did say that the concerns that he had expressed were 3 that I had went over with him on that day were the only ones 4 that he could think of at that time. 5 Q During the course of your investigation, did you 6 consult or discuss your investigation with any other member of , 7 the NRC staff? 8 A Yes. 9 Q With whom? You have already referred to Mr. Gwenn, 10 so we can pass him. 11 A John Jacobson. 12 Q on how many different occasions -- well, first of 13 all, what was Mr. Jacobson's position with the MRC staff at ( 14 this point in time? I { 15 A He's the Division of Reactor Safety metallurgist I 16 specialist. 17 Q Does he hold the same level position as you do, or 18 is he a superior? 19 A Yes. 20' Q It's the same as -- 21 A Right. He is also a reactor inspector. 22 Q Does he have a background in welding and NDE as O
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57 1 well? p) s_ 2 A Metallurgy. Yes. 3 Q On how many o,ccasions did you discuss your 4 investigation with Mr. Jacobson? 5 A I believe on two, two different occasions that I can 6 remember. 7 Q Were these discussions before or after your visit to 8 Mr. Puckett? 9 A After. 10 Q Can you recall the approximate date of the first 11 discussion? 12 A The approximate date was probably -- I will have to 13 consult my report. ( ) 14 Q Surely. 15 (Witness perusing document.] 16 [ Discussion off the record.] 17 MR. MILLER: Back on the record. 18 THE WITNESS: What's the question? 19 MR. MILLER: Yes, there is a question pending, I 20 think. 21 MR. GUILD: There is a question pending. 22 BY MR. MILLER: O
58 1 Q Why don't you answer that one, and then we'll take a O2 break. 3 A Approximately June 1985, approximately. 4 MR. MILLER: Okay, let's take a short break. 5 [ Recess.] 6 MR. MILLER: Back on the record. 7 BY MR. MILLER: 8 Q Mr. Schapker, I think just before the break you 9 testified that your first conversation with Mr. Jacobson, your 10 colleague on the NRC staff, with respect to these allegations 11 took place in June of 1985. Can you tell me the substance of 12 that conversation? ( ) 13 A I believe that we were discussing the AWS code. 14 Q In what particulars, sir? 15 A In particular to I think it's 8.85 of that code. 16 Q I see you're referring to your inspection report. 17 Is there a specific allegation -- l 18 A Yes, there is. 19 Q -- which that section has pertinence? 20 A Right. 21 Q Can you identify for us by page number of the 22 inspection report? O
59 l 1 A I am looking for it. Just a second. 2 (Pause.] 3 Okay. It's on page 20, allegation R. 4 Q All right, sir. That has to do with the fillet 5 welds deposited on the opposite sides of a common plane of 6 contact? 7 A Right. 8 Q All right. And can you tell me the substance of 9 your conversation with Mr. Jacobson with respect to that 10 section of the code as it related to allegation R in your 11 inspection report? 12 A We were discussing the application of this ( ) 13 particular -- these two members as being applicable to AWS 14 JFIl.1-h5. And at that time, I drew a sketch of the connection 15 and described the material that was involved to Mr. Jacobson. 16 Q Did you ask for his opinion as to whether 8.85 -- 17 A Yes, I did. i 18 Q -- applied to this? What was his response? 19 A It was his opinion that it did not apply any 20 application the way I had described it to him. 21 Q Did Mr. Jacobson tell you the reason for his 22 interpretation? m
60 1 A I don't -- I don't believe we discussed reason for i 2 interpretation. We just discussed that that was his -- and 3 was my interpretation, and he agreed with that 4 interpretation. I referenced the connection, Sargent & Lundy 5 . connection, the drawing, and described the -- and sketched the 6 welds involved on that connection on the blackboard. 7 MR. MILLER: Can we go off the record for just a 8 second? 9 [ Discussion off the record.] 10 MR. MILLER: Back on the record. 11 THE WITNESS: Shall I continue? 12 BY MR. MILLER: () 13 Q Yes, please. 14 A The conclusion was reached -- that I reached 15 cor.cerning this allegation is what we discussed, and this is 16 what we agreed. 17 Q When you made your sketch on the blackboard for 18 Mr. Jacobson, did you reflect physical observations that you 19 had mede of these connections in the field? 20 A Yes, I did. - .; 21 Q Approximately how many of these connections did you 22 look at at the Braidwood plant prior to your conversation with l
61 1 Mr. Jacobson? 2 A Approximately 50, as reflected in my inspection 3 report. 4 Q And can you describe for me the configuration of 5 the welds on that connection that you observed and that you 6 drew for Mr. Jacobson? 7 A There was a fillet weld on -- two fillet welds on 8 one plane and one fillet weld on the opposite plane, which 9 butted up or came close, you know, came adjacent within -- 10 adjacent to each other. 11 Q Did-you observe -- the 50 connections that you 12 looked at -- 13 A Yes. ( 14 Q -- did you observe anywhere the fillet weld was 15 continuous from plane to plane on the connection? 16 A No. None were continuous -- those that I observed 17 -- were continuous. They were three separate welds. 18 Q All right. Did you have occasion, Mr. Schapker, to 1 19 observe the fabrication of these welds in the shop? I 20 A I looked at some of those that were fabricated in 21 the shop. I did not observe them in the process of 22 fabrication. O
62 1 Q It's a fact, is it not, that all of these are -- s/ 2 these connections -- are fabricated in the shop and not in the 3 field? 4 A I don't know if that's true or not. 5 Q So, Mr. Jacobson, in effect, confirmed your own 6 analysis of the applicability of section 8.8.5 to these 7 particular fillet welds on this connection that you referred 8 to in allegation R. Correct? 9 A Yes. 10 Q All right. Was that the end of this first 11 conversation with Mr. Jacobson? 12 A No. We may have discussed other things, but it had ( } 13 nothing other than to do with this inspection report. 14 Q All right. What was the second conversation you had 15 with Mr. Jacobson? 16 A Mr. Jacobson did a review of all the procedures at 17 Braidwood. And I'm not sure, this may have been prior to 18 this. I'm not sure of the date that he performed that l 19 inspection. But it was during this period of time this 20 inspection was ongoing. 21 Q Were the procedures that he reviewed, did they i 22 include any Comstock weld procedures that were also involved l l O
63 1 in your investigation? 2 A Yes, they did. 3 Q Do you recall the number of the procedures? 4 A No, I don't. That would be reflected in his report, 5 but I don't recall the number of the procedures. I do believe 6 that he reviewed them all. 7 Q Is it your belief that Mr. Jacobson's review of the 8 Comstock procedures is reflected in a published inspection 9 report? 10 A Yes, it is. 11 Q Was that inspection report published at the time 12 that you and he had this conversation? 13 A I don't believe so, at that time. ( ) I believe he had 14 completed his inspection, but he had not published his report 15 at that time. 16 Q All right. What was the substance of your j 17 conversation with Mr. Jacobson on this occasion? 18 A We discussed the adequacy of the procedures 19 themselves. 20 Q Do you recall any specific portion of a procedure 21 that you discussed the adequacy of? 22 A No, it was just in general. O
64 1 Q Again, did you in substance ask Mr. Jacobson for his 2 overall opinion with respect to the adequacy of Comstock 3 procedures? l 4 A Yes. 1 5 Q What was his response? 6 A He felt they were totally adequate. 7 Q At the time you had this conversation with 8 Mr. Jacobson, had you reached an opinion with respect to the 9 adequacy of the Comstock procedures that you had reviewed? 10 A Yes. 11 Q What was your conclusion? 12 A I felt that they were adequate. 13 ( ) Q Do you know whether Mr. Jacobson made any change in 14 his inspection report as a result of his conversation with 15 you? 16 A No. 17 MR. BERRY: No, he didn't or -- 18 THE WITNESS: No, he didn't, not that I know of. 19 BY MR. MILLER: 20 Q Just backing up for a second to the first 21 conversation with Mr. Jacobson that you had about this 22 unistrut-to-plate weld detail that you sketched out that is O +
~,- - -.
65 1 the subject of allegation R. O2 A Yes. 3 Q When you picked the 50 connections to look at in the 4 field, how did you pick the 50? 5 A Randomly. I just walked out into the field and 6 looked for the application of that particular connection. 7 Q All right. Did you have to climb up ladders or 8 anything like that? 9 A Oh, yes. Well, in some cases I had to. Not most of 10 them. In some cases, not. You know, most of them are 11 attached to the ceiling, that's true, in some cases. 12 Q Was there a Comstock or a Commonwealth Edison () 13 employee when you made this random look? 14 A No, this was independent. 15 Q So no one steered you to any particular connection 16 or anything like that? 17 A No, no. I did this as an irdependent inrpection. 18 Q Did you spend your time in one specific area of the 19 plant or did you -- 20 A No. I went throughout the plant, all safety-related 21 areas. Reactor building, auxiliary building. 22 Q How long did this random sample look at the 50 0
66 1 connections take you? 2 A I would say it took the better part of a morning. 3 Q And the only thing you were looking for was to see 4 whether the weld was continuous across the two planes on the 5 connection? 6 A Yes. Yes, that's right. 7 Q So you weren't conducting a visual weld examination 8 or anything like that? 9 A No. No. 10 Q Mr. Schapker, in an earlier response you said that 11 you had had an inspection plan for your investigation into 12 Mr. Puckett's allegations. I realize that we don't have the 13 plan in front of us. But can you set out the sequence of 14 steps that you followed in investigating? 15 A Well, the inspection plan was essentially a draft of 16 the alleger's concerns, which I received from Mr. Ward, and 17 the comments that I had received from Mr. Puckett in an 18 interview about the concerns that he expressed in those 19 allegations. And I took the two -- the information I received 20 and combined them to develop a plan so that I could go to 21 Braidwood and go to the sources I needed to do the inspection. 22 Q All right. Did you first -- in this plan -- did you O
67 1 first review the Comstock procedures and other documentary . (m,e 2 evidence, or did you conduct your interviews first? 3 A No, as part of the inspection itself, when I went to 4 Braidwood, I started a review of the procedures initially. 5 Q All right. . 6 A I did interview, I did talk to some people as part t 7 of the entrance to other inspections to describe what my 8 inspection was -- is comprised of and what I would be looking 9 into. But other than that, my initial part of the inspection 10 was to review procedures applicable to the concerns involved. 11 Q Okay. Who were the individuals that you had your 12 entrance interview with, do you recall? 13 A Mr. Lou Kline would be one that was present -- this 14 is commonwealth Edison -- who are identified as persons 15 contacted. Mr. Schroeder, I believe, was present. 16 From Comstock, I believe, Mr. Seltmann, Mr. DeWald 17 may have been there, I'm not certain. 18 Q At the entrance interview, Mr. Schapker, was there 19 an extended conversation with these individuals, or did you 20 simply tell them what you were going to be doing and ask their 21 cooperation? Or what was the nature of the conversation? 22 A It was just an entrance to identify the scope of my
68 1 inspection. 2 Q You didn't ask for any comments of any of these 3 individuals, did you? 4 A No, no, not at the entrance examination. 5 Q All right. So after you collected the documents i 6 that I think you referred to in the previous answer, did you 7 then begin your interview process? 8 A I may have began, yes, to talk to individuals, yes. 9 I don't know the exact time frame, but as part of the review, 10 initially, I coordinated my inspection through Mr. Tony 11 Simile, the welding -- Level 3 welding engineer at 12 L.K. Comstock at that time. He had supplied me with all the 13 procedures, weld procedures and other information I requested. ( ) 14 Q At that point in time, did you obtain copies of 15 memoranda that Mr. Puckett had written from time to time to 16 Mr. DeWald and others? 17 A Not at that time. Not at the early part of the 18 inspection. 19 Q Later, though, in your investigation? 20 A Yes. 21 Q All right. Approximately how much time did you ! 22 spend interviewing Mr. DeWald after your investigation got l
69 i 1 started? 2 A I talked to Mr. DeWald maybe 10 minutes. j- 3 Q Total, during the entire investigation effort? 4 A Yes, I believe that's about right. 5 Q Approximately how many other interviews did you 6 conduct besides Mr. DeWald? i 7 A I talked to several QC inspectors. Mr. Simile -- 4 8 Q Did you talk to Mr. Gieseker? i 9 A Yes. 10 Q Did you talk to Mr. Seltmann about the substance 11 of the allegations at all? 12 A Yes, I did talk to Mr. Seltmann, the QA manager at 13 Comstock. 14 Q Of the time that you spent at the site, 15 Mr. Schapker, would you say that the majority of your time was 16 spent in document review and physical observations or the 17 majority of it was spent interviewing Comstock and licensee j 18 personnel? 19 A The majority of the time was spent insi:ecting, doing i 20 document reviews and physical inspections. j 21 Q Were there any other activities that you had 4 22 developed as a part of your inspection plan besides these site l O
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70 1 visits, the collection of the documents and physical 2 observation and talking to individuals as you deemed it 3 appropriate then? 4 A I guess I don't understand that. 5 Q Well, was there anything else that you did; for 6 example, did you physically test any materials yourself or -- 7 A No, none other than what's described in the 8 inspection report. That's -- f 9 Q I would like to turn to the inspection report and go l 10 over the allegations with you one by one. I would like to
; 11 turn first to allegation A, which is found on page 3 of f
12 Inspection Report 85-09, Puckett Deposition Exhibit 4. () 13 Am I correct, Mr. Schapker, that the AWS welding 14 code D.1.1 authorizes the welding of A-446 to A-36 material 15 without a special qualification procedure? 16 A It -- the code requires the procedure to be 17 documented. The procedure should document the materials that 18 are being connected, that will be joined up, as described 19 in the inspection report, technically, A-446, in accordance 20 with AWS code, can be joined to A-36 material. 21 Q Well, once again, you will have to forgive'me for my 22 lack of understanding of these matters. But it is correct, is
71 1 it not, that there are certain weld procedures that are 2 prequalified under the AWS code? I 3 A Yes. 4 Q And that prequalification extends to certain 5 materials that are identified in the code. Is that also 6 correct? 7 A Yes. 8 Q And is it also correct that the precise issue that 9 was addressed by Mr. Puckett's allegation was whether or not 10 there was a qualified procedure to weld A-446 material to A-36 11 material? 12 A Yes. It states that a weld procedure was not () 13 available for that, in his allegation. 14 Q All right. Calling your attention to what has 15 previously been identified as Puckett Deposition Exhibit 16 3, which is the AWS code D.1.1, 1975 version, section 5.5, can 17 you tell me whether that section would authorize the welding 18 of A-446 to A-36 materials if there was a procedure which 19 authorized A-446 to A-500 in place? 20 A Yes. As described in my inspection report, section 21 5.5, which states, in part, a qualification of a welding 22 procedure established for the base metal included in 10.2 and O l
., . - . . _ - . . _ . _ - . - _ - - _ - _ , _ _._.-~ ,,.-.- --_ ,--,-_.
72 1 not listed in 5.5.12 have a minimum specified yield point less 2 than 50,000 p.s.i. shall qualify the procedure for welding any 3 other base metal or combination of those base metals included 4 in 10.2 that have a minimum specified yield point equal to or 5 less than that of base metal used in the test. 6 Q All right. If we look at Table 4.1.1 of the AWS 7 welding code, what, if anything, does that tell us about the 8 yield strength of the A-36 material? 9 A Yield strength is 36 k.s.i. 10 Q Which is less than -- 11 A 50. 12 Q -- 50 k.s.l.? 13 A Yes.
)
14 Q So, therefore, the A-36 material, under the code, 15 would be qualified for welding with the A-446 material. 16 Correct? 17 A Yes. 18 Q Now, in fact, you agreed with Mr. Puckett's 19 allegation that the welding procedures were themselves 20 incomplete because they did not specifically reference the 21 A-36 material; is that right? 22 A to A}b They did not reference the A-446 aateri'al. I am i O V
73 1 sorry. 2 Q Let me get to the weld procedure. This weld 3 procedure has previously been marked as Puckett deposition 4 Exhibit 8 for identification. I am going to put a paperclip 5 on the page I want to get to. 6 But let me show you the cover sheet. This is the l 7 Comstock weld procedure which Mr. Puckett has testified was in 8 effect during the time he was an employee of Comstock at 9 Braidwood. Is that the weld procedure which you -- the 10 version of the weld procedure -- that you reviewed in 11 connection with your investigation into his allegations? 12 MR. GUILD: Well, just to be clear, the revision 13 l ( ) that I am looking at shows a revision date of the 29th of i 14 August 1984, Rev. D. t l 15 MR. MILLER: You're right. We're going to get back 16 to that.
- 17 Excuse me for just one second, Mr. Schapker.
l 18 (Pause.) , 19 MR. MILLER: Mr. Guild, you are quite right. We 20 could pull out the transcript, if you wished. Let me try the 21 question and start over again. 22 BY MR. MILLER: O
74 1 Q Let me call your attention, Mr. Schapker, to a page \ 2 in Exhibit 8 that is identified as Attachment 0 in the 3 right-hand, towards the bottom of the page, on the right-hand . 4 side. 5 A This is,47.33 Rev. D? /jAb-6 Q Yes, sir. I am still in the wrong pew here. I am 7 sorry. We should be at Attachment H to the procedure 4.3.3. 8 Can you identify or describe for me what the material listings 9 on the top line of that page represent? 10 Hold on for just a second and let Mr. Guild get to 11 that page. 12 MR. GUILD: Let me just say there are several H 13 pages so -- ( ) 14 MR. MILLER: There's one that's just referenced as 15 Attachment H, and then it says see AttaC ments H-1, H-2, H-3. 16 THE WITNESS: H? 17 MR. MILLER: Yes. 18 MR. GUILD: All right. 19 THE WITNESS: Yes. It states that it's ASTM A-446 20 and A-500 grade B or A-36. 21 BY MR. MILLER: 22 Q And the words and letters "For A-36" appear to be in O
75 1 a different type face and -- 2 A Yes, they do. 3 Q Am I correct that the manner in which the concerns 4 that are expressed in allegation A of your inspection report 5 were resolved simply by adding the A-36 material as a 6 qualified material to procedure H? 7 A Yes. 8 Q Mr. Schapker, in your opinion, does failure to have 9 this A-36 material specifically called out on the procedures 10 warrant a stop-work welding activity? 11 A I wouldn't be in the position to make that judgment. 12 Q Is this a deficiency in the welding procedures that () 13 you would categorize as having safety significance? 14 A In this particular. case it had no safety 15 significance. 16 Q What, if anything, does your investigation into this 17 allegation indicate to you about Mr. Puckett's familiarity 18 with the AWS welding code D.1.17 19 A Repeat the question, please. l l 20 Q Surely. What, if anything, does your investigation i 21 of this specific allegation, identified as Allegation A, 22 indicate to you about Mr. Puckett's familiarity with the AWS O
76 1 welding code D.l.l? 2 A I would say that he was somewhat knowledgeable of 3 the code. 4 Q Somewhat knowledgeable? I'm sorry, was that your 5 answer? 6 A Yes. He was correct in his allegation as far as it 7 being required to be a part of the weld procedure that it , 8 should be annotated on the procedure itself, that it is a 9 requirement of the code that it be. 4 10 Q In fact, this matter was resolved while Mr. Puckett 11 was still an employee of L.K. Comstock, was it not? 12 , A I believe it was initiated at that time anyway. I ( ) 13 don't know if all the action had been completed prior to his 14 dismissal. That I'm not sure of. I would have to review documentation to ascertain that. 15 I know that he did attend a 16 -- there is a memorandum, a document that states that he was 17 part of a meeting concerning this. 18 Q Now, Allegation B refers to his contention that the 19 Comstock weld procedure 4.3.14 was qualified to the SG weld 20 position. Correct? But the procedure was being used to weld 21 all positions. It's correct, is it not, that qualification of 4 22 the 5G position does not qualify the procedure for use in the 2 O
77 , 1 horizontal or 2G position? 2 A That's correct. 3 Q Do yet know whether Mr. Puckett made this known to 4 Comstock management while he was an employee? 5 A Yes, I believe he did. 6 Q And do you know what action Comstock management took 7 in response to his concerns about this issue? 8 A They issued a nonconformance report. J 9 Q Do you know whether there was also a stop-work on 10 stainless-steel welding on this issue? 11 A Yes, I do recall that there was a stop-work order. 12 That's part of the documentation that I reviewed. 13 Q Do you know what, if anything, was done with respect ( 14 to welds that had previously been made in the 2G position 15 prior to the stop-work order? 16 A They were -- the horizontal welds were removed and 17 replaced after the procedure was requalified in accordance 18 with the nonconformance report that was -- addressed his 19 finding. 20 Q In your opinion, Mr. Schapker, by stopping work and 21 taking the other corrective actions that we have now 22 identified on the record hc.re, was Comstock management being l O __ _ . _ _ _ , , , . _ . _ _ . _ . . . _ . _ _ . . . ._,_-.,-. y -__ , . , , - -, _. ,c . ,.. . . _ . y , _ _.__ _ -,
78 1 responsive to Mr. Puckett's expressions of concern? ; 2 MR. GUILD: Objection. That clearly calls for 3 speculation. He can say what he knows they did, and he can 4 express an opinion about the action they took themselves. 5 But in terms of whether it was responsive, that requires him 6 to make a judgment about what response was expected by 7 Mr. Puckett, and he can't do that. , 8 MR. BERRY: You can answer the question subject to 9 the objection. 10 THE WITNESS: I believe Comstock took the 11 appropriate action. 12 BY MR. MILLER: 13 Q Do you know approximately how many welds were ( ) 14 subject to this procedure? 15 A I don't know the number. I do know that it was 16 limited. 17 Q A fairly small proportion -- l 18 A Very small. 1 i 19 Q- -- of the total welds made by Comstock at the site? 20 A Yes. Probably less than two percent. i 21 Q The second half of Allegation B refers to an 22 asserted language inconsistency within the procedure. Did you !(::) -
79 1 review the procedure 4.3.14 in connection with your 2 investigation of this allegation? 3 A Yes. 4 MR. MILLER: I would like for the reporter to mark 5 as Schapker Deposition Exhibit 2, Comstock Procedure 4.3.14. 6 It bears handwritten dates on the first page of September 18, 7 1980. 8 [Schapker Deposition 9 Exhibit No. 2 was 10 marked for identification.] 11 BY MR. MILLER: 12 Q Okay, Mr. Schapker, I show you a document that has () 13 been marked as Schapker Deposition Exhibit 2 and ask you 14 if that is the version of the procedure 4.3.14 that you 15 reviewed in connection with your investigation of this 16 allegation? The reference to the QC inspection, of course, is 17 to a different section of the manual. Turn to page 4.10 of 18 Schapker Deposition Exhibit 2, under the heading "QC 19 Inspection." 20 [ Witness perusing document.] 21 Mr. Schapker -- 22 A Yes? i 4 O I
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80 1 Q -- is there, based on your review of this procedure 2 right now, can you tell me whether there is any specific 3 instruction in the procedure.itself as to the manner in which 4 the inspection is to be conducted? 5 A It says, "QC inspection shall be performed per 6 section 4 of this manual." 7 Q Right. I am sorry to say that I don't have section 8 4.8.3. Let me go back to your inspection report for just a 9 moment if I may. 10 A Yes. 11 MR. GUILD: Let me interrupt just for clarity. 12 The question that wasn't answered, and that was, "Was this the ( } 13 revision of the procedure that he inspected?" 14 MR. MILLER: Yes. 15 BY MR. MILLER: 16 Q Do your recognize this as the procedure to which you 17 conducted your inspection? 18 A I believe that I reviewed this procedure in addition 19 to others, 1.3, 1.4. 20 Q Thank you. 21 A On this particular -- 22 MR. BERRY: Is this the procedure you're referring 1 O I i
81 1 to in this part about -- O)
\s- 2 THE WITNESS: Okay.
3 MR. MILLER: Right. In Allegation B. 4 THE WITNESS: Okay. Let me look. 5 [ Witness perusing document.) 6 THE WITNESS: I am looking for that reference to 7 it. Yes. 8 BY MR. MILLER: 9 Q Turning back to your inspection report, Puckett 10 Deposition Exhibit 4, the quotation in the bottom paragraph on 11 page 4 is from the American Welding Society D.1.1 code. Is it t 12 your recollection that that exact quoted material is also ( ) 13 found in the appropriate L.K. Comstock procedure for QC 14 inspection of stainless-steel welds? 15 A No, I don't believe that it is. What procedure are 16 we talking about? 4.83? 17 Q Yes. And I would have 4.83 here to show you, and I i 18 apologize for that. 19 A To be truthful, I don't recall if it's in that 20 procedure or not, offhand. 21 Q There is a reference in the very last sentence of 22 page 4 that says that you had reviewed a sample of quality O
82
- 1 documentation in conjunction with another allegation, I take 2 it unrelated to Mr. Puckett, is that correct?
3 A Right. 4 Q To verify the proper utilization of NDE procedures. 5 What did you find with respect to the NDE procedures in use 6 for stainless-steel welds? 7 A In my review of the procedures, I found -- I'm j 8 sorry. In review of the documentation, I found that they were 9 appropriately -- the appropriate NDE had been performed. 10 There was no instance of magnetic particle examination being } 11 performed on -- 12 Q Do you recall which NDE examination was, in fact , 13 used on or indicated as being used on the documentation that ( ) 14 you looked at? 15 A Visual. Visual examination. VTs, visual test i 16 examination. 17 Q Is that a satisfactory form of NDE for 18 stainless-steel welds? j 19 A Yes. I 20 Q Was there any other form of NDE used by Comstock in j 21 its inspection of stainless-steel welds other than visual 22 inspections, if you recall? i () I l 4
,-rn,.- ,e--,-g, - - - - --,,-n,,,,a-
i 83 1 A Not that I examined, not that I reviewed. 2 MR. MILLER: All right. It's 1:00. I am about to 3 move on to another allegation. Why don't we break? An hour? 4 MR. BERRY: That will be fine. i 5 [Whereupon, at 1:03 p.m., the taking of the 6 deposition was recessed for lunch, to reconvene at 2:00 7 p.m. this same day.] 8 9 10 l 11 12 O' 14 l 15 16 17 18 19 20 21 22 i i 4
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84 1 AFTERNOON SESSION / k3s/ 2 (2:13 p.m.] 3 Whereupon, 4 JEROME F. SCHAPKER 5 the witness on the stand at the time of recess, resumed the 6 stand and was examined further and testified as follows: 7 MR. MILLER: Let's go back on the record. 8 EXAMINATION - Continued 9 BY MR. MILLER: 10 Q Mr. Schapkar, let's turn to Allegation C. There is 11 a reference there to a bi-metallic weld. Have you had the 12 occasion to review both sections of Mr. Puckett's deposition; 13 ( ) that is, both transcripts? 14 A Yes. 15 MR. BERRY: One thing we don't have, Mike, is the 16 exhibits to the first session. 17 MR. MILLER: Oh, well, that I can handle. 18 BY MR. MILLER: 19 Q At the second session of his deposition, page 237 of 20 the transcript, there is a reference to an individual QC 21 inspector who had asserted that he had been asked to inspect a 22 bi-metallic weld, starting at line 16. O
85 1 A Could you give me the page again? 2 Q Yes. 237, and it carries over onto the next page, 3 and that QC inspector is identified on the rec.ord as John 4 Minor. Other than the review that is referred to on page 5 of 5 Inspection Report 85-09, did you question any of the QC 6 inspectors that you interviewed as to whether or not they had 7 been asked to inspect a bi-metallic weld? 8 A Yes. 9 Q Did you discuss that specifically with Mr. Minor? 10 Q What did Mr. Minor tell you about being asked to 11 inspect a bi-metallic weld? 12 A He indicated that he thought there was a bi-metallic ( } 13 weld initially when he signed the NCR, the nonconformance 14 report. 15 Q Let's see if we can get that nonconformance report 16 out in front of us. 17 MR. BERRY: Let's go off the record. 18 (Discussion off the record.] 19 BY MR. MILLER: 20 Q I can show you Puckett Deposition Exhibit 11, which 21 is a memorandum from Mr. DeWald to Mr. Rolan. And there is a 22 reference in numbered paragraph C.
86 1 A Yes. 2 Q To a bi-metallic weld. Is it your recollection that 3 there is an addition to the NCR that dealt with that issue? 4 A Yes, there was. 5 Q Is it your recollection that Mr. Minor told you that 6 he had initiated an NCR on that subject? 7 A Yes, I believe it was prepared by Mr. Puckett. His 8 handwriting was vaguely discernible. And Mr. Minor signed it. 9 Q All right. 10 A And sometime after -- or before it was issued, 11 Mr. Minor corrected a portion of that NCR dealing with 12 bi-metallic welds. He crossed out the portion concerning () 13 14 bi-metallic welds. MR. MILLER: The package of documents that you have, 15 Mr. Berry, I know that they've been produced before. Do you 4 16 know whether that NCR is in there? j 17 MR. BERRY: I will look and see. I don't recollect 18 seeing that when we went through these. I don't think that 19 that NCR was among the documento in the file. 20 [ Pause.] 21 MR. BERRY: No. Apparently the only NCR that 22 Mr. Puckett furnished the NRC was a copy of 3099. l
87 1 BY MR. MILLER: 2 Q Did you physically observe this NCR with Mr. Minor's 3 deletion of the reference to the bi-metallic welds when you 4 were conducting your investigation? 5 -A Yes, while I was conducting the inspection. 6 Q Mr. Schapker, of what significance, if any, to the 7 issue of whether there were bi-metallic welds is the fact that 8 E-309 weld rod was in use by Comstock at the Braidwood site? 9 A None. If I understand the question. 10 Q Well, I hope you do. Mr. Puckett has stated in 11 substance of his deposition that -- well, let me back up. 12 E-309 weld rod can be used for welding carbon steel to 13 stainless-steel, can it not? ( ) 14 A Yes, it can. It can also be used to weld stainless 15 to stainless. It's -- E-309 is a versatile welding rod. It 16 can be used for both. That's a true statement. 17 Q All right. At the top of page 6 of Inspection l 18 Report 85-09 you state that you made inquiry to a Level 3 19 welding supervisor. That's Mr. Simile, correct? 20 A Correct. 21 Q And then there is a reference in the next line to 22 certain Level 2 weld inspectors. Did you speak to anyone O l
88 1 besides Mr. Minor on this subject? 2 A I spoke to several Level 2s, not in your interview 3 context, but just as a question, you know, are there any 4 stainless-to-carbon-steel welds being performed in the field 5 that you know of? 6 Q What was the response? 7 A The response was negative. They did not know of any 8 carbon steel-to-stainless-steel welds, bi-metallic welds, 9 being performed by Comstock. 10 Q All right. The paragraph goes on, Mr. Schapker, to 11 talk about a reference to welder qualifications being made to 12 a material identified as SA-312 to SA-312, when SA-240 to ()13 SA-312 was being performed in the field. 14 A Yes. 15 Q I would like you to turn back, if you would, to 16 Puckett Deposition Exhibit 2 for identification, which is the 17 weld procedure 4.3.14. 18 A Yes. 19 Q On the second page of the document there is, in 20 fact, a reference to the base metals on which the -- it's the 21 second page of the document, the first page of typewriting 22 in the exhibit. There is a reference in section 3.1.1 to the a
89 1 base metal that is used to qualify the welders. Correct? O2 A Yes. 3 Q Now, what is the difference between SA-240 and 4 SA-312 materials? 5 A They're both stainless materials. SA-240 is plate 6 material, stainless plate. SA-312 is pipe. 7 Q All right. Now, if we turn in the procedure to the 8 third page from the back, there is an indication, is there 9 not, that the procedure is to be qualified on pipe. Is that 10 correct? 11 MR. BERRY: Is that this document that says on the 12 page Form 110 in the lower right-hand corner? () 13 MR. MILLER: Right. 14 BY MR. MILLER: 15 Q Welding procedure qualification test record. And my 16 question is that that in fact indicates, does it not, that 17 the welding procedure qualification test record is to be 18 performed on pipe? 19 A That's correct. 20 Q All right. And it is in fact type 304 pipe? Is 21 that also correct? 22 A It's A-312 type 304. Right. O
90 1 Q If a welder is qualified on this pipe, are there any 2 restrictions under the AWS code with respect to welding pipe 3 to pipe, plate to plate, or plate to pipe? 4 A As referenced in my report, AWS D.1.1, paragraph 5 523.2.4 states qualification in the 6AF inclined position 6 qualifies for all position groove and all welding of pipe 7 tubing and plate. The only restriction here would be that 8 this is in the 5G position, so the welder would not be 9 qualified to weld in the 2G position. 10 Q Now, what, if anything, does your investigation 11 of this aspect of Allegation C indicate with respect to 12 Mr. Puckett's familiarity with the AWS D.1.1 code? 13 A I believe he was misinformed in some manner that 14 they were welding bi-metallic welds in the field, which they 15 were not. 4 16 Q Right. I am really directing your attention l 17 specifically, Mr. Schapker, to the reference to the welder 18 qualifications being made to SA-312 to SA-312 when SA-40 to 19 SA-312 was being performed in the field. My question is that 20 portion of the allegation, what does your investigation into 21 that aspect of Allegation C indicate, if anything, regarding 22 Mr. Puckett's familiarity with the AWS D.1.1 code? i O
I 91 , l 1 A As part of the -- I don't see that in the allegation i 2 itself. 3 Q No, sir. It's in your paragraph under the NRC 4 review, where it says the alleger also made reference. 5 [ Pause.] 6 MR. BERRY: Do you need to hear the question again? 7 THE WITNESS: Yes. Repeat the question now, would 8 you? 9 BY MR. MILLER: 10 Q All right. Yes, sir. I am calling your attention 11 to that portion of your discussion of Allegation C where you 12 refer to the welder qualifications being made to SA-312 to 13 SA-312 when SA-240 to SA-312 was being performed in the ( 14 field. My question to you is what, if anything, did your 15 investigation of this aspect of Allegation C indicate to you 16 regarding Mr. Puckett's familiarity with the AWS code? 17 A I believe he misinterpret'ed the intent of the code 18 in this area. He lacked some knowledge in that area. 19 Q Now, the next allegation is the statement about 20 Comstock weld procedures are filled with errors and 21 inconsistencies. 22 MR. GUILD: Which statement do you have reference O
92 1 to? l 2 MR. MILLER: It's Allegation D. 3 MR. MILLER: Did you look at all the weld procedures 4 that were in use at the time Mr. Puckett was employed by 5 Comstock at Braidwood? 6 A Yes, I did. 7 Q When you say that, "The minor typographical errors 8 were encountered but were not prevalent," what do you mean by 9 the word " prevalent"? 10 A I mean there were very few of them. 11 Q In your judgment, were the errors that you observed 12 likely to cause the procedure to be misapplied? 13 A No. ( 14 Q There is a reference in the NRC paragraph for 15 Allegation D in Inspection Report 85-09 that you had a further 3 16 discussion with the alleger. Did Mr. Puckett, in effect, 17 state to you that the weld procedures were in fact generally
- 9 18 adequate but there were just some of these clerical errors 19 that needed to be fixed up?
20 A That's true. 21 Q Now, Mr. Puckett in his deposition drew a comparison i 22 between the NRC's reaction -- or your reaction, to more l O
93 1 accurately state it -- to these inconsistencies in the O) (~- 2 Braidwood procedures and what had been his experience at the 3 Zimmer power plant. My question to you, sir, is were you 4 involved in the procedure reviews at Zimmer? - 5 A Yes. 6 Q All right. Were there also errors and " l 7 inconsistencies in the Zimmer weld procedures? 8 A Yes, there were. 9 Q I don't know how one characterizes errors and 10 inconsistencies. Were they more prevalent than the ones 11 that you found in your review of the Comstock procedures at 12 Braidwood? 13 A Yes, they were. ( ) 14 Q Were they of a nature that could lead to a 15 misinterpretation or a misapplication of procedure at Zimmer? 16 A Yes. 17 E Q All right, sir. Allegation )7 o page 6 of 18 Inspection Report 85-09 is characterized by you as Comstock 19 does not have any weld fillet material controls as the l 20 procedure is only now being written. At page 248 of l 21 Mr. Puckett's deposition he says that, "I don't think I made 22 that statement just exactly like that. What I said is the O
94 1 procedure that they have now practically gives you no control of filler material and they were in fact changing the
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2 3 procedure to make it somewhat better." 4 Now, having read Mr. Puckett's testimony, does your J 5 recollection change as to what the nature of his allegation 6 actually was? 7 A I believe this was taken -- the allegation as 8 written here was taken from the original testimony given to 9 the NRC. 10 Q Let the record reflect that the witness is referring 11 to the transcript of the interview of Mr. Puckett that took 12 place in September of 1984. 13 MR. MILLER: ( I don't want to take the time, unless 14 you have a quick page reference, Mr. Berry. 15 MR. BERRY: It appears to be page 75. Page 75 of 16 that transcript. 17 THE WITNESS: It's previous to this, it must be. 18 MR. BERRY: Apparently, what happened is -- 19 THE WITNESS: It seemed to be talking about weld rod 20 control and weld material control. It says, "They have no 21 control over it whatsoever." 22 O
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95 1 BY MR. MILLER: 2 Q Mr. Puckett's statement in the interview which you 3 have just read is the basis for your characterization of his 4 allegation; correct? 5 A I think the characterization of the allegation came 6 from this other document, which was taken from this. And
- 7 that's the Chuck Wilde investigative memorandum to Norelius 8 and Spesser, dated September 6, '84, identified as 104. And 9 that's the exact wording. "The L.K. Comstock Company does not 10 have any weld filler material controls as the procedure is 11 only now being written."
l 12 Q Now, Mr. Schapker, I am going to show you a document () 13 I am going to ask the reporter to mark as Schapker Deposition 14 Exhibit 3 for identification. 15 MR. MILLER: It is Comstock Procedure 4.3.10 1 16 Rev. C., with an effective date of December 8, 1983. 17 [Schapker Deposition 18 Exhibit No. 3 was marked 19 for identification.) 20 BY MR. MILLER: l 21 Q Having shown you Schapker Deposition Exhibit 3, I 22 ask you whether that is the same procedure that is referenced O
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96 1 at the top of page 7 of your Inspection Report 85-09? O , (s / 2 A Yes, it is. 3 Q Now, turning to a second to page 7 of Report 4 85-09, you state, "The alleger may have been referring to weld 5 filler material control problems which were identified in the 6 Comstock Nonconformance Report 32-75." Is that just your 7 hypothesis, Mr. Schapker, or did Mr. Puckett tell you that 4 8 that's what he was really referring to? 9 A Could I see 32-75 to refresh my memory on that? 10 Q Yes. 11 [ Witness perusing document.] 12 MR. MILLER: Off the record. 13 [ Discussion off the record.] ( ) 14 MR. MILLER: Back on the record. 15 Let's mark this as Schapker Deposition Exhibit 4, 16 Nonconformance Report 32-75, which bears a date of November 17 13, 1985, on the front sheet. 18 [Schapker Deposition 19 Exhibit No. 4 was marked 20 for idegpification.] 21 MR. GUILD: I've got an earlier version of 32-75. 22 It's Puckett Exhibit 26. It appears not to have a O
t 97 1 disposition. 2 BY MR. MILLER: 3 Q Mr. Schapker, if you would just take a look at that 4 for a second? 5 (Witness perusing documert.) 6 A Within NCR 32-75, sheet 3 and sheet 4 are 7 memorandums by Worley Puckett. 8 Q Well, my question to you, sir, originally was 9 whether the statement at the top of page 7 of your Inspection 10 Report 85-09, which says the alleger may have been referring , 11 to weld filler material control and so on was something that 12 Mr. Puckett told you or was that something that you came to on 13 our own analysis? ( ) 14 A This is something I came to on my own analysis by 15 review of this issue. 16 Q Now, your conclusion, as expressed, is that the 17 Comstock Company got adequate weld filler material controls in 18 place. Was that based on your review of the procedure that 19 we've marked as Schapker Deposition Exhibit 3 for 20 identification? 21 A Yes. 22 Q All right. Now, in his deposition Mr. Puckett says O
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98 1 that his problem -- this is at page 248 -- with the procedure 2 was that they had "an awful lot of difficulty even with 3 current weld rod withdrawal forms and current records trying 4 to find out what components had been welded with a particular 5 heat number of filler material, a particular rod slip." 6 My first question to you is did Mr. Puckett ever 7 express those sorts of concerns about the weld rod control 8 issue when you talked to him in March of 1985? 9 A No. 10 Q Do you know whether there is any requirement in NRC 11 regulations, the AWS welding code, or Comstock's procedures 12 that there be traceability from a particular heat number to a 13 particular weld on a component? ( ) l 14 A Should be traceable to consumption. i 15 Q Okay. You will have to tell me what you mean 16 by that. 17 A I mean the material that is utilized in a j 18 safety-related area needs to be traceable until it is used, 19 until the component is being welded. 20 Q Oh, then, in fact there is no requirement that you 21 know which specific heat number has been used on a specific 22 component, is that correct? O f
99
- 1 (Pause.]
i
\ ; 2 My question, I am sure, was confusing. That's my i
3 own familiarity with the concept. But after a weld has been 4 made, is there any requirement that there be traceability of a 5 particular weld rod heat number to a specific weld? i
- 6 A ASME does require specific heat traceability, i
i 7 Q Okay, sir. What about AWS welding? i j 8 A AWS does not require it. 1 9 Q Is there anything in the Comstock procedure that you 10 reviewed that required it for AWS weld? ., 11 A For heat traceability? 12 Q To specific -- ( ) 13 A Wald? 4
, 14 Q -- weld.
- 15 A No.
16 Q All right. Now, once again with respect to this 1 l 17 allegation in his deposition, Mr. Puckett referred to his l 18 experience at the Zimmer power plant. Mr. Schapker, as an NRC { 19 inspector, did your inspections at Zimmer cause you to become 20 familiar with their weld rod control procedures? 21 A Yes. l 22 Q Were they more or less stringent than the Comstock I I r i O i i
- _~ - . - - . __ _ - _ . _ . _. _ .. - .- . _ _ _ . . _
f 100 1 procedure that you reviewed in connection with Mr. Puckett's i 2 allegation? 4 3 A I really don't recall. 4 Q In your judgment, Mr. Schapker, does the comstock 5 procedure that you reviewed in connection with this allegation 6 generally meet regulatory requirements? l 7 A Yes. j 8 Q Mr. Schapker, this NCR 32-75 that we have marked as , l 9 Exhibit 4 identifies four clerical errors in the transfer of 10 heat numbers. Do you have your copy handy? Exhibit 4. 11 MR. GUILD: Can you give me a reference to a 4 ) 12 specific page? l 13 MR. MILLER: ( It starts on page 1 -- I'm sorry, the j 14 typed subparagraph 1 about a third of the way down the sheet. 4 , 2 15 And then it continues on to -- actually, it's the third sheet i i 16 of this NCR. ! 17 BY MR. MILLER: ! 18 Q Now, my question is are these kinds of clerical i ) 19 errors or mistyping unusual in your experience in transferring b 20 weld rod heat numbers from one form to another? 21 A No.
- 22 Q Do they indicate any deficiency in the procedure by i
I i O i
101 1 1 which weld rod is controlled? ! 2 A No. 3 Q Now, Allegation E-2 refers specifically to three 4 inconsistent heat numbers for weld rod control. Now, once 5 again, the statement is made here that you reviewed 50 of the 6 weld filler material withdrawal forms. How did you decide 7 which weld filler material withdrawal forms to review? 8 A I reviewed a random sample over a period of three 9 years. 10 Q Did anyone from Comstock direct you to a specific 11 set of forms, or did you just do -- 12 A No, no. I selected them on my own. 13 Q All right. ( ) Had Hr. Puckett in fact provided you 14 with the three heat numbers that he was unable to trace? 15 A I believe those three were referenced in one of his 16 memorandums as part of this NCR. 17 Q And you had had access to that memorandum prior to 18 the time that you made your review of these forms? 19 A Right. 20 Q All right. So you were going to look specifically 21 for those three, is that correct? 22 A Yes, I did look at those three. O
102 1 Q Were they readily ascertainable by you or could you 2 locate them fairly readily? 3 A I -- I talked to Mr. Simile in regard to these 4 three, and he assisted me in directing me where to find this 5 information. 6 Q All right. Did he suggest what the likely 7 transposition of numbers or possible substitution of a number 8 for a letter might be? 9 A No. 10 Q Did he direct you physically to the files where he 11 believed that these would be kept? 12 A Yes. He directed me to the files, the licensee's. () 13 14 Q A This is Cormonwealth Edison's files -- Yes, Commonwealth Edison's. 15 Q -- where he directed you? 16 A Yes. 17 Q It's correct, is it not, that Comstock does not 18 purchase its own weld rod for use at the Braidwood site? 19 A That's my understanding, yes. 20 Q And so the control of the quality documentation is 4 21 in the hands of the Commonwealth Edison or Phillip Getschow 22 Company, is that right? , O
103 1 A That's right. 2 Q Was there anybody at Commonwealth Edison that you 3 spoke to when you were looking for these three specific -- I 4 guess these are CMTRs, are they not, certified material test 5 reports? i 6 A Material test' reports. 7 Q Did anyone at Commonwealth Edison talk to you about 8 this, or did you talk with anyone at Commonwealth Edison? 9 A Yes, I talked to the clerks at the vault, and 10 requested assistance in locating the -- 11 Q These three CMTRs? 12 A The CMTRs, yes. ( ) 13 Q How long did it take you working with these clerks 14 to get these three? 15 A Maybe an hour. 16 MR. MILLER: I would like the reporter to mark as 17 Schapker Deposition Exhibit 5, the CMTR which bears the heat 18 number 40lS7441; as Schapker Deposition Exhibit 6, a CMTR 19 that bears the heat number 402S9011; and as Schapker 20 Deposition Exhibit 7 a CMTR that bears a lot number 3S202061. 21 Schapker Deposition Exhibits 5, 6, and 7 for identification. 22 O
104 1 (Schapker Deposition Exhibits 2 No. 5 through 7 were 3 marked for identification.] 4 BY MR. MILLER: 5 Q I want to ask you whether those are the CMTRs that 6 you observed when you went to the Commonwealth Edison vault in 7 connection with your investigation into Allegation E-2 as 8 recorded on Inspection Report 85-097 9 A Yes, they appear to be. 10 Q I notice that in what we have marked as Exhibits 5 11 and 6 the reference is to the heat number for Exhibit 7, the 12 reference is to the lot number. What significance, if any, 13 does the reference to the lot number have in terms of meeting 14 regulatory requirements with respect to traceability? , 15 A It's a unique identifying number. 16 Q So it's adequate to identify by heat or lot number 17 or heat number? 18 A Yes. 19 Q Turning to Allegation F on page 8 of Inspection 20 Report 85-09, first of all, is there a regulatory requirement 21 that the MRR number that's referred to be transferred -- well, ' 22 I better back up and ask you this question. At what point in i l0 i i I l - - - --
105 1 time does there have to be an MRR number on safety-related 2 construction materials as they're incorporated into a nuclear 3 power plant? 4 A Until they are assembled into a component. 5 Q All right. Once the component is installed, there 6 need be no number physically on the component, is that r 7 correct? 8 A The component itself is identified. 9 Q Now turning to page 259 in Mr. Puckett's deposition 10 -- if you could help the witness out, Mr. Berry -- if you 11 would just read to yourself Mr. Puckett's further explanation 12 of his concern, I would have a few questions. ( 13 A Starting at that line?
)
14 Q Yes. 15 (Witness perusing document.] 16 Now, could you just describe for me the sequence by 17 which an MRR number was maintained on, let's say, the weld rod 18 until it was incorporated into a component by L.K. Comstock? 19 A Well, in a weld rod I believe they used -- in the i J 20 case of weld rod, the heat number or lot number was utilized l 21 to maintain it. On other material such as unistrut and 22 whatever, the materials used to fabricate a hanger, the MRR
106 1 number was applied upon receipt inspection and maintained 2 until fabricated into the component or hanger was taken into 3 the field to be constructed in the field, utilized in the 4 field. 5 Q And that, in your judgment, met regulatory 6 requirements of 10 CFR.50 Appendix B? 7 A Yes. 8 Q With respect to ASME code work, are there greater 9 requirements with respect to traceability? 10 A Yes. 11 Q What is required with respect to ASME code 12 materials? ( ) 13 A Well, ASME section 3 requires traceability of the 14 weld materials to be maintained throughout. And that usually N 15 is controlled by use of an'Mel data form where the materials 16 are put into the -- either joined together or recorded -- 17 Q On the form? 18 A On this form. And kept as part of the quality 19 documentation. 1
; 20 Q Having looked at page 259 of Mr. Puckett's ,
1 21 deposition, do you have any opinion as to whether or not ha 22 was describing an ASME traceability procedure rather than a I O
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107 1 non-ASME procedure? 2 A I believe that he was making reference to procedures 3 that dare utilized at Zimmer, which were different than that 4 of Braidwood, which at Zimmer their procedures required them 5 to maintain traceability by use of heat numbers on materials 6 and transfer of heat numbers on materials. 7 Q Was this a requirement at Zimmer for non-ASME work 8 as well? 9 A Yes. 10 Q Was this a requirement that was a part of the 11 procedures for the constructor at Zimmer? 12 A Yes, that was their requirement. That was their ( ) 13 methodology of maintaining traceability of materials. 14 Q All right. Now, did you have occasion to inspect 15 the material traceability procedure at the Zimmer plant? 16 A I did some inspections of material traceability at 17 Zimmer, yes. 18 Q Did you from time to time during the course of those 19 inspections determine that they were not following their 20 procedure? 21 A Yes. 22 Q Now, if you look at page 260 of Mr. Puckett's l l
108 1 deposition, he contrasts your approach at Zimmer and your ( I 2 approach to what he characterizes as the same problem at 3 Braidwood. My question to you is what were the differences 4 between the Braidwood and Zimmer situation, if any? 5 A The difference is that at Zimmer their procedures 6 required them to maintain traceability in accordance, i 7 utilizing heat numbers. At Braidwood a different method is 8 employed which la -- also meets the requirements. 4 9 Q Returning for just one second, Mr. Schapker, to NCR 10 32-75, which I believe is Schapker Deposition Exhibit 4, 11 before I showed you the document today, had you had occasion 12 to review the NCR in its present form with the closecut as 13 indicated? l O)
\~
14 A No. No, I didn't.
- 15 Q Okay. Based on what I know has been a rather 3
16 cursory review, do you believe that L.K. Comstock acted 17 responsibly and appropriately in its disposition of that NCR? 18 A It appears it has, yes. 19 Q Let's return now to Inspection Report 85-09, 20 Allegation G. Excuse me. i 21 MR. MILLER: I would like the reporter to mark as l 22 Schapker Deposition Exhibit 8 for identification L.K. Comstock i l l O 1 --_ . _ _ . - - - . - _ . - _ - - . - . _ . - . - - . - - . - _ _ - _ _ _ - -
l l 109 1 & Company Nonconformance Report 34-23, which bears the date in _- 2 the lower right-hand corner, a handwritten date, of May 24, 3 1985. 4 [Schapker Deposition 5 Exhibit No. 8 marked 6 for identification.] 7 BY MR. MILLER: 8 Q Mr. Schapker, first of all, did you review NCR 9 34-23, in the form that I have shown it to you, prior to the 10 time that you wrote your inspection report? 11 A Yes. 12 Q Part of this allegation is that when the procedure () 13 was requalified, that quality control did not participate by 14 observing the making of the weld coupon qualifying procedure. 15 MR. GUILD: The statement is not that it was 16 requalification. 17 MR. MILLER: I am sorry. I didn't mean to imply 18 that it was. If I said that, I misspoke. 19 BY MR. MILLER: 20 Q The allegation doesn't speak as of a date in time, 21 but in order for Mr. Puckett to have made the allegation, 22 let's assume for purposes of the questioning that it took o
110 1 place during -- that he observed this during the time he was 2 employed at Braidwood. In the NRC review portion of your 3 inspection report, you state that you interviewed the QC 4 inspector who was responsible for the surveillance of the l , 5 PQRs. My first question is do you recall the name of that i ! 6 inspector? 7 A No, I do not. t i 8 Q When you interviewed this inspector, do you recall j 9 whether you asked him about his participation in the making { 10 or in observing the weld coupon in the summer of 19847 j 11 A No, I didn't question him as to when it was ! 12 performed.
- () 13 Q Did you inquire whether this inspector was the
, 14 inspector who was supposed to have observed the making of this 15 weld coupon in the summer of 19847 j 16 A No. I questioned the inspector as in asking if he f l 17 had witnessed the making of these coupons to qualify the 18 procedure. The time period had no bearing. i l 19 Q Maybe you can help me. Could you tell from NCR 20 34-23 when the test coupons that are the basis for qualifying { 21 the procedure were done? l i 22 A It appears to be February of '85. O
111 1 Q In your review, Mr. Schapker, did you see any
,2 earlier welding procedure qualification test records for an 3 earlier date?
4 A No, I didn't see any others. 5 Q Mr. Schapker, based on your review of NCR 34-23, did 1 6 Comstock respond appropriately to the nonconforming condition 7 that was identified in that NCR? 8 A Yes, they did. 9 Q In connection with this allegation, when you 10 interviewed Mr. Puckeht, did he tell you about his experience 11 that in contacting the engineering department and telling them 12 the types of materials and the thicknesses of materials 13 that were needed to qualify this new procedure, and then -- 14 well, rather than have me paraphrase it, if you would look at 15 the bottom of page 261 and the top of page 262 of 16 Mr. Puckett's deposition, did Mr. Puckett describe the events 17 that are reflected on pages 261 and 262 of his deposition to 18 you? 19 A No. 20 Q Did you see any evidence, Mr. Schapker, in your 21 review of the documentation that there had been a 22 requalification of this weld procedure prior to the date that O
112 1 is reflected in the documents that are attached to NCR 34-23, 4 2 Schapker Deposition Exhibit 87 3 MR. BERRY: I'm sorry, I didn't get the question. 4 BY MR. MILLER: 5 Q In your review of documents at the site in 6 connection with your investigation of Mr. Puckett's 7' allegations, did you see any documents that indicated that 8 this procedure had been requalified prior to the date that is 9 shown in Mr. Schapker Deposition Exhibit 8, I think you said 10 in February of 1985? 11 A No. 12 Q All right. Let's proceed to Allegation H. (' C} 13 THE WITNESS: May we take a break? 14 MR. MILLER: Oh, sure, absolutely. Let's take a 15 five-minute break. 1 16 [ Recess.] 17 MR. MILLER: Back on the record. 18 BY MR. MILLER: 19 Q Mr. Schapker, I would like now to turn, as I said, 20 to Allegation H. First of all, did Mr. Puckett identify for 21 you any of the welder qualification records that he believed 22 had inconsistencies which rendered the qualification
- O
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i 4 113 1 indeterminable? 2 A Personally, no. Through the information I received 3 through the Region and the previous testimony to the NRC, yes. 4 Q All right. Included in that information was this 5 handwritten material which has been previously identified as 6 Puckett Deposition Exhibit 2. Correct? 7 A Yes. 8 Q All right. When you went to make your review of a j 9 random sample of 75 welder qualification records, did you pick 10 any from the list that Mr. Puckett had put together, which is, 11 as I say, Puckett Exhibit 2? I 12 A No, not in the random sample. ( ) 13 Q In addition to the random sample, did you review the 14 qualification records of welders identified by Mr. Puckett in 15 his handwritten document? 16 A Yes, I did, i [ 17 Q All right. Where is that reflected in your 18 inspection report, sir? Is it the last sentence on page 97 19 A Yes. 20 Q All right. So that in fact ycu reviewed many 21 qualification records, more than just 75. It's the 75 plus 22 the ones identified by Mr. Puckett. Correct? O 1 l l_ _. . ,. , -
. _. . - = . .= _ _ - _ ._
114 1 A Right. That's right. 2 Q Do you have a total number? 3 A No, I didn't add them up. It would be the 75 plus 4 the ones that the alleger supplied. 5 Q All right. Now, there is also a reference there to ! 6 NCR 47.10. 7 A Yes. 8 MR. MILLER: I ask the reporter to mark as Schapker j 9 Deposition Exhibit 9, L.K. Comstock NCR 37-10. It bears a 10 date on it in the lower right-hand corner, in handwriting on 11 the first page, of April 29, 1985. 12 [Schapker Deposition ( 13 Exhibit No. 9 was marked 14 for identification.] 15 BY MR. MILLER: + 16 Q Having looked at Schapker Deposition Exhibit 9, l l 17 I ask you first whether the NCR in the form you have it before 18 you is the same number pages and the same condition as when 19 you reviewed it in connection with your investigation of 20 Mr. Puckett's allegations? l 21 A Yes, I believe it is. 22 Q All right. Can you tell by looking at the list of 4 O i l
- L _
115 1 welders on pages 3 and 4 of the exhibit -- it's actually page
) 2 2 of 4 and --
3 A Yes. 4 Q -- following -- whether any of these individuals 5 were individuals whose files you reviewed in connection with 6 your investigation of Mr. Puckett's allegations? 7 MR. BERRY: What are those pages? 8 MR. MILLER: Well, it's typewritten pages that start 9 with a list of welders. l 10 THE WITNESS: 2 of 4, 3 of 4, and 4 of 4? t 11 BY MR. MILLER: l 12 Q Yes, sir. {} 13 A Yes, I believe some of them were. l 14 Q Now, what is your understanding, Mr. Schapker, of 15 what Form 88 is that is referred to NCR 37? 16 A Form 88 is Comstock's form for indicating the 17 qualifications of welders and the tests that they've performed l 18 to become qualified. 19 Q Now, can you recall, sir, whether you identified any 1 20 other discrepancies in welder qualification forms, minor 1 l 21 or not, other than the three that are identified in NCR 37-10? 22 A Yes, there were some other discrepancies. ! (m) s-
116 1 Q What was the nature of the discrepancies that you 2 observed? 3 A They're described within my review here. 4 Q The white-out and so on? jg, Ern3T 5 A Yes. White-out of ECDs repl(ced A with L.K. Comstock 6 as the incorrect changes in material types A-36 for A-106. 7 Signature is not dated. Type of electrode not documented. 8 Q First of all, do you believe that the disposition of 9 the discrepancies shown in the next-to-the-last sheet of 10 Schapker Deposition Exhibit 9 is appropriate for the types 11 of discrepancies that were discovered? l 12 A Yes. 13 All right. ( Q Now, I think discrepancy number 1 is 14 more or less self-explanatory. Let me just turn for a second 15 to-discrepancy number 2. Does the Form 88 both indicate the 16 type of material -- that is, plate or pipe -- and the grade, i l 17 if you recall? 18 A Yes, I believe they do. 19 Q Do you know whether there were any qualification 20 tests that were performed on A-106 pipe? 21 A Any welder qualifications tests performed on -- 22 Q Yes. i O l l
k 117 1 A E.C. Ernst, the previous contractor, performed 2 qualifications on 106 pipe. 3 Q Now, in Mr. Puckett's deposition he says that once 4 again at Zimmer these same types of discrepancies in welder 5 qualification records were characterized by you as a category 6 3 level item of noncompliance -- well, he didn't say the same, 7 he said similar errors and inconsistencies. 8 MR. GUILD: Do you have the transcript -- 9 MR. MILLER: Yes. 10 BY MR. MILLER: 11 Q Page 269. Result in the conclusion that welder 12 qualifications were indeterminable. Do you see that? I ( ) 13 believe your counsel has the deposition transcript. 14 Did you have occasion to review, Mr. Schapker, the 15 welder qualification records at the Zimmer facility? 16 A Yes, I did. 6 17 Q And were there, in fact , as Mr. Puckett states -- or - 18 in response to a question agreed -- that there were "similar 19 errors and inconsistencies"? i i
- 20 A Yes, there was. !
t 21 Q And is there -- 22 A They were of a different nature, though. l l l O l n--.--- , . - - . - , , - - n-.-, , - - - -
----n, - , , , - - - , - , - , - - --
118 1 Q What was the difference in nature? 2 A Well, in the inconsistencies I encountered at the 3 Zimmer project, there appeared to be changes to the welder 4 qualification records which impacted on the qualification of 5 the welders. 6 Q Can you describe or give us an example of the type 7 of change to which you just referred? i 8 A Well, as an example, in one case, in some of the 9 cases that we reviewed there, the welder qualification record 10 indicated that a certain thickness coupon was welded by a 11 welder -- to the welder qualification record which made it 12 appear that the welder had actually welded to the heavier-weld 13 thickness. 14 Q What would the effect of such a change be on the 15 welder's qualifications or the -- 16 A Well, this would enable the welder to weld to a 17 thicker member than he was qualified to weld on. 18 Q Did you see any examples of those types of changes 19 in your review of the records of Braidwood? 5 20 A No, I did not. 1 21 Q You assessed in Inspection Report 85-09 an item of 22 noncompliance with respect to this issue, did you not? O F
119 1 A Yes. i 2 Q And I believe it's characterized as a Severity Level 3 5 violation. Correct? 4 A Yes, it is. 5 Q Mr. Schapker, what is the status of that item of 6 noncompliance, if you know? 7 A The status, it has not been reviewed for -- we have 8 not reviewed the noncompliance to see that everything has 9 been satisfactorily completed. The reply from the licensee at 10 this point stated that corrective actions will be completed by 11 a certain date, and that date has not -- I believe it was 12 March 31, so we haven't completed our review of the corrective 13 action. 14 Q Is NCR 37-10, which is Schapker Deposition Exhibit 15 9, a part of the corrective action? j 16 A No, that would not be. l 17 Q Do you know what the nature of the corrective 18 action is going to be or is proposed? 19 A Yes. The licensee responded to the notice of 20 violation and stated that the welder qualification records 21 will be reviewed, rereviewed, and corrective action 22 implemented during that review. I O d
120 1 Q Do you understand that it's going to be a review () 2 beyond that which is documented in NCR 37-10? 3 A Yes. 4 MR. GUILD: Could I just ask while it's fresh, is 5 that a written response that's been transmitted by Edison to 6 the NRC? 7 MR. BERRY: Well, according to the inspection report 8 itself, it states that a written response is required.
- 9 THE WITNESS: Yes, it is.
10 MR. GUILD: I guess I would ask if we could have a 11 copy made available of whatever Edison has supplied the
- 12 agency.
13 MR. MILLER: Sure. ( ) 14 BY MR. MILLER: 15 Q All right. I would like to go on to Allegation I. i 16 There appear to be a number of different allegations, or at 17 least different aspects of the same allegation. Would you 18 just describe briefly for us what the basis for a welder i 19 qualification is? Is it -- well, let me ask you this: Is it 20 the AWS, is a welder qualified to the AWS code? 21 A Yes. L.K. Comstock qualifies its welders to the l 22 requirements of the AWS code. l { O
121 1 Q All right. And that code permits them to be 2 qualified to certain prequalified weld procedures, does it 3 not? 4 A Yes. 5 Q And in addition to any specifically qualified 6 procedures that a contractor may have in addition. Also 7 correct? 8 A Yes. 9 Q All right. Now, what was Mr. Puckett's concern, as 10 you understood it? 11 A As I understood it, Mr. Puckett had some concern 12 that there was no PQR, procedures qualification record, which [~) U 13 reflected that Comstock had on record for qualifying welders. 14 In other words, they had not created a procedure to qualify 15 welders. They had not tested a procedure to qualify welders. 16 Q Did you say they did not -- are you talking about 17 an actual weld procedure, as such? 18 A Yes. Yes. 19 Q Rather than the written procedure which we've 20 previously looked at, which discusses, I believe, among other 21 things, how welders are to be qualified. Is that correct? 22 A As opposed to what Comstock was utilizing in their O
122 1 written procedures, yes, 471 procedure, there was no /~ (s,T) 2 additional procedure qualification record. 3 MR. MILLER: I would like the reporter to mark as 4 Schapker Deposition Exhibit 10 for identification, Comstock 5 Procedure 4.7.1, with an effective date on the first page of 6 April 18, 1984. 7 [Schapker Deposition 8 Exhibit No. 10 was marked 9 for identification.] 10 BY MR. MILLER: 11 Q I show you, Mr. Schapker, a document that has been 12 marked Schapker Deposition Exhibit 10 for identification 13 and ask you if this is the Comstock procedure that you ( ) 14 reviewed in connection with your investigation of Allegation 15 I? 16 A Yes, it is. 17 Q Was it Mr. Puckett's assertion that in order to -- 18 A Wait a second. 19 Q I beg your pardon? 20 A I think it's a different revision date here. 21 (Pause.] 22 MR. BERRY: Is there a question pending? O
123 1 MR. MILLER: Well, I thought Mr. Schapker was b(_/ 2 trying to confirm whether or not the procedure I marked as an 3 exhibit is the one that he looked at in connection with his 4 investigation. 5 MR. BERRY: The revision referenced in the 6 inspection report a Revision 6, dated June 22, 1982. Schapker i 7 Deposition Exhibit 10 appears to be a Revision A, dated 8 9/28/83-84 and 4/18/84. They may not be the same one. 9 MR. MILLER: The Revision A's are identified on the 10 sheets -- 11 THE WITNESS: Yes. 12 MR. MILLER: -- and they essentially are deletions 13 ( from the earlier procedure. But -- 14 THE WITNESS: Yes. 15 BY MR. MILLER: 16 Q Now, Mr. Schapker, was your understanding of 17 Mr. Puckett's concern, as expressed in the first two sentences 18 of Allegation I, that there was no welding procedure 19 qualification test record comparable to, say, Attachment H in 20 Puckett Deposition Exhibit 8, which is Comstock Procedure 21 4.3.3? 22 A Yes.
124 1 Q In your judgment, Mr. Schapker, is there any b)
\- 2 provision of the AWS code that requires that there be such a 3 welding procedure specification attached to the welder 4 qualification test procedure?
5 A No. 6 Q What, if anything, did your investigation into this 7 aspect of Mr. Puckett's Allegation I indicate to you with 8 respect to his familiarity with the AWS code? 9 A Well, in this case, he apparently did not understand 10 the AWS code. 11 Q New, the next sentences of Allegation I refer to the 12 original testing of inspectors on Schedule 80 pips but the () 13 current procedure refers to tests on plate. Okay. let's 14 just stick with that one sentence for a second. 15 Now, your review of this aspect of Allegation I 16 states in the bottom of page 10, the use of pipe or plate for 17 welder qualifications meets AWS D.1.1 for the welding 18 applications by L.K.C. 19 A Yes, it does. 20 Q Yes. First of all, Mr. Schapker, do you know 21 whether or not there are any welds made by L.K. Comstock at 22 the Braidwood site that involve welds, pipe welds? O } w m-
l 125 1 A No. f% (_) 2 Q You don't know or there -- 3 A I don't know. 4 Q All right. In your investigation, do you recall 5 seeing any Comstock welds that were made to pipe? 6 A Yes, I take that back. There was a junction, 7 junction box to stainless-steel j'.:nction box to pipe. 8 Q All right. Now, just let me ask you is this correct 9 in terms of the sequence: The E.C. Ernst procedure qualified l 10 welders on the basis of groove welds made on ASTM six-inch 11 Schedule 80 pipe. Correct? 12 A Right. () 13 Q All right. What does that qualify the welder to 14 weld in terms of fillet welds? 15 A It qualifies him to weld all fillet welds within the l i 16 positions qualified. '. ! 17 Q All right. Once a welder has qualified on the i 18 six-inch Schedule 80 pipe, is it permissible under the code 19 for him to requalify on plate? 20 A Yes. 21 Q Had you observed that there was such a 22 requalification that occurred with respect to certain welders , O _ _ _ _ _ - _ _ _ __. _ _ , - _ __ - ~ - -_ _ _ _ __ _ _ . ._ __
126 1 employed by Comstock at Braidwood? Let me see if I can be 2 more specific. Looking at Puckett Deposition Exhibit 2, is 3 the -- it's the fifth sheet of the exhibit, and there is a 4 reference to welder -- the first initial is obscured, but the 5 last name is Johnson -- Number A-427. Let's just look at 6 that. And there, there was an initial qualification on 7 six-inch Schedule 80 pipe. 8 A Uh-huh. 9 Q And there is a retest on 3/8ths inch A-36 plate. 10 A Yes. 1 11 Q Based on your inspection, Mr. Schapker, is that 12 qualification appropriate -- 13 A Yes, it is. ( } 14 Q -- in accordance with the code? l 15 A Yes. 16 Q All right. Do you know whether or not there is a 17 specific provision of the AWS code which says that it is 1 18 appropriate for there to be reliance on earlier qualifications 19 when requalifying a welder? l 20 A Yes. Under AWS there is a provision for retest, AWS 21 D.l.1, retest on the requalification. 22 Q All right. Could you help me out and I am going to O l
- - _ . . . _ - - .__- _ ._. _ - , _ _ _ . _ _ . . _ . _ _ _ - . _ _ _ _ . - _ _ - - _ . - _ _ _ _ _--_~ ~ -_ ---._.--_ _-- -- _ - _ _ _ _ _ _ .
127 1 show you what has been marked as Puckett Deposition Exhibit 2 3. It's the AWS D.l.1 code. And I have opened it to section 3 5.29. And I ask you whether those provisions are the ones 4 that you referred to in your prior answer? 5 A Now, that one is retest. That's not the one I was 6 referring to. 7 5.30 describes the period of effectiveness. "The 8 Welder qualification, as specified in this code, shall be 9 considered as remaining in effect indefinitely unless the 10 welder is not engaged in the given process of welding for 11 which he is qualified for a period exceeding six months or 12 unless there is some specific reason to question the welder's 13 ability. In case 1 the requalification test may be made only 14 on the 3/8ths inch thickness." 15 Q All right. Therefore, a welder who had qualified to 16 the E.C. Ernst procedure was deemed to be qualified except 17 under the conditions that you just read under 5.30 of the 18 code. Correct? 19 A Yes. 20 Q And that would be true even if a new contractor came 21 in to perform the same scope of work that E.C. Ernst had been 22 performing? l O l l { _ _ _ . . , _ _ _ _ _ . - - _ - - - - - - - - - - - - - - - - - - - - - - ' - - - - - - ' ~ ~ - - ~ ~ ~ -
128 1 A Yes. 2 Q Mr. Puckett at page 280 of his deposition says, "If 3 the welder was qualified to weld, he could weld. These 4 procedures were compatible. But I was concerned with just 5 paper. There should have been something on this welder's 6 qualification test card that reflected that the E.C. Ernst 7 procedure was compatible to our L.K.C. 4.7.1." 8 In your judgment, Mr. Schapker, was there a 9 requirement of the AWS code or L.K. Comstock procedures that 10 should have reflected what Mr. Puckett was saying in his 11 deposition? 12 A Not that I know of. ()13 Q All right. Mr. Puckett goes on to say, again, that 14 at the Zimmer facility such a practice would have been found 15 deficient. Mr. Schapker, did you have occasion to review the 16 use of prior welder qualifications at the Zimmer facility as 17 qualifying a welder to a successor contractor's procedures? 18 A No. 19 Q All right. Allegation J on page 11 talks about 20 further welder qualification record deficiencies. Now, there 21 is a reference there in your conclusion that there was a 22 qualification of fillet welders on a half-inch plate which l O
129 l 1 complies with a certain table in the AWS code. My first 2 question is did you observe any welders' qualification records 3 which indicated that they had qualified on half-inch plate? 4 A Yes. 5 Q All right. And under Table 5.26.1 of the AWS code, 6 I take it, by reference to figure 5.22.1 that such a weld 7 qualification test provides the welder with unlimited fillet 8 weld thickness capability. Correct?
- 9 A For fillet weld, yes.
10 Q Is there some record maintained by L.K. Comstock l 11 that would record the limitation of the welder to fillet welds 12 on material of unlimited thickness as opposed to other types 13 of welds? 14 A Yes. The welder qualification record. i 15 Q And are you aware of any mechanism for controlling 16 which welder is assigned to perform welds other than fillet 17 welds, for example? 18 A [ Inaudible.] { 19 Q Pardon me? 20 (Pause.] 21 MR. BERRY: You don't understand the question, or 22 you don't have a recollection? O f
- - - - - , , - - - . . - , , .- , . , , . . - - - - - -,__-------_--.,,.---.y-,--3-- , - . , , . _ , _ , ,
-- ._ -- .- - - - . - . . - . - -- - - _ - . .- . _ . . ~ .. . __. - . . .-
130 + 3 1 THE WITNESS: I don't have a recollection right now. (~~ 2 BY MR. MILLER: 3 Q Mr. Puckett's assertion is that a welder tested on 4 half-inch plate was able to, according to comstock records,
; 5 weld unlimited thickness on welds other than fillet welds. Do 6 you recall seeing any such records in your review at the 7 Braidwood site?
i 8 A Based on my review, from the records that I reviewed
}
9 of the welder qualification records, the welders that welded l 10 unlimited fillet welds were only qualified to weld on fillet
! 11 welds that were performed on a test on a half-inch plate were , 12 reflected. So that he was qualified only to weld on fillet
() 13 welds. Did I state that right? i 14 Q okay. The next portion of Allegation J is the i 15 testing on six-inch Schedule 80 pipe. The welder records show 16 an unlimited thickness range. Now, then, there is a reference 17 in the NRC review portion of your disposition of this 18 allegation that when you interviewed the alleger for 19 additional details, that he stated that the thickness of the 20 unistrut was approximately 0.105 inches. 21 My question, Mr. Schapker, is was Mr. Puckett's 22 concern expressed to you as the fact that these welders were t l l l l l E.
131 1 welding unistrut material less than .187 inches thick? O k_) 2 A Yes. 3 Q Did he express to you any concern that these welders 4 were welding pipe that had less than .187-inch thickness? 5 A No. 6 Q Now, is the unistrut a pipe or is it a different 7 shape? 8 A It's a structural material utilized to support cable 9 pans, cable trays. It's the -- 10 Q Now, you go on to discuss that the AWS code omitted a footnote in its 1975 version which they picked up in the 11 12 1976 version.
- 13 A Yes.
14 Q Do you know whether the footnote appeared in the 15 1974 version of the AWS code? 16 A No, I don't. 17 Q Calling your attention to Puckett Deposition Exhibit 18 3, Table 5.26.1, I just call your attention to the fact that 19 somebody has written in handwriting a 3 in the line item, the 20 second line item towards the bottom of the page, that's 21 entitled " Groove." 22 I ask you, quite apart from this handwriting, if O V
132 1 that is where the footnote 3 ought to go which would indicate 2 that a welder who performed a groove weld on six-inch Schedule i 3 80 pipe would be eligible to perform welds on unlimited 4 thickness of fillet welds? 5 A Yes. 6 Q Now, how did ascertain, as set forth in the last 7 sentence on your NRC review of Allegation J-2 in Report 85-09 8 that the welds utilized on unistrut material in the 9 installation of cable pan are fillet welds? 10 A By observation of the welds themselves. 11 Q All right. Now, in your conclusion you state that 12 the purpose of the welder qualifications is to assure that the ( } 13 welder is capable of producing sound welds within a welding 14 process position and thickness. And you go on to say that a i 15 welder who qualifies under six-inch Schedule 80 pipe, groove 16 weld demonstrates his ability to perform fillet welds. 17 On what do you base that conclusion, Mr. Schapker? 18 A I base it on the code itself, the AWS code. 19 Q Based on your experience -- 20 A Yes. 21 Q -- is that additional support for the conclusions 22 found here? O
133 1 A Yes. , 2 Q Now, what does your investigation with respect to 3 this Allegation J-2 indicate, if anything, regarding 4 Mr. Puckett's familiarity with the AWS code? 5 A Mr. Puckett appeared to be very observant to detail 6 on AWS code, but probably missed the overall intent in this i 7 area. 8 Q In your judgment, Mr. Schapker, was this discrepancy 9 in the welder qualification records to the AWS D.1.1 1975 code 10 a matter of any safety significance? 11 A No. 12 Q All right. Allegation J-3 talks about the fact that 13 ( ) welders that perform on one or more positions in their welder 14 qualification tests took only one test on their new testing. 15 Now, I take it that the code permits one test on retesting, 16 provided there is some training before the retest. Correct? 17 A That's correct. i 18 Q Were you able to ascertain whether there was in fact 19 any training given between the original test and the retest? 20 A No. 21 Q Did you ask? 22 A Did I ask? i i l 1 1 !
134 1 Q Did you ask whether any such training was given? 2 A I was reviewing records, welder qualification 3 records, and not actual welder qualifications. 4 Q So, on the record, there was no documentation of any 5 training that you were able to observe? 6 A Right. 7 Q Is there any requirement in the code or Comstock 8 procedures that such training be documented? 9 A No. 10 Q Now, once again, Mr. Puckett at page 285 of his 11 deposition contrasts the situation at Braidwood with what he i 12 understood the situation to be at Zimmer. Now, my question, ( ) 13 Mr. Schapker, is whether or not in your inspections at Zimmer 14 you had any occasion to review the documentation of further 15 training after a welder had failed a specific welder 16 qualification test in a certain position? , i 17 A I don't recall any deficiencies in that area at 18 Zimmer. 19 Q All right. Turning to Allegation 4, Mr. Schapker, 20 subparagraph J in 85-09, your conclusion, on page 14 of Report 21 85-09, is that the allegation in effect was substantiated. 22 A Yes. r i O
- _ _ . _ _ _ - - __ -. . - _ = - . . . .-- - ._ - - - - - . . ._- _ __ - . ! 135 l 1 Q Was this error in the welders qualifications records 2 one of safety significance, in your judgment?
i 3 A No.
; 4 Q And what is the basis for your conclusion?
l 5 A The basis for my conclusion that it wasn't is that i 6 there were supporting documents which clearly demonstrated 7 that this test was performed in accordance with the total 8 requirements. 9 Q Nonetheless, this was another example of a Severity 10 Level 5 item of noncompliance that you assessed in Inspection 4 11 Report 85-09. Correct? i 12 A That's right. 13 ( ) Q Now, in the course of your review of the welder 14 qualification records, had Mr. Puckett told you that he 15 thought there was falsification of the records? Did he use i t 16 that word? 17 A He never told me that, no. 18 Q Did that word appear in any of the materials that i 19 you were given before you began your inspections? 20 A Yes.
- 21 Q Did you ask Mr. Puckett at any point in time what he i
22 meant by the word " falsification"? 1 O
136 1 MR. GUILD: Objection. He never used the word 2 " falsification." The witness has just clearly stated that the i 3 word " falsification" was used by the author of the document 4 provided to him. 5 BY MR. MILLER: I 6 Q So he never discussed the word " falsification" with i 7 Mr. Puckett? 8 A Not to my recollection. 9 Q Did you, in the course of your inspection, determine 10 whether there had been any intentional changes or alterations 11 to records? 12 A There were changes, yes, as demonstrated earlier ( } 13 in the -- they were -- but they were not -- I qualify that, i 14 that the changes were not significant in that they did not 15 change the record so that it would not reflect the welder 16 qualifications as originally intended. 17 Q I think earlier you discussed these as clerical type 18 errors, is that correct? 19 A Yes, I think one of the -- as an example, the i l 20 changes where they changed the A-106 to A-36, and changes of l 21 that and deletions or the white-out of the E.C. Ernst to put 22 in L.K. Comstock. Those type of changes. I observed no
137 1 changes of essential variables of the welders' qualifications. 2 Q And the essential variables is a term of art for 3 welding qualification, is it not? l 3 4 A Yes. 5 Q That is, those are the parameters within which a 6 welder must operate in order to create quality welds, correct? 7 A Yes, that's a true statement. 8 Q All right. Turning to Allegation K-2, this is the i
- 9 face bend and route bends on one-inch thick plate material.
10 You found that the records, I take it, from one welder that i t l 11 indicated that face bends and route bends had in fact taken j 12 place? l 13 A ( ) One of the records that the alleger supplied 14 indicated that one welder had -- that he observed had this ! 15 deficiency where he had performed face and route bends all on ont 16 inch-thick plate. 17 Q Now, you say -- the Report 85-09 says that you I i 18 concluded from the records that the plate thickness was 19 actually 3/8ths inch plate. What records did you review to 20 reach that conclusion? 21 A That was substantiated to the review of the 22 independent testing laboratory who performed the testing on l O
138 1 quality welder coupons for Comstock welders. 2 Q Do you recall, Mr. Schapker, whether this testing on 3 3/8ths inch plate as it turned out was a requalification test? 4 A Yes, I believe that it was. 5 Q Now, in the NRC review section on this allegation 6 says, "The NRC inspector performed a random sample of 100 7 welder qualification records in addition to the samples 8 previously reviewed." Now let me tote them up. This is in 9 addition to the 75 earlier random sample? 10 A Yes. . 11 Q And in addition to the specific welder records 12 that Mr. Puckett listed on his handwritten notes, correct? ( ) 13 A Yes. They could have been repeated in the sample, 14 though, because this is a completely independent sample. 15 Q All right. I would like to turn to Allegation L on 1 16 page 16 of Puckett Deposition Exhibit 4 of Inspection Report ,t 17 85-09. Mr. Schapker, what is the code requirement for 18 traceability of a particular welder's welding -- that's not -- 19 let me back up and ask it again. Is there a requirement in 20 the AWS code that a weld be traceable to a specific welder? ! 21 A Yes. 1
- 22 Q And how did Comstock implement that requirement?
{ l l O i
139 1 A They implemented it by assigning a welding stamp to ' O'
\~- 2 the welder which the welder would apply adjacent to the welds 3 that he made in the field.
4 Q I take it from this discussion in 85-09 that 5 Mr. Puckett's allegation was correct that in that there was 6 more than one welder over time that was assigned the same 7 number. Right? 8 A That's correct. 9 Q All right. What effect, if any, did that have on 10 being able to trace a specific weld to a specific individual? 11 A It had no effect. 12 Q Why is that? () 13 A Because the master hammer log, as stated in the 14 inspection report, also recorded the time periods that the 15 stamp was issued. 16 Q What records would you have to go to to determine 17 when a specific weld was made? 18 A When a specific weld was made? 19 Q Yes, sir. Let's say there's a weld out in the field i 20 with the stamp number 23 adjacent to it. l 21 A Yes? 22 Q How would you determine which welder that had that t O
140 1 number did that weld? 2 A It could go to the weld inspection record, the WIR 3 record. 4 Q And that would tell you when the weld was made? 5 A Yes. 6 MR. MILLER: Off the record. 7 [ Discussion off the record.] 8 MR. MILLER: Thank you very much. We will resume at 9 .9:45. 10 [Whereupon, at 4:50 p.m., the taking of the 11 ' deposition was adjourned, to reconvene at 9:45 a.m., on 12 ' Friday, March 7, 1986.] 13 14 15 . 16 17 18 19 20 21 22 - ' t 1 O m . ( % 4 " 4 6 9
141 1 CERTIFICATE OF DEPONENT 2 3 I, JEROME F. SCHAPKER, do hereby certify that I have read 4 the foregoing transcript of my deposition testimony and, with 5 the exception of additions and corrections, if any, hereto, 6 find it to be a true and accurate transcription thereof. 7 8 ~
~ /
9 JEROME F. SCHAPKER 10 11 /2- 6 12 / DATE 13 *** 14 CERTIFICATE OF NOTARY PUBLIC 15 Sworn and subscribed to before me, this the /2 16 day of , 19 bb. 17 l $ufaad 20 NOTARY PUBLIC IN AND FOR 21 My commission expires: MyComminionExpire: Mar.28,199D 22 i l l l O l
l l 142 1 CERTIFICATE OF NOTARY PUBLIC 2 3 I, GARRETT J. WALSH, the officer before whom the 4 foregoing deposition was taken do hereby certify that the 5 witness whose testimony appears in the foregoing deposition 6 was duly sworn by me; that the testimony of said witness was 7 taken by me and thereafter reduced to typewriting by me or 8 under my direction; that said deposition is a true record of 9 the testimony given by the witness; that I am neither counsel 10 for, related to, nor employed by any of the parties to the 11 action in which this deposition was taken; and further, that I 12 am not a relative or employee of any attorney or counsel 13 employed by the parties hereto, nor financially or otherwise ( s 14 interested in the outcome of the action. 15 16 17 GARRETT J. WALSH 18 Notary Public in and for the 19 Commonwealth of Virginia 20 21 My Commission expires January 9, 1989. 22 O V
Shffh D O JEROME F. SCHAPKER Organization: U. S. Nuclear Regulatory Commission Region III Office Reactor Inspector
Title:
Birth Date: June 15, 1942 Education: Bachelor, Liberal Studies, University of Evansville Technical Schools (See Attachnent) Experience: 6/85 to Present Reactor Inspector, Region III - Reactor Safety Division, Engineering Branch. Section II, Inservice (ISI) and Construction Inspection / Investigations - Specialty Nondestructive Examination (NDE), Welding Technology, and Quality Assurance. (NRC) 4/83 to 6/85 Senior Resident Insp~ector, Region III - Marble Hill Site,
~
Tabb,IN. Plans, supervises, and conducts inspections and audits of construction activities, special processes O , and nondestructive examinations to assure compliance with design specifications, FSAR commitments, and rules and e regulations of the NRC. Serves as the lead NRC inspector supervising this site, represents the NRC to the licensee, state and local officials, and the news media. (NRC) 9/81 to 4/83 Senior Resident Inspector, Region II - Hartsville Nuclear Power Station, TN. Job duties the same as Senior Resident Inspector at the Marble Hill Site. (NRC) 1/80 to 9/81 Reactor Inspector, Regi_on III - Engineering Support Branch, Section II, Inservice (ISI) and Construction Inspections / Investigations - Specialty Nondestructive Examination (NDE) and Welding Technology. (NRC) 7/74 to 1/80 Senior Engineer - Nuclear Power Generation Group, Babcock and Wilcox, Lynchburg, VA. Resident Engineer at B&W, Mt. Vernon Plant, Nuclear Equipment Division (major components - reactor vessel, steam generators, pressurizers,etc.). Quality assurance duties, audits, inspections, and NDE. Also performed inspections, witnessed testing of vendor suppliers of reactor coolant pumps, valves, heat exchangers, etc., and provided technical services to the operating nuclear power facilities. (Babcock and Wilcox)
1 t O Jerome F. Schapker 2 9/67 to 7/74 Supervising Quality Assurance Representative - Department of Defense, DC'AY,~5FnWr Government Representative. Responsible for quality assurance of vendors contract
- technical requirements and establishment of QA program audit and inspection of special processes, and QC procedures in the manufacture of major navy nuclear components.
Supervision of five assistant QC representatives. to Nav-Ships QualifiedSupervisor-NDE,RT,UT,MT,PT,W 250-1500-1. 1966 to 1967 Flight Line Aircraft Mechanic, Crew Chief - Perfonned inspections, troubWhooting, repiiFiiig~and servicing multi-engined aircraft and component systems. Perfonned duties of flight engineer in flight, U. S. Air Force, Continental Air Connand, Civil Service position. (ART) 1965 to 1966 Lab Technician - Assistant research engineer, duties consisted of: preparation, testing of various material i combinations in polycarbonate plastics. Physical destructivetesting(impacts, bends,etc.). (General - ElectricCompany) Machine Operator - Grain elevator operator and general l {' . 1964 to 1965 laborer. (General Foods Corporation) 1960 to 1964 Aircraft Mechanic - Crew Chief. Perfonned inspections, trouble shooting, repairing and servicing to multi-engined aircraft and component systems. U. S. Air Force active duty. (USAF-SAC) O
,+ . . , '
Resume- J. Schapker Attach:nent Technical Courses course Title location-company course length- date Aircraft Mechanic Sheppard AFB, TX. 540 hrs. 1960 Acft. engine analysis Mtn. Home AFB, Idaho 80 hrs. . 1960 Acft. Specialist 80 hrs. 1962 Electronics Teletronic Tech.. Inst. 80 cr. hrs. 1965
- Evansville, Ind. .
Acft. Flight Engineer Bakalar AFB, Indiana 240 hrs. 1966 Quality Assurance DCASD, Indianapolis 80 hrs. 1967 Specialized training Knolls Atomic Power Lab. 80 hrs 1967 in Nuclear Components Schnectady, N.Y. Statistical Quality DCASD, Indianapolis 80 hrs. . 1968 Control Optical Alignment Babcocks Wilcox Co. 40 hrs. 1968 Navy Nuclear Nondest- ' Knolls Atomic Power Lab. 80 Hrs. 1968 ructive testing Specialized Navy Nuclear Welding Knolls Atomic Power Lab. 80 hrs. 1969 O Advanced Ultrasonics Bettis Atomic Power Lab. . 40 hrs. 1969 f'
. ACN-4 Pittsburgh, Pa.
Special training in DCASR, Chicago 120 hrs. . 197d Nondestructive testing ASNT Certification Level II RT,UT,MT,PT,VT BabcockCWilcox Co. 120 hrs. . 1974 Recertification 40 hrs. 1977 Fundamentals of Boiling
" ** * ~
US NRC, Bethesda, Md. 40 hrs. . 1980 Quality Assurance US NRC, Atlanta, Ga. 40 hrs. 1980 Welding Technology US NRC, Ohio State University 80 hrs. 1980 and Codes Fundamentals of US NRC, Bethesda, Md. 40 hrs. 1980 Inspection R['act US NRC, Bethesda, Md. 40 hrs. 1980 Nondestructive Examina-tion, refresher US NRC, Rockwell International s. ' 1981 Electrical Technology and Codes US NRC, Chattanooga, Tn. 80 hrs. 1982 [ [*, ,
- U US NRC, Portland Cement Asse.
Skokie, m. 80 hrs. 1982
sky b f b Brai 3.14 QA SECT L. K. COMSTOCK & COMPANY
~
10 4.3.14
, WJUAL-SFmmn METAL ARC-WELDING OF STAINLESS STEEL PAGE DATE 1 07/18/80 2 09/10/80 3 07/18/80 4 07/18/80 5 09/10/80 6 09/10/80 ,
7 07/18/80 8 09/17/80 9 07/18/80 10 09/10/80 Fem 112 09/10/80 Fem 110 09/10/80 Fom 111 09/10/80 APPROVAIS: L. K. COPSIOCK & COMDANY, DI DATE f-/8 -[C Q. C. Manager L. K. COMSTOCK & COMPA!E, INC. / 8 2 DATE <P-/f-[O Prof Maruyser L. K. C0f'S"0CK & COMPMU, INCH [/ U DATE_ F.-/d o jgyfRRATIOMunu REV. 9/17/80 o*52 - .
Braidwood 4.3.14 L. K. COMSTOCK G COMPANY. INC. QA SECT 4.3.14 MANUA6 SHIELDED ETAL ARC-WELDING OF STAINLESS STEEL 1.0 m.r: MACE i 1.1 L. K. Comstock QC Fanual 1.2 AWS D1.1-75 1.3 ASME SA 240 1.4 SFA 5.4 (Electrodes) 1.5 S&L STD 62790 2.0 PURPOSE / SCOPE 2.1 To provide instruction for welding of stainless steel, type 304 2.2 To provide instruction for qualification and certification of welders perforcing this procedure. - 2.3 To provide a record set reflecting welder activity and qualification currency, as well as weld inspection per checklist.
^ 3.0 PROCEDUEE h" Welders shall be qualified for this procedure per Procedure 4.7.1 of this manual.
3.1 BASE METAL / FILLER METAL 3.1.1 Base Metal shall confom to ASME SA240 Type 304 welded to SA312 Type 304 3.1.2 Filler Metal shall confom to E308-16 or E309-16, AWS SFA 5.4 3.1.3 Electrodes used shall conform to SFA 5.4, and may be 3/32". 3.1.4 Electrode storage shall be as detailed in LKC QC Fanual l Procedure 4.3.10. 3.2 WELDING CURPS C 3.2.1 Current for 3/32" electrodes shall be 47-63 DC Reverse polarity, at 24-26V. o FORlHf0 EON PREPARED APPROVED REVISED TITLE O RIG. DATE REV.DATE PAGE RAB RR PROCEDURE 7/18/80 1 of 10 QAS4
L. K. COMSTOCK Q COMPANY, INC. Braidwood h.3.14 QA SECT
- r~h 3.3 POSI3 0"3 3 3.1 Welding shall be performed in the 5G or 5F positions, I with procedure qualification in 5G position. Welder i perfomance qualification shall require 50 position only, per F15;ures attached.
3.3.2 Welders wno weld on stainless steel base metal shall I be qualified with stainless steel base m tals only. (See para. 5.16.1.1 in AWS D1.1-75.) 3.4 J0DE ESIGN 3.4.1 A. joint welding procedure specification for groove I welding of pipe or tubing qualified in accordance with AWS D1.1 Section 5.10,1 shall also. constitute _orocedure qualification for fillet welding pipe or tubing in the same position.(per AWS D1.1-79, cara. 5.10 3.3), 3.4.2 Fillet Weld procedures and welders qualified with the I use of a backing strip are not qualified to weld without backup. Root must be back-gouged or ground to sound metal and back welded. If backing strip is removed (using method per 3 18.2).
/Q V
3.5 JOIMT PREPARATION & CEANING 3.5.1 Joints may be prepared by machining, oxygen cutting, chipping or grinding. Roughness of oxygen cut surfaces shall not be greater than that defined by USASI surface roughness value of 1000 for material up to 4" thick. Cut surfaces and edges shall be left free of slag. 3.5.2 Prior to fitting, the surfaces of joints are to be cleaned free of rust, scale, paint, or other foreign matter. The metal shall be cleaned back from the joint edge sufficiently to insure the welded joint will not become contaninated. Cleaning may be done by wire brushing, grinding grit-blastirg, or other suitable mans. (Scraping, filing, sawing, etc.) 3.5.3 Members to be welded shall be brought into correct alignment and held in position by bolts, clamps, wedges, guy lines, struts, tack welds, or other suitable devices until welding has been ccrnpleted. 3.6 JOUE ELDING ETAILS 3.6.1 'Ihe arrargement of weld passes shall be as shown in
'igure 1 (attached).
n 3.6.2 Welding current may be adjusted per ranges listed Section PREPARED APPROV ED REVISED FOR HIFORMATION O TITLE O RIG. D A TE REV.DATE PAGE RA3 RR RAB PROCEDURE 7/18/80 9/10/80 2 of 10
~ g.
L. K. COMSTOCK & COMPANY. INC. Braidwood u.3.14 QA SECT 3.0 PROCEDURE continued 37 WELD DETAIL AND TEC EIQUE
, 3 7.1 Special technique for plug and slot welds I (Ref. Appendix AWS Dl.1-75) 3.7.1.1 In making plug welds the following technique may be used:
3.7.1.2 For welds to be made in the flat position, the arc is carried around the mot of the joint and then carried along a spiral path to the center of the hole, fusing and depositing a layer of weld metal in the root and bottom of the joint. 'Ibe arc is then carried to the periphery of the hole, and the procedure repeated, fusing and depositing successive layers to fill the hole to the depth required. 'Ihe slag covering the weld metal should be kept molten, or nearly so, until the weld is finished. If the arc is broken, the slag must be concletely removed before restartdag the weld. 3.7.1.3 For welds to be made in the vertical position,
/G the arc is started at the root of the joint,
{) at the lower side of the hole, and carried upward along a zig-zig path, deoositing a layer about 3/16 in, thick on the exposed face of the inner plate and fused to it and to the side of the hole. After cleaning the slag from the weld, other layers should be similarly deposited to fill the hole to the required depth. 3.7.1.4 For welds to be made in the overhead position, the procedure is the same for flat position weldirs except that the slag should be allowed to cool and should be completely removed after depositirs each successive layer until the hole is filled to the required depth. 3.7.1.5 Slot welds may be made with a technique similar to that specified above for plug welds, except that i if the length of the slot exceeds three times the ! diameter, or if the slot extends to the edge of the part, the technique specified in 3.7.1.4 ! should be followed for welds made in the flat position. 3.8 Weaving may be used on each weld pass up to 5 diameters of the l electrode core wire. ? l
\
') 3.9 Cracked or defective tack welds shall be removed before the first pass is deposited. , .' ,, :
,n ment 11iTIDH ORIY grirg Q;q g Patranco appaovco nevisto *at s v au. o AT E PAGE l
! RAB RR >AO'CEDUR E 7/18/80 3 of 10
L. K. COMSTOCK Q COMPANY. INC. Braidwood 4.3.14 QA SECT
' (7 3.0 PROCEDURE Continued
(\_/ 3.10 Each pass shall be cleaned of all slag or other matter before deposition of additional passes or at start-stop areas for i change of electrodes. 3.11 Slag and spatter are to be removed frcrn all finished welds. 3.12 Undercut shall not be more than 0.01" deep when weld is transverse to the prinary stress in the part that is undercut, or not more than 1/32" when weld is parallel to the primary stress in the part that is undercut. 3.13 Welds shall be free frcrn overlap. 3.14 Arc strikes outside permanent weld area shall be ground to a smooth contour. 3.15 BACK-GOUGING OF FULL PDETRA" ION JOUTTS 3.15.1 All full penetration joints are to be back-gouged to sound metal before welding the reverse side. 3.16 PREHEAT
.% 3 16.1 No preheating shall be required for base netal to 3/4" thick, except that when the base metal temperature is (N'd) below 320F. The base metal shall be heated to at least 70 F., and shall be maintained at this minimum tencerature during welding.
3.17 QC DEPECTION 3.17.1 QC Inspection shall be performed per Section 4.8.3 of this manual. i l 3.18 WELD REPAIRING AfD CORRECTION 3.18.1 Any weld requiring repair of undercut, or for undersize shall be welded in accordance with the general provisions of this instruction. ( 3.18.2 The removal of weld metal or portions of the base mtal l may be done by machining, grinding, chipping, oxygen gouging, or air Carbon-are gouging and in such a mnner that the remaining weld metal of base metal is not nicked i or undercut. Defective portions of the weld shall be removed without substantial renoval of the base metal. Additional weld metal to conpensate for deficiency in size , shall be deposited using an electrode preferably smaller l than that used for naking the original weld, and prefer-l ably not nere than 3/32 in. in diameter. The surfaces Q shall be cleaned thoroughly before welding. PREPARED APPROVED REVISED cnn IEnPMATnN MlY l yl { TIT 5515 %F1 L N. dAT E" " #EE DAT E' - PAGE RAB RR PROCEDURE 7/18/80 4 e~10 nm
Braidwood 4.3.14 L. K. COMSTOCK Q COMPANY. INC. QA SECT 3.0 PROCEDLUE Continued
'(]
b 3.18.3 Defective or unsound welds or base metal shall be corrected either by removing and replacing the entire weld, or as follows: s 3.18.3.1 Overlap or excessive convexity: Reduce by remval of excess weld metal. 3.18.3.2 Excessive concavity of weld or crater, undersize welds, undercutting: Clean and deposit additioral weld metal. 3.18.3.3 Excessive weld porosity, excessive slag inclusions, incccolete fusion: Remve defective portions and reweld. 3.18.3.4 Cracks in weld or base metal: Ascertain the extent of the crack by use of acid etching, magnetic particle inspection, or other equally positive means; remove the crack and sound metal 2 in. beyond each end of the crack, and - reweld. Cracks extending into the base metal shall require the attention of the engineer prior to repair. 3.18.4 Me:ters distorted by welding shall be straightened by I mechanical means or by carefully supervised application of a limited amount of localized heat. The temperature of heated areas as measured by approved methods shall not exceed 3500 . Parts to be heated for straightening shall be sube*antially free of stress and frcan external forces, except those stresses resulting from mechanical means used in conjunction with the application of heat. 3.19 QUALIFICATIO!E 3.19.1 Welders shall be qualified in accordance with AWS D1.1-75 Part SC.(Section 4.7.1 of this mnual) 3.20 Upon completing weld, the welder shall stamp his assigned symbol adjacent to the weld. 4.0 EQUIP!E!!T 4 A 1 ed 5.0 FORE 5.1 Fom 112 - Welder & Welding Operator Qualification Test Record, {n) attached. PREPARED APPRovEO REvlSED TITLE O RIG. D ATE REV.DATE PAGE RAB RR RAB PROCEDURE 7/10/80 9/10/80 5 ofl0
L. K. COMSTOCK & COMPANY, INC. Braidwood 4.3.14 QA SECT 5.0 POF}E 5.2 Fo= 110 - Welding Procedure Qualification Test Record, attached.
, 53 Fom 111 - Joint Weldin6 Procedure, attached.
6.0 AACHMOCS 6.1 The following tables and figures shall be used as approprinte to the procedure. 6.1.1 Table 1 - Minirne effective throat sizes for fillet welds. 6.1.2 Figure 2 Weld Profiles. 6.1.3 Fimire 1 Arrangemnt of Weld Passes (o v 0 FOR INFORMATIOM PREPARED APPROV ED REVISED TITLE O RIG. D ATE R E V. D AT E PAGE RAB RR RAB PROCEDURE 7/18/80 9/10/80 6 of 10
L K. COMSTOCK & COMPANY Braidvood 4.3.14 CA SECT TABE I i TABLE: MINIMJM EFFECTIVE THROAT SIZES FOR FILLET WELDS 1 BASE P.ETAL THICKNESS OF MINIMJM EFFECTIVE THICKER PART JOINED THROAT SIZE 1 IN. IN. TO 1/4 INCLUSIVE 1/8 OVER 1/4 TO 1/2 INCLUSIVE 3/16 OVER 1/2 TO 3/4 INCLUSIVE 1/4
, OVER 3/4 TO 1 1/2 INCLUSIVE 5/16 OVER 1 1/2 TO 2 1/4 INCLUSIVE 3/8 OVER 2 1/4 TO 6 INCLUSIVE 1/2
. OVER 6 5/8
. (- -
l I i l pegnange apomovgp ag vis t o vet Lg Omic,OaTE mgv. Daft paGE N E WORK INSTRUCTION 7/18/80. 7 oc io
L. K. COMSTOCK & COMPANY . QA $ECT f b (v/ s AR$
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FILLET WELD BEAD SEQUENCE HORIZONTAL PLA1:E
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BUTT WELO BEAD SEQUE!!CE AFTER ret:0 VAL OF BACXING STRIP
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RAB RR PROCEDURE g.17 80 8 ofl0
L K. COMSTOCK & COMPANY Braidwood 4.3.1h QA SECT O e WELD PROFILES g l
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I L. K. COMSTOCK O COMPANY. INC. QA SECT l o p
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TEMSDON SPECIMENS AENO SPECIME.NS . . Incation of Test Specimens on Welded Test Pipe 2 in. or 3 in. Diameter se % es W
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'mst Pipe 2 in. & 3 in. Diameter i
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{f i 1/8" Max. Face & Root Bend Specimens Test Pipe 2 in. & 3 in. Diameter
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RAB RR PROCEDURE 9-10-60 10 QA$A
L. K. COMSTOCK & COMPANY. INC. Braidwood 4.3.14 cA sect WELDING PROCEDURE QUALIFICATION 'IEST RECORD 'n t
\ /
- PROCEDURE SPECIFICATION GROOVE WELD TEST RESULTS Material Spec. AShd-A312-Type 304 Reduced-section tension test Welding process SMAW Tensile strength, psi:
Manyal or machine .rMJAL Position of welding SG 1 10,800lbs . , 90,750 PSI Filler metal spec. AWS A M 2 12,UUU lbs., 93,100 ps! Filler metal class. E309 Weld metal grade N/A Guided-bend test Shielding gas N/A Flow N/A Single or multiple pass Multiple Root Face Single or multiple arc Single 1 ACC 1 ACC Welding current Direct Reverse Polarity 2 ACC 2 ACC Welding progressionVertical Unware Preheat te::perature None Radiographic-Ultrasonic Exam. Sat Postheat treatment Hone Welder's name* Ron Vilt Fillet test results Min Size Multiple Pass Max Size Single Pass Macroetch Macroetch 1 N/A 3 N/A 1 N/A 3 N/A 2 N/A 2 N/A ._ . Laboratory Test No. N/A WELDING PROCEDURE
- p. , gi,,,,
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f 1 3/32 55 25 N/A Test Position SG~ 3" Schedule 40 Pipe' j~~ ' 2 3/32 55 25 3 3/32 55 25
- 4 3/32 55 25 -
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5 3/32 55 25 - 6 3/32 55 25 per M L , l 50 ' I.
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We the undersigned, certify that the staternents in this record are correct and that the test welds were p epared, welded and tested in accordance with the requirernents of 5B of AWS D1.1, Structural Weiding Code. Manufacturer or Contractord.d .h.^. HEE.E *' k#*b Authorired b h . . . . . . . If R WFORMAT,3N ONW PR 6ANI.Ci ' APPROVED REVISED TITLE W~4*- O RIG. D ATE REV.OATE PAGE RAB RR PROCEDURE 9/10/80 Fom 110
^" -
L. K. COMSTOCK & COMPANY, INC. Braidwood h.3.lh QA SECT JOINT WEIDING PROCEDURE PROCEDURE SPECIFICATION Material Specification ASME SA 240 tvoe 304 to A 312 tyne 304 Welding process SMAW Maaual or machine Manual Positon of welding 5G or 57 Filler metal specification AWS AS.4 or SFA 5.4 Filler metal classification E309 or E306 Flux N/A Weld metal grade Shielding gas N/A Flow N/A Single or multiple pass Multiple Single or multiple arc Single Welding current DC 47-63 Amp 24-26V Polarity Reverse Welding progression Upward vertical Root treatment N/A Preheat and interpass temperature N/A Postheat treatrent N/A WELDING PPOCEDURE _ NN "' Pen Electrod. Trevel mw & ' a- sia A m,., voia *"d y- l / N/A 1 3/32 55 25 , 2 3/32 55 25 N/A 3 3/32 55 25 !VA 4 3/32 N/A ka N-55 25 p Y N/A ' 5 3/32 55 25 6 3/32 55 25 N/A j g - I f-
-L.\.;
I This procedure may vary due to f abrication sequence, fit.up, pass sire, etc. within it.e limitation c variables given in 4B, C, or D AWS D't.1, Structural Welding Code. p Manufacturer or Contra: tor.d:.d.kofEfi29# 0# .. Authorized b ...s M t'--- J' y, 9 . .. . . . . . . .
'.. .y.. $......,h- $0....
P R E PA R E o Enn HmainTnN ON I AW5AD E I E E5eE% U !3I** *%P " *
- Y
~ObG.DATE REv.DATE PAGE RAB RR PROCEDURE 9/10/80 Feir. 111
^ 5'
L. K. COMSTOCK Q COMPANY, INC. Braidwood 4.3.14 QA SECT WELDER AND WELDING OPERATOR QUALIFICATION TEST RECORD
*O Q Welder or Welding Operator's Name. . . . .BQ0.Vilt . . . . . . . . . . . . . . . . . .ID No.Sy:Wol .93. . . . .
Welding Process...SMAW...%.... Manual........ Semiautomatic........ Machine............ Position. . . 5G. . . . . . (Vertical up) . . . (Flat , horizontal, o"erhead or vertical) . . . . . . . . Procedure Spec. 4.3.14. .& AWS.D1.1-75. . Material Spec. .ASTE. . . A312. .T 304. ' Diameter and wall thickness..(if Thickness range this qualifies........ pipe)bgtherwise joint.3 thickne
...M.....................................
FILLER IETAL Specification No..AWS.A5.4.......... Classification...............E309........ ...... Describe filler metal (if not covered by LKC specification. . . . . . . . . . .N/A. . . . . . . . . . . . Is backing strip used?................Yes........................................... Filler metal dia and brand. . . . . . . . . . 3/32. . . . . . . . . . . . . . . Gas for gas metal are . .N/A. TENSILE TEST RESULTS PIPE UELD VISUAL TES" RESULTS Visual Acc Remarks Ace Remarks Acc Visual Acc ,_ _ Test Conducted by. .L. ...K. . C.0.f
.. .GT.OC.K. . . . . . . . . . . . .Per. .. ... ...................
. . 4. 3. 14 O GUIDED BEND TEST FISUL"S (EV) ,2 est Conducted by. . . .R. i. ch.
. .Y.a.n.k.. e.ti. s. . . . . . . . . . . . .Per. . . . . . . . . .
..4......................
- 3. 14 Ozoe Result Type Result 50 Face Bend Acc 5G Root Bend Acc SG Face Bend Acc SG Root Bend Acc Test Evaluated by Pittsburgh Testing Lab . . . . . . . . . . . . . . . Lab Test No ATW.gR . rW. . . . . .
Per . . . . .b. .Q . ECE$M . . . . . . . . . . . . . . . . . . .
. B.57 n~4 o GROOVE WELD 'IST RESULTS HLLET WELD "EST RESULTS Visual ACC Visual N/A Break ACC Break WA Radiographic Acc Macroetch N/A Test Conducted by.PAquqqr.gh . hung .IA4 Lab Test No.1% ut. . . . . . . . .
per. .L .C .P.rA7.iAr. . . . . . . . . We the undersigned, certify that the statements in this recrod are correct and that the welds were prepared and tested in accordance with the recuirements of 50 or D of AWS D1.1 Structural Welding Coda. Q L. K. COIE)CK - per, f . . . . . .'. . . . . . 2~.I) ate . . k.7(.7.N . . . . b v' 2 0 0 l H E A n ta 1 Ta n n n m,. . , s ..p q: cj j U pacc enceanco apenovco acvisto yl } gi[Qg pi .p45 /IO u ECE LTF RAB PROCEDURE [om 112
^ ^ 5' __ _ _ _
L K. COMETOCK & COMPANY,INC. TN/t?$6A BPAIDWOOD 4.3.10 O f $} 4.3.10 STORAGE, ISSUE AND CONTROL OF WELDING MATERIAL PAGE REV/DATE 1 B - 05/20/83 2 C - 09/27/83 C - 09/27/83 C - 09/27/83 C - 09/27/83 , 6 10/23/78 Form #57 C - 09/27/83 Fom #63 C - 09/27/83
. Attachment "A" C - 09/27/83 I
APPROVALS: L. K. COMSTOCK & CO. , INC. N M DATE /0[.5
/'
3
- QUALITY CONTROL MANAGER L. K. COMSTOCK & CO. , INC. // DATE _//[hfQ W PR0fBCT MAN #,ER '
! L. K. COMSTOCK & CO., INC. DATE _// YROJEdf ENGINEER REV. C (09/27/83) EFFECTIVE DATE: 12/8/83 L I QAS1
g'I L. K COMSTOCX & COMPANY. INC. BRAIDWOOD 4.3.10 QA-S E CT c . a STORACE, ISSUE AND CONTROL p) i OF WELDING MATERIAL
SARGENT & LUNDY
- 1. muitwto a acetnto 1.0 REFE RENCE acnon s=e== oots con uurvt ce=rnace
'""'"5'8"*"'""""c*"""-
y.y American 'leiding Society (AWS Dl.1-75) F. A MM Mg,p 1.2 AWS AS.1 LY DATE 1.3 AWS AS.4 fg{c gg o g 1.4 AWS AS.5 l.5 Manufacturer's Technical Bulletins (Che= tron /McKay) 1.6 Calibrat. ion for Weld Ovens, Procedure 4.9.1 2.0 PURPOSE /S COPE 2.1 To provide instruction for handling, storing and issuing weld filler metal. 2.2 To provide documentation source of weld activity by material issue records. 2.3 To prevent use of unauthorized material for construction. 2.4 To list equipment requirements for welders which are under warehouse cont [ol. (/ 3.0 PROCEDURE 3.1 Classification of all weld filler metal (Electrodes) will be in accordance with ref erenced American Welding Society sections. Reference Procedure 4.10.2, section 3.1. 6 for procurement activities., , j 3.2 Electrode Storage I L 3.2.1 Welding elegtAAaew:krbe stored by Phillips Getschow Co. in hermatically sealed containers. The L.K. Comstock warehouse foreman will withdraw welding electrodes (in hermatically sealed containers) from Phillips Getschow Co. using the Phillips Cetschow Co. Stores Request Form (sample-page 6) . The stores request form will be filled out by Phillips Getschow personnel at the time of request for the electrodes and signed by-L. K. Comstock warehouse foreman. A copy of the stores request form will be retained by the L. K. Comstock warehouse foreman and given to the LKCE Inspector who shall verify that there is an MRR # and verify with CECO QA that certs are acceptable. Verification shall also include to check that the heat number is identified. When weld rod is received directly by Comstock Engineering or requisitioned f rom site contractors other than P.G. Co. , a copy of th h b MRR and/or applicable requisition will be placed in the stores reques file. The MRR and/or requisition must show traceability f rom heat nursber to MRR 'sumber. The information will be entered in a log cross referencing heat number, MRR number and description. TITLE ORIG. o ATE REV151oN PAGE PREPAREo APPRovEo AEve5ED B ECE IFD PROCEDURE 02/01/78 1 of 6. 09/20/h3
BRAIDWOOD 4.3.10 L. K. COMSTOCK O COMPANY. INC. 3.0 PROCEDURE - Continued 3.2.1 - Continued No rod will be released to the field until the MRR has been released (interim status as a minimum) by CECO Q.A. 3.2.2 Welding electrodes received by L. K. Comstock will be in the following containers: 3.2.2.1 E308/E309, E7018 - Hermatically sealed containers. 3.2.2.2 E6013, E6010 - Clean dry containers. - 3.2.3 The electrodes will be transferred to L.K. Comstock warehouse and/or tool crib for storage. When sealed containers are opened the electrode holder end of the rod will be painted for contract identification. 3.2.3.1 E308/E309 and E7018 electrodes will be placed in temperature controlled electrode storage ovens. 3.2.3.2 E6010 and E6013 electrodes will be placed in separate, " clean, dry containers. , 3.2.4 Electrodes of dissimilar chemical couposition shall not be kept in the same storage oven. A 3.2.4.1 All rod ovens and containers will be labeled to indicate the classification of electrodes they contain. 3.2.5 The L. K. Comstock warehouse foreman / tool crib attendant shall assure that the following electrode storage oven temperatures and conditions are utilized by production. 3.2.5.1 TOOL CRIB OVEN PORTABLE ROD OVEN E08/E309 + 155 to + 205 F + 155 to + 2050 F E7018 + 2500 to + 800 F + 250 to + 800 F 3.2.5.2 The temperature of the tool crib storage ovens shall be monitoted on a daily basis by the LKC warehouse . foreman or tool crib attendant for the purpose of setting the oven thermostat. A thermometer shall be placed inside the storage oven in a, conspicuous place and the temperature shall be recorded on LKC QC Form 63. Form 63 shall be located adjacent to the storage oven in open view. Form 63 shall be forwarded to L.K. Comstock QC at the end of each month for filing, (excluding Saturdays, Sundays and Holidays) . o p)RINFORg10H OHu T I TI.C o RIG. o ATE REVislON PAGE PR E PA R E D APPROVE D REVISED C ECE IFD IFD PROCEDURE 02/01/78 09 /27/83 2 of 6 0454
L. K. COMSTOCK Q COMPANY, INC. BRAIDWOOD 4.3.10 QA SECT 3.0 PROCEDURE - Continued A V) t
- 3. 2. 5.3 E308/E309 and E7018 electrodes may be removed from the portable ovens during construction activity not to exceed a period of four hours.
- 3. 2. 5.4 E6010, E6013 electrodes will be maintained at room tenperature in separate, clean dry containers.
3.2.5.5 Electrodes that show any of the following conditions will be discarded. 3.2.5.5.1 Excessive moisture. 3.2.5.5.2 Obj ectionable coating blisters.
- 3. 2. 5. 5.3 Direct contact with water.
3.3 Issuance of Material 3.3.1 The L.K. Comstock warehouse foreman or tool crib attendant , will issue electrodes only to worlanen in clean dry containers for transporting to work areas. 3.3.1.1 E7018 shall be placed in designated portable rod ovens to maintain heating requirements at a minimum range go setting of 250 F. -
\ \
V ' 3.3.1.2 E309 shall be placed in designated portable ovens to maintain heating requirements of a minimum range setting of 155 F. - 3.3.2 The L. K. Comstock warehouse foreman or tool crib attendant will issue electrodes upon receipt of a completed Filler Material Authorization, Form #57, with an authorized foreman signature. 3.3.2.1 A filler Metal Withdrawal Authorization Form will be required for each case and/or size of electrode. 3.3.3 The amount of rod issued will be recorded on the form at the time of withdrawal. 3.3.3.1 The Filler Metal Withdrawal Authorization Form #57 shall be forwarded to the LKC Q.C. Department for filing and logging in the Welding Log, Attachment "A". o. m FOR INFORMATION ON PN[ PARED APPRo v E D REVISED TITLE o RIG. D ATE REVISION PAGE ECE IFD IFD PROCEDURE 02/01/78 09/27/83 3 of 6
.A,.
L. K. COMSTOCK Q COMPANY, INC. BRAIDWOOD 4.3.10 QA SECT 3.0 PROCEDUPI I C ') 3.3.4 The tool crib attendant shall not issue any E309 or E7018 electrodes f rom the storage ovens that have not been maintained as per Paragraph 3.2.5.1 of this procedure. 3.3.5 Portable rod ovens will be energized to maintain the heat level. 3.4 Control of Weld Stubs and Spoiled Electrodes. 3.4.1 Each welder shall carry a stub pail for spent or spoiled electrodes and shall be near the work in progress. 3.4.2 The welder shall deposit all discarded stubs (unused portion of electrodes and spoiled rod) in th.e stub pail provided. 3.4.3 The welder shall discard any spoiled electrodes, using the stub pall provided. All electrodes which are soiled, wet, contaminated, oil-impregnated or unidentifiable shall be considered " spoiled" . Electrodes which have been " soiled" shall be discarded and cannot be rebaked. ~ 3.4.4 Each welder shall empty his stub pail daily, at the end of his shift or at the completion of the welding activity. All stubs and spoiled electrodes shall be deposited in a locked, uniquely identified barrel. Stub pails shall be 7 used for no other purpose. (d
\
3.4.4.1 Each foreman shall walk-down his immediate work area at the end of each shif t or at the completion of welding activity to verify that no weld electrodes, stubs, or spoiled electrodes have been lef t out in open. All stub pails shall be locked up in gang toxes or deposited in the crib (s) during the off time. 3.4.5 Under no circumstances shall any filler metal be removed f rom stub pails or the designated receptacle for use in welding. Such activity shall subject the welder to disciplinary action, as deemed appropriate by the IXC Project Manager and the LKC QC Manager. NOTE: Each welder must consider the work to be performed when withdrawing electrodes f rom the portable oven, in order to reduce waste of electrodes and to provide better control of weld stubs and spoiled material. Use of low-hydrogen electrodes, in conjunction with hot storage minimize problems of hydrogen cracking of welds. Observation of procedures will contribute substantially to weld quality by eliminating hydrogen, which may be introduced by water, water vapor, of hydrocarbons. Welders are encouraged to minimize the time between withdrawal of electrodes from heated ovens and their {} use in welding. pat ra n t o cnn lignDMATiflN f h I % # 1 57:45EI gr UudMd. 5 A t' W MviM d' ' Y
" " pact appnovto atvisto ECE C
IFD PROCEDURE 2/1/78 4 f6 (09/27/83) 0454 e
L. K. COMSTOCK Q COMPANY. INC. BP.AIDWOOD 4.3.10 QA SECT
' (] 4.0 TEST EQUIPMENT V
, 4.1 None
- 5. 'O F010iS 5.1 Form 57 - Filler Metal Withdrawal Authorization 5.2 Form 63 - Electrode Storage Oven Temperature 6.0.; SPECI AL INSTRUCTIONS 6.1 C. K. Newberg Personnel shall be responsible for the painting, marking, securing, placing, and emptying of disposal barrels. ,
6.2 For electrodes with low hydrogen coverings the following applies, E70XX electrodes that are not used within four hours, E80XX electrodes within two hours, E90XX within one hour, E100XX and E110XX within one-half hour after removal of the electrode from the oven shall be redried before use. Redrying shall consist of heating the electrodes for at least two hours at 450 F to 500 F for electrodes conforming to AWS - AS.1 or for at least one hour at 700 F to 800 F for electrodes conforming to AWS AS.S. 6.3 For over exposed welding materials more than four (4) hours, follow paragraph 6.2 above for disposition, (scrap). Q f FOR lHilMAT10li OitY t l pnEPARED APenovE D REVISED TI T L.E on to. DATE REV SiON PAGE l ECE IFD PROCEDURE 2/1/78 (09/27/83) 5 of 6 Q A %4 l
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~! LIPS, GETSCHOTY CO. .Ws STORES REQUEST vrs =o m ~ m. , u _ . . . . .. ......
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OVEN # , DAILY LOC MO:JTri: YEAR:
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ELECTRODE S' IMAGE OVEN EGRAWRE DNIE ' EFERA'IURE INITIAL _ 1
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i.L. K. C,OMSTOCK Q COfL_ .NY. INC. . B. .dwood .11.1 .
. . . j. . . ., e NONCONFORMANCE REPORT . . I t- -
L. K. COMSTOCK & COMPANY, INC. Sht. 1 !~f'2 o
~k NONCONFORMANCE REPORT NO. 3 2 7 5-~ REV. 1 DATE 11/7/85 INSPECTION CRITERIA: DWG. N/A REV. N/A SPEC. L-2700 PROCEDURE: 4.3.10 REV. D Int. OTHER N/A ITEM (S) DESCRIPTION Weld Rod Withdraval Fore 57's LOCATION N/A DESCRIPTION OF NONCONFORMANCE: NCR 3275 is being revised as follows: Form 57's, Weld Rod Withdrawal forms, had errors in docu=entation. Forms shoved heat nu=bers for E7018 electrodes and issuance of E6013, as shown on sheet 2 of original NCR 3275 In addition, there are clerical errors on the transfer of the heat numbers as noted below:
- 1) On sheet 2 of NCR 3275, original, a heat number is shown as h21 Phh61. This heat number is actually hil Ph161.
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(Cont. on Sht. 2) ORIGINATOR f DATE '
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[ ] Engineering HOLD TAG N0'S N/A N QC (A DEENED REPORTABLE PER 10CFR21 (l.KC 3.1.3) YES [ ] NO (( POTENTIAL 10CFR50.55(e) YES [ ] NO [F QC MANAGER / DESIGNEE REVIEW L DATE////<//P SYSTEM (S) rJ/A (if applicable) 3 DISPOSITION: [ ] USE-AS-IS [ ] REWORK [ ] REPAIR [ ] SCRAP .M OTHER CORRECTIVE ACTION / JUSTIFICATION: 4m )
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(,Rs.v. o) ATice4 c>F I4'.Jt.AMC) CMi=Et:34:=LTic44 ATTM MED TO C A T W-C) W 2h.84. AMisch 11 E.E J/i
/ ATTN uRD m , caem e4o. 85-o2.-c6 o4 Atan w OF TWCT61 ashES%*Me.
o# F%.LE2. ACTION TO PRECLUDE REPETITION: WVESE:me.TioM.
/waTAL. t stTH CeA>L MczTE. THAT PER. MEMO SSoZ OS F4emE ten M t* R E O .M E E R 6e.EE. A( T\ota to ec4Ect.ocxE. Raeu. Tires catso c.r.e.34 ATTN wa.o to esv. O c>p v e. .
DISPOSITIONE0 BY/TITL b d O
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o PR E PA R E D APPRO V E D REvtSEO FDP NRRMiTullIEY
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ORIG. O ATE % REVISION FORM p MRW RVS RVS PROCEDURE 05/31/79 10/03/85 14 QA54
L. K. COMSTOCK O COMPANY. INC. Braidwood 4.11.1 QA SECi i
. NONCONFORMANCE REPORT !
L. K. COMSTOCK & COMPANY, INC. Sht. 1~oT'"2"{ NONCONFORMANCE REPORT NO. 3o277" REV. 1 DATE 11/7/85 l INSPECTION CRITERIA: DWG. N/A REV. N/A SPEC. L-27oo PROCEDURE: h.3.10 REY. D Int. OTHER N/A ITEM (S) DESCRIPTION Weld Rod Withdrawal Form 57's LOCATION N/A DESCRIPTION OF NONCONFORMANCE: NCR 3275 is being revised as follows: Form 57's, Weld Rod Withdrawal forms, had errors in documentation. Forms showed heat numbers for E7018 electrodes and issuance of E6013, as shown on sheet 2 of original NCR 3275 In addition, there are clerical errors on the transfer of the heat numbers as noted below: l 1) On sheet 2 of NCR 3275, original, a heat number is shown as h21 Phh61. This heat number is actually h11 Ph161. t . . - (Cont. on Sht. 2) ORIGINATOR Y ~ DATE M#d.7//F
/
[ ] Engineering 7 HOLD TAG N0'S N/A N QC
' DEEMED REPORTABLE PER 10CFR21 (l.KC 3.1.3) YES [ ] NO ((
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.p. .. POTENTIAL 10CFR50.55(e) YES [ ] NO [F
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Q M NA I AE JtEVIhs h DATE/, t//v/9 v~ p ~
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SYSTEM (S) tMA ' (if applicable) 3 DISPOSITION: [ ] USE-AS-IS [ ] REWORK [ ] REPAIR [ ] SCRAP M OTHER CORRECTIVE ACTION / JUSTIFICATION: ) (bE.aL lot >TWK ATice4 6 Cn".mftl: 4 LTnc44 ATT*t ME D TO C'sa.Wat (gs.v. M c>F t4C.8- C: ATE.C> W 2h SA , AL.5w:> tmi.E A N ED N , dm4Tecm t4o. 86-o?.*o% -04 At40 MEMoCANt:cM-OF TG t N E. C.otWestbA.TioM . Horse. TMAT Peut. mW 8542 c3<4 TME EEMEO o* Fv-.L.sa. MSTAa. L.>nH&W NS g g, gP RWEED; ACTION TO PRECLUDE REPETITION: 15AMIE Ac_T\oH 11:> P**l' ' M RENTmcw CMTuo V) 74P 84 ATrhu.o To es.v. o e lilFORMATION ONLV DISPOSITIONED BY/TITL b d /dmT. MATE \l 15 85 (continued on back) l 0 P R E PA R E D APPR O V E D RE v e5E D TITLE O RIG. O ATE REVISloN FORM p G MRW RVS RVS PROCEDURE 05/31/79 10/03/85 14 l QAs4
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L. K. COMSTOCK & COMPANY, INC. BRAIDWOOD 4.11.1 QA SECT NONCONFORMANCE REPORT CONTINUATION SHEET NCR NO. 88 76~ REY. 1 Sht. 2 d 2 NOTE: STATE SECTION CONTINUE 0 ANO INITIAL ANO DATE ALL ENTRIES Description of Nonconfernance: (Cont.)
- 2) On Sheet 3 of original NCR 3275:
a) A heat number is shown as h025_9001. This heat number is actually h02S9011. b) The dates listed shov 5/25/82 and 7/22/83. The 7/22/83 date should be 7/22/82 as referenced on sheet 2 of NCR.
- 3) On Sheet h of original NCR 3275:
a) A heat number is listed as h01S9011. This heat nu=ber - is actually h02_S9011. b) A heat number is listed as 35202061. This heat number is actually 3S202061. n
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-_.................m pmEpanEO AppmOVED REvlSED 7 TLE OnlG.DATE REVISION FORM #
F JOS ITD PROCEDURE 06/18/84 14A em I
e j ., L. K. COM3TOGK & COMPANY, O. Braidwood 4.11.1
/ NONCCNFORMANCE REPORT . ' SYSTEM N/A Sht 1 of 5 NONCONFORMANCE REPORT NO. 3275 DATE September 12, 1984 INSPECTION CRITERIA: DWG.N/A REV. N/A SPEC. L-2790 PROCEDURE: 4.3.10 Rev D Int. OTHER N/A ITEM (S) DESCRIPTION Weld Rod Withdrawal LOCATION QA Records Vault Form #57 l
l DESCRIPTION OF NONCONFORMANCE: See Attached Sheets 2 Thru 5 NUMBER OF HOLD TAGS APPLIED 0 QC INSPECTOR _ 0.^TE 9-z.:2 fr 10 CFR 21 PROCEDURE 3.1.3 YES NO )( REPORTABLE ITEM CONCURRENCE BY Q.C. MANAGER A / O ' RECOMMENDED DISPOSITION: EXPLAIN JUSTIFICATION: h USE ASIS REWORK REJECT OTHER
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COMSTOCK PROJ. MGR/DE$gGNEE d Ob =. DATE b.W 8 4 p,'; [ I f ; ~- D.u.B- to.ze . e4 t , ACTION TO PRECLUDE REPETITION: 15EE ATTAC ME.O CMNTLce4 4mHEET' . 9as.a. ATTAc.ws.o coptas of: TsA%% 1besenorg Avra.Mna w a su 4 COMSTOCK PROJECT MANAGER (OR DESIGNEE)k1 1 %.h ( DATE to.1'T.eA TD 11 :n MPA "I Ail fMM V CLIENT CONCURRENCE WITH DISPOSI Ti : dbM a 15) kb touculL'S Want TME. A&:ME AnsposrT 6AJ Au0 AcDoel % P48C.L.UDE. AGMTiflM.
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ECO PROJECT SUPT. DATE CECO QA UPV. 'DXTE ECO FIELD ENG. 86 ATE G ia tcl=A. .utgec PREPARED APPROVED REVISED TITLE ORIG. D ATE HEV.DATE FORM NBR. ROM AJT IFD PROCEDURE 5/18/79 03/01/84 14 1
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NCR 3275 Sheet 2 Attached - Nonconformance - 3275 September 12, 1984 In violation of Procedure 4.3.10 Filter Metal Withdraw Forms. The forms did not specify the specific component the rod was used on and only listed general building locations, such as Auxiliary Building, elevation 463 fee t. Nine filler metal withdrawal authorization forms documented the assign-ment of E7018 weld rod for cable pan welding, even though Sargent and Lundy drawing 20E-0-3251, Revision AC and L. K. Comstock Procedure 4.3.3, dated January 29, 1982, required the use of E60 Series weld rod for cable pan welds. Detailed below are the nine forms documenting the release of E7018 weld rod, by heat number, for cable pan welding: Date of Designated Requisition Area Heat No. Class 5/25/82 Auxiliary Bldg., 383' 411P4161 *E6013 5/25/82 Auxiliary Bldg. 411P4161 *E6013 5/26/82 Auxiliary Bldg. 411P4161 *E6013 6/9/82 Auxiliary Bldg., 383' 411P4161 *E6013 6/10/82 Containment #1, 426' 411P4161 E7018 6/11/82 Auxiliary Bldg.,426' 421P4461 E7018 6/22/82 Auxiliary Bldg.,426' 402S9011 E7018 7/13/82 Auxiliary Bldg.,463' 402S9011 *E6013 7/28/82 Auxiliary Bldg.,439' 402S90ll E7018
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- Heat numbers 411P4161 and 402S9011 were actually E7018 weld rod as the inspector reviewed the material certifications. The rod issue attendants apparently thought these heats of rod were E6013. Note that the same heats, 411P4161 and 402S90ll, were handed out as both E6013 and E7018 weld rod.
s In addi. tion, further investigation /research has revealed that this was a generic violation during the same time period as per attached remorandum - Control No. 84-08-15-14,.'84-08-15-14A, 84-09-12-07. FORINFORMATION MY m (v I
NCR 3275 W Sheet 3 DN ~ Comstock Engineering, Inc. O Memorandum To: R. Saklak Office: Braidwood From: W. Puckett
Subject:
Rod Slips Date: April 15, 1984 Control No: 84-08-15-14 In regards to Weld Rod withdrawal Forms dated between 5/25/8g 4 gj ,g and 7/22/83, the main concern involves three heat numbers 411P4161 and 40259001 for E-7018 and 2D209808 for E-6013. N.R.C's concern was that the Weld Rod withdrawal Forms referenced a type of Rod i.e. , E-6013 but the heat number listed for the material is documented as being E-7018. I preformed extensive research on these Rod Slips with the following results.
- 1. We three heat numbers afore mentioned are good heat numbers traceable to valid certification papers.
- 2. The components on which they were used, the filler strength meets or exceeds the strength requirements.
- 3. We welders making the welds were qualified to use either filler.
- 4. We have an obvious procedure violation which could be aleviated in the future by a thorough Indoctornation l of the craf t tool room weld rod issue clerk.
- 5. A non conformance report should be initiated listing the heat numbers and types involved and a outline of the procedural violation.
Respectfully, l w . s.D . - b W. O. Puckett I6, WOP /pb fl ~' cc: QC File OC Mgr. ?" SlV p C
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& f F8R INFORMATQ0NM2
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NCR 3275 b Sheet 4
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r Comstock Engineering, Inc. ( Memorandum R. Saklak Office: Braidwood To: W. Puckett
Subject:
Rod Slips Date: Auoust 17, 1984 YAW Control No: 84-08-15-14 4 g/2/F/ During the period of time that I was doing Research on Neld Rod Slips for the months of May, June and July of 1982 it occured to me that the problems we were having during the afore mentioned period could possibly.te generic through other periods, so I performed a spot check on the Rod Slips Issued in December 1982, September 1983, January 1984, June and July 1984 and during this period the problem did persist, however not as prevelant in the year 1984. In addition during the period prior to May 1982 Heat Numbers for E-6013 electrode were not entered on the weld filler
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material withdrawal form. I also took a sampling of heat numbers off of these previously issued Rod Slips to see if they could be traced to documentation the Heat lot numbers in the Research of Welve separate heat numbers I was successful in all but three heats 40157441 and 401S9011 for E-7018 and 35202061 for E-6013. It would be my suggestion at the very earliest convenient time that a more thourough review be performed on all the Rod Slips so as to have an in-house identification of any major problems we may have. Respe ctfully, u.o b . C-W. O. Pucke tt l l WOP /pb l cc: QC File QC Mgr. / A RECEIVED lo FOR INFORMATION 01
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NCR 3215 fV Sheet 5 O v ~~ Comstock Engineering, Inc. Memorandum To: Irv DeWald of fice: Braidwood From: T. D. Vogt
Subject:
Weld Filler Metal Withdrawal Date: September 12, 1984 Control No: 84-09-12-07 In response to the NRC statements regarding the Comstock filler metal with-drawal program, reference NRC Docket No. 50-456 and No. 50-457, the follow-ing actions have been taken. A review of the identified items was conducted and the following has been identified.
- 1. The heat numbers identified are acceptable heat numbers trace-able to valid certification papers.
- 2. The components welded utilizing either of these electrodes meets or exceeds the strength requirements specified by AWS Dl.1-75.
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- 3. 'Ihe welders making the welds were qualified to use either filler metal.
- 4. An obvious procedure violation did occur.
- 5. A nonconforma sce report should be initiated.
Based on the above comments nonconformance report NCR 3275 has been issued to identify the procedure violations which did occur and allow time for a proper review and evaluation of the identified nonconformance condition. Correction Action Completed: Procedure 4.3.10 Rev D dated 8-12-84 titled
" Storage," Issue and Control of Welding Material has been revised and approved, which requires a filler metal issue tab to be issued for each type and size of electrode and for each day's welding activity.
Corrective Action to be Taken: Training on the Procedure Requirements will be given to all affected Personnel detailing the control of heat numbers and documentation practices for the filler metal issue tabs. T. D. Vogf - QA Welding Engineer
\ TDV/pb 4 cc: QC File
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L. K. COMSTOCK & COMPANY,IP'~ QA SECT NCR #3275 DISPOSITION O USE AS IS PQ JUSTIFICATION: The problems identified stem from documentation errors. As stated in referenced memorandum the heat numbers identified are traceable to valid certification papers, the filler metal tensile strength of either type of electrode meets or exceeds the requirements of AWS D1.1-75 and the welders making the welds were qualified to use either electrode. In addition, any unaccpetable welds would have been identified because 1005 visual inspection of welding has always been required. Per ECN #23028 the use of E7018 electrode for welding of cable pan is acceptable. ACTION TO PRECLUDE REPETITION: The applicable procedure (4.3.10) has been revised subsequent to the nonconformance to improve control of filler metal and personnel involved in issuance and control of filler metal have received training. g Ca O.es - A
- 0. Bradfute i c,.u..,4 Asst. Project Engineer OSEC ce c Nv% fr.zaw d e f.e:> GEA ,Tue_ vac a t.o gg E>El % ADOaC To T%5. h TnFic.A W oft ms N :
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COMMONWEALTH EDISON COMPANY MEMORANDUM OF TELEPHONE CONVERSATION Date: \\/ tale 6 Time: lo:Rn A.w. Person Called: L . Jac.ctass of skL 6PEb (name) (Company / Department) Person Calling: d dn s u se_ m2._ of dm P cts (name) (Company / Department) Project: 6ruidwann th rs tun 2 Subject Discussed: L.E. h erara Mch 3116 . d L E c.M
- 2 -3 0 1 1 Backaround f:fAl fMS$ d A. Aces TuqLogs., es:L'70lb 64scrEoOE. coR. MuE. PAnd uei.a bown wrtos. LEc. Mc12.32.75 usEs Eced*2342A 3 oissusmod fa Gbe6:eur usiE. a E leik Eter.xt.aes C'c e caeAsE Pa J n a .o b en o u u)1EL D S 99.4blL Tb ThE. E5ffrysOE Desnr M 1%E TCA.I. 16 Wh 96fMis<1A 7 Summary of Discussion. Decision and Commitments:
i L. )a,c. cue.s eucac.A11th nks was ***oTMLrr Aw 4 to Pacx toad M k4atu I?.EA6061 COR. T%fr 9M.
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Signature: y 924 U.. Date ulibias
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XXX/xxx (Oll7F)
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CC: O.' L . 3 A c. o u e set Y h.A - Lee , FOR INFORMATION m
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Comstock Engineering, Inc. ( Memorandum To: E. Netzel [t [E? A Office: Braidwood From: A. T. Simile ,h o ol 85-02-09-04 NRC Docket Report #50-456/84-13(DRP) ; 50-457/84-13 (DRP) and LKC NCR 3275 addresses a concern as to which type of weld material, E-60 series or E-70 series, was used on field installations. A discrepancy was found in which the heat numbers didn't match the type of electrode shown on the weld filler metal withdrawal slips. (i.e . E6013 shown with an E7018 heat number.) A review of all weld filler metal withdrawal slips was to be perform d for additional discrepancies in which heat numbers did not match the type of electrode shown. A review has been performed on all the E-60 series electrode-material test reports (attached) used by L.K. Comstock.
. This review shows that none of the E-60 series electrodes used by Comstock have a tensile strength less than 70,000 PSI.
Knowing that the E-60 series and E-70 series are compatible electrodes and the tensiles of the E-60 series electrodes do l not fall below 70,000 PSI, either rod that was used on these field installations should be acceptable and a review of the filler metal withdrawal slips should not be necessary. If this research and information is to be utilized, the disposition.for NCR 3275 will need revising. Please review this letter for your concurrence. M _ JI- 6 A. T. Simile QC Supervisor ATS/sm M' ;(' '
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~ . -f Attachment ig j i
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t cc: C. Hayes O J. Gieseker iiE:a FOR INRRMAT!0N ONLY
f ALLOY RODS DIVISION CERTIFICATE OF ANALYSIS CHEMEfr.CN CORPouriCN P.O. BOX 517 HANOVER PA 17331 717/637-8911 CERTIFIED MATERIALS TEST REPORT I l L. JSTAR Customer Order No. 9682-A 1750 MITCHELL ROAD AURORA, IL 60504 Order No. 211063-1 Shipped: REF: Commonwealth Edison P. O. 262208 This Mat ecification ASME SME B&PVC Trade Name II Material or Trademark: Atom Arc 7018 d. Sunxne r . CFR Part app l i e, s . Diameter Size: M Type: Weight: 25,000 lbs. Test No. 2-350-Y 44 P Lot Number: Control No. FF017 X-Rays Satisfactory C Heat Number: 401S7491 Moisture @ 18000 F. 0.10% h(4 ,\ 1 Carbon b '
- Menganese .71 Test No. Full Split Volts Amps 3 Chromium .03 ? v; .
Tensiles & q., Nickel .02 ' ~ ' ~ " Imp a c t s 1 4 23 140 DC+
\ Si1 icon % Columbium + Q.D21 "M A / t As Stress < Tantalum u1 .j i/ V u l t s :. Welded Relieved 8 brs. G"11500 F.
Molybdenum .0 Tungsten Yield 65 900 55 300
- Copper .02 Tensile 78 400 70 200 itanium Elon Red.gation 34 0% 37 0%
sphorus .013 of Area 75.4% 80.8% Sulphur .020
- NB-2431.1 .2 (e) anadium .01 Charpy V-No t ch Impac ts Te s t ed @ -200 F.
Cobalt Ft. Lbs. 162-117-159 256-256-249 Lat. Exp. 97-81-93 86-88-61 Ferrite: % Shear 90-60-90 100-100-100 Tensile Specimen .252" Impact Specimen .394" x .394" Fillets: OK Vertical / Overhead THIS MATERIAL IS CERTIFIED 'IV BE Location & Orientation of Charpy- FREE OF ANY MERCURY CONTAMINATION. V-Notch / Tensile S ASME NX-2322 and/pecimensor AWS/SFA ir I/A/W Quality Systems Certificate No. QSC-221 specifications as applicable. Expiration Date: September 8, 1984 State of Pennsylvania ? The undersigned certifies that the County of York J SS contents of this report are correct and accurate and that all operations
, Subscribed and sworn to before me performed by the undersigned or sub 9 this 30th day of June, 1982 contractors are in compliance with requirements of the material spect-6 fication and ASME Boiler and Pressure
. - Vessel Code Section III Division I SE . . V.........
otary Public ALLOY RODS DIVISION My Coczni s s i on expires: 11/22/82 Chemetron Corpo, ration determined per para. 25 of BY. . . . . . . d< 'D .......
!E Sec. II Part C SFA 5.5) g$GE, gg
(, hb g Q. A. CONTRACT SPECIALIST REVIEWED ANDIPPROVEO 9%E P.G. - O.A. DE . __,_ 7 9 se
.+
ALLOY RODS DIVISION CERTIFICATE OF ANALYSIS
, o sox m To"eTC757 mwen .577W#cKP Myd fy #6 CERTIFIED MATERIALS TEST REPORT ASME SECTION III CLASS 1 l
- O Cuatomer Order No. 9503-A Weldstar Q 1750 Mitchell Road gg86 Order No. 209821-1
- Aurora, IL 60504 Shipped:
Trade Name oRNDWOOD U This Materia, Con,orms to S eci,ica,,,n ASME SFA 5.1 SEC. II PART C,8e ASME S
!II, SUBSEC NB FOR CLASS 1 "
4 or Trademark: Atom Arc 7018 MN. 10 PART 1 APPLIES Diameter Size 3/32" REVIEWED AND APPROVED Type: E 7018 P.G. - QA DEPT. Weight: 25,000 lbs. 7 g' '. w .6~ 6 Test No. 7957 3 '/ - 6
?4 Control No. EE080 -
X-Rays Satisfactory Hsat Number 40239011 Moisture @, 18000 F. 0.1% Concentricity 3% Type Steel A-285 Mnnganese 1.05 Test No. Full Sp1it Volts Amps Chromium .03 Tensi1es ac Nickel .03 Impacts 1 3 21 100 DC-Silicon .41 Columbium + Test' As Stress Tentalum Results: Welded Relieved Molybdenum .01 8 Hrs. @ 00 F. Tungsten Yield 71 30 64 50
' Copper .01 Tensile 82 50 78 50 4 'ltan1um Elon 31 0% 34 0%
horus .011 Red.gation of Area 75.8% 76.6% 1 hur .015 Venakium .02 Charpy V-Notch Imp ac t s Te s t ed @ -20 F Cobalt Ft. Lbs. 100-89-91 115-127-144 Lat. Exp. 72-62-57 73-78-83 Ferrite: % Shear 60-40-40 60-70-80 Tensile Specimen .252" I Pact Specimen .394* x .394= Fillets: OK Vertical / Overhead Locat ion 8e Or i en t a t i on o f Char - V-Notch / Tensile Specimens is I /W p i e nI a p e. 1 State of Pennsylvania ? The undersigned certifies that the County of York J SS contents of this re ort are correct and accurate and th t all o l l Subscribed and sworn to before me performed by the undersignekerations or sub this 13th day of May 1982 contractors are in compliance with re uirements of the material speci-f fi ation and ASME Boiler and Pressure
' Vessel Code Section III Division I Subsection NCA-3800 b otary Public' ''
ALLOY RODS DIVISION My Comni s s i on expires: 11/22/82 Chemetron Corporation I "IEI S MATERIAL IS CERTIFIED 'ID BE
, 9 OF ANY MECURY CONTAMINATION.
2 Q.C. ACCEPTANCE D.A.SNIE QUALITY ASSURANCE DATE 2-i4KBY CDNTRACT SPECIAUST O
7f ' Th'io CMIR covsrs Conmnvecith Edison P.O. #N-
- 282460 and 141dstaYIN:;
cER kAVEdf6 ANALYSIS ALLOY ' RODS, me.
*
- P.O. 8CX 517 HANOVER, PA 17331 7174374011 S O 4 p299 : #
CERTIFIED MATERIALS TEST REPORT
) LDSTAR
~w. Cus tome r Orde r No. 2083-A 1750 MI'IQtELL ROAD AURORA, IL 60504 Order No. 225796- 1
' cLDSTAH COMPANY'S QUAll!Y SYSTEM CEST!FICi Shipped:
WT 10 M This Material Conforms to Spectiication E)fP! RATION DATE JAN. 5.1985 ASME SFA 5.1 Sec. II Part C & ASME Sec. Trade Name III Subsec. NB for Class 1 Material or Trademark: Mild Steel SW-15 1980 Ed., Wntr. 1982 Add. 10 CFR Part 21 applies. Diameter Size: 3/32" Type: E6013 Weight: 500 lbs. Tdst No. 2-2636-00 Lot Number: 3S202061 ConttoI No.- 061BBB He at Nu:nbe r : 49344 Type Steel A-285 Manganese .45 Test No. Full Spilt Volt Amps Chrotnium .03 Tensi1es & Nickel .03 Impacts --- 6 22 90 DC+ Silicon .33 Columbium + Test As Tan ta l um Results: Welded Molybdenum .01 Tungsten Yield 71 500 Copper .10 Tensile 82 000 Titanium Elon Red.gstion 0 0% Phosphorus .007 of Area 0.8% Sulphur .018
.01 OVanadium Cobalt Tens!!e Specimen .252' Fe rr i t e :
Fill et s : OK Ver t i ca l /Ove rhead 'ITIIS MATER I AL IS CERTIFIED 'IO BE FREE OF ANY MERCURY CONTAMINATION. Location & Ori en ta t ion V-Notch /Tensi1e S of Char y/W ia IA
, ASME NX-2322 and / pe c itnen s or AWS SFA uality Systems Certificate No. QSC-221 l specifications as appli able. xpiration Date: September 8, 1984
) State of Penns yl vania 1 The undersigned certifies that the County of York ? SS contents of this report are correct and accurate and that all operations Subscribed and sworn to before me performed by the undersigned or sub this 12 t h day o f Oc tobe r, 1983 contractors are in compliance with re uirements of the material speci-ation and ASME Boiler and Pressure ssel Code Section III Division I S h t O, ! ! / ,. j5I63.4.......*
"'**** " " ^- *
"f'7 ""*
My Conni s s ion e xp i r e s 14377 11/22/86 ALIDY RODS, INC. 3RAJWOOJ [
.d.O'/d 1
hDNTIC ELID : BY........ ' Oualit Systems Certificate No. QSC-458 D. A. Smith i pira ion Datet Ju!y 16, 1985 QUALI'TY ASSURANCE l CONTRACT SPECIALIST UR REFEREygg gggy
,' p1 GA*W
.D, . . ',' ' . , .
L K. COldIT"OCK & COMPANY, INC. Braidwood 4.11.1
\
.( NONCONFOR,MANCE REPORT fp yg g {
SYSTEM N/A Sht 1 of 2 NONCONFORMANCE REPORT NO. M . DATE 10/12/84 INSPECTION CRITERIA: DWG. N/A REV. N/A SPEC. L-2790 PROCEDURE: 4.3.3 REV.D 4. 3. 3.1 REV.C OTHER N/A ITEM (S) DESCRIPTION Preheat of Base Metal LOCATION Various Catecorv I Areas Materials 1 1/2" THK DESCRIPTION OF NONCONFORMANCE: In violation of LKC/QA B.P. 4. 3. 3, 4. 3. 3.1, 1.0.1 paragraph 4.7, and paragraph 4.3, and 10CFR50, App. B - criteria IX which states that: " Measures shall be established to assure that special processes, including welding, heat treating, and non-destructive testing, are controlled and i accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications, criteria, and other special requirements.", And Criteria V which states : " Activities affecting quality shall. . .
' (Cont. Page 2)[
NUMBER OF HOLD TAGS APPLIED N/A OC INSPECTOR + >#DATE M-a'-M 10 CFR 21 PROCEDURE 3.1.3 YES NO REPORTABLE ITEM CONCURRENCE BY O.C. MANAGER <
/
he.. .s ai.95 RECOMMENBED DISPOSITION: USE.AS.lS REWORK REJECT h OTHER EXPLAIN JUSTIFICATION: aft W El O Pft.ct.spo EE.S wtas. aswt iFirsC) o.sm PAm e a.7mm. w T or e.ovino x ws. risu:>. (,s s.. m **** wT ,
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QBaashsushas D.a9L/ CECO QA S 6lbs x L LL e+M CECO FIELO ENG. DATE stj;;Of ROJECT SU6T. DATE . DAyT[ fREPARED APPROVED REVISED cnn men:!MrniM l %IIM 5513 V bR e t.A T E' " WEi/.)ATF Y FORM NBR. E ROM AJT IFD PROCEDURE 5/18/79 14 03/01/84 .
. L 1 COMSTOCK & COMPANY,1NC. . QA SECT s.
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(,/ ...be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions , procedures, or drawings shall include appropriate quantitative acceptance criteria for determining that important activities have been satisfactor-ily accomplished.", various weldrents to structural steel menbers greater than 13s " in thickness may have been welded without the required pre-heat or without docucented traceability that such pre-heat was perforced within the instruction criteria outlined above in category I areas, prior to 12-5-83 (Date of WIR issuance) . 9 . l l o FOR IERMAT!0N OEY l QASI l l
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Q'.:"^ Report No: M k/O- 7// k E P'O M T Lab No. : b I -h/-/99 of Miscellaneous Welding Qualification Report Date: J 76 Job No : CH-3175 Client : Cousnonwealth Edison Company Project : Braidwood Nuclear Power Station Contractor: L. K. Comstock Contractor Supplied Information: Type of Qualification Welding Procedure Position Qualified /f - kl4T~ kfelder's Name M. D/AJFCL f Welder I.D. N d2 - Welding Process bMA h/ Manual or Machine NM /ddMl_ Material Specification M-6bb Standard A W/s Di. i - 19 76 s Data of Qualification: M -A-/- 9 I ' Visual Inspection: ACC REJ A I. L 5 ' ' Bend / Fracture : ACC J /A ,f[ DAM Hacroetch Test : C REJ N/A Test Results: forming Non-Conforming Not Applicable . Remarks: Visual inspection of weld area only. ___..._......s . . . . , , FIIR INHlHMAlluN LNLY Inspeetor/Leve1: M 44 HOMAS
- crvisor/Uatca $k1A D $Eh ~
lY 3 -$- W REWEWED BY /W~y [ B.L f2EREDim ' DATE Ol
.................................e... . . . . . . . . . . . .
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L. r.. CO?.13TOCK & COMPANY. INO. cA s!-- LKCE-PQR-076 WELDING PROCEbURE QUALIFICATION TEST RECORD j r PROCEDURE SPECIFICATION GRDOVI WELD TF 37 R13 ULT 3 Reduced.section tensson test Matenal soe=ification A588 g, , g Wetomg process SMAW g N/A Man d Manual or macnme e
- N/A h of mang 'IF-F1at .
Filter me:st soscification As.1 Guiosd-hand test Filter metal csassificanon E7018 Root Face Welo metal prese N/A N/A g N/A Shigidmg gas N/A pg,,, N/A N/A , N/A Single / Multiple
@ or saultioie ness Sinpa or mutuois art Single Radiographic-Uttrasonic Examinatier, N/A
" Fillet test results 3
.. Mm 5ize Muttrale Pass Max Stae Single Pass N/A Macrostch Macreetch W name M. Dinelli #62 1 AdC M d6 1 Md6 s kd 9 MA 9 Md.
Mwa- 7ll Mr 2 F0R imm"prar"A"!T2TN.04dLY- i.a oArsa-Lmuo... m.-asr-9ug9
- WELDING PRDCEDURE .
Pee Emes, seems et suo *M me. amies,e, ! v s. weves L SINCLE PA lS 1 1/8" 130 24 N/A 1"
" ~
9 * "A88 .
*V 1 3/32" 95 - 100 26 - 30 N/A ,
2 3/32" 90 - 100 24 - 26 N/A 3" 3 3/32" 90 - 100 24 - 26 N/A
- Single ,- 1/8" Fillet j Multiple - 3/16" Fillet ;
We tne unoernyned, certify tnat tne statements in this record are correct and that the test welds wece orsmared. wetoes and tested in accornance witn tne reovirements of 5B of A%S Dt.1. Structural Weidmg Coce.
** Base Metal Temp. 56 F Mardemrer or Contractor _
A1999 Due Date: 6-17-85 Autnorized by AA" - oste #-9-ff o , sussanco 4 == = o v r.o navisto cnt 50RWJON ONLY 11 7 :98.5 5 * olas.DATL Mvist re PRCOEDURE
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?$lSSburgh p.or,no,, s.n. g 1
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...? '..: " ' ' ' Labor a tary *~*-*' l Report No: Mk//) - /7/c'2. I REPORT Lab No. : M "T~- N 9 0 ,
of Misec114.neou Welding Qualification Report Date: ,2 8 5' l b No : NM Client : Connonwealth Edison Company i Project : Braidwood Nuclear Power Station Contractor: L. K. Comstock Contractor Supplied Information: l l Type of Qualification Welding Procedure Position Qualified O h - //d R ;ro g/ 7A [_ j 11 elder's Name W , DtLIELL I Welder I.D. M b2 - Welding Process 5 tr> 4 W Manual or Machine MMA//lk
. Material Specification M-68b Standard A\A/R hl. l- 19 7I ,7 - g
" U Date of Qualification: $2' 4 " 8 6~ [ A['[;.3,Yb \
Visual Inspection: ACC DaEJ NA ' i' hm J Tf
~
u Bend / Fracture : _ ACC N/A ggfff~ G Macroetch Test : C REJ N/A Test Results: forming Non-Conforming Not Applicable . Remarks: Visual inspection of weld area only. __.e _. meanan ATinM GNI - Y PUM mrJnmno In sper t or /1.evel : r/ M / 77- C. W. THOMAS o ,v1so:iv.t 2 9 g h j r a-y-rr ampm hka. k-2)>is s a g e w.ees o f9e. s em n0 9 e..ese 8 9 8 48 .8 9
' cA sr-7 L. K. COMSTOCK In COMPANY. INC.
~
LKCE-PQR-077 WELDING PROCEDURE QUALIFICATION TEST RECORD PROCEDURE SPECIFICATION GRODVI WELD TEST RESULTS Redused section tensson test Matenal specifiestion A588 Td m M Wetding crosess SMAW g N/A Manual or macnane Manual , gjg Pasinon of welding ">F-Morizont m1 Flher rnesat soecificauen M1 Guised bend test Fitner metal classificenon E7018 Root Face N/A g yfg pyg Weta ment erans t Shigiskng gas N/A F6eur N/A 9 N/A 9 N/A Sinale/ Multiple Single w mutuose pas Sinale Radsograonic Uttrasonic Exammatier. N/A Single or muinole are Weisbng merent MRP FE eteast e Min Site Mutt:We Pass Max size Single Pass
% U.
Macreetch Macrostch N/A Postnset westment Wekter's name M. Dinelli #62 1 Nd 't IdC- 1 NC 9 ICC. 9 OO 9 MOO. Mk/O- 742 F0 9INFORMATON'ONLY a
- WELDING PROCEDURE .
T&?sl . m.m. ' """"" rw e.o - O . SINGI E PAS i 1" 1 1/8" 120 - 130 20 - 22 N/A MULT] PLE P uiS 1 3/32" 90 - 100 22 - 24 N/A *V 2 3/32" 90 - 100 22 - 24 N/A - 3 3/32" 90 - 100 22 - 24 N/A = Multiple - [
- Single - 1/8" Fillet 3/16" Fillet g We the unoersigned, certify that tne statemems in this record are correcs and that the test welds wees preoared, wetoed and tested in accornance witn tne reavirements of 58 of AW3 Dt.*. Structural Weidmg Coce.
** Base Metal Temp. 560F A1999 Due Date: 6-17-85 Autnorized by Date o _ mennumM 00 !
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Hev. 2 9.p c a'c a = = l[ 7es(ittg ud '.. " ' ' Laboratory '-** 7/3 Report No: M u / 67 - REPORT Lab No. : 897-949/ of Misecilaneous Velding Qualification Report Dat e : M / -Rf J b No : CH-3175 Client : Cotunonwealth Edison Company Project : Braidwood Nuclear Power Station Contractor: L. K. Comstock' Contractor Supplied Information: Type of Qualification Welding Procedure Position Qualified 3 F - VERT icAL 1/ elder's Name b, kA\A/L / A]9 Welder I.D. Mh #/ . Welding Process b M A k[ - Manual or Machine ,M4 AJ/>A L Material, Specification, M-586 Standard N h / S D l. l - / 9 7 I [
/ * - ":
\
Date of Qualificacion: O- 4/ - 2f ,/ ,'f *-. p.urr, ,;[ Visual Inspection: ACC REJ A i 'd i Bend / Fracture : ACC J 1 A \ k/l ,
/
Macroetch Test : CC REJ N/A Test Results: nforming Non-Conforming ;ot Applicable . Remarks: Visual inspection of veld area only. rnn mtnDMMi'3 OELY Inspector / Level: hj [/eas/Fb .Nb rvisor /Unt et $L /}0]A J W]+ ' ff ) -- b'"* IN'7 l R L MTREDITH REVIE%'ED BY gg ?. l/. $( _
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CA II::?
. . $ L. K. COMSTOCK & COMPANY. INC.
LKCE-PQR-078 WELDING PROCEDURE QUALIFICATION TEST RECORD PROCEDURE SPECIFICATION GROOVE WELD TEST RESULT 3 Resumed-section tension test Matenal soecification A588 j Wewwis proces 8 MAW g N/A Manuel or macnme Man M , N/A Posnien of weieing 3F-Vertical Filier metal saecificauen A5.1 Geined-bend test P1her metal c:assifieraon E7018 Root Face Weis meine praos M/1 1 N/A g N/A Sheeldmg gas N/A Flour N/A , yfg , gjg Single or mutuoie pass Sincle /Multipie sinole Radiographic Ultrasonic Exammatior, N/A Einsie or neutumis are Weidag surrent M Flust test results
*E Min Site Muttrole Pass . Max Size Sinste Pass B. Rawli #97 i O 1 d N emme , Ace , Rec 20RINFORMATl0N ONLY
% = WILDING PROCEDURE .
waf38 O ~ ww g pen mess. sense se 1* l SINGLE: PASO Ml , 1 1/8" 130 - 140 20 - 22 N/A N MULTIPLE PJSS -6" x 12" N x 3" J \ 1 3/32" 90 22 N/A N 2 3/32" 90 22 N/A 3 3/32" 90 22 N/A
\
- Single - 1/8" Fillet
*\'
- j
- Multipie - 3/16" Fillet g 1
We the unoerssened. certify tnat tne statemems in this record are correct and that the tsat welds wets orcosted. wetoed ano tested in accoroance witn ins roovernments of 5B of AWS D1.1, Structural Weidmg Coos. Manufacturer or Contrs= tor ,
** Base Metal Temp. 57 F A1999 Due Dates 6-17-85 Avinorized by Date spAM Ik [ EA p y w w aw t.
.....eco . . . - -.co o 464 .
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- Regiort No: M [(/'*O - 7//-/
h E P O M "I Lab No. : 8 3 7- 94/ M of Misc <11arienus Welding Qualificotion Report D4st e : .,2 - /-f - 86 Job No : CH-3175 Client : Cotssonwealth Edison Company Project : Braidwood Nuclear Power Station Contractor: L. K. Comstock Centractor Supplied Information: Type of Qualification Welding Procedure Position Qaalified M F - O(/ERN64D Velder's Name 8. kMk/L W Q Welder.1.D. M 97 . Welding Process 3 /7) /2 (A/ Manual or Machine MAdllAL Material Specification A .5'BA ( ' Standard M NS Dl, I- N #7T Dnte of Q.:alification: 2 24-86 APPROt.'E8N g Visual Inspection: ACC /A g gj,,; Bend / Fracture : ACC J /A ,
~
Haeroetch Test : CC REJ N/A DATE N' Test Results: forming Non-Conforming Not Applicable . Remarks: Visual inspection of veld area only. l Inspertor/ Level: <_ F/ mao., /M-~ C. W. THOMAS A T- ' Supervisor / Dst cd2 /27/,1/M////T J - M a r- REV!?WED BY O ( 8. ' etenWr t . . . . z4sw. I
==f.0MNEQBMATION ONLY .
ca st:T L. V.. COM3TOCK & COMPANY. INC. IJtCE-PQR-079 WELDING PR0"EDURE QUALIFICATION TEST RECORD PROCEDURE SPECIFICATION GROOVE WELD TEST RE3 ULT 3 Re h tenmentest . Matenal specifscation A588 % g Wstemsaroussa SMAW g N/A Manuet er mannsne Man"* , N/A - Pesstaart el weMing dF-O'*Pha^d Filter mecat sassificapon A5.1 Guiesd head test Reet Face ! Filter metal asassificanon E701B Wete enemi praes M/- t N/A g W/A Shgisimggas N/A 76er. M/1 , y/g , y/g Single /Muitinie Single w mutumie aan N/A Single er mutumes are Sinole Radiograons-unresons:Exammatia. _ _ _ - ,_ _ _d. Prenset ameerature
- - .m_M_._
O 9 0 6 i O weg,,,, ,,,, B. Rawli 897 1 1
, Ade , Ace v>adi?E, . v%
F0FI INFORMATICjj0NLY . Canus lg,,,,,, Pas tom. 85 8" Asuseus vess ****8 SINGLE PAS;i . 1 1/8" 120 - 130 20 - 22 N/A 4 MULTIPLE PJ JiS 1 3/32" 90 - 100 20 - 22 N/A 2 3/32" 90 - 100 20 - 22 N/A *N # 3 3/32" 90 - 100 20 - 22 N/A 4 1
- Single - 1/8" Fillet Multiple - 3/16" Fillet We inn immeregned, certify instine summems in this record are sorrecs and that the test welds woes nessered, wetees ansinsted in sesornance wnn ine resuremems of 58 of AVS D1.1.StructuralWeidmg Coos.
Manidscuarer w Comrectar- .
** Base Metal Temp. 560F A1999 Due Date: 6-17-85 Amnortmed try o enreamco mesmov r.s asvisto g enn mmnuATKN 0HLY yl g 315 5 .3 w*** '5afa. D ATL M v t310!'
PROCEDURE esu .
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[ O) Date April 30. 1985 BRD4 15.829 TO: J. D. Deress
SUBJECT:
Non-Conformance Reports - Braidwood Station In accordance with Quality Assurance Procedure #15-1, Section 5.4 a copy of NCR # 667 is being transmitted. The corrective action indicated has been implemented and the NCR should be considered closed. h4' T.-E. Qu'aka x __ b' 3 7 ((' Q. K.-Superintendent Braidwood Station
' TEQ/CAH/mjv (0009F) cc: W. C. Cleff D. L. Shamblin W. E. Vahle ~
B. Kulik/ letter only K. A. Both N. Kaushal (BCAP NCRs Only) Q. A. File /52.1 Contractor, if applicable L. K. Comstock E0 1*12a,_ ,vi" g" n c a O M W -
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62.1 { { uce.LL7 O DATE March 26, 1985 BRD # 15.357 TO: Mr. D. L. Shamblin
SUBJECT:
Non-Conformance Reports Braidwood Station In accordance with Quality Assurance Procedure #15-1, NCR # 667 is being transmitted for completion of final disposition. T. E. Qua W ala,iw O\ , Q. A. Superintendent Braidwood Station - TEQ/CAH/mjv (0013F) cc: Q. A. File /52.1 l K. A. Both i
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C." ' R@ E M@ APR 81985 .;j .
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( ( ' ).) ' 4 ~nv DATE October 17, 1984 BRD# 13.416 l l TO: Mr. D. Elias l
SUBJECT:
Non-Conformance Reports Braidwood Station S & L Specification # L-2790A In accordance with Quality Assurance Procedure #15-1, copies of NCR # 667 'are being transmitted for review, information and resolution, if needed. Resolution of NCR by November 8, 1984 would be appreciated. 0 0 ' 1A!LL T. E. Quaka io/n/ev Q. A. Superintendent Braidwood Station TEQ/CAH/mjv (0012F) cc: D. Elias E. R. Wendorf W. C. Cleff D. L. Shamblin K. J. Hansing Q. A. File 52.1 Contractor, if applicable L. K. Comstock
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- g. NONCONFORMANCE REPORT FOR CONSTRUCTION AND TEST ; m m. M ca no te Station or Site Location Fer's ., / 1
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1'. February 1, 1985 fpjf{i{ A.a .., Pro ject Nos. 4683-00 Commonwealth Edison Company 4684-00 T' Braidwood Station - Units 1 & 2
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-W~ ~ElEc~trical Installation Work .
. M- S&L Specification L-2790 - ~~~- ~ ~
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T I*h "' CECO P. O. No. 231360 '
~ Non-Conformance Report - NCR L _667 47 Mr. W. E. Vahle .. . . *
"p Project Field Engineer- -- --
Commonwealth Edison Company .... Braidwood Station 4.l. P. O. Box 81
?; ', Braceville, Illinois 60407 .'
Dear Mr' Vahle :
~~~ -~ ~--
' ' ~ ~ ~ ~ ~ . _.. , . . -
We acknowledge dated October 11, receipt of.Non-Conformance Report (NCR) L-667, 1984 (copy enclosed) , with Mr. D. Elias' letter dated below: October 26, 1984, covering the non-conformance described
- -- - - - - - - ~
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.The required preheat for welding attachments ..to huj.1 ding. .
w steel in excess of l '1/2"' thicknss's was not .obtained.
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; J' We_have . reviewed this'-Non-ConformancF Rep'di-t"andlionduE'$haE "the .. . .
corrective action (Requalify the appro .?' ' parameters that occurred inths field;priate_ i. e . , weld.prpcedures n.o preheat maximum using the 1
.t material However, thickness) L. recommended.u.qsler Section 16 is acceptable. .
K. Comstock should be required to requalify each specific ,
~ " weld, procedure that was violated. 'All weld qualifications should be .
done on material thicknesses that are equal to, or greater,..than, the Iy6ii."a'p' p ?6ve"NCR L-667i howeverthickness of the thicker part -joined.- c.-We,;-t r 5 ~2 all ft5'itire ^Wbldi~fcf%gsTod1d be "pe' formed-in. 'accoidanTe ;.s w'if.h th..i. .'5..EeTeA. tEEciliiEsife'$Es of"XWS'blT.I.T .
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.. 12-22-82 CONSTRUCTION DEFICIENCY EVALUATION Part 1 DESCRIPTION Describe The Deficiency (Attach references)
M t[ LW 4+ 6 taid .h Ah00 YD wM g - u Part 2 EVALUATION 2A Safety Impact YES NO
/
l Does this deficiency, whether or not safety related, affect safe operation f of the facility. 2B Significance a
'YES NO
- /
Is a breakdown in QA Program apparent which requires $100,000 in resources to re-establish assurance of program? Are expenditures of $100,000 necessary to _ rework structures, systems, components into compliance with approved design? Are expenditures of $100,000 necessary to repair structures, systems, _-. components into compliance with approved design? O
\/ Is approved final design inadequate to assure compliance with SAR and L\ construction permit?
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'ilWON0 lim 0dNiW-During Installation /Tersting is it apparent that a structure, system, s component supplied by others can not meet the required performance Specifications and should be reported (10CFR21) other users? (i.e.
Potential Industry Deficiency) Does Inadequate Management review / corrective action exist which ignores significant adverse trends?. Dop)e-operationalorstart-uptestresultsdetermineasystemthatdoes _ not meet safety analysis report or technical specification requirements? Part 3 REPORTABILITY OF f.0.55e NOTIFICATION If the answer to Part 2A is Yes and any answer in Part 2B is Yes, this deficiency shall be reported to Nuclear Regulatory Cosmtission Region III Headquarters. ,
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. Items not reportable ;.
( Items reported to date . NRC Region III k alua h Reported by T L C. date lo-I(-AN Connonwealth Edison , e t 0355a V l -
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f.. K..C MSTOCK & COMPANY,INC. - BRAIDWOOD 4.11.1 QA SECT
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NONCONFORNANCE REPORT ( L. K. COMSTOCK & CONPANY. INC. Sht. 1 of 4 NONCONFORMANCEREPORTNO.[i/B REY. N/A DATE 12/o8/s4 INSPECTION CRITERIA: OWG. N/A g[y, N/A Sp(C,L-2790 PROCEDURE: LKC 4.7.1 REV. N/A OTHER Aws n.1.1 1975 ITEN(S) DESCRIPTION N/A LOCATION N/A DESCRIPTION OF NONCONFORNANCE: A review of all the welders qualifications was performed and three discrepancies were found in the documentation, which are listed on page 2 of 4. ORIGINATOR IMb DATE M M [ ] Engineering HOLD TAG N0'S N/A [
@ OEENEO REPORTABLE PER 10CFR21 (8.P. 3.1 3) YES [ ] NO [>Q QC NANAGER/ DESIGNEE REVIEW 1/O N DATE /2 -otN SYSTEN(S) YA (if applicable)
J 4 e, 34285 CAUSE CODE 1) O1 2) o1 3) OO NONCONFORNANCE CODE 6 14 OISPOSITION: M USE-AS-IS [' ]: R'EWORK.' t' ] 1EPAIR ( ) SCRAP [ ] OTHER EXPLAIN JUSTIFICATION: ,) ( m Jetym g- ' A' poa. . jus.TtFic ATWH S. Post. TME. NoEC) Ot1! ace 4LPk4C ES, .
~ ~
ACTION TO PRECLUDE REPETITI lut>Pu Toe.6 c.wir% coms:ic.Amon Tests na u s. u s e istAssa.o e TME. q M 'aMrs on P* soc.s.c:v e.r 4.1.\ , LATaa.t- w.svim . dortas. op ilt.Atatsc, tatsa.tce.4 A m c a se.e. s a s.s t s Aaa. en teos is TWE. .t. $MT. DISPOSITI O 8Y iTLE N t.3. L As&T.hr6ct0 ATE 4 2*> 85 (- (continued on back) nacenaro an novco acvisto u n.c onic.oarc navision Fonu y F ROM AJT JOS PREEWRE 05/18/79 06/18/84 14
L K. CORETOCK & CORWANY,lEC. BRA 1 NOOD 4.11.1
'QA SiCT 'O 50.55E [ ] YES bd N0 _ ,
CLIENT CONCURRENCE WITH OISPOSITION: (CONNENTS) Ptb m wiru a centsetus miw %d .eyiw i. g=metnet noen=4 2d~00. rIoe,Isc GRyad#uL dsbr G % s. h %aLaloas CECD PR6 JECT SUPT. DATE CECO QA SUPV. ' OATE /IEGO FIELD ENG. DATE CORRECTIVE ACTION CONPLETED/ ACTION TAKEN TO PRECLUDE REPETITION: U O.% *P *> ' b 5 RESPONSISLE LKC ENGINEER DATE Q.C. VERIFICATION OF CORRECTIVE ACTION [ ] REJECT QC INITIAL /DATE
' REASON FOR REJECTION: ---)
l ACCEPT h g fggg g g y o g p Q $ 4 mpy. REMARKS / ACTION TAKEN: FORMf0EM C\ i
.8 ATE NONCONFORMANCE CLOSED 9-/ 8 E. QC INSPEC ,
~
REVIEWED QC MGR/0ESIGNEE "r
- SATE ,
/
COPIES: LKC ENGINEERING DEPT. Q.C. RECORDS FILE REASON FOR VOID ICA8LE) . CEC 0 QUALITY ASSURANCE g ) 4+pl9 y, ? ! .* ._ ; ~.- ./
.' /Yfexs a'.. h,. COMSTOCK O COMP ANY. INC. BRAIDWOOD 4.11.1 OA SECT NONCONFORMANCE REPORT L. K. COMSTOCK & COMPANY, INC. Sht. 1 of 4 REY. N/A DATE 12/08/84 NONCONFORMANCEREPORTNO.['//B INSPECTION CRITERIA: OWG. N/A REY. ;i/A $p[C,L-2790 PROCEDURE: LKc 4.7.1 REY. N/A OTHER Aws o.1.1 1975 ITEM (S) DESCRIPTION N/A LOCATION N/A DESCRIPTION OF NONCONFORMANCE: A review of all the welders qualifications was performed and three discrepancies were found in t'1e documentation, which are listed on page 2 of 4. l l ORIGINATOR C ~* b OATE M- M [ ] Engineering HOLD TAG N0'S N/A [ ()C O b DEEMED REPORTABLE PER 10CFR21 (8.P. 3.1 3) YES [ ] NO [>Q QC MANAGER / DESIGNEE REVIEW 1/O N DATE /2 -0 tfY SYSTEM (S) YA (if applicable) Jr,e. Mie5 CAUSE CODE gg ) O '2. 1 2) o '2- 3) OO NONCONFORMANCE CODE h 14 DISPOSITION: M5)Sie[']REWQRK_[] REPAIR [ ] SCRAP [ ] OTHER EXPLAIN JUSTIFICATION: s m Arr m y'A, *', , ,' , , y
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y.ddt. sgwuTots. wcwt. THE. MC:' ACTION TO PRECLUDE REPETITION: h4mToR b C.Wir% C 0mFLC.AW:>4 ThT%. Ma v s. Ns* T E *.i N n.C) m Twe. wmeusens o p. e socs.come 4.7.\ , utan.t- w.s.vis.m . (.orina, o s: wg .. Tnamw, we arra.ncaw_e. s,a u ts. Aas. en sua is Tus. ,w.c.. w a r. DISPOSITI ED BN ITLEN L 3.LbA667.hrbr.DATE 42*> s's (continued on back) PREPARED APPROV E D R E vlSE D TITLE ORIG. DATE REVISION FORM g F PR EEDURE ROM AJT JOS 05/18/79 06/18/84 14 adAh4
L K. COMSTOCK & COMPANY,lr6 . BRAuN00D 4.11.1 *
'.~*
- QA' 50.55E l ) YES t>d NO -
CLIENT CONCURRENCE WITH DISPOSITION: (COMMENTS) ( PCb e s tviru n G. cersective m.w x d u T'6 * 9** C*b'- Repenried. U & >&Da rIotolV5' 0 'Y M_b1 L w . YA/n- %u. &a,,I,sg CECO PR6 JECT StiPT. DATE CECO QA SUPV. ' DATE /CEGO FIELD ENG. DATE CORRECTIVE ACTION COMPLETED / ACTION TAKEN TO PRECLUDE REPETITION: bd t.) . R RESPONSI8LE LKC ENGINEER _ *) *> 8 5 DATE Q.C. VERIFICATION OF CORRECTIVE ACTION [ ] REJECT QC INITIAL /DAT
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. REASON r0R REaECT10N:
COMS 0CK ENG. Q.C. )EPT.g 11" AL # DA~E 2.n e ( ACCEPT ffg fggngyp,p y a g p Q,$yp<$,7,9 y . RENARKS/ ACTION TAKEN: ESRlHf0Rg8 '; :, i -
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._ . _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ ___ . . . _ . . . _ _ ~__ _ _ _ _
NCR # $ 7/O Date 12/08/84 O Page 2 of 4 (b
- 1. The Form 88 requires the brand name of the electrode used. The brand name was not documented.
- 2. The Form 88 shows the wrong base metal specification for the material used. Example - 1" plate was used for the test and the material on the Form 88 is listed as A-106 GrB (pipe).
- 3. The Form 88 shows the wrong specifications for the electrodes.
Example - E7018 was used and the Form 88 shows AS.4 for the filler metal specification. The below listed welders qualifications, Form 88, have a discrepancy of which are numbered accordingly. ACTIVE WELDERS Name Symbol Discrepancy Cobb, R. 39 1,2 Cobb, W. 9 1,2 Davidson, J. 92 1 Duggan, D. 107 1 Dunbar, T. 79 1 Hisaw, I. 69 1
. Keicler, M. 76 1
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!5 l^ ( 'g. McLaughlin, R. 94 1 7' /h ,
McMannis, G. 556 1,2,3 Miller, J. 200 1 Murphy, R. 222 1
, Pace, D. 43 1 Patton,'E. 66 1 Pelfrey, H. 445 3 Peterson, D. 5 1 Rawlins, R. 97 1 Sisk, R. 70 1 Smith, J. 95 1 b)/ Stotts, A. 67 1 I pgg\nE0gg0%
NCR # h[d Date 12/08/84
- O Page 3 of 4 g
Name Symbol Discrepancy Tatro, H. 6 1 Voights, C. 244 3 Wold, G. 163 1 INACTIVE WELDERS Name Badge Discrepancy Allen, L. 627 1 Bennett, R. 602 1 Bersano, M. 647 1 Bertani, B. 852 1 Billis, R. 747 1 Briston, J. 760 1 Bucklaew, J. 537 1 Chichosz, G. 729 1 Cook II, R. 652 1 Cook, R. 653 1 Davis, J. 788 1 Deese, G. 661 1 Dorsey, R. 632 1 Egbert, L. 828 2 Forrest, D. 813 1 Helgesen, K. 600 1,2 Hicks, J. 703 1,2 Hill, C. 688 1,2 Jensen, B. 829 1 Keigher, P. 626 1 Kelly, E. 38 3 Ke mpe s , F . 779 1 Lavelle, J. 711 1 [O, FOR INFORMATICH
NCR # /0 Date 12/08/84 Page 4 of 4 k Name Badge Discrepancy Lieb, D. 789 1 Lorenz, R. 1281 1 Mack, N. 771 1 Head, G. 1131 1,2 Nash, M. 814 1 Obertini, C. 734 1 Owensby, T. 797 1 Osbourne, 735 1 Paris, T. 742 1,2 Patterson, F. 855 1 Paukestis, R. 1272 1,2 Rice, R. 854 1 Rose, G. 587 1 Sanchez, L. 624 1 A Schretti, 242 1 Sevec, J. 786 1 Shea, P. 584 1,2 Shre f f ter, B. 660 1,2 Smith, A. 784 1 . . Smith, M. 619 1,2 r), J Smolik, L. 818 1,3 M Swanson, S. 604 1 ,, l Thieme, R. 702 1
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Thomas, B. 644 1 . Thomas, C. 732 1,2 Thomas, J. 733 1 f Townsend, D. 759 1 Vancleave, J. 725 1 , Van Dyne 758 1 Van Houten 534 1,2 Venegoni, J. 785 1 i Vanick, J. 1155 1 Vota, M. 608 1 Ward, D. 1247 1
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Trans. No. b 'l17" ( Date 6' M d 6 SITE CONTRACTOR NCR TRANSMITTAL FORM BRAIDWOOD CONSTRUCTION RE i ED To: W. Vahle Project Field Engineering Manager NY 2 8 E ' FROM: Ceco Project Construction
SUBJECT:
Contractor b NCR No. M 10 0 In accordance with Quality Assurance Procedure No. 15-1 and PCD-23, the attached site contractor NCR is being routed for your review. Plaase indicate your disposition below and return to CECO Project Construction (Word Processing Typist). Sargent & Lundy, Braidwood office, has reviewed the Recommended Disposition and: ! [ Approves the Recommended Disposition Approves the Recommended Disposition modified as i indicated on the documents listed below Rejects the Recommended Disposition - installation to be reworked to conform with design documents . 7 MCannot evaluate the Recommended Disposition (SEE E/ 7mh The approved or modified disposition has been incorporated in the following Sargent & Lundy documents: Document No. Revision Egig, L __ = G = \ _ % ,G-= C _._' ,-T
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Srcidwood Proj:ct Fiold Engineering Proceduro 15-3 Exhibit B Proiect Field Engineerina On-Site Contractor MCR Evaluation Foru ' (D (V M b NCR$: 37IO Date: I
- 1. Action Required to Correct the Nonconformance:
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- 2. FCR required O YES h NO
- 3. Corrective Action Required to Prevent Recurrence of Nonconformance:
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c,y nD,, I,N,,E, A.R..M....A.T. in - - - Evaluated B : h 8 I XC Reviewed By f/7/ Project Field Eng ring Sdpervisor Approved By: ^- ' O fl I3 Project Field Engineering Manag6r
- b (d (Please use back of sheet, if more space is needed)
S/MfWeR Defo Q, #fo L. K. COMSTOCK & COMPANY. lNC. OA SECT m 4.7.1 MANUAL SHIELDED METAL ARC-WELDING FOR STRUCTURAL STEEL AND l STAINLESS STEEL QUALIFICATION PAGE REV/DATE 1 06/18/82 2 07/18/80 3 A - 09/28I83 4 06/18/82 5 07/18/80 6 A - 09/28/83 7 A - 09/28/83 8 A - 09/28/83 9 06/18/82 10 06/18/82 Form #83 06/05/80 Form #86 06/05/80 Form #88 A - 09/28/83 Attachment ' - 09/28/83 Attachment ' 09/28/83 APPROVALS: L. K. COMSTOC4'AND COMPANY, INC.N__ / / MATE /4-/-M Qua i ty- nt r 1 Manager L. K. COMSTOCK AND COMPANY, INC. I DATE\ O ' 4 S S Project Manager L. K. COMSTOCK AND COMPANY, INC. DATE l e-3 -33 oject Engineer Rev. A - 09/28/83
. EFFECTIVE DATE: 4/18/84 00011 fla t 1
L. K. COMSTOCK Q COMPANY, INC. QA SECT l SARGENT & LUNDY 4.7.1 2. YNSSa' N Mu.I c'I' Ec S"**$'a
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4ca;gt.*g; g,r;ec= MANUAL SHIELDED METAL ARC ELDING R STRUCTURAL STEEL STA NLESS STEEL QUALIFICATION F. A. KosiK st ((/kgong setc.ggPnot , p .
1.0 REFERENCES
The following documents form a,part of this specification to the extent specified herein. 1.1 AWS Structural Welding Code AWS 01.1 1.2 AWS Specification for Mild Steel Covered Arc-Welding Electrodes, AWS AS.1 2.0 PURPOSE / SCOPE 2.1 This procedure is established to qualify welders per AWS 01.1 as applicable, for welding flare-bevel grooves and fillets in all positions. 3.0 PROCEDURE
, 3.1 BASE METAL Steel will comply with the specifications of AWS 01.1-75.
3.2 FILLER METAL The filler metal employed will conform to the following requirements: 3.2.1 Electrodes will conform to American Welding Specification for Mild Steel Covered Arc Welding Electrodes, AWS AS-1, 3.2.2 Electrodes will be stored, and handled in accordance with L. K. COMSTOCK, the " Storage and Control of Welding Material" procedure. (Sect. 4.3.10) 3.3 POSITION The welding will be performed in a 3G and 4G position as Structural Welding Code D1.1-75, Para. 5.23.1.3 and Para. 5.23.1.4. 3.4 JOINT DESIGN Joint design will be as per AWS Structural Welding Code 01.1 for fillet ' welds and groove welds. PH INFORMATION ONl.Y ORIG.DATE REVISION PAGE PREPARED APPR O V E D REVISED T s T L.E ECE LJF RAB PROCEDURE 6-18-82 1 of 10
- L. K. COMSTOCK O COMPANY, INC. smwooo 4.7.1 QA SECT O 3.0 PROCEDURE - continued i
3.5 JOINT PREPARATION AND CLEANING 3.5.1 Joints may be prepared by machining, oxygen gouging, air carbon are gouging, chipping or grinding. Cut surfaces and edges shall be free of slag. 3.5.2 Prior to fitting, the surfaces of joints are to be cleaned free of rust, scale, paint or other foreign matter. The metal shall be cleaned back from the joint edge sufficiently to insure that the welded joint will not become contaminated. The cleaning may be done by wire brushing, grinding, gritblasting or other suitable means. 3.5.3 The members to be welded will be brought into correct alignment and held in position by bolts, clamps, wedges, guy lines, struts, other suitable devices or by tack welds until welding has been completed. 3.6 JOINT WELOING DETAILS Single and multiple pass of fillet welds and groove welds will be specifed as below: 3.6.1 The minimum size of a root pass shall be sufficient to prevent O . 3.7 cracking. OVALIFICATION All welds will be qualified by the make-up of the weld coupons as indicated in this section. 3.7.1 Material 3.7.1.1 The base metal shall conform to ASTM A-36 or A106 specifications for structural steel. 3.7.1.2 Filler Metal Electrodes will be Group F4 Class, EXX15, EXX16, EXX18*.
- The letters XX stand for the various strength levels (60, 70, 80, 90, 100, and 120) of deposited weld metal.
3.7.1.3 A welder qualified for shielded metal arc-welding with an electrode identified above will be qualified to weld or tack weld with any electrode in this group designation. 3.7.1.4 A welder qualifying for shielded metal arc-welding of stainless steel shall qualify with E308 or E309 fDMDRMATIONalLY PAGE PREPARED APPR O V E D RE VISED TITLE ORIG. D ATE REVISION ECE IJF RAB PROCEDURE 7-18-80 2 of ln
- - _ . _ . _ ~
- L. K. COMSTOCK O COMPANY, INC. BRAIDWOOD 4.7.1 OA SECT 3.0 PROCEDURE - continued 3.7.2 Position of Test Welds for Welder Qualification 3.7.2.1 Groove Plate Welds Qualification in the 3G (vertical) position qualifies for flat, l.orizontal, and vertical position groove and flat, horizontal, and vertical position fillet welding of plate.
Qualification in the 4G (overhead) position qualifies for flat and overhead position groove and flat, horizontal, and overhead position fillet welding of plate. 3.7.2.2 Fillet Welds 3.7.2.2.1 Qualification in the 3F (vertical) position qualifies IF (flat), 2F (horizontal) and 3F (vertical) position fillet welding. 3.7.2.2.2 Qualification in the 4F (overhead) position qualifies for IF (flat), 2F (horizontal) and 4F (overhead) position fillet welding. 3.7.2.2.3 Qualification in the 3F (vertical) position, and the 4F (overhead) position qualifies for IF (flat), 2F (horizontal), 3F (vertical) and 4F (overhead). 3.7.3 Test Coupons 3.7.3.1 Groove Plate Welds qualifying to unlimited thickness. The joint detail will be l' plate, single V-groove, 45 included angle, 1/4" root opening with backing. (See Page 7, Fig, la) backing must be at least 3/8" x 2" for mechanical testing or for radiographic testing i after the backing is removed. l 3.7.3.2 DELETED. - g l l l 88 A E PA R E D APPROvtD REveSED TITLE O RIG. D ATE FIEV lON PAGE ECE I,JF IFD PROCEDURE (09/28/83) 3 Of 10
L. K. COMSTOCK O COMPANY, INC. BRAIDWOOD 4 7 1 g 3.0 PROCEDURE - continued I 3.7.3.3 Fillet Welds The fillet weld qualification test for all positions will be made with two 1/2" x 4" x 8" plates arranged in the configuration of the position in which the welder is to qualify as shown in Fig. 2. The welder will make a S/16" weld in the length of the test joint with a required stop and restart of the weld near the center of the test plate and in those positions in which he is to qualify (flat, horizontal, vertical, or overhead). 3.7.3.4 Tack Weld The tack weld qualification test for all positions will be made with two 1/2" x 4" x 4" plates arranged in the configuration of the positions in which the welder is to qualify. A tacker shall make a 1/4" maximum size tack weld approximately 2" long as shown on Page 9, (Fig. 3), using a S/32" diameter, electrode and in those positions in which he is to qualify (f11.t vertical, horizontal, or overhead). 3.7.4 Test Specimen Preparation 3.7.4.1 Groove Plate Welds Upon completion of the weld, the test coupon will be submitted for test as prepared. No further preparation is required. 3.7.4.2 Fillet Welds Upon completion of the weld, the welder will prepare the test plates as shown on Page 8 (Figure 2). l 3.7.4.3 Tack Welds The tack weld plate as welded will be submitted for tests as prepared. No further preparation is j required. 3.7.5 Test Specimen Identification . l The welder will identify each weld sample with an initial i designating the position in which the weld was made and his initials. 3.7.6 Specimen Tes h I,. 1 Test plates and coupons will be examined by an independent testing company, approved by Commonwealth Edison Company. Testing of plates and coupons will be as specified below: TITLE OmlG.DATE REVISION PAGE PR EPA R E D Appmovt O REvaSED RAB PROCEDURE 6-18-82 4 of 10 ECE LJF
L. K. COMSTOCK O COMPANY, INC. BRAIDWOOD 4.7.1 OA SECT 3.0 PROCEDURE - continued ( 3.7.6.1 Tack Weld test plates will be tested using the break test. 3.7.6.2 Fillet Weld test plates will be tested using the break test and macroetch test. 3.7.6.3 Groove plate weld test coupons will be subjected to a side bend test. 3.7 7 Test Results The results of all tests performed by the independent testing company will be submitted by L. K. Comstock Quality Control Manager, or his designee. 3.8 RETEST A welder who fails to meet the requirement of one or more test welds may, at the request of a L. K. Comstock Superintendent, be retested under the following conditions: 3.8.1 An immediate retest may be made consisting of two test welds of each type on which the welder failed. All retest specimens shall meet all the specified requirements. 3.8.2 A retest may be made provided there is evidence that the welder has had further training or practice. In this case, a complete retest shall be made. 3.9 WELDER OUALIFICATION A numeric welding symbol hammer will be issued by the Quality Control Manager or his designee when the welder has been qualified. The welder will return the welding symbol hamer upon the termination of his welder status. 3.10 WITNESS OF WELOS l All welds made for the purpose of welder qualification require the following: 3.10.1 A L. K. Comstock Q.C. Inspector must be present to witness the welding process, position of weld, electro.de used, etc. 3.10.2 The L. K. Comstock Q.C. Inspector is required to have in his possesion a welder and Welding Operator Qualification Test Record, Form 88. This form is to be completed during the period that the welder is performing the weld process.
- 1. ,'.
.a. , due -
ORIG. D ATE REVISION PAGE PREPARED APP R OV E D REvaSED T4TLE ECE W RAB PROCEDURE 7-18-80 5 Of 10
L. K. COMSTOCK O COMPANY, INC. BRAIDWOOD 4.7.1 OA SECT 3.0 PROCEDURE - continued 3.10.3 The original Weld and Welding Operator Qualification Test Record will accompany the test coupons to the independent test company. A copy of the Form 88 will be retained by witnessing L. K. Comstock Q. C. Inspector. 3.10.4 When the report is returned to L. K. Comstock, the witnessing L. K. Comstock Q. C. Inspector will complete the following _ information on the bottom of Form 86: g MANUFACTURER OR CONTRACTOR AUTHORIZED 8Y DATE 4.0 TEST EQUIPMENT 4.1 As Required. 5.0 RECORDS
- 5.1 Qualification Records will be maintained as per L. K. Comstock procedure " Quality Assurance Records".
5.2 The welders qualification shall be considered as remaining in effect indefinitely unless 5.2.1 The welder is not engaged in the given process of welding for which he is qualified for a period exceeding six months. 5.2.2 There is some specific reason to question the welding operator's ability. Qualification records will be maintained per the " Quality Assurance Records' procedure. _ 5.2.3 A Welder Qualification Card shall be issued to each welder upon successful completion of the Qualification Test. The welder, b l upon termination from the site, shall return the Qualification l Card, and weld symbol to the LKC, QC Department. , 5.2.4 The issuance and return of the welder symbol hammer will be documented using Weld Symbol Hammer Log. Form 83. 5.2.5 A weekly report of the welder status will be submitted to the CECO Site Q.A. Supervisor noting any change in the welders qualifications. This report will be sub e K. g ComstockQ.gMa _ k 5.2.6 The Weld [rkshkryh M rM meb % part of each welders record in the QC files. a , be a permanent Effective g Revision A. _. APPRO V E D REvlSED TITLE O RIG. D ATE REVislON PAGE PR EPA R E D ECE LJF IFD PROCEDURE (09/28/83) 6 of 10
L. K. COMSTOCK Q COMPANY, INC. BRAIDWCOD 4.7.1 QA SECT 6.0 FORMS 6.1 Form #83 - Welder Symbol Hammer Control Log
. 6.2 Form #86 - Tacker Qualification Test Record 6.3 Form #88 - Welder and Welding Operator Qualification Test Record 6.4 Attachment "A" - Welder History Record 6.5 Attachment "B" - Welder Qual. Card <o .
1 , FOR INFORMATION ONLY l ,( l 00011 l T a T LE ORIG. D ATE REV SiON PAGE PREPARED APP R OV E D R E V15E D ECE IJF IFD PROCEDURE (09/28/83) 7 of 10
BRAIDWOOD 4.7.1 t.. r.. to:.'.5 0 C g A t c:/.r t.:?Y FIG. 1 A og 5-Direction of Rolling .
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t TITLE Om G.DATL REv.DATE 88GE PmEPAmED ADemovCD REvtSED ECE IJF RAB PROCEDURE 6-5-80 Fom 8-cas4
K. COMSTOCK O COMPANY. INC. Braidwood 4.7.1 CA sEc7
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- 2 TACKER QUALIFICATION TEST RECORD
' ' ~
Tacker's name ~ . Identifica1 ion No. Walfing process - . P1sition - .... . _ . (FI:t. horizontal, overhead or vertical-il vertical state whether upward or downward) In accordance with procedure specification no. MIteri;l specification _ - Di: meter and wall thickness (if pipe) otherwise joint thickness Filler Metal Classification. F No. Specification No. _ Describe filler metal (if not covered by AWS specification) For Information Only Flux for submerged arc or gas for gas metal are Filler metal diameter and trade name or flux cored arc welding _. Test Results ance Fillet Size re Test Root Penetration Soundness - ibe the location, nature and size of any crack or tearing of the specimen.) Test conducted by Laboratory and test,no. per . Wa the undersigned certify that the statements in this record are correct and tested in accordance with the requirements JE AWS DI.1,-Structural Welding Code. Manufacturer or Contractor Authorized by Date _ i
* ' ' * ' meaMM10H ONLY t 's . g'.2a.&88
[ A TIT t.E ORIC.DATE mEv.DATE *AoC I l RE r A ta E D asemovED REvtSED I ECE LTF RAB IU" ' PROCEDURE 1 i l . - ~ . - .
L K. COMSTOCK & COMPANY QA SECT o WELDER AND WELDING OPERATOR QUALIFICATION TEST RECORD n Wel der o r Wel d i ng Ope ra tor 's Name . . . . . . . . . . . . . . . . . . . . . . . . . . . . ID No . . . . . . . . . . . . . Welding Process . . . . SMAW . . . . . . . Manual . . . . . . . Semiau tomatic . . . . . . Machine. . . . . Position............................................................................ Procedu re Spec . . . . . . . . & AWS D1.1 -75. . Ma te ri al S pec . . . ASTM. . . . . . . . . . . . . . . . . . . . . . . Diameter and wall thickness (if pipe) otherwise joint thickness . . . . . . . . . . . . . . . . . . Thickness range this' qualifies ................................................... . FILLER METAL i Specification No. e... . . ..... . Classification ............................... . , Describe filler me.tal (i f not covered by LKC Specification) . . . . . .N/A. . . . . . . . . . . . . . Is backing strip used? .....Yes................................................... Filler metal dia . and brand . . . . . . . . . . . . . . . . . . . . Gas for gas metal Arc. . . . . . . . . . . . . . . PIPE WELD VISUAL TEST RESULTS Visual REMARKS
,i Test Conducted by . . .L K Coms tock . . . . . . . . Per. . . . . . . . . . . . . . . . . . . . . . . . . .
GUIDED BEND TEST RESULTS Test Conducted by ...............'................ Per............................ TYPE RESULT TYPE RESULT Test Evaluated by Pittsburgh Testing Lab ................. Lab Test No.............. Per..................................... FILLET WELD TEST RESULTS Visual N/A Break N/A l Macroetch N/A Test Conducted by ..........N/A.......... Lab Test No..........N/A.......... ~ Per ..........N/A.......... We the undersigned, certify that the statements in this record are correct and that the welds were prepared and tested in accordance with the requirements of SC or D of AWS Dl.1 Structural Welding Code. L . K . COMSTO C K - P e r . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Da te . . . . . . . . . . . . . . . . . . . .
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